UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Petition For Rulemaking of the Liquids ) Shippers Group, Airlines for America, and ) Docket No. RM15-19-000 the National Propane Gas Association ) POST TECHNICAL CONFERENCE COMMENTS OF TESORO REFINING & MARKETING COMPANY LLC Tesoro Refining & Marketing Company LLC (Tesoro) is pleased to provide these written comments as a supplement to the comments it provided at the Technical Conference on July 30, 2015. At the Technical Conference, attorney Matthew Corcoran of Goldstein & Associates, P.C. and economist Peter K. Ashton from Premier Quantitative Consulting, Inc. provided substantive comments on behalf of Tesoro in support of revisions to page 700 of the FERC Form 6 (1) for oil pipelines who qualify to report separate cost of service and revenue information for crude oil and product pipelines as well as for each individual pipeline system or segment; and (2) for all oil pipelines to make the workpapers associated with the page 700 computations available to shippers upon request. I. INTRODUCTION Tesoro believes that these changes are very important for the Commission to address in order to increase the transparency of these carriers financial reporting and to give shippers the information necessary to properly evaluate the reasonableness of rates. While the burden is generally on shippers to identify whether a pipelines rates may be unjust or unreasonable, the page 700 as a screening tool is not currently effective where a pipeline has multiple segments or operates both crude oil and product pipelines. This more detailed reporting would make the screening process more efficient and that efficiency would far outweigh any additional reporting costs. Indeed, as Mr. Ashton stated at the Technical Conference, the number of pipeline companies that would be affected by this change is relatively limited, and is likely to involve less than 30 companies or only about 15% of those roughly 200 companies that file an annual FERC Form 6. Contrary to the assertions of representatives from Association of Oil Pipelines (AOPL) at the Technical Conference, the increased burden is not significant, and the benefits including increased transparency and greater efficiency in the screening process for which the page 700 is largely used would far outweigh any additional costs. The burden of the proposed change to the page 700 is not significant because the pipeline companies that would be affected already report much of their financial and cost data on a segment by segment basis. Some pipelines may incur a one-time cost to develop certain allocations, but ...