UNOPPOSED MOTION FOR LEAVE TO FILE AMICUS CURIAE
BRIEF IN SUPPORT OF PETITIONER
The National Association of Manufacturers, Chamber of Commerce of the United States of America, Interstate Natural Gas Association of America, American Gas Association, American Petroleum Institute, American Chemistry Council, Natural Gas Supply Association, American Forest & Paper Association, and Process Gas Consumers Group (together, “Movants”) respectfully request leave to file an amicus curiae brief in support of petitioner Constitution Pipeline Company. Counsel for respondents has indicated that they do not oppose this motion.
Together, Movants represent a wide range of companies and organizations in the manufacturing, commercial, energy, and oil and gas sectors. Movants have a vital interest in this case. As some of the largest producers, transporters, and users of natural gas in the country, many of Movants’ members are directly affected by the decision under review, which denied a certification necessary for the construction of an important interstate pipeline. Further, Movants are concerned by the broader impacts of certification denials like this one on the development of much-needed natural gas infrastructure. Total natural gas demand, driven in particular by manufacturing and power generation, is poised to increase by 40 percent over the next decade, and the U.S. supply is expected to increase by 48 percent over the same period. Further, explosive growth in shale gas requires the construction of new pipeline capacity.
Movants thus have a strong interest in the effectuation of Congress’s policy for the efficient, transparent, and predictable approval of natural gas pipelines.