Columbia Gas Transmission Corp. v. An Exclusive Gas Storage Easement
In Columbia Gas Transmission Corp. v. An Exclusive Gas Storage Easement, 776 F.2d 125 (6th Cir.1985), a natural gas company, Columbia, sought to condemn an easement for underground storage of natural gas in property that was one to two miles away from Columbia's storage field. See id. at 125-26.
Columbia possessed a 1953 CPCN (certificate of public convenience and necessity) which did not cover the property it sought to condemn, but Columbia argued that it did not need an amended CPCN because the property it sought to condemn contained gas that had migrated from Columbia's gas storage reservoir and the easement was necessary to protect its certificated natural gas storage pool. See id. at 126.
The Court recognized that "the transportation of natural gas in interstate commerce" includes the storage of natural gas by stating:
"Underground gas storage facilities are a necessary and integral part of the operation of piping gas from the area of production to the area of consumption." Id. at 129.