Motion to Intervene of St. Paul Park Refining Company LLC and Answeer in Support of Petitions and Motions of Concord Energy LLC, Enwest Marketing LLC, and WPX Energy Marketing, LLC under OR14-21.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATION COMMISSION North Dakota Pipeline Company LLC Docket No. OR14-21-000 MOTION TO INTERVENE OF ST. PAUL PARK REFINING COMPANY LLC AND ANSWER IN SUPPORT OF PETITIONS AND MOTIONS OF CONCORD ENERGY LLC, ENWEST MARKETING LLC, AND WPX ENERGY MARKETING, LLC Lesley Zaun Marcus W. Sisk, Jr. St. Paul Park Refining Company LLC Frederick G. Jauss IV 301 St. Paul Park Road Dorsey & Whitney LLP St. Paul Park, MN 55071 1801 K Street, N. W., Suite 750 651-769-2031 Washington, D. C. 20006 lesley.zaun@ntenergy.com 202-442-3000 sisk.marcus@dorsey.com jauss.fred@dorsey.com Attorneys for St. Paul Park Refining Company LLC March 4, 2014 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATION COMMISSION North Dakota Pipeline Company LLC Docket No. OR14-21-000 MOTION TO INTERVENE OF ST. PAUL PARK REFINING COMPANY LLC AND ANSWER IN SUPPORT OF PETITIONS AND MOTIONS OF CONCORD ENERGY LLC, ENWEST MARKETING LLC, AND WPX ENERGY MARKETING, LLC 1. Pursuant to Rules 212, 213, and 214, St. Paul Park Refining Company LLC (SPPRC) hereby moves to intervene in this proceeding and submits its answer (Answer) in support of the petitions and motions filed herein on February 25, 2014, by Concord Energy LLC, EnWest Marketing LLC, and WPX Energy Marketing, LLC (collectively the Shippers). As explained in the Answer set forth below, the petitions and motions filed by the Shippers (Petitions and Motions) are well-founded, and the relief requested by the Shippers should be granted. ADDRESS AND COMMUNICATIONS 2. The principal place of business of SPPRC is located at 301 St. Paul Park Road, St. Paul Park, Minnesota 55071. Communications to SPPRC in this proceeding should be addressed to the persons shown on the cover of this filing. THE PETITION OF NDP 3. On February 12, 2014, North Dakota Pipeline Company LLC (NDP) filed a petition for declaratory order herein (Petition) requesting certain advance rulings on the rate treatment for a proposed expansion and extension of its pipeline system known as the Sandpiper Project. If constructed, the Sandpiper Project would include a new pipeline installed alongside the existing NDP pipeline from Beaver Lodge, ND to Clearbrook, MN. Petition at 14-16. According to NDP, the current pipeline from Beaver Lodge to Clearbrook has a capacity of 210,000 bpd, but has been curtailed temporarily to 170,000 bpd by a pipeline integrity program. Petition at 12. The new parallel pipeline to Clearbrook would add 230,000 bpd so that the combined pipeline system would have a capacity of 440,000 bpd. ...