FERC continues with inadequate carbon analysis


In a recent Environmental Assessment (EA) of Morgan Falls project, FERC has yet again failed to perform a complete analysis of carbon footprint of the project. The EA states:

If relicensed, the power from the project would continue to be useful in meeting art of the local and regional need for power and continue to displace the operation of fossil-fueled facilities thus avoiding significant fossil-fueled power plant emissions and creating an environmental benefit. If the electric output of the project were replaced with coal-fired generation, greenhouse gas emissions would increase by 15,000 metric tons of carbon annually.

HRC contends that this statement wrongly assumes that -

  • If the Morgan Falls plant ceased generation, it would be replaced by a fossil-fuel fired facility, more specifically a coal-fired facility.
  • The electricity now produced could not be replaced by other renewable source of energy such as wind or solar or through efficiency and conservation.
  • The reservoir associated with the operation of Morgan Falls project is not a significant source of greenhouse gases.

The Commission simply assumes that if the Morgan Falls project were to stop generating, it would be replaced by a coal-burning plant. This analysis does not include or refer to any supporting evidence, and fails to consider other perfectly reasonable options such as solar or wind. Alternatively, its power could be replaced through conservation and/or efficiency measures.[img_assist|nid=3868|title=|desc=|link=none|align=right|width=75|height=54] The Commission also ignores the findings of recent researches that indicate that reservoirs can be a significant source of greenhouse gases, specifically carbon dioxide (CO2) and methane (CH4). Scientists in Canada and Brazil have estimated that reservoirs could contribute to as much as 4% of total CO2 and 10% of total CH4 emissions. Despite these findings, FERC simply assumes that hydro projects, such as Morgan Falls, are carbon free sources of electricity. HRC filed comment on Dec 10, demanding that FERC's carbon analysis must feature a more realistic consideration of the carbon that might be emitted by various sources of replacement power, as well as a more accurate accounting of a project’s carbon emissions. Such a careful analysis is missing from the EA for the Morgan Falls project. HRC also demanded that in case of absence of such an analysis, FERC should strike the paragraph from the EA altogether.