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Small scale LNG "Virtual Pipeline" up and running Tioga County PA to Norwich CT!?
What the hell? I try to stay informed about such things, and I've never heard of this.
Interstate bulk-haul natural gas by truck or rail, (either CNG/LNG) seems to be obviously "interstate commerce in natural gas" and this jurisdictional under §7 of the Natural Gas Act.
In the case of New Fortress LNG, which is seeking to create a truck+rail Virtual Pipeline between Wyalusing, Bradford Co. PA and Gibbstown, Gloucester Co NJ and has declared this will be for export, this seems jurisdictional under both §7 (interstate) and §3 (export) jurisdictional.
FERCs own case, Gulf Oil, Ltd's, Petition for Declaratory Order, 148 FERC ¶ 61,029 (CP14-132) suggests that under these conditions, these bulk route activities would be jurisdictional.
Thus, the ground facilities should be subject to National Environmental Policy Act and require a Certificate of Public Convenience and Necessity from FERC.
I know it might seem weird to this list, but this is a case where I am arguing FOR FERC jurisdiction, because it would buy us more time and require an EA or ideally and EIS.
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