Reply Testimony Exhibits of the State of Alaska by Morrison & Foerster LLP under IS09-348, et. al.

Exhibit No. SOA-584 Docket Nos. IS09-348-004 et al.; RCA Docket Nos. P-08-9 et al Page 1 of 105 STATE OF ALASKA REGULATORY COMMISSION OF ALASKA ConocoPhillips Transportation Alaska Inc. Dockets P-08-9, et al. ExxonMobil Pipeline Company (Consolidated) Unocal Pipeline Company Koch Alaska Pipeline Company, L.L.C. UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION BP Pipelines (Alaska) Inc. Docket No. IS09-348-004, et al. Responses of the Trans Alaska Pipeline System Carriers to the State of Alaskas Fifth Set of Data Requests Pursuant to the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC), 18 C.F.R. 385.401, et seq., and the Order Adopting Discovery Time Standards issued by the Presiding Administrative Law Judge on February 18, 2010, the Trans- Alaska Pipeline System (TAPS) Carriers 1/ submit these responses to the State of Alaskas Fifth Set of Data Requests in the above-captioned proceedings, subject to and without waiver of the objections to those Data Requests set forth in the Objections of the Trans Alaska Pipeline System Carriers to the State of Alaskas Fifth Set of Data Requests dated July 13, 2011. 1/ The TAPS Carriers are: BP Pipelines (Alaska) Inc., ConocoPhillips Transportation Alaska, Inc., ExxonMobil Pipeline Company, Koch Alaska Pipeline Company, LLC, and Unocal Pipeline Company. Each of the TAPS Carriers owns an undivided joint interest in TAPS. 1 Exhibit No. SOA-584 Docket Nos. IS09-348-004 et al.; RCA Docket Nos. P-08-9 et al Page 2 of 105 SOA-ATC-273: Please provide or identify (if already produced) all responses from any TAPS Carrier or Alyeska to the letter from Assistant Attorney General Jan Levy dated October 10, 2003, referenced in the testimony of Jeffrey Ray and attached as Exhibit ATC-198. See ATC-18 at 21. Response: Subject to the TAPS Carriers objections dated July 13, 2011, after a reasonable search, the TAPS Carriers have not located a formal, written response to Assistant Attorney General Jan Levys October 10, 2002 letter. The document Bates-labeled TC10AY022- 00493564 to 65 describes a follow up meeting with Ms. Levy that took place on November 7, 2003, the purpose of which was to answer specific questions Ms. Levy ha[d] regarding strategic reconfiguration. Response prepared by: Counsel 2 Exhibit No. SOA-584 Docket Nos. IS09-348-004 et al.; RCA Docket Nos. P-08-9 et al Page 3 of 105 SOA-ATC-277: Please define the term SR Program and identify with specificity your understanding of what activities, projects, and expenditures were included within the scope of the SR Program. See ATC-18 at 1. ...