Energy Mgt. P 26,603 Panhandle Producers & Royalty Owners Association v. Economic Regulatory Administration

PATRICK E. HIGGINBOTHAM, Circuit Judge:

In each of these three consolidated cases, the Economic Regulatory Administration issued an order authorizing imports of Canadian natural gas despite the objections of petitioner, Panhandle Producers and Royalty Owners Association. PPROA’s petition for review raises a number of objections to the ERA’S orders, including the validity of certain guidelines issued by the Secretary of Energy in 1984 and their application in these orders. PPROA argues that the ERA’s reliance on the guidelines was not proper because they were not the product of rulemaking…