Attorney General Ken Paxton joined a 22-state coalition in a letter opposing the use of “Social Cost of Carbon” (SCC) analysis by the Federal Energy Regulatory Commission (FERC) in certification decisions related to interstate natural gas pipeline constructions. The letter argues that the SCC analysis is speculative and scientifically flawed, and the Natural Gas Act (NGA) and National Environmental Policy Act (NEPA) do not authorize FERC to use the analysis. 

NEPA does not mandate or permit FERC to use the “Social Cost of Carbon” analysis for pipeline certifications and contains no clear statement of Congress delegating authority to FERC to anticipate and mitigate global climate change under the shield of promoting affordable natural gas. Under the SCC analysis, private companies that want to build interstate natural gas pipelines to provide affordable energy to Americans would be subjected to crushing federal regulations and fees.

Read a copy of the letter here.