Request for Rehearing of Ted Cady under CP12-72.

BEFORETHEUNITEDSTATESOFAMERICA FEDERALENERGYREGULATORYCOMMISSION DominionTransmissionInc. ) ) DocketNo.CP1272 AlleghenyStorageProject ) REQUESTFORREHEARINGBYTHEODORECADYOFORDERISSUINGCERTIFICATETO DOMINIONTRANSMISSIONINC. PursuanttoRule713oftheCommissionsRulesofPracticeandProcedure,Iherebyseekrehearingofthe CommissionsDecember20,2012decisionissuingacertificatefora16,600horsepowercompressorstationthat willbelocatedinMyersville,Maryland.1TheCommissionabuseditsdiscretionbyissuingthecertificate becauseoferrorsinfindingsandignoringtheevidence. ThesepointsandmoreareexplainedinmoredetailintheStatementofIssuessectionnotedbelow WHEREFORE,fortheforegoingreason,IaskFERCtoGRANTthistimelyrehearingrequestandDENYthe certificatefortheMyersvilleCompressorstation. Respectfullysubmitted, 2763FlintridgeDr. Myersville,MD21773 TCady21773@gmail.com Home(301)2932194 Date:January21,2013 1 DominionPipeline,Inc.,OrderIssuingCertificate,141FERC61,240(December20,2012). Statement of Issues ISSUE No. 1: FERCs decision to grant the certificate to Dominion must be vacated because it is based on inherently flawed process that inappropriately favors the gas industry over local citizens and violates citizens due process rights. The procedures leading to FERCs grant of a certificate are so inherently flawed that the entire certificate must be vacated. First, FERC lacks accountability or regulatory oversight. Nor is FERC impartial because it recovers the full cost of its operations through fees assessed on the industry and thus, is motivated to bias its process towards industry interests. Second and specific to this case, FERCs entire EA process was flawed. Intervenors lacked access to information, were forced to comply with short deadlines to comment on the EA in the absence of full access to information relied on by DTI. In addition, FERC made no effort to address confusion arising out of DTIs deceptive use of the Commission seal on a DTI-prepared EA or repeated errors in the notices issued related to the process. Taken together, all of these deficiencies lead to a process so flawed that the decision resulting from the process cannot be sustained. ISSUE No. 2: FERCs decision to grant a certificate to Dominion is not supported by substantial evidence because there is no evidence of public need for the proposed Myersville Compressor Station. Under the Natural Gas Act, FERC must find that there is a need for a proposed project in order to grant a certificate. The record overwhelmingly shows that there is no need for the Myersville Compressor station. Evidence from EIA and other credible publications that FERC erroneously minimized or ignored shows a decline in demand for natural gas. In addition, the 16,000 horespower compressor station is overbuilt and far bigger than what is needed to serve the modest needs of two customers and instead, is likely to be used to export gas to Cove Point. Both the CEII data and Dominions own power point presentations provide evidence of Dominions intent to export gas to Cove Point. In shor