Cost and Revenue Study of Millennium Pipeline Company, L.L.C. in Compliance with December 21, 2006 Order under CP98-150.

One Blue Hill Plaza, 7th Floor Post Office Box 1565 Pearl River, NY 10965 845.620.1300 Voice | 845.620.1320 Fax December 21, 2011 Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Millennium Pipeline Company, L.L.C. Docket No. CP98-150-006 Compliance Filing - Cost and Revenue Study Dear Ms. Bose: In compliance with Paragraph 104 of the Federal Energy Regulatory Commissions (FERC or the Commission) December 21, 2006 Order (Certificate Order),1 Millennium Pipeline Company, L.L.C. (Millennium) hereby submits the attached Cost and Revenue Study (Attachment A) in accordance with Section 154.313 of the Commissions regulations.2 Although the study shows that Millennium is under-recovering its cost of service, Millennium is not proposing to change its rates at this time. Millennium is nearly fully subscribed under negotiated rate contracts. In Millenniums opinion, the market (and its existing contractual commitments) will not support a rate increase at this time. Explanation of Cost and Revenue Study Millennium has calculated a Cost of Service of $177 million based on the twelve months ended September 30, 2011 (Schedule A). The costs are based on the actual per-books costs during that period except where certain adjustments were made. These adjustments have been footnoted on the relevant schedules. The calculated Cost of Service of $177 million substantially exceeds the $112 million in Revenues realized in primarily negotiated rate agreements during the base period (Schedule G). Millennium, however, is submitting this Cost and Revenue Study solely to comply with the Commissions Certificate Order and is not proposing any revisions to existing transportation rates. In the event that the Commission opens a NGA Section 5 proceeding against Millennium, or Millennium elects at some future date to file a rate increase under NGA Section 4, Millennium reserves the right to make usual and customary adjustments to its Cost of Service. 1 Millennium Pipeline Co., L.L.C., 117 FERC 61,319 (2006). 2 Millennium commenced operations on December 22, 2008. See Millennium Pipeline Co., L.L.C., Notification of Commencement of Service, Docket No. CP98-150-006 (Dec. 31, 2008). www.millenniumpipeline.com Millennium respectfully requests that the Commission issue an order finding that the attached Cost and Revenue Study fully justifies its cost-based firm and interruptible transportation rates as required by the Certificate Order. Correspondence All communications and correspondence with respect to this proceeding should be Addressed to the following: Gary A. Kruse* Thomas E. Holmberg* Vice President - General Counsel & Secretary Jerrod L. Harrison Millennium Pipeline Company, L.L.C. BAKER BOTTS L.L.P. ...