Motion to Intervene and Statement of Support of CHESAPEAKE ENERGY CORPORATION under CP11-72.
03/03/2011UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION In the Matter of ) Sabine Pass Liquefaction, LLC and ) Docket No. CP11-72-000 Sabine Pass LNG, L.P. MOTION TO INTERVENE AND STATEMENT OF SUPPORT OF CHESAPEAKE ENERGY CORPORATION Chesapeake Energy Corporation (Chesapeake), pursuant to the provisions of the Natural Gas Act and the Commissions Rules of Practice and Procedure, hereby moves to intervene in this proceeding on the terms set forth below. Chesapeake supports the application of Sabine Pass Liquefaction, LLC and Sabine Pass LNG, L.P. (collectively, Sabine Pass), filed pursuant to Section 3(a) of the Natural Gas Act, to site, construct and operate liquefaction and export facilities at the existing Sabine Pass LNG terminal, located in Cameron Parish, Louisiana. Correspondence and communications with regard to this matter should be addressed to: Bill Wince1 Vice President, Transportation and Business Development Chesapeake Energy Marketing, Inc. 6100 North Western Avenue Oklahoma City, Oklahoma 73118 (405) 935-4210 bill.wince@chk.com David I. Bloom1 Mayer Brown LLP 1999 K Street, N.W. Washington, D.C. 20006 (202) 263-3204 dbloom@mayerbrown.com 1 Designated for official service list. In support of this pleading, Chesapeake respectfully represents: 1. The exact legal name of Chesapeake is Chesapeake Energy Corporation. Chesapeake is an Oklahoma corporation with its principal place of business located at 6100 North Western Avenue, Oklahoma City, Oklahoma 73118. Subsidiaries have made significant investments in the development of domestic natural gas production, and Chesapeake is the second largest producer of natural gas in the United States. 2. Sabine Pass has filed for authority under Section 3(a) of the Natural Gas Act to construct facilities that would enable it to liquefy domestic natural gas supplies for export of approximately 16 million metric tones of liquefied natural gas per annum. (Sabine Pass has filed with the Office of Fossil Energy, Department of Energy, for authority to export natural gas.) 3. Chesapeake is the second largest producer of natural gas in the United States, and it may, at some point in the future, enter into contracts for the sale of natural gas to foreign markets. Chesapeake therefore has an interest in this proceeding which would be directly affected by the determination hereof and with respect to which it would be bound by the Commissions action. This interest is not adequately represented by existing parties. 4. Chesapeake supports the application filed by Sabine Pass. The project would enable Chesapeake and other producers to export natural gas to markets around the ...