Comment of Delaware Riverkeeper Network under PF14-8.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Seaway Crude Pipeline Company LLC ) Docket No. OR15-6-000 MOTION TO INTERVENE, PROTEST, REQUEST FOR DISMISSAL OR, IN THE ALTERNATIVE, DISCOVERY AND HEARING PROCEDURES OF THE CANADIAN ASSOCIATION OF PETROLEUM PRODUCERS The Canadian Association of Petroleum Producers (CAPP) hereby submits, pursuant to; 18 C.F.R. 348.2, and the Commissions Rules of Practice and Procedure, 18 CFR 385.211, 385.212 and 385.214, and 343.2, its protest of the application filed herein. CAPP requests that the application be dismissed. Should the Commission determine that further review of the application is warranted, CAPP requests that discovery and hearing procedures be adopted in order to resolve the issues raised with respect to the application. Support and background for CAPPs protest include the accompanying affidavit of Dr. John R. Morris, an expert economist and recognized authority in the field of market power and competition analysis. CAPPs economic interests in this proceeding are set forth in the accompanying verified statement of Nancy Brard-Brown. In support whereof, CAPP states as follows: I. IDENTITY OF MOVANT AND INTERVENTION CAPP is a corporation organized pursuant to the laws of the province of Alberta, with its principal place of business located in Calgary, Alberta, Canada. Its membership represents virtually the entirety of the producing sector of the Canadian petroleum industry. The members of CAPP 1 produce most of the crude oil and other petroleum products originating in Canada and destined for markets in the U.S. Canadian-produced crude oil supplies can and do access markets throughout the U.S., including the Gulf Coast. Canadian crude oil is transported to, utilizes storage facilities located at, and is transported from, the Cushing, Oklahoma crude oil hub. The services described in the instant application are potentially available to transport Canadian-sourced supplies from Cushing to the Gulf Coast. The economics of export arrangements into U.S. markets, including those that are and may be served by Seaway, are directly impacted by the availability and terms of the transportation services that are the subject of this application. Movements of crude supplies from Cushing to Gulf Coast refining facilities, covered in the application, are of direct interest to CAPPs members, which are suppliers and potential shippers of crude oil on the Seaway pipeline. CAPP thus has a vital interest in this proceeding within the meaning of the relevant statutory and procedural provisions, an interest that is not represented by any other party. CAPP ...