Truckline Gas Company, LLC submits Abbreviated Application for an Order Permitting and Approving Mainline Abandonment under CP12-491.

no determination has yet been made regarding the issue. The Commission therefore should dismiss the petition as premature without prejudice to Flint Hills ability to refile if and when the issue becomes ripe. Second, if the Commission decides to address the Petition on its merits, the Commission should rule that a minimum temperature requirement that is applied uniformly to all persons that deliver oil to TAPS and is adopted to ensure the continued operation of TAPS would not be discriminatory or otherwise unlawful. Finally, if the Commission does not dismiss the Petition as premature, the Indicated TAPS Carriers request that this matter be referred to a settlement judge to provide an opportunity to resolve this matter by agreement. I. BACKGROUND TAPS is an 800-mile pipeline that transports oil produced on the North Slope of Alaska. Petroleum is tendered to TAPS from several production fields. For fields that are somewhat distant from TAPS origin point at Pump Station No. 1, feeder pipelines transport the petroleum from the fields to Pump Station No. 1. Throughput on TAPS peaked in 1988-1989 and has declined since that time as production of petroleum from North Slope fields has declined. See Exhibit No. FHR-2 at 6. As throughput has declined, the transit time for petroleum to complete the journey from Pump Station No. 1 to the Valdez Marine Terminal has increased. The increased transit time results in greater cooling of the petroleum as it moves through the pipeline. The temperature of the petroleum that is transported on TAPS is important. Exhibit No. FHR-2 to the Petition is a Low Flow Plan Summary (Low Flow Plan)2 that summarizes the 2 The TAPS Carriers have continued to study the issues associated with low flows on TAPS since issuing the Low Flow Plan that Flint Hills attached as Exhibit No. FHR-2. As a result of that work, the TAPS Carriers have prepared a more recent version of the plan. However, the general problems that declining throughput causes for TAPS are the same as identified in Exhibit No. FHR-2. 2 operational issues that will arise as TAPS throughput continues to decline and the temperature of the petroleum declines with it. These problems include the following: (i) Problems associated with freezing of soil surrounding the buried portion of the pipeline. Just less than half of the pipeline is buried below-ground. If the pipeline operates at temperatures below freezing, the soil around the pipeline could freeze, which could ...