Motion to intervene of ChevronTexaco Global Trading and Answer to Protest re Chevron Pipe Line Co under IS04-283.

Jnofficial FERC-Generated PDF of 20040505-0087 Received by FERC OSEC 05/03/2004 in D o c k e t # : IS04-283-000 L G O ~ & ASSOCIAq[I~ P.C. ATTORNEYS AND COUNS[LOR$ 1 7 5 7 P STRI[L'T. N.W. W A S H I N G T O N * D.C. = ) 0 0 3 6 AT LAW oRIGINAL 202) 87L:L8740 FAX: [ 2 0 2 ] 8 7 ~ - 8 7 4 4 :0 May 3, 2004 BY HAND D E L I V E R Y Ms. Magalie R. Salas Secretary "G f;,'-.c~ Federal Energy Regulatory Commission 888 First Street, N.E. R o o m 11-G Washington, D.C. 20426 Re: ChevronPipe Line Company Docket Nos. IS04-283-000 Dear Secretary Salas: Enclosed for filing with the Commission are an original and 14 copies of the Motion to Intervene of ChevronTexaco Global Trading and Answer to Protest. I would appreciate your date-stamping the extra copy of the document which we have enclosed and returning it to us. Thank you for your assistance in this matter. Sincerely, Counsel for ChevronTexaco Global Tradin~ Enclosures Jnofflclal FERC-Generated PDF of 20040505-0087 Received by FERC OSEC 05/03/2004 in D o c k e t # : IS04-283-000 BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Chevron Pipe Line Company ) Docket No. IS04 - 283 - 000 M O T I O N TO I N T E R V E N E O F C H E V R O N T E X A C O G L O B A L T R A D I N G AND A N S W E R T O P R O T E S T Pursuant to Rule 214 of the Commission's Procedural Rules,~ ChevronTexaco Global Trading, a divisionof Chevron USA, (ChevronTexaco), respectfully moves to intervene in this Protest proceeding. As we demonstrate below, ChevronTexaco has a substantial economic interest in the subject matter of this Protest. This proceeding involves a crude oil quality provision in a joint tariff t h a t was published by Chevron Pipe Line Company (CPL) with Anadarko Gulf of Mexico Pipeline, Inc. (Anadarko). ChevronTexaco is currently shipping crude oil on the joint tariff that is being challenged in this proceeding and will be adversely affected if the position of the Protestant, Marathon Pipe Line LLC (Marathon), is accepted by the Commission. At stake in this proceeding is the integrity of a low sulfur crude stream that supplies several large Louisiana refineries with sweet type crude oil. As we demonstrate in this Answer, this proceeding is ...