The Interstate Natural Gas Association of America (“INGAA”) moves for leave to submit and submits these supplemental reply comments on the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) draft Updated Policy Statement on Certification of New Interstate Natural Gas Facilities (“Updated CPS”) and Interim Policy Statement on Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (“GHG Statement” and, collectively with the Updated CPS, “Draft Policy Statements”). Although the Commission’s order soliciting comment on the Draft Policy Statements did not provide for supplemental replies, the Commission should nonetheless consider INGAA’s comments because, as discussed further below, the comments will assist the Commission in understanding the issues raised.
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