12/9/15 letter/exhibits regarding recent disclosures by Pacific Connector Gas Pipeline in its 11/4/15 Data Response to FERC's 10/14/15 Data Request for info relating to Pacific Connector's application for a certificate of public convenience and necessity.

ANDYE Bennett 3lumstein LLP ATTORNEYS December 9, 2015 Page 4 the veracity of Pacific Connector's assurances, that helped prompt the Office of Energy Project's October 14, 2015 Data Request. What appear to be questionable decisions by Pacific Connector's investors should not be used by FERC as a proxy for evidence of genuine market demand. This is especially true when FERC is balancing the project's claimed benefits against the legitimate interests of landowners who would be subject to eminent domain actions if FERC issues a certificate. In addition to the substantial impacts to landowners supported by testimony in the record, issuance of the requested certificate would translate into years more of uncertainty for landowners regarding the fate of their property, and, then if the pipeline was in fact constructed, the impacts of construction and operation. It is also important to recognize that the public interest review for the Pacific Connector Pipeline is different in key respects from many pipeline projects FERC considers. This pipeline would not, for example, lower prices for domestic consumers or increase gas supplies to a U.S. community facing a gas shortage. Instead, the project is principally designed to export natural gas for the primary benefit of corporations producing natural gas and transporting it to international buyers. In the absence of true "public" benefits, Pacific Connector attempts to justify the project's benefits primarily by pointing to the temporary construction jobs it would create. Pacific Connector LP's November 4, 2015 Data Response at 2. But any gas infrastructure project will obviously create at least some temporary construction jobs. As a result, were such a consideration given substantial weight in FERC's certificate decision making, it would undermine the purpose and value of FERC's public interest review in deciding on certificate decisions. Pacific Connector LP also claims that, "[c]ommunities along the Pacific Connector pipeline will have access to a new source of gas supply, which will provide an additional benefit." Id. But such a claim ignores the fact the Pacific Connector Pipeline is not intended or being permitted as a distribution pipeline nor is there any evidence to support the contention that it will actually be used to provide gas to communities along its route that have an unmet need for gas. 2. Pacific Connector's failure to secure a single pipeline or terminal customer highlights the need for FERC to consider the crash of the Pacific LNG market and fundamental changes in the international LNG market when weighing ...