Dear Secretary Bose: The U.S. Chamber of Commerce (“the Chamber”), appreciates the opportunity to respond to the Notice of Inquiry (“NOI”)¹ issued by the Federal Energy Regulatory Commission (“FERC” or “Commission”) on February 18, 2021, to review the Commission’s current policy framework for the certification of new natural gas transportation facilities (the “Certificate Policy Statement”).²
The Chamber’s Global Energy Institute previously submitted comments in this docket on July 25, 2018³ in response to the Commission’s initial NOI of April 25, 2018.⁴ These new comments address changed circumstances occurring since our 2018 comments were filed. Hence, they supplement but do not replace our prior statements. These comments also address additions and revisions to the questions posed by FERC since 2018, including but not limited to the additional category of questions added to the NOI on the potential impacts of pipeline certifications on environmental justice communities.⁵ We hope to be of service to the Commission as it considers whether modifications to its 1999 Certificate Policy Statement are necessary to ensure that FERC’s regulatory interpretations continue to align with its statutory mandates under the Natural Gas Act (“NGA”).⁶