MOTION FOR LEAVE TO INTERVENE AND COMMENTS OF FLORIDIAN NATURAL GAS STORAGE COMPANY, LLC under CP14-114.

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Emera CNG, LLC Docket No. CP14-114-000 MOTION FOR LEAVE TO INTERVENE AND COMMENTS OF FLORIDIAN NATURAL GAS STORAGE COMPANY, LLC On March 19, 2014, Emera CNG, LLC (Emera) filed a Petition for a Declaratory Order (Petition), requesting that the Federal Energy Regulatory Commission (Commission or FERC) issue an order declaring that Emeras proposed construction of a new compressed natural gas (CNG) compression and loading facility and its planned export of CNG via truck and trailer and ocean-going carrier are not subject to the jurisdiction of the Commission under the Natural Gas Act (NGA). Floridian Natural Gas Storage Company, LLC (FGS) hereby moves for leave to intervene in this proceeding and submits its comments on Emeras Petition pursuant to the Commissions March 24, 2014 Notice of the Petition and Rules 211 and 214 of the Commissions Rules of Practice and Procedure, 18 C.F.R. 385.211 and 385.214. All communications with respect to this matter should be served on the following persons: David W. Sharp Beth L. Webb Floridian Natural Gas Joan M. Darby Storage Company, LLC Dickstein Shapiro LLP 1000 Louisiana Street, Suite 4300 1825 Eye Street, NW Houston, TX 77002 Washington, DC 20006 Telephone: 800-621-6843 Telephone: 202-420-2200 Facsimile: 866-616-6706 Facsimile: 202-42-2201 dsharp@floridiangasstorage.com webbb@dicksteinshapiro.com darbyj@dicksteinshapiro.com DSMDB-3249120 v1 Motion for Leave to Intervene Floridian Natural Gas Storage Company, LLC, a Delaware limited liability company, has its principal place of business located at 1000 Louisiana Street, Suite 4300, Houston, TX 77002. FGS holds a certificate of public convenience and necessity under NGA Section 7(c) issued in FERC Docket No. 08-13-000 on August 29, 2008 and amended in Docket No. CP12-100-000 on August 31, 2012. That certificate authorizes FGS to construct and operate a new natural gas liquefaction, storage, vaporization and truck loading facility near Indiantown in Martin County, Florida. FGS, as the developer of a FERC-regulated natural gas liquefaction facility located in Florida approximately 35 miles from the location of Emeras proposed natural gas compression facility, has a substantial interest that may be affected by the outcome of this proceeding. FGSs interest cannot be adequately represented or protected by any other party. FGSs participation in this proceeding is therefore in the public interest. Comments In FGSs view, a disclaimer of Commission NGA jurisdiction over Emeras exports of CNG, and over Emeras Port facility that compresses natural gas to facilitate its export, would be inconsistent with the Commissions longstanding assertion of its ...