Comment of Jennifer Jordan in Docket(s)/Project(s) CP15-500-000 Submission Date: 6/26/2015

PUBLIC VERSION Exhibit No. BPL-89 Docket No. OR14-4-000 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 TO COMMISSION TRIAL STAFF OF DR. MICHAEL J. WEBB ON BEHALF OF BUCKEYE PIPE LINE COMPANY, L.P. June 26, 2015 PUBLIC VERSION Exhibit No. BPL-89 Docket No. OR14-4-000 Page 1 of 21 TABLE OF CONTENTS I. INTRODUCTION..................................................................................................... 2 II. ASSESSING THE EXERCISE OF MARKET POWER ...................................... 3 III. DELIVERED PRICE METHOD VERSUS DELIVERED COST METHOD . 16 IV. BEHAVIORAL ANALYSIS AND TRUCKING DATA ..................................... 18 V. CONCLUSION ....................................................................................................... 21 PUBLIC VERSION Exhibit No. BPL-89 Docket No. OR14-4-000 Page 2 of 21 PREPARED ANSWERING TESTIMONY TO COMMISSION TRIAL STAFF OF MICHAEL J. WEBB 1 I. INTRODUCTION 2 Q. Please state your name, occupation, and business address. 3 A. My name is Michael J. Webb. I am a Director with Regulatory Economics Group, 4 LLC. My office is at 11180 Sunrise Valley Drive, Suite 320, Reston, Virginia 5 20191. 6 Q. Are you the same Michael J. Webb who filed answering testimony in this 7 proceeding on January 20, 2015? 8 A. Yes I am. In my previous answering testimony, I responded to the testimony of 9 Guttman Energy, Inc., d/b/a Guttman Oil Company (Guttman) and PBF Holding 10 Company LLC (PBF) (collectively Complainants) witness Dr. Daniel Arthur. 11 In the instant testimony, which again is filed on behalf of Buckeye Pipe Line 12 Company, L.P. (Buckeye), I respond to the testimony of Federal Energy 13 Regulatory Commission (FERC or Commission) Staff witness Mr. Aaron 14 Siskind.1 For completeness, I have attached an updated curriculum vitae to my 15 testimony as Exhibit No. BPL-90. 16 Q. Please summarize your testimony. 1 On May 28, 2015, Staff filed an errata and corrections to Mr. Siskinds Testimony. This will be referenced throughout this testimony as Exhibit No. S-5 (Corrected). PUBLIC VERSION Exhibit No. BPL-89 Docket No. OR14-4-000 Page 3 of 21 1 A. In Section II, I will present empirical analysis that strongly suggests that Buckeye 2 has not exercised market power in the Harrisburg market, as well as in the 3 Pittsburgh market. In Section III, I will address confusion created by Mr. Siskinds 4 testimony between my Delivered Cost Analysis and the analysis presented in the 5 testimony of my colleague Dr. George Schink. Finally, in Section IV, I will present 6 various behavioral indicia, including an analysis of trucking data ...