Viking Gas Transmission Company. Notice Of Compliance Filing

607 14th St. N.W. Washington, DC 20005-2006 202-347-1000 Main 202-661-6970 Main Fax www.postschell.com Christopher J. Barr cbarr@postschell.com 202-661-6950 Direct 202-661-6951 Direct Fax April 9, 2013 VIA ELECTRONIC FILING Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: CenterPoint Energy Mississippi River Transmission, LLC, Docket Nos. RP12-955-000, et al. Dear Ms. Bose: Enclosed for filing is the Prepared Answering Testimony of James A. Doering on behalf of Laclede Gas Company in the above referenced proceeding, submitted in accordance with the Commissions Rules of Practice and Procedure and with the requirements established by Presiding Administrative Law Judge Judith A. Dowd. Very truly yours, /s/ Christopher J. Barr Enclosures cc: Service List Presiding Administrative Law Judge Judith A. Dowd ALLENTOWN HARRISBURG LANCASTER PHILADELPHIA PITTSBURGH PRINCETON W ASHINGTON, D.C. A PENNSYLVANIA PROFESSIONAL CORPORATION Summary of the Prepared Answering Testimony of James A. Doering The testimony of Mr. James A. Doering examines the CenterPoint Energy -- Mississippi River Transmission, LLC (MRT) proposal to redesign its rate zones so that its existing Field Zone is divided into a South Field Zone and a North Field Zone, with the demarcation between the two new rate zones at the Glendale Compressor Station. In particular, the testimony reviews, evaluates and responds to the direct testimony of MRT witnesses Robert A. Trost (Exh. No. MRT-90) and Barry E. Sullivan (Exh. No. MRT-114). Mr. Doering states that the information contained in MRTs testimony and exhibits, and certain of MRTs responses to discovery, demonstrates that the proposed change from one to two field zones, with an accompanying change from one to two field zone rates, is unreasonable and unjustified and results in clearly discriminatory rates. Mr. Doering recommends that the Commission reject the MRT proposal due to several serious defects. He concludes that the proposed zone rates do not reflect the extent to which MRT relies on displacement transportation or the physical gas flows on the MRT system that occur because it is the most efficient way to operate the MRT system. Further, he concludes that the MRT proposal conflicts with the integrated operational nature of the proposed North and South Field Zones due to the fact that displacement transportation would take place across the proposed zone boundary. Mr. Doering shows that the proposed zone rates do not reflect the rate principle of cost causation because they ...