The Association of Oil Pipe Lines submits their comments to the Commission's 6/26/03 Notice of Proposed Rulemaking on Quarterly Financial Reporting and Revisions to the Annual Report published on 7/6/03 under RM03-8.

Jnofflclal FERC-Generated P D F o f 20031211-0102 Received by FERC OSEC 12/01/2003 in D o c k e t # : RM03-8-000 ASSOCIATION OF OIL PIPE LINES Suite 604 1101 Vermont AvtmueqN.W. ORI61NAL Washington, D.C. 20005-3521 TELEPHONE (202) 4011-7970 FAX (202) 4os-'lgs3 November 26, 2003 'f _ ..'~; . ,'.-, ~' :~ I l~ ~'~ The Honorable PaMck Wood, IH Chairman Federal Energy Regulatory Commission ~,.', .to Room 11B-1, Mailstop CO-5 888 First Street NE Washington, DC 20426 Re: Notice of Proposed Rulemaklug on Quarterly Financial Reporting and Revisions to the Annual Report, docket number RM03-8 Dear Chairman Wood: We are writing to you today to exp~-ss our concern with the proposed quarterly financial rule that is problematic for the oil pipeline industry. We understand that the Commission desires to have more current reporting on significant changes to the companies it regulates. We believe this can be achieved for the oil pipeline industry in a much less burdensome way than that proposed in the NOPR. We hope to visit with you and your colleagues to discuss our concerns and proposal in more detail. AOPL staff will be calling your office shortly to schedule an appoinUnent. We in the oil pipeline industry appreciate the time you and your colleagues have taken to meet with us over the last year and the effort the Commission has made to address our concerns. The revision of the oil pipe]ine rate index to more closely t~'ack oil pipel/ne cost increases has greatly helped tkis industry fund needed integrity work. Support for, and clarification of, the security cost surcharge for post-September 11 security enhancements has resulted in timely recovery for these important improvements. The Commission's Jnofflclal FERC-Generated P D F o f 20031211-0102 Received by FERC OSEC 12/01/2003 in D o c k e t # : RM03-8-000 responsiveness to proposed rate styuctures aimed at fostering system expansions or new construction, such as those approving expansions o f existing systems and facilitating construction o f two off-shore pipelines, have accelerated improved pipeline service in the United States. We thank you for your attention to these important matters. Unlike the Commission's actions over the last year that have fostered safer and more efficient pipeline service, the Commission's Notice o f Proposed Rulemaking to require quarterly financial reporting to the Commission will greatly increase pipeline costs and burdens, will not achieve the stated goal to better evaluate "the adequacy o f existing ...