Example of Filing

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
)
)
)
Tesoro Refining and Marketing Company, )
)
Complainant,
)
)
)
v.
)
)
SFPP, L.P.,
)
)
)
Respondent.
)

Docket No. OR11-________

)
)
)
)
COMPLAINT OF TESORO REFINING
AND MARKETING COMPANY
) INCREASES OF SFPP, L.P.
AGAINST INDEX-BASED RATE

By:

Melvin Goldstein
Matthew A. Corcoran
GOLDSTEIN & ASSOCIATES, P.C.
1757 P Street, N.W.
Washington, D.C. 20036
(202) 872-8740
Attorneys for Tesoro Refining and
Marketing Company

Date:

July 20, 2011

1.

Pursuant to Rule 206 of the Rules of Practice and Procedure of the

Federal Energy Regulatory Commission (“Commission” or “FERC”), 18 C.F.R.
§ 385.206; the Procedural Rules Applicable to Oil Pipeline Proceedings, 18 C.F.R.
§ 343.2; Sections 1(4), 1(5), 8, 9, 13, 15, and 16 of the Interstate Commerce Act
(ICA), 49 U.S.C. App. §§ 1(4), 1(5), 8, 9, 13, 15, and 16 (1988); and Section 1803 of
the Energy Policy Act of 1992 (EPAct), Tesoro Refining and Marketing Company
(Tesoro) hereby files this Complaint against SFPP, L.P. (SFPP). Tesoro challenges
the justness and reasonableness of SFPP’s proposed indexed-based rate increases
for transportation on its interstate pipeline system that it filed with the
Commission on May 27, 2011 in Docket No. IS11-444-000. SFPP’s filing proposes to
increase its Watson Volume Deficiency Charge by 5.6 percent and to increase all of
its transportation rates by 6.9 percent. SFPP’s proposed indexed rates are
contained in FERC Tariff Nos. 194.1.0, 195.1.0, 196.3.0, 197.1.0, 198.3.0, 199.1.0,
and 200.1.0.
2.

Tesoro submits that this Complaint presents reasonable grounds to

conclude that SFPP’s proposed rates are unjust and unreasonable on their face.
Accordingly, Tesoro requests that the Commission reject SFPP’s proposed indexedbased rate increases, prescribe just and reasonable rates, and order SFPP to refund
to Tesoro, with interest, the rates that it will pay in excess of the Commission’s
prescribed just and reasonable rates for the period from July 1, 2011 through the
resolution of this Complaint.
3.

In support hereof, Tesoro states as follows:

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I. COMMUNICATIONS AND CORRESPONDENCE
4.

Communications and correspondence regarding this Complaint should

be directed to the following persons:
Barron Dowling
Associate General Counsel, Supply and Logistics
Tesoro Companies, Inc.
19100 Ridgewood Parkway
San Antonio, TX 78259
Tele: (210) 626-4415
Email: [email protected]

Melvin Goldstein
Matthew A. Corcoran
GOLDSTEIN & ASSOCIATES, P.C.
1757 P Street, N.W.
Washington, D. C. 20036
Tele: (202) 872-8740
Fax: (202) 872-8744
E-Mail: [email protected]
[email protected]

II. PARTIES
5.

Respondent SFPP is an oil pipeline company engaged in the

transportation of refined petroleum products in interstate commerce. It is regulated
as a common carrier by the Commission under the Interstate Commerce Act (ICA)
and the Energy Policy Act of 1992 (EPAct). SFPP operates approximately 2,500
miles of pipeline consisting of the following four lines:
a. The West Line, which originates at Watson Station and East Hynes in
the Los Angeles, California area and makes deliveries to Phoenix,
Arizona. The West Line also interconnects with Calnev Pipe Line,
LLC (Calnev), an affiliate of SFPP, at Colton, CA for further deliveries
to Las Vegas, Nevada;
b. The East Line, which originates in El Paso and Diamond Junction,
Texas and makes deliveries to Lordsburg, New Mexico; Tucson and
Phoenix, Arizona; and various military destinations;
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c. The North Line, which originates at Richmond and Concord, CA and
makes deliveries to the Reno, NV area; and
d. The Oregon Line, which originates at Portland, Oregon and makes
deliveries to Eugene, Oregon.
6.

SFPP is a subsidiary of Kinder Morgan Energy Partners, L.P. (KMEP),

a publicly-traded master limited partnership and registered tax shelter. In turn,
Kinder Morgan, Inc. (KMI) owns the general partner interest of KMEP. KMEP is
both a “Master Limited Partnership” (MLP) and a “Publicly Traded Partnership”
(PTP) presently eligible to be taxed as a partnership.
7.

As the attached Sworn Declaration of Counsel demonstrates, Tesoro is

a shipper of refined petroleum products on SFPP’s interstate pipeline system.1
Tesoro has shipped and continues to ship significant quantities of refined petroleum
products on SFPP’s lines in interstate commerce. Tesoro intends to continue to ship
refined petroleum products on SFPP’s pipeline system in the foreseeable future.
Tesoro therefore has a substantial economic interest in SFPP’s rates and the unjust
and unreasonable rates SFPP has charged in the past.2

1

Ex. A, Verified Statement of Melvin Goldstein, Counsel for Tesoro Refining and
Marketing Company (hereinafter “Statement of Counsel”).
2
Id.
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III.
A.

BACKGROUND FACTS

Tesoro’s Shipments on the SFPP Pipeline System.
8.

The SFPP lines at issue in this proceeding are subject to the

jurisdiction of the Commission, and SFPP has published transportation tariffs for
its pipeline system with the Commission. As the attached Statement indicates,
during each of the past several years, Tesoro shipped significant quantities of
refined petroleum products on the SFPP interstate lines at rates charged by SFPP
under tariffs on file with the FERC.3 Tesoro’s shipments of refined petroleum
products on the SFPP pipeline system will continue into the indefinite future.
B.

FERC and Court of Appeals Decisions With Respect to the West Line
and Calnev Line.
9.

In a series of decisions that were issued in 2004 and 2005, the

Commission and the Court of Appeals for the District of Columbia Circuit have held
that the rates that SFPP has charged shippers for shipping petroleum products on
the West Line and Calnev Line have been unjust and unreasonable and that SFPP’s
rates must be reduced.4 Those decisions are the following:
a.

BP West Coast Products, 374 F.3d 1263 (2004)

10.

In a decision issued on July 20, 2004, the Court of Appeals for the

District of Columbia remanded to the Commission the issue of whether the West
Line and Calnev Line had experienced “substantially changed circumstances” since
3

Id.
Although SFPP files separate tariffs for its West Line and Calnev Line rates, both
the Commission and the Court of Appeals consider the Calnev Line to be part of the
West Line. The FERC and Court of Appeals decisions referred to in the text
therefore apply both to the West Line and the Calnev Line.
4

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1992. The court held that if substantially changed circumstances exist, then the
rates SFPP charged for transportation on the West Line and Calnev Line would not
be subject to the “grandfathering” provision of Section 1803 of the Energy Policy Act
of 1992. This statutory provision generally applies to pipeline transportation rates
that were in effect for the 365 days prior to the enactment of the EPAct on October
24, 1992.
b.

11.

ARCO Products Co., et al. v. SFPP, L.P., 106 FERC ¶ 61,300
(2004)
In this Decision, the Commission found that the threshold “changed

circumstances” standard in Section 1803(b)(1) of EPAct had been satisfied with
respect to the West Line and Calnev Line. In an Initial Decision, an Administrative
Law Judge specifically found that the substantially changed circumstances
standard had been satisfied with regard to West Line and Calnev Line rates for
1996, 1997, 1998, and 2000. The Commission subsequently confirmed that
determination, concluding that “substantial changes in circumstances [existed] that
were the basis for the Yuma, Calnev and West Tucson rates beginning in 1995, and
for the West Phoenix rates beginning in 1997.”5
c.

SFPP, L.P., 111 FERC ¶ 61,334 ( 2005)

12.

This order addressed the remand to the Commission by the United

States Court of Appeals for the District of Columbia Circuit in BP West Coast
Products, the Phase I proceeding in Docket No. OR96-2-000, et al., and issues raised
by the Commission’s March 24, 2004 Order in that proceeding. These issues all
5

106 FERC ¶ 61,300 at P 53 (2004).
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concerned the extent to which SFPP’s rates for the West Line and the Calnev Line
were subject to the grandfathering provision of Section 1803 of the Energy Policy
Act. The Commission “again conclude[d] that there were substantially changed
circumstances on the West Line for the years stated in the March 2004 Order.”6
d.

SFPP, L.P., 113 FERC ¶ 61,277 (2005)

13.

Since the Commission had found the rates on the West Line and

Calnev Line were not grandfathered, in a further order issued on December 16,
2005, the Commission clarified the methodology that SFPP must use in establishing
new interim rates for the West Line and the Calnev Line. The Commission stated
that “[t]his order makes certain determinations for establishing interim just and
reasonable rates for SFPP, L.P.’s (SFPP) East and West Line rates pursuant to
section 15(1) of the Interstate Commerce Act.”7 Based on this Order, “the
Commission [required] SFPP to make several compliance filings and to establish
new interim rates for its West Line…as of May 1, 2006.”8
e.

Tariffs Nos. 120 and 121 and Commission Order Suspending
Tariffs Subject to Refund

14.

As a result of the previous decisions, on March 7, 2006, SFPP filed

FERC Tariff Nos. 120 and 121 for transportation on the West Line and Calnev
Lines, respectively. SFPP stated that the new rates it established in these tariffs
for the West Line and Calnev Line were intended to comply with the Commission’s

6

111 FERC ¶ 61,334 at P 39 (2004).
113 FERC ¶ 61,277 at P 1 (2005).
8
Id. at P 2.
7

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December 16 Order and the Order on Rehearing issued February 13, 2006.9 The
Commission accepted and suspended SFPP Tariffs Nos. 120 and 121, subject to
refund, to be effective May 1, 2006.10
IV.
15.

BASIS OF COMPLAINT

The Commission has noted on a number of occasions that the annual

Form No. 6 that a pipeline files can be used by shippers as evidence that a pipeline
is charging unjust and unreasonable rates. Specifically, the Commission has stated
that “page 700 [of Form No. 6] was designed as a preliminary screening tool for
pipeline rate filings. It provides a means for a shipper to determine whether a
pipeline’s cost of service or per-barrel/mile cost is so substantially divergent from
the revenues produced by its rates to warrant a challenge that requires the pipeline
to justify its rates… [It will] enable a shipper to challenge a pipeline's rates.”11
16.

The Commission has, in the past, used two different standards for

determining whether an index rate increase is improper: (i) the “substantially
exacerbate” standard and (ii) a percentage comparison test.

9

Order on Rehearing in Docket No. OR92-8 et al., 114 FERC ¶ 61,136 (February 13,
2006).
10
Order Accepting and Suspending Tariff Filings, 115 FERC ¶ 61,125 (April 28,
2006).
11
Revisions to and Electronic Filing of the FERC Form No. 6 and Related Uniform
Systems of Accounts, 93 F.E.R.C. ¶ 61,262 (2000); See Cost-of-Service Reporting and
Filing Requirements for Oil Pipelines, Order No. 571, FERC Stats. & Regs. [Regs.
Preambles 1991-1996] P 31,006 at 31,168 (1994), 59 F.R. 59137 (November 16,
1994); Order on Reh'g, Order No. 571-A, FERC Stats. & Regs. [Regs. Preambles
1991-1996] P 31,012 (1995), 60 F.R. 356 (January 4, 1995); Order No. 561, FERC
Stats. & Regs. [Regs. Preambles, 1991-1996] ¶ 30,985 (1993) (requiring the use of
FERC Form 6 to challenge oil pipeline rates).
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17.

Under the “substantially exacerbate” standard, a determination is

made as to whether (1) the pipeline is substantially over-recovering its cost of
service, and (2) an index-based increase so exceeds the actual increase in the
pipeline’s cost that the resulting rate increase would substantially exacerbate that
over-recovery.12 Under the “percentage comparison test,” a comparison is made of a
pipeline’s page 700 cost data as contained in its Form No. 6 with the data that is
reflected in the index filing and the data for the prior year. If the comparison
indicates that the index rate is substantially in excess of the pipeline’s actual costs,
then the pipeline’s index rate increase is unreasonable. The Commission recently
stated that with respect to Protests, the only acceptable test is the “percentage
comparison test.” However, it is unclear whether both tests are applicable to
Complaints. Nonetheless, under either the “substantially exacerbate test” or the
“percentage comparison test,” SFPP’s proposed index rate increases are unjust and
unreasonable.
18.

With respect to the “substantially exacerbate test,” page 700 of SFPP’s

2010 Form No. 6 clearly demonstrates that both criteria of the “substantially
exacerbate” standard are met in the instant proceeding. As for the first criterion,
Tesoro discussed in its concurrently filed Complaint against SFPP’s base rates that
the 2010 Form No. 6 filed by SFPP shows that its total revenues exceeded its total
cost-of-service by approximately $32.6 million, or 22.7 percent, in that year. On its

12

SFPP, L.P., 129 FERC ¶ 61,228, 62,099 (2009).
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face, this represents a substantial over-recovery by SFPP of its cost-of-service and
demonstrates that at least some of its existing rates are unjust and unreasonable.13
19.

As for the second criterion, SFPP’s 2010 Form No. 6 demonstrates that

SFPP’s cost-of-service in 2010 decreased by $6 million, or 4 percent, while its
revenue increased by $27.9 million, or 18.8 percent, from 2009. Thus, SFPP’s
proposed 6.9 percent increase in rates clearly exceeds the 4 percent decrease in its
cost-of-service so as to substantially exacerbate the 22.7-percent over-recovery that
it experienced in 2010. As the Commission stated in its June 30, 2011 Order in
Docket No. IS11-444-000:
A 4 percent decrease in costs combined with the proposed index-based rate
increase of 6.9 percent for all the transportation rates would still provide
SFPP an approximately 10.9 percent revenue increase under its
transportation rates. The Commission previously found this magnitude of a
divergence between the pipeline’s change in costs, as expressed in percentage
terms, and the proposed rate increase raises an issue of reasonableness that
the Commission will investigate.14
20.

With respect to the percentage comparison test, as the Commission

itself found:
SFPP’s revised FERC Form No. 6, as filed on June 17, 2011, shows a total
cost of service decrease between 2009 and 2010 of approximately 4.0 percent.
A 4 percent decrease in costs combined with the proposed index-based rate
increase of 6.9 percent for all the transportation rates would still provide
SFPP an approximately 10.9 percent revenue increase under its
transportation rates.15

13

As Tesoro discussed in its Complaint against SFPP’s base rates, the data
compiled in FERC Form No. 6 is reported on a system-wide basis; therefore, it is
impossible to determine at this time which particular rates are unjust and
unreasonable and led to SFPP’s over-recovery.
14
SFPP, L.P., 135 FERC ¶ 61,274 at P 11 (2011) (internal citations omitted).
15
Id.
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An 11-percent divergence between SFPP’s change in costs, as expressed in
percentage terms, and the proposed rate increase results in a rate that is unjust
and unreasonable.
21.

Accordingly, Tesoro requests that the Commission: (i) find SFPP’s

proposed index-based rate increases to be unjust and unreasonable; (ii) prescribe
new just and reasonable rates that SFPP may lawfully charge Tesoro for the
shipment of petroleum products on the SFPP pipeline system; and (iii) award
Tesoro reparations, plus interest, for overcharges that Tesoro will pay under the
indexed tariffs in question.
V.
22.

COMPLIANCE WITH PROCEDURAL REGULATIONS

Under 18 CFR § 343.2(c)(1), a Complainant must allege reasonable

grounds for asserting that the rates charged by an oil pipeline under the indexation
provisions of the Commission’s regulations are “so substantially in excess of the
actual cost increases incurred by the carrier that the rate is unjust and
unreasonable.”16 That requirement has been fully satisfied with respect to Tesoro’s
Complaint against SFPP.
23.

In further support of its Complaint, Tesoro states as follows in

accordance with the provisions of 18 CFR § 385.206:
a.

Rule 206(b)(3): Business, Commercial or Economic Issues
Which Affect the Complainant

24.

Tesoro has shipped a substantial quantity of refined petroleum

products on the SFPP pipeline system at the rates established by SFPP in its
16

18 C.F.R. § 343.2(c)(1).
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interstate tariffs. The rates Tesoro has been charged for that transportation have
been unjust and unreasonable. Accordingly, the just and reasonable rates for
SFPP’s pipeline are substantially lower than the rate that SFPP is now charging.
Tesoro has a substantial business, commercial and economic interest in being
charged the just and reasonable rate, as opposed to the unjust and unreasonable
rate.
b.

Rule 206(b)(4): Financial Impact

25.

When the volumes Tesoro shipped on the SFPP pipeline are factored

into the difference between the just and reasonable rates that SFPP should have
charged Tesoro and the rates that SFPP has actually charged Tesoro, it appears
that Tesoro was overcharged by substantial amounts for the period July 1, 2011 to
the present. Tesoro is also continuing to incur damages for overcharges.
c.

Rule 206(b)(5): Non-Financial Impacts

26.

The adverse impact that Tesoro alleges under this Complaint is

financial as set forth above.
d.

Rule 206(b)(6): Related Matters

27.

The amount of damages that Tesoro is entitled to receive for SFPP’s

unjust and unreasonable rates has not been addressed in any proceeding.
e.

Rule 206(b)(7): Relief Requested

28.

Tesoro seeks reparations from the period July 1, 2011 to the date of

decision on its Complaint, plus interest, and the prescription of new just and
reasonable rates on the SFPP pipeline system.

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f.

Rule 206(b)(8): Documents

29.

Tesoro is still evaluating whether the documents in its possession

support its Complaint.
g.

Rule 206(b)(9): Alternative Dispute Resolution

30.

It is possible that an effort by the Alternative Dispute Resolution

branch of the Commission’s staff might be undertaken in the near future. However,
the issues presented in this Complaint are at present unresolved. Consequently,
Tesoro requests that these matters be set for hearing and consolidated with current
on-going proceedings.
h.

Rule 206(b)(10): Form of Notice

31.

A form of notice suitable for publication in the Federal Register in

accordance with the specifications in Rule 203(d) has been attached to this
Complaint as Exhibit B.
VI.
32.

REQUEST FOR RELIEF

WHEREFORE, Complainant Tesoro Refining and Marketing

Company respectfully requests that the Federal Energy Regulatory Commission:
a.

Determine that the rates established by SFPP, L.P. in the

following tariffs for the shipment of refined petroleum products are unjust and
unreasonable, thereby violating Sections 1(4) and 1(5) of the Interstate Commerce
Act and Section 343.2(c)(1) of the Commission’s regulations: FERC Tariff Nos.
194.1.0, 195.1.0, 196.3.0, 197.1.0, 198.3.0, 199.1.0, and 200.1.0;

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b.

Prescribe new rates that are just and reasonable for the

shipment of refined petroleum products on the SFPP pipeline system on the routes
specified in the above tariffs;
c.

Order SFPP to pay refunds, reparations and damages, plus

interest, to Tesoro for shipments made by Tesoro under each of the tariffs specified
above from July 1, 2011 through the date on which the Commission resolves the
issues presented in this docket and related proceedings;
d.

Grant Tesoro such other, different or additional relief as the

Commission may determine to be appropriate.

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Date: July 20, 2011

Respectfully submitted,
TESORO REFINING AND MARKETING COMPANY

By: /s/ Melvin Goldstein
Melvin Goldstein
Matthew A. Corcoran
GOLDSTEIN & ASSOCIATES, P.C.
1757 P Street, N.W.
Washington, D.C. 20036
Tele: (202) 872-8740
Fax: (202) 872-8744
E-Mail: [email protected]
[email protected]
Attorneys for Tesoro Refining and
Marketing Company

Of Counsel:
Barron Dowling
Associate General Counsel, Supply and Logistics
Tesoro Companies, Inc.
19100 Ridgewood Parkway
San Antonio, TX 78259
Tele: (210) 626-4415
Email: [email protected]

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CERTIFICATE OF SERVICE
I hereby certify that I have this 20th day of July 2011 served the foregoing
Complaint of Tesoro Refining and Marketing Company on the persons listed on the
Commission’s list of Corporate Officials for SFPP, L.P.

/s/ Melvin Goldstein
Melvin Goldstein

EXHIBIT A

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

SFPP, L.P.

)
)
)

Docket No. OR11-_____

VERIFIED STATEMENT OF COUNSEL
FOR TESORO REFINING AND MARKETING COMPANY
I, Melvin Goldstein, counsel for Tesoro Refining and Marketing Company
(Tesoro), hereby verify that Tesoro is a past, current, and future shipper of refined
petroleum products on the interstate pipelines of SFPP, L.P. (SFPP). Tesoro is also
a protestant and complainant in numerous cases involving the rates of SFPP, and
would be economically impacted by SFPP’s proposed index-based rate increases
filed in FERC Tariff Nos. 194.1.0, 195.1.0, 196.3.0, 197.1.0, 198.3.0, 199.1.0, and
200.1.0. Consequently, Tesoro has a substantial economic interest in the rate
increases filed by SFPP that no other party can adequately represent.
Executed on this 20th day of July 2011 at Washington, D.C.
/s/Melvin Goldstein
Melvin Goldstein
GOLDSTEIN & ASSOCIATES, P.C.
1757 P St., NW
Washington, D.C. 20036
Tel: (202) 872-8740
Fax: (202) 872-8744
[email protected]

EXHIBIT B

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Tesoro Refining and Marketing Company,
Complainant,
v.

Docket No. OR11-_______

SFPP, L.P.,
Respondent
NOTICE OF COMPLAINT
Take notice that on July 20, 2011, Tesoro Refining and Marketing Company (Tesoro)
filed a formal complaint against SFPP, L.P. (SFPP) pursuant to Rule 206 of the Rules of Practice
and Procedure of the Federal Energy Regulatory Commission, 18 C.F.R. § 385.206; the
Procedural Rules Applicable to Oil Pipeline Proceedings, 18 C.F.R. § 343.2; Sections 1(4), 1(5),
8, 9, 13, 15, and 16 of the Interstate Commerce Act (ICA), 49 U.S.C. App. §§ 1(4), 1(5), 8, 9, 13,
15, and 16 (1988); and Section 1803 of the Energy Policy Act of 1992 (EPAct).
Tesoro alleges that because SFPP has over-recovered its cost of service in 2010, and their
proposed index-based rate increases exceed the actual decrease in the pipeline’s previous-year
costs in such a manner that substantially exacerbate that over-recovery, SFPP is not entitled to
raise its rates. Tesoro requests that the Commission determine that the rates established by
SFPP, L.P. in FERC Tariff Nos. 194.1.0, 195.1.0, 196.3.0, 197.1.0, 198.3.0, 199.1.0, and 200.1.0
are unjust and unreasonable; prescribe new just and reasonable for the SFPP interstate pipeline
system; and order SFPP to pay refunds, plus interest, to Tesoro for shipments made by Tesoro
under each of the tariffs specified above from July 1, 2011 through the date on which the
Commission resolves the issues presented in this docket and related proceedings. Tesoro has
also requested that the Commission grant such other, different or additional relief as it may
determine to be appropriate.
Tesoro certifies that copies of the complaint were served on the contacts for SFPP as
listed on the Commission’s list of Corporate Officials.
Any person desiring to intervene or to protest this filing must file in accordance with
Rules 211 and 214 of the Commission’s Rules of Practice and Procedure (18 CFR 385.211 and
385.214). Protests will be considered by the Commission in determining the appropriate action
to be taken, but will not serve to make protestants parties to the proceeding. Any person wishing
to become a party must file a notice of intervention or motion to intervene, as appropriate. The
Respondent’s answer and all interventions, or protests must be filed on or before the comment
date. The Respondent’s answer, motions to intervene, and protests must be served on the
Complainant.
The Commission encourages electronic submission of protests and interventions in lieu
of paper using the “eFiling” link at http://www.ferc.gov. Persons unable to file electronically
should submit an original and 14 copies of the protest or intervention to the Federal Energy
Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426.

This filing is accessible on-line at http://www.ferc.gov, using the “eLibrary” link and is
available for review in the Commission’s Public Reference Room in Washington, D.C. There is
an “eSubscription” link on the web site that enables subscribers to receive email notification
when a document is added to a subscribed docket(s). For assistance with any FERC Online
service, please email [email protected], or call (866) 208-3676 (toll free). For
TTY, call (202) 502-8659.
Comment Date: 5:00 pm Eastern Time on (insert date).
Kimberly D. Bose
Secretary