20121003-5157 FERC PDF (Unofficial) 10/3/2012 4:28:47 PM UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION IN THE MATTER OF ) ) FERC Docket No. CP12-509 Freeport LNG Development, L.P. ) FLNG Liquefaction, LLC ) FLNG Liquefaction 2, LLC ) FLNG Liquefaction 3, LLC SIERRA CLUBS MOTION TO INTERVENE, PROTEST, AND COMMENTS Nathan Matthews Kathleen Krust Associate Attorney Paralegal Sierra Club Environmental Law Program Sierra Club Environmental Law Program 85 2nd St., Second Floor 85 2nd St., Second Floor San Francisco, CA 94105 San Francisco, CA 94105 (415) 977-5695 (tel) (415) 977-5696 (tel) (415) 977-5793 (fax) 20121003-5157 FERC PDF (Unofficial) 10/3/2012 4:28:47 PM UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION IN THE MATTER OF ) ) FERC Docket No. CP12-509 Freeport LNG Development, L.P. ) FLNG Liquefaction, LLC ) FLNG Liquefaction 2, LLC ) FLNG Liquefaction 3, LLC SIERRA CLUBS MOTION TO INTERVENE, PROTEST, AND COMMENTS Freeport LNG Development, L.P. and FLNG Liquefaction, LLCs 1, 2, and 3 (collectively, Freeport LNG) request authorization to site, construct, and operate natural gas liquefaction and liquefied natural gas (LNG) export facilities at and nearby the existing Freeport LNG Development LNG import terminal located on Quintana Island, Texas. These facilities will have the capacity to export the equivalent of 1.8 billion cubic feet per day (bcf/d) of LNG. Pursuant to section 3(a) of the Natural Gas Act, the Federal Energy Regulatory Commission (FERC) must determine whether siting, construction, and operation of the proposed facilities is consistent with the public interest. 15 U.S.C. 717b(a). Sierra Club moves to intervene in this proceeding to protect our members interests in the local environment surrounding the proposed facilities as well as our members interests in the broader environment that will be affected by LNG exports and the increase in domestic natural gas production that exports will inevitably induce. In conjunction with this motion to intervene, Sierra Club offers comment on the need for examination of local impacts of the facility and reiterates our contention that FERC must analyze the effects of induced drilling. Although FERC recently refused to consider induced production in a similar proceeding, Sierra Club contends that that decision was wrongly decided and is alternatively distinguishable from the instant proceeding. Tellingly, Freeport LNG continues to cite the economic effects of induced production as purported benefits to be considered in FERCs public interest analysis. I. Sierra Club Should be Granted Intervention FERC regulations permit intervention upon a showing that either the movant has or represents an interest which may be directly affected by the outcome of the proceeding ...