Exhibit PAI-68 in Trans Alaska Pipeline System's et al proceeding under OR89-2 et al: Affidavit of Joe F Moore re formal complaint of Tesoro Alaska Petroleum Co against Amerada Hess Pipeline Corp et al.
10/23/2002Jnofflclal FERC-Generated PDF of 20040907-1187 Received by FERC OSEC 10/24/2002 in D o c k e t # : OR89-2-017 b P.~I-68 , Page 1 of 6 D UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Tram Alaska PipelineSystem. et al. ) Doci0et Nos. OR89-2-007, et al. Exxon Company, U.S.A. ) It ) v. ) Docket No. OR96-14-0~ ) Amerada Hess Pipeline Corporation, ctil. ) THE STATE OF ALASKA BEFORE THE ALASKA PUBLIC ~ COMMISSION P In Re: Formal Complaim of Tesoro ) Alaska Petroleum Company ) Docket Nos. P-89-I,~ al. aga'mst Amerada Hess Pi~line ) Corporation, ct ai. ) AFFIDAVIT OF JOE F. MOORE B Joe F. Moore, being fu-~duly sworn, upon his oath deposes and sm~s: - ~ "~ !~! I. I am Chairman of Bonnet & Moo~ Associates. Inc. My b ~ i n e ~ ~.~ : ,: policymatle~ in the energy field. A deraileddescriptionof my background, qualif~.ations and professionalcxperien~ has been submiued with affidavitsthatI haw filedp~viously in the above-referencedproceedings. I submit thisaffidavitin supportof the Comments of Exxon Company, U.S.A. Opposing the Group Of Nincs Offer of Settlementand, in Jnofflclal FERC-Generated PDF of 20040907-1187 Received by FERC OSEC 10/24/2002 in D o c k e t # : O R 8 9 - 2 - 0 1 7 PAd~ r Page 2 of 6 ~[ lon~ as tb uualiw soecifications for VGO are satisfied." (emphasis added). He then draws an illogical conclusion, gating: "Accordingly, I sought to value all resid cuts the same." O'Bricu 1-28-97 Aft. 145. Mr. O'Bricu pointedly omits the caveat in the former quote: "as long as the quality specifications...are satisfied." Mr. O'Brien certainly }mows, as well as I do, that re/'merz, when valuing crude oil components, do not use generic values for crude oil cut qualities. 15. Mr. O'Brien obfuscates the issue of how a residuum cut's quality affects its coking value. He states "Coker yields are unaffected by resid viscosity." O'Bricu 1-28-97 Aff. 28. This sentence is footnoted to the effect that resid's fuel oil value is affected by viscosity. This statement has appeared earlier in the record by other experts on behalf of certain members of the Group of Nine and could mislead ~ Commission io believe th/lt the coking value of, for example, Kuparuk P,.iver Unit ( ' K R U ' ) residuum and Prudhoe Bay Unit ( ' P B U ' ) residuum is the same. In fact they are greatly different, as I will show. 16. One laboratory test routinely used to characterize residua is Conradr,...