Columbia Gas Transmission, LLC submits Supplemental Information under CP15-514.
10/22/2015UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION CHS Inc. ) Federal Express Corporation ) GROWMARK, Inc. ) HWRT Oil Company LLC ) MFA Oil Company ) Docket No. OR13-___-000 Southwest Airline Co. ) United Airlines, Inc. ) UPS Fuel Services, Inc. ) ) Complainants, ) ) v. ) ) Enterprise TE Products Pipeline ) Company, LLC, ) ) Respondent. ) COMPLAINT REQUESTING FAST TRACK PROCESSING OF CHS INC.; FEDERAL EXPRESS CORPORATION; GROWMARK, INC.; HWRT OIL COMPANY, LLC; MFA OIL COMPANY; SOUTHWEST AIRLINES CO.; UNITED AIRLINES, INC.; AND UPS FUEL SERVICES, INC. AGAINST ENTERPRISE TE PRODUCTS PIPELINE COMPANY LLC 1. Pursuant to Sections 13(1) and 15(1) of the Interstate Commerce Act, Rule 206 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or the Commission), 18 C.F.R. 385.206 (2012); and Rules 343.1(a) and 343.2(c) of the Commissions Procedural Rules Applicable to Oil Pipeline Proceedings, 18 C.F.R. 343.1(a) and 343.2(c); CHS Inc. (CHS); Federal Express Corporation (FedEx); GROWMARK, Inc. (GROWMARK); HWRT Oil Company, LLC (HWRT); MFA Oil Company (MFA); Southwest Airlines Co. (Southwest); United Airlines, Inc. (United); and UPS Fuel Services, Inc. (UPS) (jointly, Complainants) submit this complaint challenging the lawfulness of Enterprise TE Products Pipeline Company LLCs (Enterprise TEPPCO) FERC Tariff No. 6815340-v3 55.28.0. Specifically, Complainants allege that Tariff No. 55.28.0, in providing that Enterprise TEPPCO will no longer accept nominations for the transportation of jet fuel or distillates, violates the Settlement Agreement signed by Enterprise TEPPCO in Docket No. IS12-203-000 and approved by the Commission via letter order on May 31, 2013. See Enterprise TE Products Pipeline Company LLC, 143 FERC 61,197 (2013). The Joint Explanatory Statement Regarding Offer of Settlement, Docket No. IS12-203-000 (April 3, 2013) (Explanatory Statement), including a copy of the executed Settlement Agreement and Appendix D thereto containing the Settlement Rates and Settlement Tariffs is Exhibit 1 hereto. 2. The Settlement Agreement in Docket No. IS12-203-000 states that the rates provided therein for enumerated services shall remain in effect for the remainder of the Settlement Period. Settlement Agreement, Section III.D.2(b). Tariff No. 55.28.0 eliminates the distillate and jet fuel transportation services that correspond to these settlement rates. The rates for these services are, therefore, no longer in effect. Enterprise TEPPCO has therefore violated the Settlement Agreement, and the Commission should order it to continue to provide the transportation of distillate and jet fuel service to give effect to the Settlement Agreement. I. COMMUNICATIONS AND CORRESPONDENCE Richard E. Powers, Jr. Steven A. Adducci Matthew D. Field Venable LLP 575 7th Street, N.W. ...