The Interstate Natural Gas Association of America (“INGAA”) submits these comments in response to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) notice of inquiry (“NOI”) on its currently effective policy statement1 on the certification of new interstate natural gas transportation facilities, issued April 19, 2018.2 As further discussed herein, the Commission’s Certificate Policy Statement has provided a durable framework to review certificate applications in a reasoned, consistent, and predictable manner. While incremental improvements may be achieved through this proceeding from incorporating stakeholder suggestions, including INGAA’s suggestions detailed below, there is no evidence to suggest the need for wholesale policy changes. To the contrary, wholesale policy changes likely would result in problematic consequences to the detriment of domestic consumers.
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