Motion to Intervene and Protest of StopNED under CP16-21-000

Submission Description: (doc-less) Motion to Intervene and Protest of  StopNED under CP16-21-000.
Submission Date: 1/15/2016 10:44:48 AM
Filed Date: 1/15/2016 10:44:48 AM
CP16-21-000 Application for a Certificate of Public Convenience and Necessity (Northeast Energy Direct Project)

Filing Party/Contacts:
Filing Party                                 Signer (Representative)
Other Contact (Principal)
————                                   ———————–

Basis for Intervening:
Pursuant to Sections 212 and 214 of the Rules of Practice and Procedure of the Federal Energy regulatory Commission (the “Commission”) promulgated at 18 C.F.R. 382.212 and 385.214, StopNED respectfully (1) moves to intervene in the Tennessee Gas Pipeline Company, LLC Docket #: CP16-21-000, regarding the application (the “Application”) of Tennessee Gas Pipeline Company, LLC (the “Company”) for a certificate of public convenience and necessity for the Northeast Energy Direct (“NED”) project, and (2) protests the proposed project as well as the Commission’s acceptance of an incomplete application.

StopNED is a grassroots coalition of leaders of impacted communities in Massachusetts and New Hampshire which have organized to oppose the NED fracked gas pipeline project. Our mission is to provide education about the negative health, safety, environmental, and economic impacts from the pipeline, to oppose ratepayer forced risk-taking of funding the construction of fossil fuel infrastructure, and other forms of opposition support while at the same time pursuing legislation for a clean energy future of reduced reliance on fossil fuels, increased efficiency, expanded renewable technologies, and mandated repairs of existing infrastructure.

StopNED seeks to intervene in opposition to the proposed NED project. StopNED’s interests that may be directly affected by the outcome of the proceeding include:

  • The pipeline is not in the interest of the public good. It directly and negatively impacts our member communities.
  • Our communities have passed Non-binding Resolutions in opposition to the pipeline. Our Resolutions identify the concerns expressed by our communities related to their rights to clean air, clean water, and a future with a reduced reliance on fossil fuels.
  • Our communities are now represented on two different Alternative routes, the Massachusetts Alternative Route and the  Massachusetts Route 2, Article 97 Co-Location Hybrid Alternative Route. Our presence on alternative routes puts us squarely in the sights of this pipeline project.
  • Many conservation and agricultural parcels are put at risk within our communities due to this proposal. Some of these parcels are permanently protected by the Commonwealth of Massachusetts, some by the municipalities, and some by private landowners. All actions taken to preserve these lands were intended to be permanent meaning into perpetuity, not until a commercial entity came along to take it.
  • StopNED has spent countless hours working with directly and indirectly impacted residents, leaders of directly impacted communities, and legislators of impacted constituencies to stop the Kinder Morgan Tennessee Gas Pipeline.

Pursuant to 18 CFR 157.10(a)(1), StopNED respectfully requests a formal hearing on the Application, including the environmental impacts of and public need for NED.

StopNED is applying to intervene in the interest of the public good. Our interests cannot be adequately or completely represented by any other party and in accordance with the Commission’s Rules of Practice and Procedure, we believe we satisfactorily meet the conditions for intervention because our participation is in the public interest. We have a direct and substantial interest in the outcome of this  proceeding. Therefore, StopNED requests that the Commission grant this motion to intervene.

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