Certification of New Interstate Natural Gas Facilities Comments

Letters
July 25, 2018
The Global Energy Institute (GEI), an affiliate of the U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to respond to the Notice of Inquiry (“NOI”)1 from the Federal Energy Regulatory Commission (“FERC” or “Commission”) as the Commission reviews the current policy framework for the certification of new natural gas transportation facilities (the “Certificate Policy Statement”).  
The Chamber is the world’s largest business federation. It represents the interests of more than 3 million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations. The Chamber is dedicated to promoting, protecting, and defending America’s free enterprise system.  
 
The mission of the GEI is to unify policymakers, regulators, business leaders, and the American public behind a common sense energy strategy to help keep America secure, prosperous, and clean. In that regard we hope to be of service to this Committee, this Congress as a whole, and the administration. 
 
Energy infrastructure is an essential element of a productive and competitive economy. The development of new infrastructure to expand and modernize existing energy systems is a long and capital-intensive process, which requires an environment of regulatory predictability to allow businesses to plan and invest with confidence. The Chamber has long focused on encouraging improvements to the federal permitting process to improve the transparency and predictability of the process and has advocated for improved coordination among federal agencies to eliminate unnecessary barriers that prevent or delay the construction of these important energy infrastructure projects.  
 
The Chamber’s interest in this proceeding is to represent American businesses and promote policies that help America realize the full potential of its energy resources. In the past decade, America has experienced an energy revolution that has transformed the way energy resources are developed, transported, and consumed. This transformation has supported a dramatic increase in domestic manufacturing and improved the country’s international competitiveness. Low-cost, abundant natural gas has played a key role in this energy revolution, and natural gas pipelines serve as the critical link to enable consumers to take advantage of the many wide-spread benefits offered by this domestic energy resource. Enhancing the development of the nation’s natural gas transportation network is an essential component of broader infrastructure reform that will create jobs and promote economic growth.  
 
The Commission’s natural gas pipeline permitting process, guided by the 1999 Certificate Policy Statement, has aimed to facilitate the efficient, market-driven development of natural gas infrastructure. This goal should be sustained in any revisions to the Certificate Policy Statement contemplated by the Commission.  The bedrock principles of increased competition, access, reliability, and decreased costs must be affirmed and retained. These principles have produced significant benefits for American consumers, businesses, and the economy, and they will continue to be essential in guiding the nation’s dramatic energy transformation. The Chamber is pleased to offer comments in response to the Commission’s NOI that focus on maintaining and improving this successful and proven framework...