Answering Testimony of ConocoPhillips Alaska, Inc. under OR14-6.
01/02/2014Exhibit CPA-1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION BP Pipelines (Alaska) Inc. ) ConocoPhillips Transportation Alaska, Inc. ) Docket No. OR14-06-000 ExxonMobil Pipeline Company ) ANSWERING TESTIMONY OF JOHN B. O'BRIEN (Exhibits CPA-1 to CPA-15) January 3, 2014 S KADDEN , A RPS , S LATE , M EAGHER & F LOM LLP 1440 NEW YORK AVENUE , N.W. FIRM/AFFILIATE OFFICES WASHINGTON, D.C. 20 005- 2111 ----------- ________ BOSTON CHICAGO TEL: (202) 371-7000 HOUSTON FAX: (202) 393-5760 LOS ANGELES NEW YORK www.skadden.com PALO ALTO DIRECT DIAL WILMINGTON ----------- 202-371-7227 BEIJING DIRECT FAX BRUSSELS 202-661-9064 FRANKFURT EMAIL ADDRESS HONG KONG MESTES@SKADDEN.COM LONDON MOSCOW MUNICH PARIS SO PAULO January 3, 2014 SHANGHAI SINGAPORE SYDNEY TOKYO TORONTO H. Peter Young Presiding Administrative Law Judge Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 RE: Docket No. OR14-06-000, Answering Testimony of ConocoPhillips Alaska, Inc. Dear Judge Young: In accordance with the procedural schedule established in this proceeding and Rule 507 of the Commissions Rules of Practice and Procedure, attached is the Answering Testimony and Exhibits of ConocoPhillips Alaska, Inc. (CPAI). CPAI is presenting testimony by two witnesses, as follows: John B. OBrien Exhibits CPA-1 to CPA-15 Dr. Sam Van Vactor Exhibits CPA-16 to CPA-21 Copies of this testimony are being served on all parties. Sincerely, /s/Matthew W. S. Estes Counsel for ConocoPhillips Alaska, Inc. EXHIBIT CPA-1 Exhibit CPA-1 of the Methodology with which they do not agree and that their client would like to see changed. However, none of their arguments raises anything new. Second, Mr. OBrien testifies that the purpose of the QB Methodology is to determine the relative values of the crude streams transported by TAPS, not their absolute market values or the absolute market value of ANS. Dr. Verleger never addresses the question of whether the TAPS Quality Bank provides accurate relative values of the crude streams transported by TAPS, or if the value of the Resid cut is unreasonable in relation to the values of the other cuts valued by the QB Methodology. Thus, Dr. Verleger fails to even address any questions that might relate to the continuing validity of the QB Methodology. Third, Mr. OBrien testifies that Dr. Verlegers contention that the QB Methodology is, in his words, broken is based on an erroneous view of how the QB Methodology works and what its ultimate purpose is. Dr. Verlegers contention is based on his assertion that the QB ...