The Sierra Club in the Commonwealth of Virginia is urging the Federal Energy Regulatory Commission (FERC) to adopt a climate test for two pipelines that would transport natural gas from fracking fields in West Virginia into southern Virginia and North Carolina.

The Mountain Valley and Atlantic Coast pipelines would carry more than 3.4 billion cubic feet of gas per day and double the state’s greenhouse gas emissions, said Sierra Club’s Virginia Director, Glen Besa. But FERC’s model for pipeline reviews only includes direct environmental threats, not indirect emissions—in this case, from significant methane releases—or cumulative effects of multiple projects.

“The potential total GHG emissions associated with these two proposed new pipelines could greatly increase emissions from this region for decades into the future,” Sierra concludes. “Hence, in an era where climate change mitigation will require reducing GHG emissions sharply, decision-makers need to consider whether approval of these projects is consistent with national and international goals for climate.”

Based on Sierra’s research on methane emissions from fracking operations and the “very high total potential GHG emissions,” the report notes, “it is important that the transmission pipeline companies and FERC provide complete life-cycle estimates of methane and CO2 emissions from their projects,” along with “ detailed documentation of their assumptions, so that the potential GHG emissions and other environmental impacts of the pipeline stage can properly be judged.”

That’s because “ expanding gas usage and supporting it with new pipelines and production implies substantially greater total GHG emissions than appear when agencies or advocates focus on only one stage at a time and ignore the indirect impacts of the immediate project.”