Flint Hills Resources Alaska, LLC's Request for Issuance of a Subpoena Duces Tecum to BP West Coast Products LLC To Respond To Data Requests and Produce Documents under OR14-6.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) BP Pipelines (Alaska) Inc. ) ConocoPhillips Transportation Alaska Inc. ) Docket No. OR14-6-000 ExxonMobil Pipeline Company ) FLINT HILLS RESOURCES ALASKA, LLCS REQUEST FOR ISSUANCE OF A SUBPOENA DUCES TECUM TO BP WEST COAST PRODUCTS LLC TO RESPOND TO DATA REQUESTS AND PRODUCE DOCUMENTS To: The Honorable H. Peter Young Presiding Administrative Law Judge Pursuant to Rule 409, 18 C.F.R. 285.409 (2013), of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (Commission), Flint Hills Resources Alaska, LLC (FHR) respectfully requests that the Presiding Administrative Law Judge issue the attached subpoena duces tecum compelling BP West Coast Products LLC (BP West Coast), who is not a party to this proceeding, to respond to data requests and produce documents regarding BP West Coasts Cherry Point and former Carson refineries at which Alaska North Slope (ANS) crude oil has been processed. Responses to these data requests and the production of documents regarding those refineries are necessary for FHR to develop a full and complete record on the issue of the accurate value of ANS Resid.1 Under existing procedural rules, objections would be due five calendar days from the date of service and responses would be due ten calendar days from the date of service. 1 Flint Hills Resources Alaska, LLC v. BP Pipelines(Alaska) Inc., et al., 145 FERC 61,117 (2013) (order setting case for hearing). 1 I. BACKGROUND On November 29, 2013, FHR served BP Exploration (Alaska) Inc. (BPXA), who is a party intervenor, with data requests related to ANS coker yields.2 On December 4, 2013, BPXA responded that it had no refineries and objected to the requests on the grounds that FHR sought information that was not within BXPAs possession, custody or control.3 BPXA did state, however, that the information FHR seeks pertaining to the Cherry Point and former Carson refineries is in the possession of BP West Coast Products LLC and that FHR should direct its data requests to BP West Coast through the issuance of a subpoena duces tecum. II. REQUEST FOR A SUBPOENA DUCES TECUM Commission Rule 409 authorizes the Presiding Administrative Law Judge to issue a subpoena for the production of documents.4 FHR requests that the Presiding Administrative Law Judge issue a subpoena to BP West Coast to answer data specific requests and produce documents limited to its refineries at which ANS crude oil has been processed. The refinery information that is in BP West Coasts ...