Infrastructure projects are the veins for the lifeblood of commerce, but what kind of commerce? Natural gas pipelines, for instance, feed a host of energy, commercial, and industrial activity. But energy infrastructure and industrial and commercial commerce must confront the exponentially increasing threat of climate change and the rapidly developing alternative sources of energy. And new energy infrastructure projects present unique challenges because of the challenging regulatory environment and their typical durability and long payback periods. A seeming acquiescence by the Federal Energy Regulatory Commission (FERC or the Commission), to approve almost all new proposed interstate natural gas pipelines, embeds a long-term commitment to a certain amount of greenhouse gas (GHG) emissions, perhaps too precipitously.
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