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`UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
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`El Paso Natural Gas Company
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`Docket No. CP07‐448‐000
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`MOTION FOR LEAVE TO INTERVENE
`AND COMMENTS
`OF BP AMERICA PRODUCTION COMPANY
`AND BP ENERGY COMPANY
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`Pursuant to Rules 211, 212 and 214 of the Rules of Practice and Procedure of the
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`Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§
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`385.211, 385.212, and 385.214 (2007), BP America Production Company and BP Energy
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`Company (jointly “BP”), hereby file this motion for leave to intervene, and file
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`comments in the above‐captioned proceeding.
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`In support of its motion for leave to intervene, BP states the following:
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`The names and addresses of the persons upon whom all communications
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`concerning this proceeding should be served are as follows:
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`Frederick T. Kolb
`BP America Production Company
`BP Energy Company
`501 WestLake Park Boulevard, Mail Code 16.150
`Houston, TX 77079
`(281) 366‐5009
`kolbft@bp.com
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`* Designated to receive service pursuant to Rule 2010 of the Commission’s Rules
`of Practice and Procedure, 18 C.F.R. § 385.2010 (2007).
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`Steve P. Tarpey
`BP America Production Company
`BP Energy Company
`501 WestLake Park Boulevard
`Houston, TX 77079
`(281) 366‐2690
`steve.tarpey@bp.com
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`Katherine B. Edwards
`Edwards & Associates
`1517 King Street
`Alexandria, VA 22314
`(703) 549‐0888
`kbe@kbelaw.com
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`John Paul Floom
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`Edwards & Associates
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`1517 King Street
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`Alexandria, VA 22314
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`(703) 549‐0888
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`jpf@kbelaw.com
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`On September 17, 2007, El Paso Natural Gas Company (“El Paso”) filed an
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`application for a certificate of public convenience and necessity to construct and operate
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`compression located in Pinal County, Arizona (“Picaho Compressor Station Project” or
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`Project”).
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`BP has a direct interest in the subject filing as a supplier to and/or shipper on El
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`Paso’s pipeline system. BP has a substantial interest in and will be directly affected by
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`the outcome of this proceeding. No other party can adequately represent BP’s interests.
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`Given BP’s interests in the subject filing, granting its motion to intervene would be in
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`the public interest. 18 C.F.R. § 385.214 (2007).
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`Further, in the Application, El Paso stated that it was not seeking a pre‐
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`determination of roll‐in for the Project costs at this time, but that El Paso would address
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`the issue in its next rate case, for non‐gas cost issues, or in the next applicable fuel
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`tracker following the in‐service date of the Project, for fuel costs. In light of El Paso’s
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`statements, BP requests the Commission to clarify that it will not address in this
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`proceeding the issue of the appropriateness (or inappropriateness) of rolled‐in rates for
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`the Project. Parties should have the opportunity to examine El Paso’s proposed rate
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`treatment of the Project‐related costs when El Paso makes its filing on the rate treatment
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`for the Project, and to take whatever positions they deem appropriate at that time.
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`WHEREFORE, for the foregoing reasons, BP respectfully requests that it be
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`permitted to intervene with full rights as a party in this proceeding, and that the
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`Commission accept these comments.
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`By:
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`DATED: October 24, 2007
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`Respectfully submitted,
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`BP AMERICA PRODUCTION COMPANY
`BP ENERGY COMPANY
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`Frederick T. Kolb
`BP America Production Company
`BP Energy Company
`501 WestLake Park Boulevard
`Mail Code 16.150
`Houston, TX 77079
`(281) 366‐5009
`kolbft@bp.com
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`/s/ Katherine B. Edwards
`Katherine B. Edwards
`John Paul Floom
`Edwards & Associates
`1517 King Street
`Alexandria, VA 22314
`(703) 549‐0888
`kbe@kbelaw.com
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`Attorneys for
`BP America Production Company
`BP Energy Company
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`CERTIFICATE OF SERVICE
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`Pursuant to Rule 2010 of the Commission’s Rules of Practice and Procedure, 18
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`C.F.R. § 385.2010 (2005), I hereby certify that I have this day served the foregoing
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`document upon each person designated on the official service list compiled by the
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`Secretary in this proceeding.
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`Dated at Alexandria, Virginia this 24th day of October, 2007.
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`/s/ John Paul Floom
`Katherine B. Edwards
`John Paul Floom
`Edwards & Associates
`1517 King Street
`Alexandria, VA 22314
`(703) 549‐0888
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