UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`
`
`Venture Global CP2 LNG, LLC
`Venture Global CP Express, LLC
`
`)
`)
`
`Docket Nos. CP22-21-000
` CP22-22-000
`
`
`MOTION FOR LEAVE TO ANSWER AND
`ANSWER OF VENTURE GLOBAL CP2 LNG, LLC
`AND VENTURE GLOBAL CP EXPRESS, LLC
`OPPOSING UNTIMELY MOTION TO INTERVENE
`
`Pursuant to Rules 212 and 213 of the Rules of Practice and Procedure of the
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`Federal Energy Regulatory Commission (“Commission”),1 Venture Global CP2 LNG,
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`LLC (“CP2 LNG”) and Venture Global CP Express, LLC (“CP Express”) (together the
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`“Applicants”) hereby move for leave to answer and provide this answer to the untimely
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`Motion to Intervene (“Motion to Intervene”) of the Niskanen Center (“Niskanen”) filed
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`March 1, 2022, in the above-captioned dockets.2 Because Niskanen failed to articulate
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`any direct interest in the proceedings and its alleged interest in offering “landowner
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`perspectives” is already provided by its representation of individual landowners,
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`Niskanen’s own intervention is not in the public interest and should be denied. 3 Most
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`clearly, Niskanen’s Motion to Intervene failed to offer any reason for, much less
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`demonstrate good cause for, its failure to intervene on a timely basis as required by Rule
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`214(d).4 This failing alone is sufficient reason for the Commission to deny the Motion
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`to Intervene. In addition, Niskanen’s recent actions in the proceedings—including filing
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`1
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`18 C.F.R. §§ 385.212 and 213 (2022).
`
`
`
`2
`Motion to Intervene of the Niskanen Center, filed in the above-captioned dockets on March 1,
`2022 (Accession No. 20220301-5105).
`
`See 18 C.F.R. § 385.214.
`
`Id.
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`3
`
`4
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`
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`

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`untimely, duplicative “scoping” comments that are misinformed— show that Niskanen’s
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`participation creates additional burden on Applicants and disruption unjustified by any
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`countervailing public interest. Niskanen’s interest in bringing constitutional challenges
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`to the Natural Gas Act’s eminent domain provisions is fully served by its representation
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`of landowners in these proceedings. Therefore, Niskanen’s Motion to Intervene in its
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`own right should be denied.
`
`I. Background
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`The Applicants filed a request to initiate the Commission’s Pre-Filing Process in
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`Docket No. PF21-1 in January 2021. Commission Staff commenced that process in
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`February 2021. As part of that process, the Commission issued a public notice soliciting
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`comments on the scope of the environmental review for the Applicant’s proposed
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`liquefied natural gas (“LNG”) facilities located in Cameron Parish, Louisiana and certain
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`pipeline facilities located in Louisiana and east Texas (“Project”) on April 27. 2021.5 On
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`May 27, 2021, the Sierra Club submitted extensive scoping comments in response to the
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`Commission’s notice. Among other things, the Sierra Club urged the Commission to
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`consider the impacts of climate change associated with the Project, 6 assess indirect
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`upstream and downstream greenhouse gas (“GHG”) emissions, and impacts associated
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`with sea level rise.7
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`
`
`5
`Notice of Scoping Period Requesting Comments on Environmental Issues for the Planned CP2
`LNG and CP Express Project and Notice of Public Scoping Sessions, Accession No. 20210427-3029.
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`6
`Comments of Sierra Club in Response to Notice of Scoping Comments on Environmental Issues
`at 1-2 (Accession No. 20210527-5247).
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`Id. at 2-3.
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`7
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`
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`2
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`

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`The Applicants submitted a joint application to construct and operate the Project
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`on December 2, 2021 in the above-captioned dockets (“Application”). The Commission
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`issued public notice of the Application on December 16, 2021, establishing a deadline
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`for intervention and comments of January 6, 2022. Timely motions to intervene were
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`submitted by a number of non-governmental organizations (“NGOs”), including Healthy
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`Gulf, Sierra Club, Natural Resources Defense Council (“NRDC”), and Public Citizen,
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`Inc (“Public Citizen”).8 Formal protests, or comments opposing the Application, were
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`submitted in these proceedings by only Healthy Gulf and Sierra Club, et al., opposing
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`the Project on a variety of grounds, including climate change, GHG emissions, and
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`project need.9 The Applicants responded to those protests in their answer submitted on
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`March 3, 2022.10
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`On February 9, 2022, the Commission issued its Notice of Intent to Prepare an
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`Environmental Impact Statement (“EIS”) to discuss the environmental impacts of the
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`Project pursuant to the National Environmental Policy Act.11 The notice requested public
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`comments on the scope of issues for the EIS by March 11, 2022.
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`Niskanen filed its Motion to Intervene, with no substantive comments, on March
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`1, 2022.12 Despite being submitted almost two months past the intervention deadline,
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`
`
`8
`Accession No. 20220105-5151 (Healthy Gulf); Accession No. 20220106-5162 (Sierra Club);
`Accession No. 20211216-5124 (NRDC); Accession No. 20211203-5080 (Public Citizen).
`
`9
`Sierra Club, et al. captioned its pleading (Accession No. 20220106-5165) as an protest; Healthy
`Gulf styled its submission (Accession No. 20220105-5148) as comments, but the content essentially
`constitutes a protest.
`
`10
`See Motion for Leave to File Answer and Response of Venture Global CP2 LNG, LLC and
`Venture Global CP Express, LLC to Filed Comments at 10, Docket No. CP22-21, et al. (Accession No.
`20220303-5139) (Filed Mar. 3, 2022).
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`Accession No. 20220209-3046.
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`Accession No. 20220301-5105.
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`11
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`12
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`3
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`

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`Niskanen’s Motion to Intervene did not explicitly acknowledge that it was filed late nor
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`provide an explanation for its lack of timeliness.13
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`Niskanen describes itself as “a 501(c)(3) libertarian think tank and advocacy
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`organization”14 that “litigates to protect landowners from . . . gas pipeline companies that
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`seek to seize land for their for-profit projects.”15 Niskanen maintains that any exercise
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`of eminent domain authority by a natural gas pipeline violates the Constitution.16 With
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`respect to pipelines supplying LNG export terminals in Louisiana, Niskanen contends
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`that “export-only projects are not in the public interest and that the project developers
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`therefore cannot use eminent domain authority to compel landowners to sell the land
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`needed for these pipelines.”17 Niskanen’s Annual Report announces that it will argue
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`that point “to FERC (and eventually to the D.C. Circuit).”18 When moving to intervene
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`in these proceedings, Niskanen described itself simply as an “advocacy organization that
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`represents landowners impacted by pipelines throughout the country in court and
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`administrative proceedings.”19 Niskanen’s Motion to Intervene, however, failed to
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`13
`
`See generally id.
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`
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`14
`Final Brief Amicus Curiae of Niskanen Center in Support of Petitioner at 1, Delaware Riverkeeper
`Network v. FERC, D.C. Cir. No. 18-1128 (filed June 4, 2019).
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`15
`Niskanen Center, https://www.niskanencenter.org/niskanen-litigation-holding-power-to-
`account/protecting-property-owners-from-pipeline-eminent-domain/.
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`16
`See, e.g., id. (summarizing Niskanen’s position that eminent domain under a conditioned
`certificate violates the Takings Clause); Atlantic Coast Pipeline, LLC, 180 FERC ¶ 61,059 at PP 11-15
`(2022) (rejecting Niskanen’s rehearing request regarding the Commission’s failure to order the release of
`all easements acquired via eminent domain); Spire STL Pipeline LLC, 178 FERC ¶ 61,109 (2022) (rejecting
`Niskanen’s request for rehearing regarding the use of eminent domain under a temporary certificate).
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`17
`Niskanen Center 2022 Annual Report at 20, https://www.niskanencenter.org/wp-
`content/uploads/2023/01/Niskanen-Annual-Report-2022.pdf.
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`18
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`19
`
`
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`Id.
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`Accession No. 20220301-5105 at pp. 1-2.
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`4
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`

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`identify any such landowners in these proceedings.20 Nonetheless, Niskanen asserted
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`that unspecified landowners along the CP Express route will be “significantly impacted,”
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`and claimed that it will provide “landowner perspectives” and “is well-suited to protect
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`landowner interests.”21 Niskanen further asserted that its intervention would not disrupt
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`the proceedings or impose any prejudice or additional burden on any party, and stated
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`that no other party can adequately represent its interests.22
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`On April 6, 2022, the Applicants received notice from the Commission’s Office
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`of External Affairs that Niskanen submitted a request under the Freedom of Information
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`Act (“FOIA”) for the private landowner lists filed by the Applicants in these proceedings.
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`On April 15, 2022, the same Commission Office notified the Applicants that portions of
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`the landowner lists would be released to Niskanen with certain information redacted. 23
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`Prior to June 2022, no landowners had intervened in these proceedings. On June
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`10, 2022, the Motion to Intervene of Affected Landowners Bernard Webb, Georgia
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`Webb, and Jerryd Tassin (“Affected Landowners’ Motion”) was filed with the
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`Commission.24 The Affected Landowners’ Motion alleges a lack of “clear and adequate”
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`notice as good cause to grant their untimely motion to intervene.25 Although counsel for
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`Niskanen did not sign the pleading, Kathryn Schroeder from Niskanen is listed as the
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`agent for the document in eLibrary and signed the certificate of service. 26
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`
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`See generally id. at pp. 1-2.
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`Id. at pp. 1-2.
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`Id. at p. 3.
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`20
`
`21
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`22
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`23
`FOIA No. FY22-13, Notice of Intent to Release, letter from FERC’s Office of External Affairs to
`counsel for the Applicants.
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`24
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`25
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`26
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`
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`Accession No. 20220610-5071.
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`Id. at 1.
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`Id. at 3 (listing Kathryn Schroeder from Niskanen as the signer of the certificate of service).
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`5
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`

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`On September 13, 2022, the Motion to Intervene of Affected Landowner Mary
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`Alice Nash (“Nash Motion”) was filed and served by Ms. Schroeder of Niskanen on
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`behalf of Ms. Nash.27 As with the Affected Landowners’ Motion, the Nash Motion cited
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`alleged defects in the Commission’s notice process as the cause for late intervention. 28
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`The Nash Motion then proceeded to raise a litany of potential constitutional challenges
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`including that (i) the Commission’s notice procedures violate due process for the taking
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`of an individual’s land by eminent domain,29 and (ii) if landowners’ intervention were
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`limited to intervening on “specific intervention grounds” during the Draft Environmental
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`Statement window, it may impede the landowner’s ability to raise a constitutional public
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`use challenge.30 The Nash Motion also included a footnote incorporating these
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`arguments by reference into the previously submitted Affected Landowners’ Motion. 31
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`On January 13, 2023, Niskanen joined with the Sierra Club and other NGOs and
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`the four landowners represented by Niskanen in filing what is styled as a “scoping
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`comment” for the draft EIS32 (which was issued by FERC Staff four days later). With
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`the exception of the NGOs’ opinions about guidance recently issued by the Council on
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`Environmental Quality, the NGO Comments are duplicative of arguments previously
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`27
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`Accession No. 20220913-5085.
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`
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`28
`Nash Motion at 1. (Accession No. 20220913-5085) (alleging the “brevity and opacity of FERC’s
`certificate application notification process” as cause for seeking late intervention).
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`29
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`30
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`31
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`Id. at 3.
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`Id. at 3-4.
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`Id. at 1 n.1.
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`32
`Scoping Comment for Draft Environmental Impact Statement (“DEIS”) on Behalf of Niskanen
`Center, Sierra Club, Public Citizen, Natural Resources Defense Council, and Impacted Landowners
`Georgia Webb, Bernard Webb, Mary Alice Nash, and Jerryd Tassin, Docket No. CP22-21, et al.
`(Accession No. 20230113-5277) (filed Jan. 13, 2022) (herein the “NGO Comments”).
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`6
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`

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`raised by Sierra Club and others to which Applicants have already responded. 33 For
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`example, much of the pleading argues against the need for LNG exports generally and
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`the CP2 LNG Project in particular.34 The basis of that argument – that CP2 LNG
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`purportedly has no LNG offtake contracts and that the need for LNG exports from the
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`Project could be served by other Venture Global facilities – is, at best, ignorant, and at
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`worst, intentionally misleading, as further explained below.
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`II. Motion for Leave to File Answer Opposing Intervention
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`The Commission’s procedural rules generally provide for answers to be submitted
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`within 15 days, unless otherwise allowed by the Commission.35 The Applicants request
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`waiver of this procedural rule and leave to submit this answer at this time for good cause.
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`The evolving and growing role of Niskanen in these proceedings was not known at the time
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`of its motion to intervene, nor when an answer to the motion would have been timely.
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`Furthermore, after Niskanen’s motion to intervene, individual landowners (who appear to
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`be represented or supported by Niskanen) submitted motions to intervene – which the
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`Applicants do not oppose. Given these subsequent events, good causes exists for the
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`Applicants to be permitted at this time to express their opposition to Niskanen’s
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`intervention.
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`III. Answer Opposing Late Intervention
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`The basic standard for intervention pursuant to Commission Rule 214 requires the
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`movant to “state the movant’s interest in sufficient factual detail” to demonstrate that
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`
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`See supra n.10.
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`See NGO Comments at 5-9.
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`18 C.F.R. § 385.213(d) (time limitation) and (a)(2) (answers to protests).
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`7
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`33
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`34
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`35
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`(i) The movant has a right to participate which is expressly
`conferred by statute or by Commission rule, order, or other
`action; or
`(ii) The movant has or represents an interest which may be
`directly affected by the outcome of the proceeding,
`including any interest as a:
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`(A) Consumer,
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`(B) Customer,
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`(C) Competitor, or
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`(D) Security holder of a party; or
`(iii) The movant's participation is in the public interest. 36
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`When a motion to intervene is filed after the deadline for interventions established
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`by notice, the movant also “must show good cause why the time limitation should be
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`waived.”37 In considering motions for late intervention, the Commission may consider
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`whether
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`(i) The movant had good cause for failing to file the motion
`within the time prescribed;
`(ii) Any disruption of the proceeding might result from
`permitting intervention;
`(iii) The movant's interest is not adequately represented by
`other parties in the proceeding; and
`(iv) Any prejudice to, or additional burdens upon, the
`existing parties might
`result
`from permitting
`the
`intervention.38
`
`
`
`At the time of its Motion to Intervene, Niskanen had no specific or particular
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`interest in these proceedings. Niskanen simply asserted that the construction of CP
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`Express would adversely affect landowners and offered itself as an advocate for unnamed
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`landowner interests more than a year after the initiation of the Pre-Filing process for the
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`Project (in which Niskanen did not participate in any way). Niskanen did not provide
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`any particularized facts to demonstrate any interest in these specific proceedings. Still,
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`
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`Id. at 385.214(b)(2).
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`Id. at 385.214(b)(3).
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`Id. at 385.214(d).
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`36
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`37
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`38
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`8
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`

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`read most charitably, Niskanen’s Motion to Intervene might be seen as showing that its
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`intervention could be “in the public interest”39 had the motion been submitted timely.
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`
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`Niskanen’s Motion to Intervene, however, was submitted nearly two months after
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`the deadline established by the Commission for interventions. Yet, the Motion to
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`Intervene offers nothing whatsoever to explain why that time limitation should be
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`waived; indeed, the motion does not even request such a waiver. The absence of any
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`justification (much less a persuasive one) for the late filing alone is sufficient cause to
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`deny the Motion to Intervene.40
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`
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`In addition, individual landowners have filed motions to intervene after Niskanen
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`did so. Applicants do not oppose those motions. Individual landowners’ participation in
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`their own right negates Niskanen’s claimed purpose to offer the “landowner perspective.”
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`And other NGOs (including a co-signatory to Niskanen’s “scoping comments”) are
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`advancing other arguments shared by Niskanen, countering any claim that its “interests”
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`are not otherwise represented.
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`
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`Furthermore, Niskanen’s participation in the proceedings is imposing additional
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`burdens on the Applicants in responding to uninformed and duplicative claims. For
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`example, the NGO Comments, assert that CP2 LNG “has no off-take contracts,” citing
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`
`
`39
`Niskanen certainly has no legal right to participate in these proceedings nor is it a consumer,
`customer, competitor, or security holder of a party. Therefore, its intervention may be justified, if at all,
`only under the “public interest” standard of subpart (iii) of Rule 214(b)(2).
`
`40
`E.g., Rio Grande LNG, LLC, Docket No. CP16-454, et al., Notice Denying Late Intervention,
`Nov. 9, 2022, Accession No. 20221109-3029 (denying unopposed late intervention because motion failed
`to justify the inability to intervene in a timely manner and failed to address the Rule 214(d) factors for late
`intervention); Texas LNG Brownsville LLC, Docket No. CP16-116, et al., Notice Denying Late
`Intervention, Nov. 9, 2022, Accession No. 20221109-3025 (same); Transcontinental Gas Pipe Line
`Company, LLC, Docket No. CP21-94, Notice Denying Late Intervention, Sept. 22, 2022, Accession No.
`20220922-3082 (denying late intervention because the explanation why the motion was not submitted
`timely failed to demonstrate a “particular interest in the proceeding”); Spire STL Pipeline LLC, 175 FERC
`61,149 (2021) (denying late intervention because movant failed to demonstrate sufficiently its interest in
`the proceeding and failed to demonstrate good cause that excused its failure to file a timely intervention).
`
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`9
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`the Application.41 However, basic research of public sources would have revealed that,
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`following the filing of the Application, CP2 LNG entered into 20-year Sale and Purchase
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`Agreements (“SPAs”) during 2022 with five separate counterparties, each for 1 million
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`metric tonnes per annum (“MTPA) of LNG.42 Even assuming Niskanen had no
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`awareness of these long-term offtake agreements, its co-signatory the Sierra Club
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`certainly did, as CP2 LNG explained that it already entered into its first SPA in response
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`to Sierra Club’s protest of CP2 LNG’s DOE export application in March 2022.43
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`Accordingly, it is difficult to comprehend how the signatories of NGO Comments,
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`including Niskanen, could possibly certify – as they did pursuant to Commission Rule
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`2005(a)(2) – that the contents of their pleading were true to the best of their knowledge
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`and belief.
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`These incorrect statements regarding the status of CP2 LNG’s off-take
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`agreements are not mere commentary but rather are the centerpiece of the NGO’s claim
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`41
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`NGO Comments at p. 5 & n.4.
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`42
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`Those SPAs – with affiliates of New Fortress Energy, ExxonMobil, the German energy company
`EnBW, Chevron, and Japan’s INPEX have been widely reported in the press and announced in Venture
`Global press releases readily available on its website. The long-term SPAs also have been filed with the
`DOE and its website includes information about them. See https://www.energy.gov/fecm/articles/venture-
`global-cp2-lng-llc-facility. The recently issued draft EIS for the Project at p. 1-3, as well as the
`Commission’s press release regarding the draft EIS states: “CP2 LNG has entered into 20-year LNG Sales
`and Purchase Agreements with four counter-parties (affiliates of New Fortress Energy, ExxonMobil, and
`Chevron, as well as one of the largest energy companies in Germany, EnBW Energie Baden-Württemberg
`AG).” See https://www.ferc.gov/news-events/news/ferc-staff-issues-draft-environmental-impact-statement-
`eis-cp2-lng-and-cp-express. Regarding CP2 LNG’s most recent SPA, with INPEX, that was not mentioned
`there, see the following press release issued on December 26, 2022:
`https://venturegloballng.com/press/venture-global-and-inpex-announce-lng-sales-and-purchase-
`agreement/.
`
`43
`
`See Answer of Venture Global CP2 LNG, LLC to Interventions and Protests, filed on March 28,
`2022, in DOE/FE Docket No. 21-131-LNG at p. 9, available at:
`https://www.energy.gov/sites/default/files/2022-
`03/CP2%20Answer%20to%20Protests%20to%20Application%20in%20DOE%20Docket%2021-131-
`LNG.pdf.
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`10
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`that “the project’s only impetus appears to be ‘if we build it, they will come.’”44 To
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`further this misinformed theory, the NGO Comments further assert that other Venture
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`Global LNG facilities either have sufficient uncontracted capacity or could be
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`reconfigured to serve any incremental global demand.45 Again, public sources plainly
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`contradict such assertions. Indeed, other Venture Global projects cannot possibly serve
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`the purpose of the CP2 LNG Project of liquefying, storing, and exporting an additional
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`nameplate liquefaction capacity of 20 MTPA of LNG.
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`Finally, approximately half of the NGO Comments are duplicative of arguments
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`previously raised by other intervenors and addressed by Applicants in these proceedings.
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`Indeed, Sierra Club raised the same arguments as the NGO Comments regarding the
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`evaluation of climate change, indirect upstream and downstream GHG emissions, and
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`impacts associated with sea level rise as far back as its pre-filing scoping comments.46
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`The issues in the NGO Comments are not only not new, but the Applicants previously
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`responded to these issues. For example, Applicants previously responded to the
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`argument that CP2 LNG is somehow duplicative of other Venture Global facilities in
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`response to Healthy Gulf’s comments.47 Applicants also previously addressed the
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`argument in the NGO Comments that there is no need for CP2 LNG due to uncontracted
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`capacity at other approved, yet-to-be-built facilities.48
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`46
`
`Compare Comments of Sierra Club in Response to Notice of Scoping Comments on
`Environmental Issues at 1-3 (Accession No. 20210527-5247) with NGO Comments at 4-5.
`
`47
`
`Compare NGO Comments at 7 with CP2 LNG Answer at 10 (“Healthy Gulf charges that the CP2
`LNG Project is “duplicative” of the Venture Global Calcasieu Pass project.”).
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`48
`
`Compare Scoping Comments at 5-8 with CP2 LNG Answer at 10 (“Sierra Club, et al. presents a
`broader argument that uncontracted capacity of other proposed LNG projects could serve the purpose of
`CP2.”).
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`11
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`

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`Niskanen has provided no good cause to justify the burden on Applicants to
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`respond to these untimely, uninformed, and duplicative arguments. Therefore, these
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`claims provide further cause to deny Niskanen’s late-filed Motion to Intervene.
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`IV. Conclusion
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`Wherefore, for all the foregoing reasons, Applicants request that the Commission
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`(i) grant Applicants leave to answer the Motion to Intervene of Niskanen Center and (ii)
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`deny the Motion to Intervene of Niskanen Center.
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`
`
`
`
`Respectfully submitted,
`
`/s/ J. Patrick Nevins
`J. Patrick Nevins
`Carlos E. Clemente
`Latham & Watkins LLP
`555 Eleventh Street, N.W.
`Suite 1000
`Washington, D.C. 20004
`Telephone:
` (202) 637-3363
` (202) 637-2269
`Patrick.Nevins@lw.com
`Carlos.Clemente@lw.com
`
`
`Ruth M. Porter
`Assistant General Counsel
`Venture Global LNG, Inc.
`1001 19th Street North
`Suite 1500
`Arlington, VA 22209
`Telephone: (703) 740-2419
`rporter@venturegloballng.com
`
`Counsel to:
`
`Venture Global CP2 LNG, LLC and
`Venture Global CP Express, LLC
`
`Dated: February 2, 2023
`
`
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`12
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that I have this day served the foregoing document upon
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`each person designated on the official service list compiled by the Secretary in these proceedings.
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`Dated at Washington, D.C., this 2nd day of February, 2023.
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`/s/ Carlos E. Clemente
`Carlos E. Clemente
`Latham & Watkins LLP
`555 Eleventh Street, N.W.
`Suite 1000
`Washington, D.C. 20004
`Telephone:
` (202) 637-2269
`Carlos.Clemente@lw.com
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