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`BP Pipelines (Alaska) Inc.
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`UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
` )
` )
` )
` )
` )
`
`
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`
`
`
`
`Docket Nos. IS09-348-004, et al.
` IS09-348-006, et al.
`
`(Superseded)
`(SR Phase I Prudence)
`(SR Phase II Cost of Service)
`
`LIMITED BRIEF ON EXCEPTIONS OF
`ANADARKO PETROLEUM CORPORATION
`
`
`
`Joseph S. Koury, Esq.
`Jeffrey G. DiSciullo, Esq.
`Andrew T. Swers, Esq.
`WRIGHT & TALISMAN, P.C.
`1200 G Street, N.W.
`Washington, D.C. 20005-3802
`Telephone: (202) 393-1200
`Facsimile: (202) 393-1240
`koury@wrightlaw.com
`disciullo@wrightlaw.com
`swers@wrightlaw.com
`
`
`
`Robin O. Brena
`David W. Wensel, Esq.
`Anthony S. Guerriero, Esq.
`BRENA, BELL & CLARKSON, P.C.
`810 N Street, Suite 100
`Anchorage, Alaska 99501-2014
`Telephone: (907) 258-2000
`Facsimile: (907) 258-2001
`rbrena@brenalaw.com
`dwensel@brenalaw.com
`aguerriero@brenalaw.com
`
`Sherri B. Manuel, Counsel
`Anadarko Petroleum Corporation
`1201 Lake Robbins Drive
`The Woodlands, Texas 77380
`Telephone: (832) 636-1000
`Facsimile: (832) 636-8001
`sherri.manuel@anadarko.com
`
`
`May 16, 2014
`
`
`
`

`

`
`
`
`I.
`
`TABLE OF CONTENTS
`
`
`PAGE
`
`LIMITED EXCEPTION RAISED ..........................................................................1
`
`II.
`
`SUMMARY .............................................................................................................2
`
`III.
`
`STATEMENT OF THE CASE ................................................................................2
`
`IV.
`
`POLICY CONSIDERATIONS WARRANTING FULL COMMISSION
`REVIEW AND OPINION .......................................................................................3
`
`V.
`
`ARGUMENT ...........................................................................................................4
`
`A.
`
`B.
`
`C.
`
`D.
`
`Anadarko’s Five Remedy Formulations. .....................................................4
`
`The Presiding Judge Found that All SR Costs Are Imprudent and
`Otherwise Unrecoverable in Rates. ..............................................................5
`
`The Presiding Judge’s Selection of Remedy 3 Would Allow $229.2
`Million of Imprudent and Unreasonable SR Costs to be Recovered
`in the Cost of Service. ..................................................................................5
`
`Remedy 1 Is Commensurate with the Presiding Judge’s Findings
`Regarding the SR Project. ............................................................................8
`
`E.
`
`Anadarko’s Other Remedy Proposals. .........................................................8
`
`VI.
`
`CONCLUSION ......................................................................................................10
`
`
`
`
`
`
`
`
`
`i
`
`

`

`TABLE OF AUTHORITIES
`
`
`ADMINISTRATIVE DECISIONS
`
`PAGE
`
`BP Pipelines (Alaska) Inc.,
`
`Notice of Extension of Time,
`
`Docket Nos. IS09-348-004, et al. (Mar. 6, 2014) ....................................................3
`
`BP Pipelines (Alaska) Inc.,
`146 FERC ¶ 63,019 (2014) ........................................................................................ passim
`
`BP Pipelines (Alaska) Inc.,
`
`Order of Chief Judge Extending Initial Decision Deadline,
`
`Docket Nos. IS09 348-004, et al. (Oct. 30, 2013) ...................................................3
`
`BP Pipelines (Alaska) Inc.,
`
`130 FERC ¶ 61,042 (2010) ......................................................................................3
`
`BP Pipelines (Alaska) Inc.,
`
`Order of Chief Judge Severing Strategic Reconfiguration
`
`Issues and Scheduling Prehearing Conferences,
`
`Docket Nos. IS09-348-000, et al. (Jan. 13, 2010) ....................................................3
`
`STATUTES & REGULATIONS
`
`18 C.F.R. § 385.711 .............................................................................................................1
`
`
`
`
`
`
`
`
`
`ii
`
`

`

`TABLE OF ABBREVIATIONS
`
`
`
`
`Authorization for Expenditure
`
`
`AFE
`State of Alaska
`Alaska or State
`Anadarko Petroleum Corporation
`Anadarko
`BP Pipelines (Alaska) Inc.
`BP or BPPA
`BP Exploration (Alaska), Inc.
`BPXA
`ConocoPhillips or CPTAI ConocoPhillips Transportation Alaska, Inc.
`ExxonMobil or EMPCo
`ExxonMobil Pipeline Company
`FERC or Commission
`Federal Energy Regulatory Commission
`
`Koch
`RCA
`SIPPS
`SR
`
`Koch Alaska Pipeline Company
`Regulatory Commission of Alaska
`Safety Integrity & Pressure Protection System
`Strategic Reconfiguration
`
`TAPS
`
`
`
`
`
`Trans Alaska Pipeline System
`
`TAPS Carriers, Carriers or
`Owners
`
`
`Tesoro
`Unocal
`
`
`
`
`
`
`
`BP Pipelines (Alaska) Inc.
`ConocoPhillips Transportation Alaska, Inc.
`ExxonMobil Pipeline Company
`Koch Alaska Pipeline Company, and
`Unocal Pipeline Company
`
`Tesoro Alaska Company
`Unocal Pipeline Company
`
`iii
`
`

`

`
`
`LIMITED BRIEF ON EXCEPTIONS OF
`ANADARKO PETROLEUM CORPORATION
`
`
`To: The Commission
`
`
`
`Pursuant to Rule 711 of the Rules of Practice and Procedure of the Federal Energy
`
`Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.711, Anadarko
`
`Petroleum Corporation (“Anadarko”) submits this limited brief on exceptions to the
`
`Initial Decision (“ID”), issued by Presiding Judge Cintron, on February 27, 2014.1
`
`
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`Anadarko would welcome complete affirmance of the ID. Yet, Anadarko expects
`
`that the TAPS Carriers2 will file exceptions to the ID. Accordingly, to fully preserve its
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`rights, Anadarko raises the limited exception set forth below.
`
`I.
`
`
`
`LIMITED EXCEPTION RAISED
`
`The Presiding Judge found that all costs of the TAPS Carriers’ Strategic
`
`Reconfiguration (“SR”) project were imprudently incurred, are not “used and useful,”
`
`and fail to provide ratepayer benefits; however, the remedy adopted by the Presiding
`
`Judge would allow a significant portion ($229.2 million) of such imprudent and
`
`unreasonable SR costs to be included in rates through an amortization in the cost of
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`service.3 Accordingly, Anadarko raises this limited exception and claim of error in order
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`to preserve for the Commission the full array of potential remedies that may be adopted
`
`
`1
`2
`
`BP Pipelines (Alaska) Inc., 146 FERC ¶ 63,019 (2014).
`At the commencement of the proceedings, the Trans Alaska Pipeline System
`(“TAPS”) Carriers (also referred to as “Carriers”) included BP Pipelines (Alaska)
`Inc. (“BP”); ConocoPhillips Transportation Alaska, Inc. (“ConocoPhillips”);
`ExxonMobil Pipeline Company
`(“ExxonMobil”); Koch Alaska Pipeline
`Company, LLC (“Koch”); and Unocal Pipeline Company (“Unocal”). Koch and
`Unocal withdrew from TAPS ownership and cancelled their TAPS tariffs
`effective August 1, 2012.
`The $229.2 million would be part of the total system cost of service that is
`allocated through rate design between the interstate and intrastate costs of service.
`
`3
`
`
`
`
`
`

`

`in accordance with the findings of fact and law to ensure that rates are just and
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`reasonable.
`
`II.
`
`SUMMARY
`
`
`
`The Presiding Judge found that “the Carriers were imprudent in the development,
`
`design, implementation and management” of the SR project, ID at P 1451, and that “the
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`SR expenses at issue . . . cannot be flowed through rates.” ID at P 4. The Presiding
`
`Judge further found that the SR costs should be excluded from rates for the separate and
`
`independent reason that the project is “not used and useful and does not provide any
`
`discernable benefits to shippers.” ID at P 1674; see also ID at P 1588.
`
`
`
`To be clear, Anadarko fully endorses these findings. Yet, notwithstanding the
`
`finding that all SR costs are imprudent and cannot be flowed through rates, the remedy
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`adopted by the Presiding Judge would allow $229.2 million of imprudent and
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`unreasonable SR costs to be included in rates through an amortization in the cost of
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`service. ID at P 1673. Specifically, the Presiding Judge adopted “Remedy 3” of five
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`possible remedies proposed by Anadarko. Id. Anadarko’s proposed Remedy 1 would
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`exclude from rates all SR capital costs and therefore is commensurate with the Presiding
`
`Judge’s findings of fact and law.4 Anadarko raises this limited exception in order to
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`preserve for the Commission and possibly a future reviewing court the opportunity to
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`consider the full array of remedies appropriate to establish just and reasonable rates.
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`III.
`
`STATEMENT OF THE CASE
`
`These consolidated proceedings concern rates for TAPS for 2009 and 2010 rate
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`periods, which were protested and set for hearing. The Chief Judge bifurcated the
`
`
`4
`
`Remedy 1 would exclude all capital costs of SR except for approximately $17
`million in Safety Integrity & Pressure Protection System (“SIPPS”) costs.
`
`
`
`2
`
`

`

`hearing into two phases:5 the SR phase, which the ID addressed, and the “Non-SR” phase
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`which involved pooling and rate of return issues and is currently on appeal at the D.C.
`
`Circuit.6 Given that the SR phase involved issues common to both interstate and
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`intrastate rates, FERC authorized concurrent hearings with the Regulatory Commission
`
`of Alaska.7
`
`The SR phase addressed a variety of TAPS rate issues, including the prudence and
`
`recoverability of SR costs, supplemental ad valorem taxes from prior periods, and other
`
`cost of service issues. The SR phase hearings spanned 48 days and produced an
`
`enormous record, including over 2000 exhibits and 12,294 transcript pages.8 The parties
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`submitted 1,817 pages of briefing to the Presiding Judge.9 Briefs on exceptions to the ID
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`are due May 16, 2014 and briefs opposing exceptions are due July 25, 2014.10 Further
`
`details concerning the SR phase procedural history may be found in the ID at PP 28-91.
`
`IV.
`
`POLICY CONSIDERATIONS WARRANTING FULL COMMISSION
`REVIEW AND OPINION
`
`
`
`The central policy consideration warranting Commission review is that of
`
`ensuring just and reasonable rates and protecting ratepayers from paying imprudent and
`
`unreasonable costs, as discussed in this brief.
`
`
`5
`
`BP Pipelines (Alaska) Inc., Order of Chief Judge Severing Strategic
`Reconfiguration Issues and Scheduling Prehearing Conferences, Docket Nos.
`IS09-348-000, et al. (Jan. 13, 2010).
`Tesoro Alaska Co. v. FERC, Case Nos. 13-1248 & 13-1249 (D.C. Cir. filed Sept.
`13, 2013).
`BP Pipelines (Alaska) Inc., 130 FERC ¶ 61,042 (2010).
`BP Pipelines (Alaska) Inc., Order of Chief Judge Extending Initial Decision
`Deadline, Docket Nos. IS09-348-004, et al., at P 1 (Oct. 30, 2013).
`Id.
`BP Pipelines (Alaska) Inc., Notice of Extension of Time, Docket Nos. IS09-348-
`004, et al. (Mar. 6, 2014).
`
`6
`
`7
`8
`
`9
`10
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`
`
`3
`
`

`

`V.
`
`ARGUMENT
`
`A.
`
`Anadarko’s Five Remedy Formulations.
`
`Anadarko proposed for the Presiding Judge’s consideration five possible remedies
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`in order of preference and appropriateness:
`
`Remedy 1:
`
`
`
`Remedy 2:
`
`
`
`
`Remedy 3:
`
`
`
`
`Remedy 4:
`
`
`
`Remedy 5:
`
`
`Exclude all SR capital costs from rates, except for SIPPS costs. ID at
`P 1424; Anadarko Initial Brief at 228-33.11
`
`Exclude all SR capital costs after initial project sanction and amortize in
`the cost of service SR capital costs in original sanction AFE S020. ID at
`PP 1425-26; Anadarko Initial Brief at 234-38.
`
`Exclude all SR capital costs beginning with AFE S020 Supplement 2 and
`amortize in the cost of service SR capital costs prior to AFE S020
`Supplement 2. ID at PP 1427-32; Anadarko Initial Brief at 238-44.
`
`Exclude all capital costs of SR electrification. ID at PP 1433-39;
`Anadarko Initial Brief at 244-51.
`
`Exclude SR Costs as supported in the State of Alaska’s case. ID at
`P 1440; Anadarko Initial Brief at 251-52.
`
`
`
`
`Notably, Anadarko’s Remedies 1-4 would fully exclude all SR capital costs from
`
`rate base, although Remedies 2-4 would permit the Carriers to amortize a portion of SR
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`costs in their cost-of-service.12 This is consistent with the Presiding Judge’s finding that
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`all SR costs are imprudent and that “it is unfair to require TAPS ratepayers to pay the
`
`Carriers additional return and taxes due to the inflated costs of a poorly planned and
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`managed project.” ID at P 1447.
`
`
`11
`
`Post Hearing Initial Brief of Anadarko Petroleum Corp. and Tesoro Alaska Co.
`Following Supplemental Prudence Hearing, Docket Nos. IS09-348-004, et al.
`(Nov. 30, 2012) (“Anadarko Initial Brief”).
`See ID at PP 1425 (Remedy 2), 1427 (Remedy 3), 1433 (Remedy 4); Anadarko
`Initial Brief at 234 (Remedy 2), 238 (Remedy 3), 244 (Remedy 4). All of these
`remedy options propose exclusions of SR capital costs. None attempt to identify
`exclusions of operation and maintenance expenses associated with SR.
`
`12
`
`
`
`4
`
`

`

`
`
`Anadarko proposed this “menu” of remedy options because, while Anadarko
`
`argued that the evidence clearly demonstrated that the SR project was imprudent and not
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`used and useful to ratepayers, it was impossible to know which remedy would suit the
`
`Presiding Judge’s factual and legal findings. Those findings are now clear.
`
`B.
`
`The Presiding Judge Found that All SR Costs Are Imprudent and
`Otherwise Unrecoverable in Rates.
`
`
`
`The Presiding Judge found that “the Carriers were imprudent in the development,
`
`design, implementation and management” of the SR project. ID at P 1451. Further, the
`
`Presiding Judge ruled that “the SR expenses at issue (which at the time of this decision is
`
`approximately $750 million) were imprudently incurred and cannot be flowed through
`
`rates.” ID at P 4. The Presiding Judge stated, “[s]ince the costs were imprudent, the
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`recovery of these costs should not be allowed.” ID at P 1458. Additionally, the
`
`Presiding Judge found that SR costs should be excluded from rates for the separate and
`
`independent reason that the project is “not used and useful and does not provide any
`
`discernible benefits to shippers.” ID at P 1674; see also P 1588. In sum, the Presiding
`
`Judge concluded that the costs of SR “should be borne by shareholders and not
`
`ratepayers.” ID at P 1455.
`
`C.
`
`The Presiding Judge’s Selection of Remedy 3 Would Allow $229.2
`Million of Imprudent and Unreasonable SR Costs to be Recovered in
`the Cost of Service.
`
`More than 500 pages of the ID address the Judge’s findings that all SR costs are
`
`imprudent and otherwise not suitable for recovery in rates. Yet, the Presiding Judge
`
`allows the Carriers to recover $229.2 million as a “remedy in equity” because “there are
`
`new assets in the ground [thus] it seems reasonable to let the Carriers recover some of the
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`costs.” ID at P 1459.
`
`
`
`5
`
`

`

`Specifically, the Presiding Judge adopted Anadarko’s Remedy 3, ID at PP 4,
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`1458, 1673, which allows the Carriers to amortize $229.2 million of SR capital costs in
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`their cost of service, outside of rate base and with no return, over the remaining life of
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`TAPS. ID at P 1427. The $229.2 million allowed under Remedy 3 is the cost level
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`included in the Carriers’ original corporate authorization that sanctioned the SR project,
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`i.e. AFE S020,13 plus amount authorized by Supplement 1 to AFE S020.14 As proposed
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`by Anadarko and adopted by the Presiding Judge, the $229.2 million serves as an
`
`absolute cap on SR recovery for both historic rate periods and future rate periods. ID at
`
`P 1458. Remedy 3 excludes $225.2 million in SR capital costs for 2009 and 2010 rate
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`periods. ID at PP 1427, 1458.
`
`In explaining why SR cost recovery should be cut off beginning with
`
`Supplement 2,15 the Presiding Judge found that “SR was a discretionary project with the
`
`purpose of reducing costs.” ID at P 1453. Yet, by the time the Carriers were considering
`
`whether to authorize Supplement 2, the Presiding Judge found that they knew that “SR
`
`was off track, original cost estimates were wrong, the scope was not defined, contractors
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`were not performing, and the economics were not favorable.” ID at P 1444. “When
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`Exxon evaluated the project economics at Supplement 2 it . . . determined that SR had a
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`negative net present value. At this point in time they should have stopped and analyzed
`
`
`13
`
`AFE S020 authorized $216.3 million in capital costs. This amount consisted of
`$206.3 million in new funding plus $10 million in capital previously approved.
`Ex. SOA-60 at 2 (Cost Summary); see ID at P 1425.
`Supplement 1 to AFE S020 authorized an additional $16.9 million of additional
`funding for self-generation of power at Pump Station 1. Ex. SOA-65 at 6 (Cost
`Summary).
`See generally ID at PP 1427-1432, 1458; Anadarko Initial Brief at 238-44.
`
`14
`
`15
`
`
`
`6
`
`

`

`the economics of the project and they did not.” ID at P 1452 (citation omitted). The
`
`Presiding Judge concluded:
`
`At supplement 2 the Carriers knew the project was a “train wreck.” Costs
`had nearly doubled, the schedule could not be accomplished, contractors
`were underperforming, the owners were failing to make timely decisions,
`engineering delays, design issues, revision of drawings, unproven pump
`motors, the scope of the project was not well defined (the project scope
`was not fully established until well into detailed design) significant
`brownfield work, inadequate cost accounting. The Carriers knew the
`original cost estimates were wrong. The benefits were eroded once the
`schedule had changed.
`
`ID at P 1458.
`
`
`
`The Presiding Judge further found “[o]wner misalignment and upstream interests
`
`were elements of imprudence at sanction, at approval of supplement 2,” in particular
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`“BPPA’s concern for its affiliate booking of additional reserves [which] led it to push for
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`additional funding for SR.” ID at P 1115, see ID at PP 1063, 1067, 1070, 1111, 1169. At
`
`the same time BP executives had determined that SR was a “train wreck” and a
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`“performance bust,” ID at PP 1036, 1455, “they were advocating that the project continue
`
`because BPXA, the production affiliate, had booked 63 million barrels of oil based on the
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`SR project.” ID at P 1455; see also ID at P 1067.
`
`
`
`Anadarko certainly understands the Presiding Judge’s rationale for adopting
`
`Remedy 3, which was one of Anadarko’s proposals. However, Anadarko made multiple
`
`remedy proposals because it was not certain what factual and legal findings the Presiding
`
`Judge would make. Now, in light of the ID, it cannot be ignored that Remedy 3 allows
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`the Carriers to recover from ratepayers $229.2 million of SR capital costs that the
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`Presiding Judge found to be imprudent and otherwise not suitable for recovery in rates.
`
`See supra Section V.B.
`
`
`
`7
`
`

`

`D.
`
`Remedy 1 Is Commensurate with the Presiding Judge’s Findings
`Regarding the SR Project.
`
`
`
`Anadarko’s proposed Remedy 1 would exclude from TAPS rates all capital costs
`
`of the SR project, except SIPPS costs. ID at P 1424; Anadarko Initial Brief at 228-33.
`
`Remedy 1 comports with the breadth of the Presiding Judge’s findings that “the Carriers
`
`were imprudent in the development, design, implementation and management” of the SR
`
`project, ID at P 1451, and that the project is “not used and useful and does not provide
`
`any discernible benefits to shippers.” ID at P 1674; see also id. at P 1588. Remedy 1
`
`would ensure that ratepayers do not pay costs found to be imprudent and unreasonable
`
`and properly places responsibility for the project on the pipeline owners – who were in
`
`full control of the project.16
`
`E.
`
`Anadarko’s Other Remedy Proposals.
`
`The Presiding Judge commented favorably on all of Anadarko’s remedy
`
`proposals, stating “Anadarko’s remedies are consistent with the evidence in this case and
`
`case law.” ID at P 1443. As discussed above, while the Presiding Judge selected
`
`Remedy 3, Remedy 1 is commensurate with the Presiding Judge’s factual and legal
`
`findings. Given that the ID is subject to review, Anadarko also raises on exceptions its
`
`16
`
`The Presiding Judge viewed it as equitable to permit some recovery of capital
`costs by the Carriers because there are “new assets in the ground.” ID at P 1459.
`However,
`these new assets
`resulted
`from
`imprudent planning and
`mismanagement. ID at PP 1456-59. Indeed, the Presiding Judge found that the
`new turbines are not appropriately sized, ID at P 1521, and should not have been
`electrified. ID at PP 348, 425, 1451. Moreover, concerning the automated
`control system, the Presiding Judge found that “the Carriers automated in an
`imprudent manner . . . and then what was developed is substandard.” ID at
`P 1460; see ID at PP 1552, 1557-62. Thus, from the ratepayers’ perspective,
`simply because the assets are in the ground does not support increased rates for
`equipment that was imprudently constructed, improperly sized, and otherwise not
`beneficial to shippers. Indeed, the ratepayers already paid for the existing
`equipment, which, as the ID found, remained adequate to the task. ID at PP 1451,
`1456.
`
`
`
`8
`
`

`

`additional remedy proposals for the purpose of preserving these remedy options for the
`
`Commission and possibly a reviewing court.
`
`Remedy 2 (Exclude all costs after initial project sanction)
`
`Anadarko’s proposed Remedy 2 would exclude from rates all SR capital costs
`
`above the initial sanction amount of $216.3 million set forth in AFE S020. The $216.3
`
`million would be amortized in the cost of service over the remaining useful life of TAPS,
`
`but would not be allowed rate base treatment and therefore would earn no return. The
`
`$216.3 million would serve as an absolute cap on SR capital cost recovery. Thus, for
`
`2009 and 2010 rates, $238.1 million of SR capital costs would be excluded, and no
`
`further SR capital cost recovery would be permitted in future TAPS rates. ID at P 1425;
`
`Anadarko Initial Brief at 234-38. As the Presiding Judge explained, “this proposal would
`
`charitably give the Carriers the costs of the project they believed would be used and
`
`useful, while protecting the ratepayers from the increased costs of the poorly executed SR
`
`project.” ID at P 1426.
`
`Though she did not select it, the Presiding Judge commented that Remedy 2
`
`“gives the Carriers the benefit of the doubt on their initial sanction decision even though
`
`the evidence in this case supports the finding that at that point in time the economics of
`
`SR were indeed dubious. [Remedy 2] is a ceiling on ratepayer benefits and utility of the
`
`project.” ID at P 1443. Additionally, Remedy 2 is very similar to, and is the foundation
`
`for, Remedy 3, which the Presiding Judge adopted. Those remedies are identical, except
`
`that Remedy 2 would exclude the cost of Supplement 1 ($16.9 million), which is included
`
`under Remedy 3.
`
`
`
`9
`
`

`

`Remedy 4 (Exclude electrification costs)
`
`Anadarko’s Remedy 4 would exclude from rates the capital costs associated with
`
`the electrification of the pump stations. For 2009 and 2010 rates, $397.1 million would
`
`be excluded from TAPS rates, and $57.3 million would be amortized in the cost of
`
`service, outside of rate base, over the remaining useful life of TAPS. ID at P 1433; see
`
`Anadarko Initial Brief at 244-45. Anadarko witness Gary Grasso developed this remedy
`
`calculation based on actual capital cost data in the record, at the request of the Presiding
`
`Judge. Anadarko Initial Brief at 244-45. Again, while the Presiding Judge selected a
`
`different remedy, she favorably commented that “Anadarko’s fourth disallowance theory
`
`under use[d] and useful would be equitable.” ID at P 1674.
`
`Remedy 5 (State’s remedy)
`
`
`
`In addition to proposing the four remedy formulations discussed above, Anadarko
`
`also supported the State’s proposed remedy as a fifth option. Anadarko understands that
`
`the State will discuss its remedy option in its brief on exceptions.
`
`VI. CONCLUSION
`
`
`
`Wherefore, for the foregoing reasons, Anadarko respectfully requests that the
`
`Commission promptly affirm the ID, subject to Anadarko’s limited exception discussed
`
`above.
`
`
`
`10
`
`

`

`By /s/ Robin O. Brena
`Robin O. Brena
`David W. Wensel, Esq.
`Anthony S. Guerriero, Esq.
`BRENA, BELL & CLARKSON, P.C.
`810 N Street, Suite 100
`Anchorage, Alaska 99501-2014
`Telephone: (907) 258-2000
`Facsimile: (907) 258-2001
`rbrena@brenalaw.com
`dwensel@brenalaw.com
`aguerriero@brenalaw.com
`
`By /s/ Joseph S. Koury
`Joseph S. Koury, Esq.
`Jeffrey G. DiSciullo, Esq.
`Andrew T. Swers, Esq.
`WRIGHT & TALISMAN, P.C.
`1200 G Street, N.W.
`Washington, D.C. 20005-3802
`Telephone: (202) 393-1200
`Facsimile: (202) 393-1240
`koury@wrightlaw.com
`disciullo@wrightlaw.com
`swers@wrightlaw.com
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`Sherri B. Manuel, Counsel
`Anadarko Petroleum Corporation
`1201 Lake Robbins Drive
`The Woodlands, Texas 77380
`Telephone: (832) 636-1000
`Facsimile: (832) 636-8001
`sherri.manuel@anadarko.com
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`Attorneys for
`Anadarko Petroleum Corporation
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`May 16, 2014
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`11
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`CERTIFICATE OF SERVICE
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`I hereby certify that I have this day served the foregoing document upon each
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`person designated on the official service list in accordance with the protective order
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`issued in this proceeding.
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`Dated at Washington, D.C., this 16th day of May, 2014.
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` /s/ Andrew T. Swers
`Andrew T. Swers
`Wright & Talisman, P.C.
`1200 G Street, N.W., Suite 600
`Washington, D.C. 20005-3802
`(202) 393-1200
`
`Attorney for
`Anadarko Petroleum Corporation
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