`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
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`Certification of New Interstate Natural Gas
`Facilities
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`Docket No. PL18-1-000
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`Docket No. PL21-3-000
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`Consideration of Greenhouse Gas Emissions
`in Natural Gas Infrastructure Project
`Reviews
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`MOTION TO INTERVENE OF
`GOLDEN PASS LNG TERMINAL LLC
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`Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal Energy
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`Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.214 (2021), and
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`Section 157.10 of the Commission’s Regulations, 18 C.F.R. § 157.10 (2021), Golden Pass
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`LNG Terminal LLC (“GPLNG”) hereby moves to intervene in the captioned proceedings with
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`full rights as a party.
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`In support of this Motion, GPPL respectfully states as follows:
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`COMMUNICATIONS
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`GPPL requests that correspondence and communications regarding this Motion be
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`directed to the following persons:
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`S. Diane Neal
`Assistant General Counsel
`Golden Pass LNG Terminal LLC
`811 Louisiana, Suite 1500
`Houston, TX 77002
`(713) 324-6703
`dneal@goldenpasslng.com
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`Kevin M. Sweeney
`Law Office of Kevin M. Sweeney
`1717 K Steet, NW
`Suite 900
`Washington, DC 20006
`(202) 609-7709
`ksweeney@kmsenergylaw.com
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`1
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`BACKGROUND
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`On February 18, 2022, in Docket No. PL18-1-000, the Commission issued its
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`“Updated Policy Statement on Certification of New Interstate Natural Gas Facilities.”1
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`This policy statement purports to describe how the Commission will evaluate all factors
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`bearing on the public interest in determining whether a new interstate natural gas
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`transportation project is required by the public convenience and necessity under the Natural
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`Gas Act (“NGA”).2
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`Also on February 18, 2022, in Docket No. PL21-3-000, the Commission issued its
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`“Interim Policy Statement.” This interim policy statement purports to describe
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`Commission procedures for evaluating climate impacts under the National Environmental
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`Policy Act, including a description of how the Commission intends to integrate climate
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`considerations into its public interest determinations under the NGA.
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`MOTION TO INTERVENE
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`Golden Pass LNG Terminal LLC is a limited liability company organized and
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`existing under the laws of the State of Delaware, with its principal place of business at 811
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`Louisiana, Suite 1500, Houston, Texas 77002. GPLNG owns and operates a liquefied
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`natural gas (“LNG”) import terminal owned and at the Sabine-Neches Waterway, on the
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`existing Port Arthur Ship Channel, in the vicinity of Sabine Pass in Jefferson County,
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`Texas. In an order issued on December 21, 2016,3 the Commission authorized the
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`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).
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`2
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`construction and operation of facilities adjacent to and integrated with the existing GPLNG
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`facilities to enable GPLNG to liquefy and export as LNG natural gas received at the
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`terminal. GPLNG’s facilities are interconnected with the interstate pipeline system of
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`Golden Pass Pipeline LLC (“GPPL”). GPPL’s existing 69-mile pipeline system extends
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`from the LNG import terminal owned and operated by GPLNG to delivery points in Texas
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`and Louisiana. In the same December 2016 Order, the Commission authorized the
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`construction and operation of an expansion of the existing GPPL system to transport up to
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`2.5 Bcf/d of domestically sourced natural gas in a south-flow direction to the GPLNG
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`Terminal for liquefaction and export. Construction of the LNG export facilities is ongoing.
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`Construction of the pipeline facilities has not yet commenced.4
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`As the owner and operator of an LNG Terminal in the process of constructing
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`export facilities to be supplied by an interstate pipeline located, GPLNG has an interest
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`that may be directly affected by the outcome of these proceedings. GPLNG’s interest
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`cannot be effectively represented in this proceeding by any other party. GPLNG therefore
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`respectfully submits that its intervention and participation is in the public interest.
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`4 GPPL has filed applications in Docket Nos. CP21-1-000 and CP21-458-000 to amend its 2016
`authorization. Those applications are pending.
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`3
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`WHEREFORE, for the foregoing reasons, GPLNG hereby respectfully moves for
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`leave to intervene in the captioned proceedings with full rights as a party.
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`S. Diane Neal
`Assistant General Counsel
`Golden Pass LNG Terminal LLC
`Golden Pass Pipeline LLC
`811 Louisiana, Suite 1500
`Houston, TX 77002
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` Respectfully submitted,
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`/s/ Kevin M. Sweeney
`Kevin M. Sweeney
`Law Office of Kevin M. Sweeney
`1717 K Street, NW
`Suite 900
`Washington, DC 20006
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`Counsel for
`Golden Pass Pipeline LLC
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`4
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`CERTIFICATE OF SERVICE
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`I hereby certify that I have this day served the foregoing document upon each person
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`designated on the official service list compiled by the Secretary in this proceeding.
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`Dated in Washington, DC, this 21st day of March, 2022.
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`/s/ Kevin M. Sweeney
`Kevin M. Sweeney
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