16th 70-9117

UNITED STATES OF AMERICA
BEFORE THE SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.


IN THE MATTER OF
NATIONAL FUEL GAS COMPANY,                           16th CERTIFICATE
SENECA INDEPENDENCE PIPELINE COMPANY,                PURSUANT TO RULE 24
NIAGARA INDEPENDENCE MARKETING COMPANY,
ET AL.
FILE NO. 70-9117
(Public Utility Holding Company Act of 1935)

        This is to certify, pursuant to Rule 24 under the Public Utility Holding Company Act of 1935, as amended, that the transactions referred to below have been carried out in accordance with the terms and conditions of and for the purpose represented by the Declarations of National Fuel Gas Company ("National"), Seneca Independence Pipeline Company ("Seneca"), and Niagara Independence Marketing Company ("Niagara"), et al., as amended, in the above file and pursuant to the Order, dated March 13, 1998, of the Securities and Exchange Commission with respect thereto ("Order").

        The following exhibits are attached to and made a part of this Certificate:

        Exhibit A      Income Statement of Seneca for the quarter ended December 31, 2001 (Confidential Treatment
                            Requested Pursuant to Rule 104(b)).

        Exhibit B      Balance Sheet of Seneca as of December 31, 2001 (Confidential Treatment Requested Pursuant to
                            Rule 104(b)).

        Exhibit C      Income Statement of Niagara for the quarter ended December 31, 2001 (Confidential Treatment
                            Requested Pursuant to Rule 104(b)).

        Exhibit D      Balance Sheet of Niagara as of December 31, 2001 (Confidential Treatment Requested Pursuant to
                            Rule 104(b)).

        Exhibit E      Seneca’s Allocated Share of the Profits/Losses of Independence Pipeline Company for the quarter
                            ended December 31, 2001 (Confidential Treatment Requested Pursuant to Rule 104(b)).

        Exhibit F      Niagara’s Allocated Share of the Profits/Losses of DirectLink Gas Marketing Company for the
                             quarter ended December 31, 2001 (Confidential Treatment Requested Pursuant to Rule 104(b)).

        IN WITNESS WHEREOF, the undersigned companies have caused this Certificate to be executed as of this 25th day of February, 2002.

                                      NATIONAL FUEL GAS COMPANY


                                      By:  /s/ J. R. Peterson
                                         --------------------------------------
                                         J. R. Peterson
                                         Assistant Secretary


                                      SENECA INDEPENDENCE PIPELINE
                                      COMPANY


                                      By:  /s/ W. E. DeForest
                                         --------------------------------------
                                         W. E. DeForest
                                         President, Secretary and Treasurer


                                      NIAGARA INDEPENDENCE MARKETING
                                      COMPANY


                                      By:  /s/ W. M. Petmecky
                                         --------------------------------------
                                         W. M. Petmecky
                                         Secretary