Request for Rehearing of Allegheny Defense Project, et. al. of the November 19, 2015 Order under CP14-555.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Dominion Transmission, Inc. Docket No. CP14-555-000 REQUEST FOR REHEARING OF ALLEGHENY DEFENSE PROJECT, FRESHWATER ACCOUNTABILITY PROJECT, HEARTWOOD, AND OHIO VALLEY ENVIRONMENTAL COALITION Pursuant to section 19(a) of the Natural Gas Act (NGA), 15 U.S.C. 717r(a) and Rule 713 of the Federal Regulatory Energy Commissions (FERC) Rules of Practice and Procedure, 18 C.F.R. 385.713, the Allegheny Defense Project, FreshWater Accountability Project, Heartwood, and Ohio Valley Environmental Coalition hereby request rehearing of FERCs Order Issuing Certificate, issued November 19, 2015 in the above-captioned proceeding (Order). See Dominion Transmission, Inc., 153 FERC 61,203 (2015). The Order grants Dominion Transmission, Inc. (Dominion) authority to construct and operate pipeline, compression, regulation, valves, and other facilities in Ohio and Pennsylvania as part of the Lebanon West II Project. We request that the Order, Finding of No Significant Impact (FONSI), and Environmental Assessment (EA) be withdrawn and the environmental analysis redone in a manner that complies with FERCs obligations pursuant to the National Environmental Policy Act (NEPA), 42 U.S.C. 4321 et seq., and the NGA, 15 U.S.C. 717 et seq., and their respective implementing regulations. All communications regarding this request should be addressed to and served upon Ryan Talbott, 5020 NE 8th Avenue, Portland, OR 97211. I. Statement of the Issues 1. FERC violated NEPA by failing to adequately consider the indirect and cumulative effects of natural gas drilling, failing to prepare a programmatic regional EIS, and improperly segmenting the Lebanon West II Project from other connected, cumulative, and/or similar projects. 40 C.F.R. 1508.8(b) requires FERC to consider the indirect effects of a proposed action. 40 C.F.R. 1508.7 requires FERC to consider the incremental effect of the proposed action when combined with past, present, and reasonably foreseeable future effects. 40 C.F.R. 1502.4(b) requires federal agencies, in certain circumstances, to prepare a programmatic EIS for broad federal actions. Finally, 40 C.F.R. 1508.25(a) requires FERC to consider connected, cumulative, and similar actions in the same EIS as the proposed action. a. Indirect effects FERC claims that the record in this proceeding does not demonstrate the requisite reasonably close causal relationship between the impacts of future natural gas production and the Lebanon West II Project which would necessitate further analysis. Order at P 28. FERC further claims that even if a causal relationship between our action here and additional production were presumed, the scope of the impacts from any such induced production ...