[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 4300 Introduced in Senate (IS)]

<DOC>






119th CONGRESS
  2d Session
                                S. 4300

       To promote interagency coordination for reviewing certain 
   authorizations under the Natural Gas Act, and for other purposes.


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

               April 15 (legislative day, April 14), 2026

  Mr. Cotton introduced the following bill; which was read twice and 
       referred to the Committee on Energy and Natural Resources

_______________________________________________________________________

                                 A BILL


 
       To promote interagency coordination for reviewing certain 
   authorizations under the Natural Gas Act, and for other purposes.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Jurisdictional Oversight and 
Adjudication for Natural Gas Act'' or the ``JOAN Act''.

SEC. 2. PROMOTING INTERAGENCY COORDINATION FOR REVIEW OF NATURAL GAS 
              INFRASTRUCTURE.

    (a) Definitions.--In this section:
            (1) Commission.--The term ``Commission'' means the Federal 
        Energy Regulatory Commission.
            (2) Federal authorization.--The term ``Federal 
        authorization'' has the meaning given that term in section 
        15(a) of the Natural Gas Act (15 U.S.C. 717n(a)).
            (3) NEPA review.--The term ``NEPA review'' means the 
        process of reviewing a proposed Federal action under section 
        102 of the National Environmental Policy Act of 1969 (42 U.S.C. 
        4332).
            (4) Project-related nepa review.--The term ``project-
        related NEPA review'' means any NEPA review required to be 
        conducted with respect to the issuance of an authorization 
        under section 3 of the Natural Gas Act (15 U.S.C. 717b) or a 
        certificate of public convenience and necessity under section 7 
        of such Act (15 U.S.C. 717f).
    (b) Commission NEPA Review Responsibilities.--In acting as the lead 
agency under section 15(b)(1) of the Natural Gas Act (15 U.S.C. 
717n(b)(1)) for the purposes of complying with the National 
Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) with respect 
to an authorization under section 3 of the Natural Gas Act (15 U.S.C. 
717b) or a certificate of public convenience and necessity under 
section 7 of such Act (15 U.S.C. 717f), the Commission shall, in 
accordance with this section and other applicable Federal law--
            (1) be the only lead agency;
            (2) coordinate as early as practicable with each agency 
        designated as a participating agency under subsection (d)(3) to 
        ensure that the Commission develops information in conducting 
        its project-related NEPA review that is reasonably required by 
        the participating agency in considering an aspect of an 
        application for a Federal authorization for which the agency is 
        responsible; and
            (3) take such actions as are necessary and proper to 
        facilitate the expeditious resolution of its project-related 
        NEPA review.
    (c) Deference to Commission.--In making a decision with respect to 
a Federal authorization required with respect to an application for 
authorization under section 3 of the Natural Gas Act (15 U.S.C. 717b) 
or a certificate of public convenience and necessity under section 7 of 
such Act (15 U.S.C. 717f), each agency shall give deference, to the 
maximum extent authorized by law, to the scope of the project-related 
NEPA review that the Commission determines to be appropriate.
    (d) Participating Agencies.--
            (1) Identification.--The Commission shall identify, not 
        later than 30 days after the Commission receives an application 
        for an authorization under section 3 of the Natural Gas Act (15 
        U.S.C. 717b) or a certificate of public convenience and 
        necessity under section 7 of such Act (15 U.S.C. 717f), any 
        Federal or State agency, local government, or Indian Tribe that 
        may issue a Federal authorization or is required by Federal law 
        to consult with the Commission in conjunction with the issuance 
        of a Federal authorization required for such authorization or 
        certificate.
            (2) Invitation.--
                    (A) In general.--Not later than 45 days after the 
                Commission receives an application for an authorization 
                under section 3 of the Natural Gas Act (15 U.S.C. 717b) 
                or a certificate of public convenience and necessity 
                under section 7 of such Act (15 U.S.C. 717f), the 
                Commission shall invite any agency identified under 
                paragraph (1) to participate in the review process for 
                the applicable Federal authorization.
                    (B) Deadline.--An invitation issued under 
                subparagraph (A) shall establish a deadline by which a 
                response to the invitation shall be submitted to the 
                Commission, which may be extended by the Commission for 
                good cause.
            (3) Designation as participating agencies.--Not later than 
        60 days after the Commission receives an application for an 
        authorization under section 3 of the Natural Gas Act (15 U.S.C. 
        717b) or a certificate of public convenience and necessity 
        under section 7 of such Act (15 U.S.C. 717f), the Commission 
        shall designate an agency identified under paragraph (1) as a 
        participating agency with respect to an application for 
        authorization under section 3 of the Natural Gas Act (15 U.S.C. 
        717b) or a certificate of public convenience and necessity 
        under section 7 of such Act (15 U.S.C. 717f) unless the agency 
        informs the Commission, in writing, by the deadline established 
        pursuant to paragraph (2)(B), that the agency--
                    (A) has no jurisdiction or authority with respect 
                to the applicable Federal authorization;
                    (B) has no special expertise or information 
                relevant to any project-related NEPA review; or
                    (C) does not intend to submit comments for the 
                record for the project-related NEPA review conducted by 
                the Commission.
            (4) Effect of designation and non-designation.--Designation 
        or non-designation of an agency as a participating agency under 
        paragraph (3) with respect to an application for an 
        authorization under section 3 of the Natural Gas Act (15 U.S.C. 
        717b) or a certificate of public convenience and necessity 
        under section 7 of such Act (15 U.S.C. 717f) may not serve as 
        evidence of an incomplete record before a court.
    (e) Water Quality Impacts.--
            (1) In general.--Notwithstanding section 401 of the Federal 
        Water Pollution Control Act (33 U.S.C. 1341), an applicant for 
        a Federal authorization shall not be required to provide a 
        certification under such section with respect to the Federal 
        authorization.
            (2) Coordination.--With respect to any NEPA review for a 
        Federal authorization to conduct an activity that will directly 
        result in a discharge into the navigable waters (within the 
        meaning of the Federal Water Pollution Control Act (33 U.S.C. 
        1251 et seq.)), the Commission shall identify as an agency 
        under subsection (d)(1) the State in which the discharge 
        originates or will originate, or, if appropriate, the 
        interstate water pollution control agency having jurisdiction 
        over the navigable waters at the point where the discharge 
        originates or will originate.
            (3) Proposed conditions.--A State or interstate agency 
        designated as a participating agency pursuant to paragraph (2) 
        may propose to the Commission terms or conditions for inclusion 
        in an authorization under section 3 of the Natural Gas Act (15 
        U.S.C. 717b) or a certificate of public convenience and 
        necessity under section 7 of such Act (15 U.S.C. 717f) that the 
        State or interstate agency determines are necessary to ensure 
        that any activity described in paragraph (2) conducted pursuant 
        to such authorization or certification will comply with the 
        applicable provisions of sections 301, 302, 303, 306, and 307 
        of the Federal Water Pollution Control Act (33 U.S.C. 1311, 
        1312, 1313, 1316, 1317).
            (4) Commission consideration of conditions.--The Commission 
        may include a term or condition in an authorization under 
        section 3 of the Natural Gas Act (15 U.S.C. 717b) or a 
        certificate of public convenience and necessity under section 7 
        of such Act (15 U.S.C. 717f) proposed by a State or interstate 
        agency under paragraph (3) only if the Commission finds that 
        the term or condition is necessary to ensure that any activity 
        described in paragraph (2) conducted pursuant to such 
        authorization or certification will comply with the applicable 
        provisions of sections 301, 302, 303, 306, and 307 of the 
        Federal Water Pollution Control Act (33 U.S.C. 1311, 1312, 
        1313, 1316, 1317).
    (f) Schedule.--
            (1) Deadline for federal authorizations.--A deadline for a 
        Federal authorization required with respect to an application 
        for authorization under section 3 of the Natural Gas Act (15 
        U.S.C. 717b) or a certificate of public convenience and 
        necessity under section 7 of such Act (15 U.S.C. 717f) set by 
        the Commission under section 15(c)(1) of such Act (15 U.S.C. 
        717n(c)(1)) shall be not later than 90 days after the 
        Commission completes its project-related NEPA review, unless an 
        applicable schedule is otherwise established by Federal law.
            (2) Concurrent reviews.--Each Federal and State agency--
                    (A) that may consider an application for a Federal 
                authorization required with respect to an application 
                for authorization under section 3 of the Natural Gas 
                Act (15 U.S.C. 717b) or a certificate of public 
                convenience and necessity under section 7 of such Act 
                (15 U.S.C. 717f) shall formulate and implement a plan 
                for administrative, policy, and procedural mechanisms 
                to enable the agency to ensure completion of Federal 
                authorizations in compliance with schedules established 
                by the Commission under section 15(c)(1) of such Act 
                (15 U.S.C. 717n(c)(1)); and
                    (B) in considering an aspect of an application for 
                a Federal authorization required with respect to an 
                application for authorization under section 3 of the 
                Natural Gas Act (15 U.S.C. 717b) or a certificate of 
                public convenience and necessity under section 7 of 
                such Act (15 U.S.C. 717f), shall--
                            (i) formulate and implement a plan to 
                        enable the agency to comply with the schedule 
                        established by the Commission under section 
                        15(c)(1) of such Act (15 U.S.C. 717n(c)(1));
                            (ii) carry out the obligations of that 
                        agency under applicable law concurrently, and 
                        in conjunction with, the project-related NEPA 
                        review conducted by the Commission, and in 
                        compliance with the schedule established by the 
                        Commission under section 15(c)(1) (15 U.S.C. 
                        717n(c)(1)) of such Act, unless the agency 
                        notifies the Commission in writing that doing 
                        so would impair the ability of the agency to 
                        conduct needed analysis or otherwise carry out 
                        such obligations;
                            (iii) transmit to the Commission a 
                        statement--
                                    (I) acknowledging receipt of the 
                                schedule established by the Commission 
                                under section 15(c)(1) of the Natural 
                                Gas Act (15 U.S.C. 717n(c)(1)); and
                                    (II) setting forth the plan 
                                formulated under clause (i) of this 
                                subparagraph;
                            (iv) not later than 30 days after the 
                        agency receives such application for a Federal 
                        authorization, transmit to the applicant a 
                        notice--
                                    (I) indicating whether such 
                                application is ready for processing; 
                                and
                                    (II) if such application is not 
                                ready for processing, that includes a 
                                comprehensive description of the 
                                information needed for the agency to 
                                determine that the application is ready 
                                for processing;
                            (v) determine that such application for a 
                        Federal authorization is ready for processing 
                        for purposes of clause (iv) if such application 
                        is sufficiently complete for the purposes of 
                        commencing consideration, regardless of whether 
                        supplemental information is necessary to enable 
                        the agency to complete the consideration 
                        required by law with respect to such 
                        application; and
                            (vi) not less often than once every 90 
                        days, transmit to the Commission a report 
                        describing the progress made in considering 
                        such application for a Federal authorization.
            (3) Failure to meet deadline.--If a Federal or State 
        agency, including the Commission, fails to meet a deadline for 
        a Federal authorization set forth in the schedule established 
        by the Commission under section 15(c)(1) of the Natural Gas Act 
        (15 U.S.C. 717n(c)(1)), not later than 5 days after such 
        deadline, the head of the relevant Federal agency (including, 
        in the case of a failure by a State agency, the Federal agency 
        overseeing the delegated authority) shall notify Congress and 
        the Commission of such failure and set forth a recommended 
        implementation plan to ensure completion of the action to which 
        such deadline applied.
    (g) Consideration of Applications for Federal Authorization.--
            (1) Issue identification and resolution.--
                    (A) Identification.--Federal and State agencies 
                that may consider an aspect of an application for a 
                Federal authorization shall identify, as early as 
                possible, any issues of concern that may delay or 
                prevent an agency from working with the Commission to 
                resolve such issues and granting such authorization.
                    (B) Issue resolution.--The Commission may forward 
                any issue of concern identified under subparagraph (A) 
                to the heads of the relevant agencies (including, in 
                the case of an issue of concern that is a failure by a 
                State agency, the Federal agency overseeing the 
                delegated authority, if applicable) for resolution.
            (2) Remote surveys.--
                    (A) In general.--If a Federal or State agency 
                considering an aspect of an application for a Federal 
                authorization requires the person applying for such 
                authorization to submit data, the agency shall consider 
                any such data gathered by aerial or other remote means 
                that the person submits.
                    (B) Conditional approval.--The agency may grant a 
                conditional approval for the Federal authorization 
                based on data gathered by aerial or remote means, 
                conditioned on the verification of such data by 
                subsequent onsite inspection.
            (3) Application processing.--The Commission, and Federal 
        and State agencies, may allow a person applying for a Federal 
        authorization to fund a third-party contractor to assist in 
        reviewing the application for such authorization.
    (h) Accountability, Transparency, Efficiency.--For an application 
for an authorization under section 3 of the Natural Gas Act (15 U.S.C. 
717b) or a certificate of public convenience and necessity under 
section 7 of such Act (15 U.S.C. 717f) that requires multiple Federal 
authorizations, the Commission, with input from any Federal or State 
agency considering an aspect of the application, shall track and make 
available to the public on the website of the Commission information 
related to the actions required to complete the Federal authorizations. 
Such information shall include the following:
            (1) The schedule established by the Commission under 
        section 15(c)(1) of the Natural Gas Act (15 U.S.C. 717n(c)(1)).
            (2) A list of all the actions required by each applicable 
        agency to complete permitting, reviews, and other actions 
        necessary to obtain a final decision on the application.
            (3) The expected completion date for each such action.
            (4) A point of contact at the agency responsible for each 
        such action.
            (5) In the event that an action is still pending as of the 
        expected date of completion, a brief explanation of the reasons 
        for the delay.

SEC. 3. ACCELERATION OF CLAIMS.

    (a) Definitions.--In this section:
            (1) Civil action.--The term ``civil action'' means an 
        initial claim challenging a core authorization for a covered 
        project.
            (2) Commission.--The term ``Commission'' means the Federal 
        Energy Regulatory Commission.
            (3) Core authorization.--The term ``core authorization'' 
        means a Federal authorization issued pursuant to section 3(e) 
        or section 7(c) of the Natural Gas Act (15 U.S.C. 717b(e), 
        717f(c)).
            (4) Covered project.--The term ``covered project'' means a 
        project requiring a core authorization.
            (5) Federal authorization.--The term ``Federal 
        authorization'' means any license, permit, approval, finding, 
        determination, or administrative decision issued by an agency, 
        and any interagency consultation that is required or authorized 
        under Federal law, to site, construct, reconstruct, abandon, or 
        commence operations of a covered project administered by--
                    (A) a Federal agency; or
                    (B) in the case of a State participating in or 
                administering a review required or authorized under 
                Federal law, as applicable, a State agency.
            (6) Project sponsor.--The term ``project sponsor'' means 
        any person, including a State, Tribal, or local government 
        entity, that--
                    (A) is an applicant for, or holder of, a core 
                authorization or any other Federal authorization for a 
                covered project; or
                    (B) otherwise proposes to site, construct, 
                reconstruct, own, or operate a covered project.
            (7) Related claim.--The term ``related claim'' means a 
        claim challenging a Federal authorization that is joined to a 
        civil action after that civil action has been filed.
    (b) Final Agency Action.--Notwithstanding any other provision of 
law, issuance of a core authorization for a covered project shall be 
considered a final agency action for the purposes of chapter 7 of title 
5, United States Code, with respect to all Federal authorizations 
required for that covered project.
    (c) Claims.--
            (1) Sole and exclusive relief.--
                    (A) In general.--The filing and final adjudication 
                of a civil action shall constitute the sole and 
                exclusive means of judicial review and relief with 
                respect to the applicable covered project and all 
                Federal authorizations issued for that covered project.
                    (B) Bar on subsequent actions.--After the final 
                adjudication of a civil action, any subsequent cause of 
                action or challenge, whether statutory, procedural, or 
                substantive, related to or connected with the 
                applicable covered project or any Federal authorization 
                for that covered project brought by any party except 
                the project sponsor shall be barred and dismissed for 
                lack of jurisdiction.
            (2) Venue.--
                    (A) In general.--A civil action shall be filed 
                exclusively in--
                            (i) the United States Court of Appeals for 
                        the District of Columbia Circuit; or
                            (ii) the court of appeals of the United 
                        States for the judicial circuit in which the 
                        principal place of business of the project 
                        sponsor for the applicable covered project is 
                        located.
                    (B) Related claims.--After a civil action is filed 
                in an applicable court described in subparagraph (A), 
                all related claims arising out of the same nucleus of 
                operative fact as that civil action shall be joined or 
                consolidated to that court for adjudication.
            (3) Time to file.--A civil action and all related claims 
        arising out of the same nucleus of operative fact shall be 
        filed with the applicable court by the earlier of--
                    (A) the date that is 60 days after the core 
                authorization is published in the Federal Register; and
                    (B) the statutory deadline required for causes of 
                action relating to that core authorization.
            (4) Judicial review.--
                    (A) In general.--Subject to subsection (d), the 
                filing and final adjudication of a civil action shall 
                constitute the only opportunity for judicial review of 
                the applicable covered project and all Federal 
                authorizations issued for that covered project.
                    (B) Scope.--Judicial review of a civil action and 
                any related claim arising out of the same nucleus of 
                operative fact under this section--
                            (i) shall--
                                    (I) be limited to the finalized 
                                consolidated record under subsection 
                                (g)(3)(C); and
                                    (II) be based exclusively on that 
                                finalized consolidated record; and
                            (ii) shall not take evidence, permit 
                        discovery, receive testimony, or engage in 
                        fact-finding.
                    (C) Preliminary injunctions.--
                            (i) Multiplicative merit standard.--In any 
                        civil action seeking a preliminary injunction 
                        or a temporary restraining order to halt a 
                        Federal action based on an alleged violation of 
                        this Act, the applicable court shall determine 
                        the likelihood of success on the merits by 
                        calculating the cumulative probability of 
                        success across all independent legal and 
                        jurisdictional requirements.
                            (ii) Probabilistic calculation.--A court 
                        may not find a likelihood of success on the 
                        merits under clause (i) unless the product of 
                        the probabilities of success for each 
                        independent legal and jurisdictional 
                        requirement, including standing under article 
                        III of the Constitution of the United States, 
                        final agency action, and the merits of the 
                        underlying claim, exceeds 50 percent.
                            (iii) Written findings.--The court under 
                        clause (ii) shall issue written findings of 
                        fact and conclusions of law specifying--
                                    (I) the estimated probability of 
                                success assigned to each independent 
                                legal and jurisdictional requirement; 
                                and
                                    (II) the cumulative probability of 
                                success.
                    (D) Deadline.--If the applicable court does not 
                issue a final determination for a filed civil action 
                and all related claims arising out of the same nucleus 
                of operative fact by the date that is 180 days after 
                the expiration of the applicable timeline described in 
                paragraph (3), the core authorization and all 
                associated Federal authorizations for the applicable 
                covered project shall be considered approved and not 
                subject to further review.
                    (E) Identification of factual determinations.--For 
                the purposes of judicial review, the statements of 
                material fact submitted under subsection (g)(2) shall 
                not constitute independent evidence or a freestanding 
                factual determination apart from the cited 
                administrative record material.
            (5) Relief.--
                    (A) In general.--In reviewing a civil action, the 
                applicable court may not--
                            (i) issue an injunction lasting for a 
                        period exceeding 60 days;
                            (ii) enjoin any covered project activity 
                        unrelated to a specific issue identified by the 
                        court; or
                            (iii) grant permanent injunctive relief 
                        unless the plaintiff demonstrates by clear and 
                        convincing evidence that--
                                    (I) the plaintiff has suffered an 
                                irreparable injury;
                                    (II) remedies available at law, 
                                including monetary damages, are 
                                inadequate to compensate for the 
                                irreparable injury;
                                    (III) considering the balance of 
                                hardships between the plaintiff and 
                                defendant, a remedy in equity is 
                                warranted; and
                                    (IV) the public interest would not 
                                be disserved by a permanent injunction.
                    (B) Permanent injunction.--Any permanent injunction 
                issued by a court pursuant to this subsection shall be 
                supported by a finding, by clear and convincing 
                evidence, of extraordinary circumstances, and shall be 
                as narrowly tailored as possible to correct the injury 
                and the least intrusive means necessary to correct the 
                injury.
                    (C) Security for injunctive relief.--Any court 
                issuing a temporary restraining order or preliminary 
                injunction in a civil action under this section shall 
                require the movant to provide security in an amount 
                that the court considers proper to pay the costs and 
                damages sustained by any party found to have been 
                wrongfully enjoined or restrained, consistent with rule 
                65(c) of the Federal Rules of Civil Procedure.
            (6) No remand with vacatur.--In reviewing a civil action, 
        the applicable court may not issue a remedy of remand with 
        vacatur.
            (7) Project segmentation.--After the filing of a civil 
        action, the project sponsor for the implicated covered project 
        may continue construction for any part of the covered project 
        that is unaffected by the civil action.
            (8) Prohibited civil actions.--A civil action may not be 
        filed by any party that did not raise the issue giving rise to 
        that civil action during the notice and comment period for the 
        applicable Federal authorization.
    (d) Project Sponsor Exception.--
            (1) In general.--Notwithstanding subsection (c), a project 
        sponsor may bring a separate claim challenging a Federal 
        authorization for an applicable covered project regardless of 
        whether a civil action concerning that Federal authorization 
        has been filed and adjudicated, subject to the condition that 
        the specific underlying issue of that separate claim has not 
        previously been finally adjudicated.
            (2) No related claims.--A claim described in paragraph (1) 
        may not be joined by a related claim or any other claim arising 
        out of the same nucleus of operative fact.
    (e) Effect on Substantive Standards.--Nothing in this section 
alters substantive environmental requirements or reduces opportunities 
for public comment under applicable Federal law.
    (f) Multiple Core Authorizations.--If more than 1 Federal agency 
issues a core authorization for a covered project, the Commission shall 
be the lead agency for purposes of an environmental review for the 
covered project under the National Environmental Policy Act of 1969 (42 
U.S.C. 4321 et seq.), if applicable.
    (g) Statement of Material Facts and Technical Findings.--
            (1) Definition of statement of material fact.--In this 
        subsection, the term ``statement of material fact'' means a 
        citation index identifying, by specific record citation, the 
        portions of the administrative record that set forth the 
        material factual determinations and technical conclusions 
        relied on in a Federal authorization for a covered project.
            (2) Transmission.--Not later than 60 days after the date of 
        publication of a core authorization in the Federal Register, 
        each Federal agency that issued, or is required to issue, a 
        Federal authorization for the applicable covered project shall 
        submit to the Commission--
                    (A) the administrative record for that Federal 
                authorization; and
                    (B) a statement of material fact and technical 
                conclusions that identifies, by specific citation to 
                the administrative record, the portions of the record 
                containing the material factual determinations and 
                technical conclusions relied on by the Federal agency.
            (3) Consolidated administrative record.--
                    (A) Consolidate and publish.--Not later than 90 
                days after the date of publication of a core 
                authorization in the Federal Register, the Commission 
                shall--
                            (i) consolidate the submissions under 
                        paragraph (2) (referred to in this subsection 
                        as the ``consolidated administrative record''); 
                        and
                            (ii) publish a notice of availability of 
                        the consolidated administrative record.
                    (B) Objections.--
                            (i) In general.--Not later than 30 days 
                        after the date of publication of the notice 
                        under subparagraph (A), any party may submit to 
                        the Commission a written objection limited to 
                        whether the consolidated administrative record 
                        omits materials--
                                    (I) that were before the Federal 
                                agency; and
                                    (II) that were directly or 
                                indirectly considered in issuing a 
                                Federal authorization.
                            (ii) No merits.--An objection to the 
                        consolidated administrative record submitted 
                        under clause (i) may not--
                                    (I) raise merit arguments; or
                                    (II) seek discovery, testimony, or 
                                new evidence.
                            (iii) Resolution.--Not later than 60 days 
                        after the date of publication of the notice 
                        under subparagraph (A), the Commission shall 
                        resolve each objection to the consolidated 
                        administrative record submitted under clause 
                        (i) and, as necessary, direct limited 
                        supplementation of the consolidated 
                        administrative record by the relevant Federal 
                        agency.
                    (C) Closure.--After all objections to the 
                consolidated administrative record are resolved under 
                subparagraph (B)(iii)--
                            (i) the consolidated administrative record 
                        shall be considered final and closed; and
                            (ii) the Commission shall issue a public 
                        written order indicating the consolidated 
                        administrative record is finalized and closed.
                    (D) Final agency action.--The written order of the 
                Commission under subparagraph (C)(ii) shall constitute 
                a final agency action for the purposes of chapter 7 of 
                title 5, United States Code, solely with respect to the 
                contents and completeness of the consolidated 
                administrative record.
                                 <all>