Comments of Yvonne Taylor re the New Market Project under CP14-497.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Petition for a Rulemaking of the ) Liquids Shippers Group, Airlines for ) Docket No. RM15-19-000 America, and the National Propane ) Gas Association ) COMMENTS OF THE ASSOCIATION OF OIL PIPE LINES The Association of Oil Pipe Lines (AOPL) hereby submits its comments in response to the petition for rulemaking filed by the Liquids Shippers Group, Airlines for America and the National Propane Gas Association (collectively Petitioners). AOPL is a nonprofit trade association that represents the interests of oil pipelines regulated by the Federal Energy Regulatory Commission (FERC or Commission). AOPL members transport approximately 90 percent of the crude oil and refined petroleum products shipped through pipelines in the U.S. Petitioners ask the Commission to issue a Notice of Proposed Rulemaking (NOPR) to require oil pipelines to submit a separate Page 700 for each individual pipeline system or segment as well as a separate Page 700 for crude oil and refined products transportation (collectively referred to herein as a request for segmented Page 700 filings). Petitioners further request that oil pipelines be required to provide their Page 700 workpapers to shippers and interested parties upon request. Those proposals have been considered by the Commission many times in the past and have rightly not been adopted, since they are unnecessary and inconsistent with the statutory and regulatory regime that governs oil pipelines. AOPL supports maintaining accurate and transparent pipeline financial reports consistent with the Commissions policies for oil pipelines. Petitioners proposals, however, are not necessary for the evaluation of pipeline rates. Moreover, Petitioners proposals are fundamentally inconsistent with the unique statutory and regulatory framework applicable to oil pipelines, which differs substantially from the statutes and regulations that govern the natural gas pipeline and electric industries. Congress requires the Commission to maintain a simplified and generally applicable ratemaking methodology for oil pipelines that streamline[s] the Commissions procedures and avoid[s] unnecessary regulatory costs. Energy Policy Act of 1992, 1801, 1802, Pub. L. No. 102-486 1801(a), 106 Stat. 3010 (Oct. 24, 1992) (EPAct). Accordingly, the Commission regulates most oil pipeline rates pursuant to an industry-wide rate index, while providing exceptions for rates to be set using other methods such as market-based rates, settlement rates and cost-of-service rates in appropriate circumstances. Most oil pipeline rates are therefore not set on a traditional cost-of-service basis, precisely as Congress intended. Petitioners proposals would stand this approach on its head, by imposing detailed, onerous annual cost-of-service reporting requirements ...