Plains PIpeline, LP submits FERC Form 6 Annual Report of Oil Pipeline Companies for the year ending 2014.

PUBLIC VERSION Exhibit No. BPL-52 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Guttman Energy, Inc., d/b/a ) Guttman Oil Company, and ) PBF Holding Company LLC, ) ) Complainants, ) ) v. ) Docket No. OR14-4-000 ) Buckeye Pipe Line Company, L.P. and ) Laurel Pipe Line Company, L.P., ) ) Respondents ) PREPARED ANSWERING TESTIMONY OF ROBERT G. VAN HOECKE ON BEHALF OF BUCKEYE PIPE LINE COMPANY, L.P. April 10, 2015 PUBLIC VERSION Exhibit No. BPL-52 Page 1 of 49 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Guttman Energy, Inc., d/b/a ) Guttman Oil Company, and ) PBF Holding Company LLC, ) ) Complainants, ) ) v. ) Docket No. OR14-4-000 ) Buckeye Pipe Line Company, L.P. and ) Laurel Pipe Line Company, L.P., ) ) Respondents ) SUMMARY OF THE PREPARED ANSWERING TESTIMONY OF ROBERT G. VAN HOECKE ON BEHALF OF BUCKEYE PIPE LINE COMPANY, L.P. 1 Mr. Van Hoecke discusses the principles governing intrastate versus interstate 2 jurisdictional status as well as the pertinent facts with respect to the transactions at issue 3 in this proceeding. He concludes that the shipments appear to be continuous interstate 4 movements commenced with an intent to be interstate in nature, based on several factors. 5 Mr. Van Hoecke further analyzes the agreement between the Complainants and finds that 6 its structure and the manner in which the parties must nominate and coordinate their 7 shipments with the carriers involved also demonstrates the interstate nature of the PUBLIC VERSION Exhibit No. BPL-52 Page 2 of 49 1 movements at issue. He explains that breakout storage tankage, like that used at Booth, is 2 an integral part of the transportation by the pipeline and that passage through breakout 3 storage tankage does not transform an interstate movement into two movements, one of 4 which is intrastate. He also describes how the Booth storage tankage cannot form the 5 basis for a break into two movements even under the Complainants theory of the case. 6 Mr. Van Hoecke further discusses how the commingling of shipments on the 7 Laurel/Buckeye system, including commingling at Booth, should not affect the 8 jurisdictional conclusion. He also concludes that, regardless of whether the current 9 agreement between the Complainants was intended to game the jurisdictional status of 10 the shipments, the jurisdictional standard advanced by the Complainants would, if 11 accepted by the Commission, encourage and enable gaming, with potentially widespread 12 consequences. Mr. Van Hoecke recommends that the Commission find the shipments at 13 issue to be interstate in nature. PUBLIC VERSION Exhibit No. BPL-52 ...