Letter: New Hampshire Municipal Pipeline Coalition’s Letter to FERC

NHPLAN Logo 2015-11-07May 3, 2016

“Notwithstanding this unsupported claim about moving forward with existing contracts, there are no existing contracts to consider—at least from a FERC regulatory perspective. TGP has effectively terminated the NED Project and associated contracts, key utility counterparties have accepted the termination, and state regulators have stayed proceedings expecting withdrawal, all thereby precluding any valid basis for further review. On its face, and as a matter of law, in the absence of valid contracts for capacity, there is no demonstrated need for the project—at best, TGP has only provided vague and generalized assertions of speculative need based upon a future “process.” See e.g., Turtle Bayou Gas Storage Co., LLC, 135 FERC ¶ 61,223 (2011) (which found the applicant did not demonstrate need where it did not have precedent agreements and provided only vague and generalized evidence of need). Moreover, to what extent TGP would be able to secure additional contractual commitments, if any, remains purely speculative at this stage. Simply put, in this Application, there is no longer a “project” or contracts to be reviewed, and the Commission should dismiss the Application forthwith.”

NHMPC 20160503

link25 NHMPC FERC 20160504-5006(31439957)