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UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`
`Certification of New Interstate Natural Gas
`Facilities
`
`Docket No. PL18-1-000
`
`
`Docket No. PL21-3-000
`
`
`Consideration of Greenhouse Gas Emissions
`in Natural Gas Infrastructure Project
`Reviews
`
`)
`)
`)
`)
`)
`)
`
`MOTION TO INTERVENE OF
`GOLDEN PASS LNG TERMINAL LLC
`
`Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal Energy
`
`Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.214 (2021), and
`
`Section 157.10 of the Commission’s Regulations, 18 C.F.R. § 157.10 (2021), Golden Pass
`
`LNG Terminal LLC (“GPLNG”) hereby moves to intervene in the captioned proceedings with
`
`full rights as a party.
`
`In support of this Motion, GPPL respectfully states as follows:
`
`COMMUNICATIONS
`
`GPPL requests that correspondence and communications regarding this Motion be
`
`directed to the following persons:
`
`S. Diane Neal
`Assistant General Counsel
`Golden Pass LNG Terminal LLC
`811 Louisiana, Suite 1500
`Houston, TX 77002
`(713) 324-6703
`dneal@goldenpasslng.com
`
`Kevin M. Sweeney
`Law Office of Kevin M. Sweeney
`1717 K Steet, NW
`Suite 900
`Washington, DC 20006
`(202) 609-7709
`ksweeney@kmsenergylaw.com
`
`
`
`
`
`1
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`BACKGROUND
`
`On February 18, 2022, in Docket No. PL18-1-000, the Commission issued its
`
`
`
`“Updated Policy Statement on Certification of New Interstate Natural Gas Facilities.”1
`
`This policy statement purports to describe how the Commission will evaluate all factors
`
`bearing on the public interest in determining whether a new interstate natural gas
`
`transportation project is required by the public convenience and necessity under the Natural
`
`Gas Act (“NGA”).2
`
`
`
`Also on February 18, 2022, in Docket No. PL21-3-000, the Commission issued its
`
`“Interim Policy Statement.” This interim policy statement purports to describe
`
`Commission procedures for evaluating climate impacts under the National Environmental
`
`Policy Act, including a description of how the Commission intends to integrate climate
`
`considerations into its public interest determinations under the NGA.
`
`MOTION TO INTERVENE
`
`Golden Pass LNG Terminal LLC is a limited liability company organized and
`
`
`
`existing under the laws of the State of Delaware, with its principal place of business at 811
`
`Louisiana, Suite 1500, Houston, Texas 77002. GPLNG owns and operates a liquefied
`
`natural gas (“LNG”) import terminal owned and at the Sabine-Neches Waterway, on the
`
`existing Port Arthur Ship Channel, in the vicinity of Sabine Pass in Jefferson County,
`
`Texas. In an order issued on December 21, 2016,3 the Commission authorized the
`
`
`1 Certification of New Interstate Natural Gas Facilities, 178 FERC ¶ 61,107 (2022), 87 Fed.Reg.
`11548 (March 1, 2022).
`2 Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews,
`178 FERC ¶ 61,108 (2022), 87 Fed.Reg. 14104 (March 11, 2022).
`3 Golden Pass Products LLC and Golden Pass Pipeline LLC, 157 FERC ¶ 61,222
`(2016)(December 2016 Order).
`
`
`
`2
`
`

`

`construction and operation of facilities adjacent to and integrated with the existing GPLNG
`
`facilities to enable GPLNG to liquefy and export as LNG natural gas received at the
`
`terminal. GPLNG’s facilities are interconnected with the interstate pipeline system of
`
`Golden Pass Pipeline LLC (“GPPL”). GPPL’s existing 69-mile pipeline system extends
`
`from the LNG import terminal owned and operated by GPLNG to delivery points in Texas
`
`and Louisiana. In the same December 2016 Order, the Commission authorized the
`
`construction and operation of an expansion of the existing GPPL system to transport up to
`
`2.5 Bcf/d of domestically sourced natural gas in a south-flow direction to the GPLNG
`
`Terminal for liquefaction and export. Construction of the LNG export facilities is ongoing.
`
`Construction of the pipeline facilities has not yet commenced.4
`
`
`
`As the owner and operator of an LNG Terminal in the process of constructing
`
`export facilities to be supplied by an interstate pipeline located, GPLNG has an interest
`
`that may be directly affected by the outcome of these proceedings. GPLNG’s interest
`
`cannot be effectively represented in this proceeding by any other party. GPLNG therefore
`
`respectfully submits that its intervention and participation is in the public interest.
`
`
`
`
`
`
`4 GPPL has filed applications in Docket Nos. CP21-1-000 and CP21-458-000 to amend its 2016
`authorization. Those applications are pending.
`
`
`
`3
`
`

`

`
`
`WHEREFORE, for the foregoing reasons, GPLNG hereby respectfully moves for
`
`leave to intervene in the captioned proceedings with full rights as a party.
`
`
`
`S. Diane Neal
`Assistant General Counsel
`Golden Pass LNG Terminal LLC
`Golden Pass Pipeline LLC
`811 Louisiana, Suite 1500
`Houston, TX 77002
`
`
` Respectfully submitted,
`
`
`
`/s/ Kevin M. Sweeney
`Kevin M. Sweeney
`Law Office of Kevin M. Sweeney
`1717 K Street, NW
`Suite 900
`Washington, DC 20006
`
`Counsel for
`Golden Pass Pipeline LLC
`
`4
`
`
`
`
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that I have this day served the foregoing document upon each person
`
`designated on the official service list compiled by the Secretary in this proceeding.
`
`Dated in Washington, DC, this 21st day of March, 2022.
`
`
`/s/ Kevin M. Sweeney
`Kevin M. Sweeney
`
`
`
`
`
`
`
`

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