Reply comments of Lion Oil Co, National Cooperative Refinery Association, Sinclair Oil Corp and Tesoro Petroleum Co, Inc re the Five Year Review of Oil Pipeline Pricing Index under RM05-22.

Jnofflclal FERC-Generated PDF of 20051014-0088 Received by FERC OSEC 10/13/2005 in D o c k e t # : R M 0 5 - 2 2 - 0 0 0 ORIGINAL GOLDSlZm P.C. A T T O R N E Y S A N D COUNSIELORS AT L A W 1 7 5 7 P STREET. N.W. WASHINGTON. D.C. 2 0 0 3 6 ~'OP-} 8 7 2 - B 7 4 0 FAX: { 2 0 2 1 8 7 2 - 8 7 4 4 October 13, 2005 BY H A N D DELIVERY f~ Ms. Magalie R. Salas ~ornr-- Secretary Federal Energy Regulatory Commission ~,-nC) 888 First Street, N.E. Room 11-G Washington, D.C. 20426 Re: Five-Year Review of Oil Pipeline Pricing Index D0ket No. RM05-22-000 Dear Secretary Salas: Enclosed for filing with the Commission are an original and 14 copies of the Reply Comments of Lion Oil Company, National Cooperative Refinery Association, Sinclair Oil Corporation and Tesoro Petroleum Company, Inc. Counsel for Lion Oil Comvanv. National Cooverative Refinery Association. Sinclair Oil Corvoration a~dTesoro Refinine and Msrketing Company. Enclosures Jnofflclal FERC-Generated PDF of 20051014-0088 Received by FERC OSEC 10/13/2005 in D o c k e t # : R M 0 5 - 2 2 - 0 0 0 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Five-Year Review Of ) Oil Pipeline Pricing ) D o c k e t No. R M 0 5 - 2 2 - 0 0 0 Index ) REPLY COMMENTS OF LION OIL COMPANY, NATIONAL COOPERATIVE REFINERY ASSOCIATION, SINCLAIR OIL CORPORATION AND TESORO REFINING AND MARKETING COMPANY On July 15, 2005, the Commission published a Notice of Inquiry (NOI) in which it proposed to continue to utilize the Producer Price Index (PPI) for the next five years as the inflationary index that would best track changes in the costs incurred by the oil pipeline industry. The Commission therefore proposed to determine rate ceiling levels for oil pipeline rate changes on the basis of the PPI. 1 The Commission invited initial comments as well as reply comments by interested persons. Lion Oil Company (Lion), National Cooperative Refinery Association (NCRA), Sinclair Oil Corporation (Sinclair) and Tesoro Refining and Marketing Company (Tesoro) are pleased to submit these reply comments in response to initial comments submitted on September 13, 2005 by the 1 Ex. A. Notice of Inquiry, Five-Year Review of Oil Pipeline Pricing Index, 70 Fed. Reg. 40,943 (July 15, 2005) (hereafter "NOI 2005"). Jnofflclal FERC-Generated PDF of 20051014-0088 Received by FERC OSEC 10/13/2005 in D o c k e t # : R M 0 5 - 2 2 - 0 0 0 Association of Oil Pipelines (AOPL). Each of these companies is an independent refiner and marketer of petroleum products. As we discuss in further detail below, each of these companies is also dependent on interstate ...