Regulatory Submissions

August 19, 2021
Federal Energy Regulatory Commission
888 First Street, N.E. Washington, D.C. 20426

The Honorable Richard Glick, Chairman
The Honorable Neil Chatterjee, Commissioner
The Honorable James Danly, Commissioner
The Honorable Allison Clements, Commissioner
The Honorable Mark C. Christie, Commissioner

Re: Spire STL Pipeline LLC Application for Temporary Emergency Certificate in Docket No. CP17-40-007

Dear Chairman Glick and Commissioners,

Thank you for your continued leadership in furthering the development of safe and reliable U.S. energy infrastructure. As organizations that represent the interests of business, manufacturing and organized labor we write in support of Spire STL Pipeline, LLC’s (“STL Pipeline”) July 26, 2021 temporary certificate application at the Federal Energy Regulatory Commission (“FERC” or “Commission”).

The U.S. relies on critical energy infrastructure to deliver reliable, diverse supplies of energy needed to fuel our economy. Further, its construction and maintenance support jobs for thousands of skilled workers across the country.

The Commission approved a Certificate of Public Convenience and Necessity for the STL Pipeline Project in 2018, authorizing the construction and operation of this infrastructure. STL Pipeline was constructed by union labor, ensuring the highest construction standards performed by skilled and well-trained building trades men and women. Since being placed into service in 2019, the STL Pipeline has delivered critical gas supply for the more than 650,000 Missouri homes and businesses that Spire Missouri serves.

During Winter Storm Uri, the STL Pipeline also proved to be critical energy infrastructure, continuing to deliver reliable, affordable natural gas to eastern Missouri from gas producing basins not impacted by the extreme weather. Without the STL Pipeline, Spire Missouri may not have been able to secure required gas supplies to meet customer demand and estimates that up to 133,000 customers could have been without gas service.

Spire Missouri estimates that, without STL Pipeline, approximately 175,000-400,000 Spire Missouri customers may be without gas service to heat homes, cook food and fuel industry, based on previously modeled extreme cold weather planning scenarios. Among these customers are close to 20,000 commercial customers – nearly 40 percent of all Spire commercial customers in the region – ranging from small businesses to major health centers and industrial manufacturing facilities. Failure to keep this infrastructure in service would have a detrimental impact on the families, businesses, and the economy of the St. Louis region.

We support STL Pipeline’s application so that the St. Louis region can avoid gas shortages in the months ahead and throughout the winter to provide a reliable supply of energy to the area. We look forward to the Commission’s prompt consideration and response on the temporary certificate application so that all stakeholders understand the immediate path forward for this crucial energy infrastructure.

Sincerely,
American Gas Association
American Public Gas Association
Consumer Energy Alliance
Distribution Contractors Association
Energy Equipment & Infrastructure Alliance
GPA Midstream Association
Hearth Patio Barbeque Association
Independent Petroleum Association of America
International Brotherhood of Electrical Workers
LIUNA
National Association of Manufacturers
National Utility Contractors Association
North America’s Building Trades Unions
The Utility Workers Union of America, AFL-CIO