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Pivotal LNG Requests FERC Ruling on LNG Terminal Definition and LNG Transportation Jurisdiction

Sutherland Asbill Brennan LLP - Washington Office

April 17, 2014

Previously published on April 14, 2014

Pivotal LNG has filed a petition for declaratory order with FERC seeking a ruling that existing LNG production facilities not otherwise subject to FERC’s jurisdiction under Section 3 of the Natural Gas Act would not be deemed “LNG terminal[s]” subject to Section 3 jurisdiction by virtue of producing LNG that subsequently may be transported in interstate commerce by waterborne vessel. Pivotal LNG also requests a ruling that certain transactions involving sales of LNG sourced from an existing LNG production facility or from a non-affiliated LNG supplier and subsequently transported in interstate commerce by means other than interstate pipeline to a noncontiguous U.S. state or territory are not subject to FERC’s jurisdiction.


The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.

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