Answer to complaint re ConocoPhillips Transportation Alaska,Inc under OR05-8.
07/31/2005Jnofflclal FERC-Generated P D F o f 20050802-0235 Received by FERC OSEC 08/01/2005 in D o c k e t # : OR05-8-000 ~TEPTOE &JOHNSON"" AI I ~ h ~ : , ~ AT LAW ORIGINAL OF_rlcF 'T . ,~ECft~ ?;,grt y " Steven Reed 1330 Connecticut Avenue. N'W 202.429.6232 Washington. DC 20036-1795 steed@steptoe.com Tel 202.429.3000 AUG - I ts Fax 202.429.3902 'r~EGULA f O " " ;. '!,-t,u 'f steptoe.com . r UUHHISSION August 1, 2005 The Honorable Magalie R. Salas Secretary Federal Energy Regulatory Commission 888 First Street N.E. Room IA Dockets Washington, D.C. 20426 Re: Docket No. 0R05-8-#0# Dear Ms. Saias: Enclosed please find the original and fourteen (14) copies of ConocoPhillips Transportation Alaska, Inc.'s Answer To Complaint for filing in the above-captioned proceeding. Counsel for all parties have been served as indicated in the attached certificate of servicc. Please acknowledge receipt of this transmittal by date-stamping the enclosed duplicate file copy and return it to our courier at the time of filing. Steven Reed Enclosures co: Counsel for all parties WASIIINGTON NLW YORK PHOEhlX lOS ANGLLLS LONDO'~ BRUSSELS Jnofflclal FERC-Generated P D F o f 20050802-0235 Received by FERC OSEC 08/01/2005 in D o c k e t # : OR05-8-000 G,I ^/A,.. lJ UNITED STATESOF AMERICA ~4/~'..,/ ~[~ BEFORE THE ~'~,,~.., <.'?, , FEDERAL ENERGY REGULATORY COMMISSION ~o~. /6" m % ConoeoPhillips Transportation Alaska, lnc~ ) Docket No. OR05-8-000 I ANSWER TO COMPLAINT t I Pursuant to the Notice of Complaint issued July 90, 2005 in the above-captioned proceeding and Rules 206(0 and 213 of the Commission's Rules of Practice and Procedure, 18 I C.F.R. 385.206(f), 385.213 (2004), respondent ConocoPhillips Transportation Alaska, Inc. e ("CPTAI") hereby answers the complaint against its new proration policy filed by BP Exploration (Alaska) Inc. and BP Oil Supply Company (collectively, "BP"), on June 30, 2005 I ("BP Complaint"). I For the reasons set forth below, the BP Complaint is without legal merit and I should be rejected. In addition, as explained further below, Fast Track Processing of the BP Complaint is unnecessary, since CPTAI's new proration policy will not take effect until January I 2006. 411 1 The BP Complaint is contained within a pleading styled "Motion to Intervene, Protest and Request for Rejection or Suspension, and Request for Acceptance of Late Filed Protest or, in the Alternative, Complaint Requesting Fast Track Processing and Request for Reparations of BP Exploration (Alaska) Inc. and BP Oil Supply Company," which was also filed as a protest in Docket No. IS05-351-000. Since ...