Motion for Leave to Answer and Answer of Cameron LNG, LLC and Cameron Interstate Pipeline, LLC in Docket Nos. CP13-25, et al.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Cameron LNG, LLC ) Docket Nos. CP13-25-000 Cameron Interstate Pipeline, LLC ) CP13-27-000 ) MOTION FOR LEAVE TO ANSWER AND ANSWER OF CAMERON LNG, LLC AND CAMERON INTERSTATE PIPELINE, LLC Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commissions (Commission) Rules of Practice and Procedure, 18 C.F.R. 385.212 and 385.213 (2012), Cameron LNG, LLC (Cameron LNG) and Cameron Interstate Pipeline, LLC (Cameron Interstate) (collectively, Cameron) hereby move for leave to answer and submit this Answer to the Motion to Intervene, Protest, and Comments filed by Sierra Club and Gulf Restoration Network (Intervenors) in the above-captioned proceedings on January 16, 2013.1 The protests to which Cameron responds would have the Commission use this project- specific proceeding to challenge and revise national policies and decisions regarding natural gas exports made by Congress many years ago. Their protests lack focused analysis and should be dismissed by the Commission. The contention that the Commission should evaluate the Cameron LNG Project using some national programmatic model is inconsistent with governing statute and precedent. 1 Motion to Intervene, Protest, and Comments of Sierra Club and Gulf Restoration Network, Docket Nos. CP13-25-000 and CP13-27-000 (filed Jan. 16, 2013). 1 For the reasons stated below, Cameron respectfully requests that the Commission accept this Answer and deny the Intervenors protest. In support of this Answer, Cameron states as follows: I. BACKGROUND On April 30, 2012, Cameron LNG filed a request to commence the Commissions National Environmental Policy Act (NEPA)2 pre-filing process in connection with its proposal to site, construct, and operate new liquefaction and export facilities (Liquefaction Project) at the site of the existing Cameron LNG liquefied natural gas (LNG) terminal located in Cameron Parish, Louisiana. On that same day, Cameron Interstate filed a request to commence the Commissions NEPA pre-filing process in connection with its proposal to construct, own, and operate additional pipeline and compression facilities that will enable Cameron Interstate to transport domestically-produced natural gas on a firm basis to the Cameron LNG terminal for processing, liquefaction and export. On May 9, 2012, the Director of the Office of Energy Projects issued a letter order in Docket No. PF12-13-000 granting both pre-filing requests. During their respective pre-filing processes, Cameron LNG and Cameron Interstate participated in numerous meetings with local, state and federal officials and individual and agency stakeholders to discuss the Liquefaction Project and proposed pipeline facilities. Cameron LNG and Cameron ...