Summaries of the agenda items for the Federal Energy Regulatory Commission's monthly open meeting to be held on September 19, 2024, pursuant to the sunshine notice released on September 12, 2024.
In this issue…
- Electric Items
- Gas Items
- Hydro Items
- Certificate Items
Electric
E-1 – Supply Chain Risk Management Reliability Standards Revisions (Docket No. RM24-4-000). The formal record of this docket has not yet been populated. Agenda item E-1 may be an action that is being taken sua sponte by the Commission in order to initiate a rulemaking proceeding with respect to supply chain risk management reliability standards.
E-2 – Critical Infrastructure Protection Reliability Standard CIP-015-1 – Cyber Security – Internal Network Security Monitoring (Docket No. RM24-7-000). On June 24, 2024, North American Electric Reliability Corporation (NERC) submitted a Petition for approval of the proposed Reliability Standard CIP-015-1 (Cyber Security - Internal Network Security Monitoring). NERC explains that the Proposed Reliability Standard CIP-015-1 would advance reliability by establishing requirements for internal network security monitoring for network traffic inside an Electronic Security Perimeter (ESP). The Proposed Reliability Standard CIP-015-1 addresses the Commission's directives in No. 887 that NERC modify the Critical Infrastructure Protection ("CIP") Reliability Standards to provide protections to improve the probability of detecting anomalous or unauthorized network activity to facilitate improved response to and recovery from network attacks. Agenda item E-2 may be an order on the proposed Reliability Standard.
E-3 – Idaho Power Company (Docket No. ER24-10-001). On May 28, 2024, Idaho Power Company (Idaho Power) submitted pro forma revisions contained in Order No. 2023-A that reaffirmed and clarified certain requirements from the Commission's Order No. 2023, which revised portions of the pro forma Large Generator Interconnection Procedures (LGIP), Large Generator Interconnection Agreement (LGIA), Small Generator Interconnection Procedures (SGIP), and Small Generator Interconnection Agreement (SGIA). On May 31, 2024, Idaho Power submitted a clarification that its May 28 filing was late-filed due to a clerical error associated with the filing code used with Idaho Power's original submission and that Idaho Power originally submitted its compliance filing on May 14, 2024. Commission staff contacted Idaho Power asking that Idaho Power withdraw and refile its compliance filing using a different filing code. Idaho Power's May 31 clarification also withdrew its original filing and refiled utilizing the filing code requested by FERC staff. Agenda item E-3 may be an order on Idaho Power's Order No. 2023-A compliance filing.
E-4 – Puget Sound Energy, Inc. (Docket No. ER24-1559-000). On March 18, 2024, Puget Sound Energy, Inc (Puget Sound) submitted pro forma revisions contained in Order No. 2023, which revised portions of the pro forma LGIP, LGIA, SGIP, and SGIA). On May 24, 2024, Puget Sound submitted its pro forma revisions to the Commission's Order No. 2023-A, which required revisions to Puget Sound's proposed Annexes A and B submitted in its Order No. 2023 compliance filing. On June 14, 2024, Accelergen Energy LLC (Accelergen) submitted Limited Comments to support Puget Sound's proposed transition process applicable to interconnection customers that have a queue position within 30 days of Puget Sound's First Compliance Filing from March 18, 2024. Puget Sound proposed to deviate from the pro forma LGIP by allowing interconnection customers to extend to December 31, 2030 instead of December 31, 2027. Puget Sound explains that it is extending the date to no later than December 31, 2030, because that is the latest commercial operation date of active projects in Puget Sound's interconnection queue. Accelergen supports Puget Sound's extended proposal. Agenda item E-4 may be an order on Puget Sound's Order No. 2023 and 2023-A compliance filings.
E-5 – Black Hills Colorado Electric, LLC (Docket No. ER24-2023-000). On May 14, 2024, Black Hills Colorado Electric, LLC (Black Hills Colorado Electric) submitted its Order No. 2023 and Order No. 2023-A compliance filing containing revisions to its Standard LGIP, LGIA, SGIP, and SGIA of its Open Access Transmission Tariff (OATT). Agenda item E-5 may be an order on Black Hills Colorado Electric's Order No. 2023 and Order No. 2023-A compliance filing.
E-6 – Golden Spread Electric Cooperative, Inc. (Docket No. ER24-2027-000). On May 16, 2024, Golden Spread Electric Cooperative (Golden Spread Electric) submitted its Order No. 2023 and Order No. 2023-A compliance filing containing revisions to its Standard LGIP, LGIA, SGIP, and SGIA of its OATT. Agenda item E-6 may be an order on Golden Spread Electric's Order No. 2023 and Order No. 2023-A compliance filing.
E-7 – Valcour Altona Windpark, LLC, Valcour Bliss Windpark, LLC, Valcour Chateaugay Windpark, LLC Valcour Clinton Windpark, LLC, Valcour Ellenburg Windpark, LLC, Valcour Wethersfield Windpark, LLC, Valcour Wind Energy, LLC, AES Laurel Mountain, LLC, Highlander Solar Energy Station 1, LLC, Highlander IA, LLC, Pleinmont Solar 1, LLC, Pleinmont Solar 2, LLC Richmond Spider Solar, LLC, Riverhead Solar Farm, LLC, Skipjack Solar Center, LLC, Laurel Mountain BESS, LLC, Cavalier Solar A, LLC, AES Integrated Energy, LLC, AES Solutions Management, LLC, AES Marketing and Trading, LLC, AES CE Solutions, LLC, sPower Energy Marketing, LLC (Docket Nos. ER19-1793-002, ER19-1795-002, ER19-1796-002, ER19-1797-002, ER19-1798-002, ER19-1799-002, ER19-902-003, ER11-2036-015, ER20-1593-005, ER20-1594-004, ER20-1596-005, ER20-1597-005, ER20-1599-005, ER18-2327-007, ER21-2767-002, ER22-1518-002, ER23-1631-001, ER19-1597-005, ER20-1620-003, ER22-414-003, ER23-495-004, ER20-902-002). The above-referenced entities market-based rate sellers filed their respective triennial market power analysis for the Northeast Region. Agenda item E-7 may be an order on the triennial market power analysis filed by the above-referenced market-based rate sellers.
E-8 – Bridgeport Energy LLC, Elgin Energy Center, LLC, Essential Power Massachusetts, LLC, Essential Power Newington, LLC, Essential Power OPP, LLC, Essential Power Rock Springs, LLC, Hamilton Liberty LLC, Hamilton Patriot LLC, Hamilton Projects Acquiror, LLC, Lakewood Cogeneration, L.P., Lincoln Power, L.L.C., Nautilus Power, LLC, Revere Power, LLC, Rhode Island State Energy Center, LP, Rocky Road Power, LLC, Rumford Power LLC, SEPG Energy Marketing Services, LLC, Tiverton Power LLC (Docket Nos. ER19-1634-003, ER14-152-012, ER13-1141-006, ER13-1142-006, ER13-1143-009, ER13-1144-009, ER20-2452-004, ER20-2453-005, ER20-844-003, ER10-2196-008, ER20-528-003, ER17-1849-007, ER19-1009-002, ER16-918-005, ER10-2740-016, ER19-1633-003, ER15-1657-013, ER19-1638-003). The above-referenced entities market-based rate sellers filed their respective triennial market power analysis for the Northeast Region. Agenda item E-8 may be an order on the triennial market power analysis filed by the above-referenced market-based rate sellers.
E-9 – Blackstone Wind Farm, LLC, Blackstone Wind Farm II LLC, High Trail Wind Farm, LLC, Marble River, LLC, Meadow Lake Wind Farm LLC, Meadow Lake Wind Farm II LLC, Meadow Lake Wind Farm III LLC, Meadow Lake Wind Farm IV LLC, Paulding Wind Farm II LLC, Sustaining Power Solutions LLC, Headwaters Wind Farm LLC, Jericho Rise Wind Farm LLC, Paulding Wind Farm III LLC, Arkwright Summit Wind Farm LLC, Meadow Lake Wind Farm VI LLC, Paulding Wind Farm IV LLC, Headwaters Wind Farm II LLC, Timber Road Solar Park LLC, Blue Harvest Solar Park LLC, Riverstart Solar Park III LLC (Docket Nos. ER10-2398-014, ER10-2399-014, ER10-2406-015, ER10-2408-009, ER10-2409-014, ER10-2410-014, ER10-2411-015, ER10-2412-015, ER11-2935-016, ER13-1816-020, ER14-1933-014, ER16-1152-007, ER16-1724-012, ER17-1314-006, ER18-1189-009, ER19-1282-007, ER20-2714-005, ER22-2115-002, ER22-2116-002, ER23-1585-001). The above-referenced entities market-based rate sellers filed their respective triennial market power analysis for the Northeast Region. Agenda item E-9 may be an order on the triennial market power analysis filed by the above-referenced market-based rate sellers.
E-10 – Duquesne Light Company, Duquesne Power, LLC (Docket Nos. ER10-1910-027, ER10-1911-027). The above-referenced entities market-based rate sellers filed their respective triennial market power analysis for the Northeast Region. Agenda item E-10 may be an order on the triennial market power analysis filed by the above-referenced market-based rate sellers.
E-11 – Southwest Power Pool, Inc. (Docket No. ER24-2570-000). On July 22, 2024, Southwest Power Pool, Inc. (SPP) filed, pursuant to Section 205 of the FPA, proposed revisions to Attachment AE of the SPP's Open Access Transmission Tariff (Tariff) to allow make whole payments for incremental energy costs for offers that fall under Order No. 831 (Offer Caps for Markets Operated by Regional Transmission Organizations and Independent System Operators). Agenda item E-11 may be an order on SPP's proposed Tariff revisions.
E-12 – Virginia Municipal Electric Association #1 v. Virginia Electric and Power Co. (Docket No. EL24-99-000). On April 5, 2024, Virginia Municipal Electric Association #1 (VMEA) filed a complaint, pursuant to sections 206, 306, and 309 of the Federal Power Act (FPA), against Virginia Electric and Power Co., operating as Dominion Energy Virginia (VEPCO). In the complaint, VMEA alleged that VEPCO has violated the Uniform System of Accounts in connection with the Regional Greenhouse Gas Initiative (RGGI). Specifically, VMEA stated that VEPCO violated the Commission's accounting rules and regulations by invoicing and collecting a regulatory asset, without express authorization, from VMEA in association with RGGI costs VEPCO incurred in 2021 and 2022. According to the complaint, VEPCO established a new regulatory asset rather than recover those costs as incurred expenses, and subsequently, VEPCO wrote off the regulatory asset in a retail regulatory proceeding. VMEA alleged that VEPCO did not possess the authority to amortize the regulatory asset as an ongoing expense, as recorded in the Uniform System of Accounts, which was then included in wholesale power rates charged to VMEA. In total, VMEA asserted that VEPCO has improperly overcharged VMEA $2.8 million, not including interest. On May 6, 2024, VEPCO submitted its answer, arguing that the Commission should dismiss the complaint. VEPCO contended that VMEA improperly interpreted that relevant retail ratemaking proceedings, as well as incorrectly concluded that the RGGI costs were disallowed by the retail state regulator. Accordingly, VEPCO stated that the regulatory asset was recorded in the correct account in the Uniform System of Accounts. Agenda item E-12 may be an order on the complaint brought by VMEA against VEPCO.
E-13 – Enerwise Global Technologies, LLC v. PJM Interconnection, L.L.C. (Docket No. EL23-104-000). On September 28, 2023, Enerwise Global Technologies, LLC, doing business as CPower (CPower) filed a complaint, pursuant to Rule 206 of the Commission's rules and regulations, against PJM Interconnection, L.L.C. (PJM). In the complaint, CPower requested that the Commission direct PJM to amend its Open Access Transmission Tariff (OATT), manuals, and related governing documents in order to enable third-party Curtailment Service Providers (CSRs) to be able to serve residential customers. CPower stated that CSPs, by providing Demand Response (DR) resources into the PJM wholesale markets, would ensure just and reasonable prices as well as prevent alleged undue discrimination from CSPs in participating in PJM. Particularly, CPower requested that the DR rules in PJM should allow CSPs to use a statistical sample of interval meter data from a subset of residential DR customers to approximate the quantity of services provided by all customers in lieu of comprehensive metering data. On October 18, 2023, PJM submitted its response, stating that the complaint seeks to improperly expand the use of statistical sampling and that the current use of sampling to non-interval metered residential DR customers is appropriate from both a DR participation and data transparency perspective. Several parties filed motions to intervene and comments in support of both CPower and PJM, respectively. For instance, on October 18, 2023, the Sierra Club submitted comments in support of the complaint, asserting that removing barriers to DR aggregators from participating in the market will increase the aggregate amount of DR available to the grid. Agenda item E-13 may be an order on the complaint brought by CPower against PJM.
Gas
G-1 – Standards for Business Practices of Interstate Natural Gas Pipelines (Docket No. RM96-1-043). On October 2, 2023, the North American Energy Standards Board (NAESB) submitted a report regarding Version 4.0 of the NAESB Wholesale Gas Quadrant (WGQ) Business Practice Standards published on September 29, 2023. NAESB stated that the report includes new and revised standards, such as several revisions to enhance cybersecurity-related protections such as the use of multi-factor authentication and the practice of whitelisting. In addition, the standards would promote increased efficiencies in conducting commercial transactions as well as two new addendums to the NAESB Base Contract for the Sale and Purchase of Natural Gas (Base Contract) that support transactions for certified gas and renewable natural gas. On March 21, 2024, the Commission issued a Notice of Proposed Rulemaking (NOPR) with respect to proposed additions and revisions to Version 4.0 of the WQG Business Practice Standards. On June 4, 2024, two parties filed respective comments. American Gas Association stated that the formal process to revise the force majeure provisions in the NAESB Base Contract was ended prior to being incorporated into any potential language reflected in Version 4.0 of the WGQ Business Practice Standards. The Interstate Natural Gas Association of America stated that, while it supports the NOPR, the Commission should ensure that implementation of a final rule occurs for the first gas day of the month but not before April 1, 2025 (following the winter heating season). Agenda item G-1 may be an order on the NOPR.
G-2 – Vector Pipeline L.P. (Docket No. RP24-971-000). The formal record of agenda item G-2 has not yet been populated in eLibrary and may represent a new proceeding initiated by the Commission with respect to the interstate natural gas pipeline rates of Vector Pipeline, L.P.
Hydro
H-1 – Pembroke Tidal Power Project, LLC (Docket No. P-15340-001). On March 1, 2024, Pembroke Tidal Power Project, LLC (Pembroke) submitted an application for a preliminary permit, under Part I of the FPA, for the proposed Pembroke Tidal Power Plant, Project No. P-15340, to be located in Maine. In the preliminary permit application, Pembroke stated that the project would be a retiming tidal range plant and requested a license term of 48 months. On March 28, 2024, the Division of Hydropower Licensing for the Commission issued a letter acknowledging the preliminary permit application and instructing Pembroke to send respective copies to the US Coast Guard, the Nautical Data Branch of the US Department of Commerce, the Fisheries Service of the National Oceanic and Atmospheric Administration, and the Maine Bureau of Land and Water Quality. During the comment period, a number of stakeholders and citizens filed comments in opposition to the project. Most of the comments found the proposal to use “experimental” hydroelectric technology that could pose significant risks to the local environment. Commenters generally pointed to recent decades where hydroelectric dams have not been constructed and asserted that this proposal should consider an alternate approach and less impactful site location if it were to proceed. On May 13, 2024 and May 20, 2024, respectively, Pembroke filed answers to the comments, clarifying that the project is not in fact a hydroelectric dam and that the proposed technology would not be the first in operation. Agenda item H-1 may be an order on the preliminary permit application by Pembroke.
H-2 – Village of Highland Falls High-Point Utility, LDC (Docket No. P-7656-019, P-7656-017). On January 18, 2024, the Commission issued an order proposing the revocation of license with respect to the Buttermilk Falls Hydroelectric Project No. 7656, operated by the Village of Highland Falls High-Point Utility, LDC (High-Point Utility). In accordance with section 31(b) of the FPA, the Commission stated that High-Point Utility violated the license for the project by failing to obtain certain necessary property rights. Standard Article 5 of the license requires the licensee to acquire and retain title in fee, or the right to use in perpetuity, all non-federal property necessary to carry out construction, maintenance, and operation of the project. On June 12, 2009, the Commission received a complaint from a landowner that a portion of the project had encroached on their property. On April 15, 2016, Commission staff issued a Notice of Proposed Termination of License by Implied Surrender, pursuant to Article 16 of the project license. In the notice, Commission staff stated that the applicant had not acquired the property necessary to continue operation of the project nor attempted to return the project to service following Hurricane Sandy in the fall of 2012. On August 11, 2016, as supplemented on November 28, 2016 and January 24, 2017, High-Point Utility filed an application to receive the project upon being transferred from the original owner. Based on the provisions furnished in the application, such as a financing plan to acquire the property rights and to restore project operations, the Commission issued an order approving the license transfer on September 21, 2017. On January 23, 2018, High-Point Utility filed plans and costs associated with the resumption of service and acquisition of property rights. However, on January 10, 2022, the landowner filed a complaint, alleging that High-Point Utility had failed to satisfy the requirements of Article 5 of the project as well as ordering paragraph (C) of the transfer approval order. Accordingly, the landowner requested that the Commission revoke the project license and direct High-Point Utility to restore the project to its original condition. Agenda item H-2 may be an order on the proposed license revocation for the project.
Certificates
C-1 – ANR Pipeline Company (Docket No. CP23-15-001). On December 19, 2023, the Commission issued ANR Pipeline Company (ANR) a certificate of public convenience and necessity and related authorizations for the Wisconsin Reliability Project (Certificate Order). According to the Certificate Order, the Wisconsin Reliability Project is designed to upgrade existing pipeline and compression facilities with new, more modern pipeline and compression facilities and provide 132,000 dekatherms per day (Dth/d) of incremental transportation service on ANR's pipeline system. On May 23, 2024, a landowner along the proposed route for the Wisconsin Reliability Project filed a motion to intervene out-of-time. The landowner explained she was filing late because her ongoing negotiations with ANR regarding the removal from her property of a portion of pipeline being abandoned had broken down. Such landowner requested that the Commission reopen the certificate proceeding and amend the Certificate Order to require abandonment by removal of the pipeline crossing her field. On June 27, 2024, the Commission issued an order denying late intervention by such landowner, explaining that the time period to file a request for rehearing of the Certificate Order passed in January 2024, such that granting such landowner late intervenor status would gain her nothing. On July 26, 2024, such landowner filed a request for rehearing (Rehearing Request) of the Commission's June 27 order denying her motion to intervene out-of-time, and again asked the Commission to reopen the certificate proceeding and amend the Certificate Order to require abandonment by removal of the pipeline crossing her field. On August 26, 2024, the Commission issued a notice of denial of rehearing by operation of law with respect to the Rehearing Request while providing that the Commission would address the Rehearing Request in a future order. Agenda item C-1 may be a further order on the Rehearing Order.
C-2 – National Fuel Gas Supply Corporation (Docket No. CP24-68-000). On February 23, 2024, National Fuel Gas Supply Corporation (National Fuel) filed an abbreviated application (Abandonment Application) with the Commission seeking authorization to abandon by sale the Derby Storage Field, the New Oregon Road Wells, and associated facilities in Erie County, New York. Commission staff issued an Environmental Assessment (EA) on March 7, 2024, determining that the Abandonment Application qualifies for a categorial exclusion under the Commission's regulations. Agenda item C-2 may be an order on the Abandonment Application.
C-3 – LA Storage, LLC (Docket No. CP24-487-000). On June 28, 2024, LA Storage LLC (LA Storage) filed an application (Amendment Application) with the Commission seeking to amend the certificate of public convenience and necessity issued by the Commission in Docket No. CP21-44-000, authorizing LA Storage to construct and operate the Hackberry Storage Project. As authorized, the Hackberry Storage Project consists of four (4) natural gas storage caverns with a total 25.5 billion cubic feet of capacity; one 21,400 horsepower compressor station with four (4) natural gas-driven compressor units; an approximately 4.9-mile, 42-inch diameter bi-directional natural gas pipeline (CIP Lateral); an approximately 11.1-mile, 42-inch diameter bi-directional natural gas pipeline (Hackberry Pipeline); and other associated facilities. Specifically, the Amendment Application seeks a limited amendment to the Hackberry Storage Project in order to reduce the diameter of the previously authorized Hackberry Pipeline from 42-inch to 36-inch diameter. Commission staff issued an Environmental Assessment (EA) on August 8, 2024, determining that no additional impact would occur as a result of construction or operation of the proposed change in pipeline diameter of the Hackberry Pipeline. Agenda item C-3 may be an order on the Amendment Application.
C-4 – Port Arthur Pipeline, LLC (Docket Nos. CP18-7-000, CP20-21-000, CP23-513-000). On July 23, 2024, Port Arthur Pipeline, LLC (Port Arthur) submitted a limited motion (Limited Motion) to partially vacate certificates of public convenience and necessity (Certificated Orders) previously issued by the Commission for a specific, limited segment of unconstructed pipeline facilities for the Louisiana Connector Project. According to the Certificate Orders, the as-authorized 130.9-mile-long Louisiana Connector Project would transport up to 2,000,000 MMBtu per day of natural gas from interconnections in Louisiana and Texas to the vicinity of Port Arthur, Texas, where it would be liquefied for export to foreign markets. Port Arthur explains in its Limited Motion that, following discussions with its customers and a review of pipeline engineering, it now believes that the demand for transportation previously contemplated on that segment of pipeline facilities (northeast from MP 76.9 to MP 130.9) can be met with a more limited segment of its certificated system and systems of interconnecting pipelines. Accordingly, Port Arthur states it currently has no intent to construct that segment of the Louisiana Connector Project, and requests that the Commission partially vacate the Certificate Orders as they pertain to that discrete segment of pipeline facilities. Agenda item C-4 may be an order on the Limited Motion.
C-5 – Venture Global Calcasieu Pass, LLC (Docket Nos. CP15-550-002, CP15-550-000). On February 21, 2019, the Commission issued an order (Authorization Order) authorizing Venture Global Calcasieu Pass, LLC (Venture Global) to site, construct, and operate a new liquefied natural gas (LNG) terminal in Cameron Parish, Louisiana (Calcasieu Pass LNG Terminal). As relevant here, Ordering Paragraph (B) of the Authorization Order required Venture Global to place its proposed liquefaction facilities in-service within five (5) years of the Calcasieu Pass Order (i.e., by February 21, 2024) (In-Service Deadline). On February 15, 2024, Venture Global filed a request for a one-year extension of time (Extension Request) of the In-Service Deadline or, alternatively, clarification that no such extension is required. According to the Extension Request, even though all of Venture Global's liquefactions facilities were in-service, Venture Global believed some interested stakeholders may nevertheless interpret the In-Service Deadline more broadly than its plain language suggests, and in a manner where Venture Global would not be able to comply with the In-Service Deadline as a result of the continuing need for further commissioning, repair, rectification, and completion of certain Calcasieu Pass LNG Terminal facilities. In response to the Extension Request, a number of Venture Global's customers submitted comments disagreeing with Venture Global's claim that it had not completed the construction and commissioning of the entire Calcasieu Pass LNG Terminal; in their view, no one disputes Venture Global's position that proposed liquefaction facilities in Ordering Paragraph (B) of the Authorization Order includes only the liquefaction blocks at the Calcasieu Pass LNG Terminal, and not every last piece of equipment on-site at the entire Calcasieu Pass LNG Terminal. Those customers therefore contend that the Commission need only answer that question in the affirmative and then deny as moot Venture Global's Extension Request. Agenda item C-5 may be an order on the Extension Request.
C-6 – Leaf River Energy Center LLC (Docket No. CP24-40-000). On January 17, 2024, Leaf River Energy Center LLC (Leaf River) submitted a request (Amendment Request) with the Commission seeking to amend the certificate of public convenience and necessity (Certificate Order) issued by the Commission in Docket No. CP08-8-000, authorizing Leaf River to own and operate a salt dome natural gas storage facility and associated pipeline facilities in Mississippi (Leaf River Storage Facility). As relevant here, the Leaf River Storage Facility includes leaching facilities, which consist of: (i) four water supply wells, (ii) five brine disposal wells, (iii) one 5,000 barrel water tank, (iv) one 5,000 barrel brine tank, (v) two 3,000 horsepower (hp) raw water pumps, (vi) two 1,000 hp pond pumps, (vii) two 1,000 hp brine disposal pumps, (viii) a 16-inch-diameter water supply pipeline connecting the water supply wells to the salt caverns; and (ix) a 16-inch-diameter brine disposal pipeline connecting the salt caverns to the brine disposal wells. In its Amendment Request, Leaf River requests that the Commission amend the Certificate Order to permit Leaf River to use its leaching facilities for the development and maintenance of five (5) non-jurisdictional hydrogen storage caverns, in addition to their existing use for the development and maintenance of natural gas storage capacity. Commission staff issued an Environmental Assessment (EA) on July 24, 2024, determining that the Amendment Request did not involve the environment. Agenda item C-6 may be an order on the Amendment Request.
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