INGAA Motion for Leave to Intervene Out-of-Time

The Interstate Natural Gas Association of America (“INGAA”) filed this motion for leave to intervene out-of-time or, in the alternative, to file an amicus brief, and the brief set forth below, to assist the Commission in its consideration of exceptions to the Initial Decision in Rockies Express Pipeline LLC, 143 FERC ¶ 63,017 (2013) (“I.D.”). 

Because the I.D. in this case has the potential to set a troublesome and prejudicial precedent for the interstate gas pipeline industry, INGAA respectfully requested leave to intervene out-of-time and, in the alternative, to file an amicus brief. INGAA, a trade organization representing the majority of U.S. interstate natural gas pipeline companies, has a strong and legitimate interest apart from the outcome of this single case. INGAA is moved to intervene and submit this brief on exceptions out of concern about the impacts of the I.D. on INGAA’s members, on the natural gas industry, and on natural gas consumers. INGAA’s prominence as an industry trade group for interstate gas pipelines makes INGAA uniquely qualified to present an industry perspective on the I.D., and this perspective should be considered desirable and relevant to the case.

INGAA could not have known about the importance of this case prior to the I.D. The I.D. reopens a closed proceeding that the Presiding Judge admits was not set for hearing. Thus, INGAA could not have known about this issue until now. Points in the I.D. with industry-wide ramifications also merit clarification from the Commission. Therefore, for good cause shown, INGAA’s participation should be permitted.