SFPP, L.P.. Errata

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION R. Gordon Gooch, ) ) Complainant, ) ) v. ) Docket No.________ ) Colonial Pipeline Company, ) ) Respondent. ) COMPLAINT REQUESTING FAST TRACK PROCESSING AND FOURTH PETITION FOR REDRESS OF GRIEVANCES OF R. GORDON GOOCH R. Gordon Gooch Travis & Gooch 1111 19th St North Suite 2504 Arlington, VA 22209 703-351-7520 travisgooch1@earthlink.net August 14, 2012 TABLE OF CONTENTS Page 2. Identification Of Principal Collectors of Unlawful Revenues in 2010. ................ 60 3. Analyzing Colonial in 2011 ...................... 62 4. The Correlation of Creamy Returns and the Wall Street Fat Cats, as the President Calls Them. ............ 63 5. My Opinion, Under First Amendment Privilege: Just as the Electric Utility Industry was Devastated by the Implosion of the Holding Company Structures Pioneered by Insull, the Natural Gas Pipeline and Oil Pipeline Industry is at Serious Risk of Implosion. .................... 68 6. Private Equity, Formerly Known as Leveraged Buy Outs, of Public Utilities is Not Likely to End Up Attracting New Equity Capital to the Public Utilities, if Alan Sloan Knows What he is Talking About. ........................ 69 7. A Sad Note: The Investor Owned Electric Utilities Now Want to be Allowed to Convert to Master Limited Partnerships ................................. 71 8. The Turning Point: When Big Oil Became Junior Partners in the Oil Pipeline Industry, Selling to the Wall Street Fat Cats. .......................................... 71 C. How the Prior Commissions Permitted and Encouraged Unlawful Rates for Oil Pipelines. ............................................................... 72 (1) Index rates -- 18 C.F.R. 342.3 ................ 72 (2) Market based rates -- 18 C.F.R. 342.4(b) .................................................. 79 (3) Negotiated rates -- 18 C.F.R. 342.2 ....... 85 (4) The new paradigm, the end of non- discriminatory transportation at non- discriminatory rates, the very cornerstone of oil pipeline regulation since 1906. ................................................ 86 iii TABLE OF CONTENTS Page (5) Why do shippers submit to paying unlawful rates to oil pipelines? ................. 89 a. Shippers dont care because the costs are passed through to the consumers. .......................... 91 b. Shippers wont complain because some have affiliated pipelines who also are collecting unlawful revenues ........ 93 c. Shippers are intimidated into acquiescence ................................. 96 d. Shippers feel that they cannot get a fair shake at the Commission; the deck appears stacked against them ...... 100 (6) The Commission cannot abdicate its responsibility to ensure that all rates are lawful on the theory that shippers will fulfill that function ........................... 102 (7) Anticipated Response of Pipelines Collecting Unlawful Rates if the Commission enforces the law ................. 104 (a) Pol