Lamar County Expansion Project DOCKET NO. CP19-___-000

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Lamar County Expansion Project

DOCKET NO. CP19-___-000

Application

Exhibit F – Location of Facilities Exhibit J – Federal Authorizations Exhibit K – Cost of Facilities Exhibit N – Revenues - Expenses – Income Exhibit P – Tariff

Volume I

Public Information

September 2019

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

) Gulf South Pipeline Company, LP ) CP19-___-000 )

ABBREVIATED APPLICATION OF GULF SOUTH PIPELINE COMPANY, LP FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY AND RELATED AUTHORIZATIONS

Pursuant to Sections 7(c) and 7(e) of the Natural Gas Act (“NGA”), 15 U.S.C. § 717f(c),

§ 717f(e), and Part 157, of the regulations of the Federal Energy Regulatory Commission

(“Commission” or “FERC”), 18 C.F.R. Part 157, Gulf South Pipeline Company, LP (“Gulf

South”) submits this abbreviated application for a certificate of public convenience and necessity

(“Application”) seeking authority for Gulf South to construct, operate, and maintain (i) an approximately 3.4 mile 20-inch diameter natural gas delivery lateral, including appurtenant, auxiliary facilities, (ii) a new delivery meter station, and (iii) a new mainline compressor station with approximately 5,000 horsepower (“HP”) (referred to herein as the “Black Creek

Compressor Station”) and other associated auxiliary appurtenant buildings and facilities, all located in Lamar and Forrest counties, Mississippi, (“Lamar County Expansion Project” or

“Project”). Gulf South also requests as part of its Application that the Commission approve the refunctionalization of its existing Hattiesburg 20-inch pipeline from storage to transmission in order to provide supplemental transportation service.

The proposed Lamar County Expansion Project will allow Gulf South to provide up to

200,000 dekatherm per day (“Dth/d”) of new firm transportation service to Cooperative Energy

(“Cooperative”) primarily to serve Cooperative’s proposed new 550 megawatt combined cycle gas turbine generation facility (the “Morrow Repower Project” or “Morrow Power Station”) to

be located at Cooperative’s existing Morrow coal-fired power plant site (“Plant Morrow”) in

Lamar County, near Purvis, Mississippi. Cooperative’s Morrow Repower Project will utilize high-efficiency combined cycle gas turbines to replace older coal-fired units as well as new emissions control technology that will further lower emissions. The Lamar County Expansion

Project will also allow for transportation services to Cooperative’s existing Moselle Power Plant and Benndale Power Plant.

Subject to receiving all required authorizations and approvals, Gulf South proposes to begin construction of the Project in the fourth quarter of 2020 and place the Project in-service

January 1, 2022. Gulf South requests that the Commission complete its review of the

Application and grant the requested authorizations in this Application on or before September

17, 2020. Receipt of an order by September 17, 2020, will allow Gulf South to meet the in- service requirements of Cooperative, the customer supporting the Project. Gulf South’s commitment to meet the January 1, 2022 in-service date is a critical component of its transportation agreement with Cooperative. Gulf South will devote the resources necessary to respond promptly to any requests for additional data or information in order to assist the

Commission in its review of this Application. In support of this abbreviated Application, Gulf

South submits the following:

I. APPLICANT

The exact name of Gulf South is Gulf South Pipeline Company, LP, and its principal place of business is 9 Greenway Plaza, Suite 2800, Houston, Texas 77046. Gulf South is a limited partnership organized and existing under the laws of the state of Delaware and is duly authorized to do business in the states of Texas, Louisiana, Mississippi, Alabama, and Florida.

Gulf South is a natural gas company within the meaning of the NGA. It currently owns and operates approximately 7,200 miles of pipeline facilities extending from south and east

Texas through Louisiana, Mississippi, southern Alabama, and western Florida. Gulf South has numerous interconnects with other interstate and intrastate pipelines and storage facilities, which allow it to serve various on-system and off-system markets. Gulf South is an open-access pipeline company that provides transportation and storage services pursuant to Part 284 of the

Commission’s regulations.

The names, titles, and mailing addresses of the persons to whom communications and correspondence regarding this filing should be addressed are:

Michael E. McMahon A. Gregory Junge Senior Vice President and General Counsel Hogan Lovells US LLP J. Kyle Stephens Columbia Square Vice President, Regulatory Affairs 555 Thirteenth Street, NW Juan Eligio Jr. Washington, D. C. 20004 Supervisor, Regulatory Affairs Phone: (202) 637-6642 Payton Barrientos Fax: (202) 637-5910 Senior Regulatory Analyst [email protected] Gulf South Pipeline Company, LP 9 Greenway Plaza, Suite 2800 Houston, Texas 77046 Phone: (713) 479-3480 Fax: (713) 479-1818 [email protected] [email protected] [email protected] [email protected]

Each of these persons is designated to receive service in accordance with 18 C.F.R.

§ 385.203(b)(3). Gulf South requests the Commission to place these persons on the official service list for this proceeding pursuant to 18 C.F.R. § 385.2010. Gulf South requests that the

Commission waive Rule 203(b)(3) to allow designated service to each of these persons.

II. OPEN SEASON & PRECEDENT AGREEMENT

Open Season

In accordance with Section 6.20[7] of the General Terms and Conditions (“GT&C”),

Gulf South reserved the available capacity pursuant to a notice dated February 1, 2019. Gulf

South proceeded with the Open Season prior to executing any binding commitments, with a target to have the Lamar County Expansion Project ready for service as early as January 1, 2022.

In accordance with Section 6.24 of the GT&C of its FERC Gas Tariff, Gulf South conducted the binding Open Season from Monday, May 20, 2019 through Friday, May 24, 2019 for the Lamar

County Expansion Project, which included the following:

 200,000 Dth/d of capacity with primary receipts in the Perryville, Louisiana area and Petal, Mississippi area, and primary deliveries in the McComb/Baxterville/Petal area (Available Capacity); and  200,000 Dth/d of capacity from facilities which includes a new pipeline lateral extending from Gulf South’s Index 299, compression located on Index 299 and new delivery meter.

Cooperative was the only shipper to submit a conforming binding bid and requested both new and existing transportation capacity to serve its new Morrow Power Station as well as its existing Moselle Power Plant and Benndale Power Plant. Gulf South and Cooperative entered into a precedent agreement (“Precedent Agreement”) for this Project.

Precedent Agreement

If the Lamar County Expansion Project is approved by the Commission, Cooperative will execute two conforming service agreements, one under Rate Schedule Firm Transportation

Service (“FTS”) for 200,000 Dth/d and the other under Rate Schedule Firm Lateral Service

(“FLS”) for 200,000 Dth/d, as described in more detail below.

1. FTS Service Agreement

The FTS Service Agreement will have a term of twenty (20) years and will be placed in- service on January 1, 2022. The contract will provide Cooperative with access to various eligible primary receipt points as well as existing supplemental receipt points on Gulf South’s existing Legacy System for a discounted rate. The Precedent Agreement states Gulf South will provide the proposed service under its Rate Schedule FTS to allow Cooperative to transport natural gas supplies from the Perryville Transportation Point and the Petal Storage Complex, for delivery primarily to the interconnect between the proposed new delivery lateral and the Legacy

System located in the station yard of the proposed Black Creek Compressor Station in addition to

Cooperative’s existing Moselle Power Plant and Benndale Power Plant. Transportation will be provided by means of an executed, conforming FTS service agreement and in accordance with

Gulf South’s existing Rate Schedule FTS, and FERC Gas Tariff. No new tariff provisions are required to facilitate the FTS service on the Project.

2. FLS Service Agreement

The FLS Service Agreement will have a term of twenty (20) years and will be placed in- service on January 1, 2022. The Precedent Agreement states Gulf South will provide the proposed service under its Rate Schedule FLS at a discounted rate and Cooperative will transport a maximum of 200,000 Dth/d of natural gas supplies from the interconnect between the proposed new delivery lateral and the Legacy System located in the station yard of the proposed Black

Creek Compressor Station for delivery to the Morrow Power Station. Transportation will be provided by means of an executed, conforming FLS service agreement and in accordance with

Gulf South’s proposed Rate Schedule FLS and FERC Gas Tariff.

On September 3, 2019, in Docket RP19-1539-000, Gulf South filed with the Commission to add new Rate Schedules FLS and Interruptible Lateral Service (“ILS”) to its Tariff. Service under Rate Schedules FLS and ILS would provide additional flexibility on the Gulf South system and is intended to be utilized to provide transportation service on new laterals built for the benefit of one or a limited number of customers. Gulf South requested that the Commission approve the proposed FLS and ILS rate schedules to be effective October 4, 2019. The comment period expired on September 16, 2019. Gulf South received comments and a request for additional information from BP Energy Company, ExxonMobil Upstream Oil & Gas Company, a division of ExxonMobil Corporation, and Chevron Natural Gas, a division of Chevron U.S.A.

(collectively, “Indicated Shippers”). On September 20, 2019, Gulf South filed an Answer to the comments filed by the Indicated Shippers that addressed the comments and provided the requested clarifications. Gulf South is awaiting a Commission order on proposed Rate Schedule

FLS and ILS, which Gulf South requested to become effective October 4, 2019.

The Precedent Agreement between Cooperative and Gulf South is included in Exhibit I,

Volume II, of this Application and is filed with a request for Privileged Treatment under 18

C.F.R. § 388.112 (2019) and marked “CUI//PRIV” and “Contains Privileged Information –

Do Not Release”.

III. AUTHORIZATION REQUESTED AND DESCRIPTION OF FACILITIES

Proposed Facilities

The Lamar County Expansion Project will consist of both (i) a new delivery lateral pipeline (“Lamar County Lateral”), delivery meter station, and associated auxiliary, appurtenant facilities (“Lamar County Lateral Facilities”), and (ii) the construction of a new mainline

compressor station and other associated auxiliary appurtenant buildings and facilities on existing

Index 299, part of Gulf South’s Legacy System (“Legacy System Facilities”). The primary purpose of the proposed Project is to expand the Legacy System to provide 200,000 Dth/d of firm natural gas transportation service to Cooperative’s Morrow Power Station, Moselle Power

Plant, and Benndale Power Plant. A detailed Project location map is provided in Exhibit F,

Volume I, and a detailed description of the proposed facilities to be constructed is provided in the attached Environmental Resource Report included in Exhibit F-I, Volume I-A.

1. Lamar County Lateral Facilities

The Lamar County Lateral Facilities consist of (i) an approximately 3.4 mile 20-inch diameter natural gas delivery lateral, and (ii) a new delivery meter station, to be sited at the

Morrow Power Station, and associated auxiliary, appurtenant facilities located in Lamar County,

Mississippi. The 20-inch delivery lateral will extend from an interconnect with existing Index

299 in the station yard of the proposed Black Creek Compressor Station, and extend to

Cooperative’s Morrow Power Station site. The delivery meter station located on Cooperative’s property at the Morrow Power Station site will be the custody transfer point for measurement between Gulf South and Cooperative. The total cost for the Lamar County Lateral Facilities is approximately $17.6 million, as detailed in the attached Exhibit K.

2. Legacy System Facilities

The Lamar County Expansion Project will also require the construction of the new Black

Creek Compressor Station located in Forrest County, Mississippi on Index 299 at approximate

Station No. 128+08. The station will consist of two gas-fired compressor units1 capable of providing approximately 5,000 HP, as well as associated auxiliary buildings and facilities. The proposed Black Creek Compressor Station will be constructed off Gulf South’s Index 299

1 Each respective compressor engine unit having a total of 2,500 HP.

mainline to increase operating pressure and allow for bi-directional operation of Index 299 between the Baxterville Junction and the Petal Storage Complex but also increase reliability and operational flexibility in the central Mississippi area.

The Black Creek Compressor Station is designed with two identical reciprocating compressor engines to ensure reliable delivery to the new Lamar County Lateral. During normal operations, the Black Creek Compressor Station will operate with both compressor engines running at a reduced load. However both units are required to deliver the full contracted quantities to the Lamar County Lateral at the desired delivery pressure.

The total cost for the Legacy System Facilities is approximately $36.8 million, as detailed in the attached Exhibit K.

Flow Diagrams

Gulf South has traditionally operated its Index 299 on a south-to-north flow basis. The

Legacy System facilities will allow Gulf South to expand the Legacy System, provide bi- directional service on Index 299, and increase reliability and operational flexibility in the central

Mississippi area. To provide the transportation service contemplated by the FTS Service

Agreement, Gulf South will transport 120,000 Dth per day from the Perryville Transportation

Point and 80,000 Dth per day from the Petal Storage Complex, utilize reserved and existing capacity from receipt points to Index 299, and the proposed Black Creek Compressor Station will allow Gulf South to bring these additional volumes onto Index 299 in a bi-directional manner in order to facilitate deliveries to the proposed Lamar County Lateral. The flow diagrams and data demonstrate daily design and the maximum capability of the Project facilities.

The flow diagrams and data also illustrate that the Project facilities maximum design flow will result in 16,200 Dth/d of unsubscribed capacity from south-to-north on Gulf South’s

mainline Index 299 from the Baxterville Junction to the Petal Storage Complex. The unsubscribed capacity will be sold in accordance with Gulf South’s FERC Gas Tariff. The flow diagram and data that demonstrate the effect of the proposed facilities on the existing operational capabilities and conditions during maximum design are included in Exhibit G, page 4 of 4,

Volume III – CEII.

Exhibits G, G-1, and G-II are provided in Volume III, of this Application and filed under a request for treatment as Critical Energy Infrastructure Information under 18 C.F.R. §388.112

(2019) and are marked “CUI/CEII” and “Contains Critical Energy Infrastructure

Information - Do Not Release”.

The Project proposed herein will be constructed in compliance with all applicable rules and regulations, and operated in accordance with the applicable federal pipeline safety regulations of the U.S. Department of Transportation.

IV. REFUNCTIONALIZATION OF UNUTILIZED STORAGE PIPELINE

In order to increase transportation reliability in the area, Gulf South also requests as part of its Application that the Commission approve the refunctionalization, from storage to transmission, of the Hattiesburg 20-inch pipeline, currently part of Gulf South’s Petal Storage

Complex and designated as a storage facility. The Hattiesburg 20-inch pipeline has not been utilized to provide storage services for the past five years and refunctionalizing it will provide additional reliability and operational flexibility on Gulf South’s transmission system.

The Hattiesburg 20-inch pipeline is currently connected to Index MS100-001 on the east and the Petal Storage Complex on the west. It also interconnects with Index 299. In the past, the

Hattiesburg 20-inch pipeline provided redundant access from Index 299 to the Petal Storage

Complex. Due to changing service obligations and pressures this pipeline has not been used in

approximately five years. Refunctionalizing it to transportation will allow Gulf South to increase transportation access from the Expansion Facilities (through Index MS100-001) in north central

Mississippi to Index 299. Cooperative has requested several supplemental receipt points which it could utilize access to the Expansion Facilities.

If this refunctionalization request is approved, Gulf South will close Valve 285023, which will isolate the Hattiesburg 20-inch pipeline from the Petal Storage Complex and allow transportation service from Gulf South’s existing Expansion Facilities down Index MS100-001

(the Petal 36-inch transmission line) over to the Index 299. This will provide Cooperative additional or supplemental access to supplies from Gulf South’s existing Expansion Facilities.

The Hattiesburg 20-inch pipeline is shown as refunctionalized in the proposed Exhibit G and G-I diagrams, Pages 3 of 4 and 4 of 4, provided in Volume III. At this time the pipeline does not contribute to firm transportation quantities and Exhibits G and G-I illustrate that the refunctionalization of the Hattiesburg 20-inch pipeline will not affect the Petal Storage Complex deliverability. Since there will be no ground disturbing activities to perform the refunctionalization of the Hattiesburg 20-inch pipeline, no environmental impacts will result from the refunctionalization of the pipeline and Gulf South has not included details in its environmental report.

V. RATE TREATMENT

The Lamar County Expansion Project is fully supported under Cooperative’s Precedent

Agreement. Prior to the Project being constructed, Cooperative will execute the firm transportation (FTS and FLS) and associated discounted rate agreements with a primary term of

twenty (20) years.2 Gulf South will offer any unsubscribed or available capacity created by the

Project facilities to all customers in accordance with its FERC Gas Tariff. Gulf South requests authority to (i) establish initial rates under Rate Schedules FLS and ILS for the new Lamar

County Lateral Facilities, as reflected in the pro forma tariff records included as Exhibit P, (ii) charge its existing system-wide rates as the recourse rates for the mainline facilities to be constructed on the Legacy System Facilities, and (iii) maintain a predetermination that it may roll the Legacy System Facilities costs into its Commission-approved system-wide rates in a future rate proceeding.

Lamar County Lateral Service

Prior to the Project being placed in-service, Cooperative will execute two firm transportation and discounted rate agreements having a primary term of twenty (20) years, one under Rate Schedule FTS and the other under Rate Schedule FLS. Firm transportation service under Rate Schedule FLS will provide primary transportation rights on the new Lamar County

Lateral Facilities, which is described in more detail below.

The FLS and ILS recourse rates for service on the Lamar County Lateral Facilities will be based solely on the specific lateral facilities costs, and only the customers using the Lamar

County Lateral Facilities will pay rates to recover the costs of service on those facilities. The

Lamar County Lateral Facilities will provide deliveries solely to the Morrow Power Station, and the new delivery meter, to be sited at the Morrow Power Station, will be the only delivery point located on the lateral. Cooperative will be the sole primary firm shipper on the lateral with an

FLS contract for all of the capacity of the lateral. Exhibit N – Lamar County Lateral Facilities, included herein, sets forth the derivation of the daily incremental recourse rates for the Lamar

2 See Exhibit I. The transportation and discounted rate agreements will be executed prior to the in-service date of the Lamar County Expansion Project. These discounted rate agreements will not contain provisions that materially deviate from Gulf South’s filed tariff.

County Lateral Facilities. The FLS and ILS recourse rates for the Lamar County Lateral

Facilities are based on the billing determinants associated with the firm transportation contract quantities for Cooperative’s new FLS contract on the Lamar County Lateral Facilities and the cost of service associated only with the Lamar County Lateral Facilities. The proposed FLS recourse demand rate for the lateral will be $0.0404 per Dth/d based on billing determinants of

200,000 Dth/d. The initial rates are reflected on the pro forma tariff records included in Exhibit

P.3 Upon approval by the Commission of the lateral rates, Gulf South will file these tariff records as part of its FERC Gas Tariff no less than 30 days prior to the in-service date of the

Lamar County Lateral Facilities. Consistent with the Commission’s policy on incremental rates,

Gulf South will maintain a separate record of capital costs for only the Lamar County Lateral

Facilities in its books and accounts. To the extent a customer utilizes only the Lamar County

Lateral Facilities, the customer will only be charged the FLS or ILS recourse rate associated with the Lamar County Lateral Facilities. If such customer utilizes both the Legacy System and the

Lamar County Lateral Facilities under one, secondary or supplemental transaction, the customer will be charged both the applicable Legacy System rate(s) and the Lamar County Lateral

Facilities lateral rate. The Project will have no impact on rates currently charged to Gulf South’s existing customers who do not utilize the Lamar County Lateral Facilities. To the extent a Rate

Schedule FLS or ILS customer utilizes the Legacy System on a secondary or supplemental basis,

Gulf South’s existing system fuel charges will be assessed for that transaction.

3 As illustrated in Exhibit N – Lamar County Lateral Facilities, Gulf South has elected to credit its cost of service for presumed interruptible revenues under Rate Schedule ILS and charge the 100% load factor Rate Schedule FLS rate for ILS service. Consistent with Commission policy this is done in lieu of allocating costs and volumes to interruptible services as part of rate design. See Transcon. Gas Pipe Line Co., 130 FERC ¶ 61,019 (2010) and Maritimes and Northeast Pipeline L.L.C., 80 FERC ¶ 61.136 (1997).

Legacy System Facilities Service

The Commission should grant Gulf South’s proposal to utilize its existing system-wide

Rate Schedule FTS rates as the recourse rates for firm transportation service on the Legacy

System Facilities. Exhibit N – Legacy System Facilities, which utilizes its last-stated capitalization (including capital structure and returns on equity and debt) from Docket No. RP97-

373-000 consistent with the Commission’s recent direction to pipelines to utilize their last stated capitalization components in the development of rates for certificate projects.4 As shown in the attached Exhibit N – Legacy System Facilities, the incremental cost-based transportation rates for the Legacy Facilities calculated on a stand-alone basis would be less than Gulf South’s existing approved maximum transportation rate for Rate Schedule FTS. The current maximum daily FTS reservation charge is $0.3380 per Dth. The calculated stand-alone daily FTS reservation charge for the proposed expansion facilities is $0.0844 per Dth. Because Gulf

South’s existing system-wide rates will fully recover the costs of the Legacy System Facilities, including the costs of the proposed Black Creek Compressor Station, existing customers will not subsidize any of the costs.

The Project is fully supported by Cooperative’s Precedent Agreement. The FTS service agreement will contain a discounted rate and is also subject to applicable surcharges and fuel retention percentages reflected in Gulf South’s FERC Gas Tariff. The FTS and FLS Agreements reflected in the Precedent Agreement are included in Exhibit I, Volume II of this Application,

4 On February 1, 2019, the Commission denied Gulf South’s request for rehearing of the Commission’s determination that Gulf South must use its last-approved capital structure and cost of capital when computing the rate of return to be used in designing the rates of the Westlake Expansion Project (CP17-476-000). Gulf South Pipeline Company, LP, 166 FERC ¶ 61,089 (2019). Gulf South filed a petition for review of the Commission’s determinations regarding the initial rates for the Westlake Expansion Project, including the requirement that Gulf South use its last-approved capitalization components, and Gulf South South’s petition remains pending before the D.C. Circuit. See Gulf South Pipeline Company, LP, Petition for Review, No. 19-1074 (D.C. Cir. filed Apr. 2, 2019). By proposing to utilize Gulf South’s last-approved capitalization components in this proceeding, Gulf South is not waiving its right to continue to pursue its petition for review of the Commission’s rate determinations regarding the Westlake Expansion Project or to propose alternative capitalization components in future proceedings.

and filed under a request for Privileged Treatment as part of this Application and marked

“CUI//PRIV” and “Contains Privileged Information – Do Not Release”.

Request for Predetermination of Rolled-in Rate Treatment

The Legacy System Facilities qualify for a pre-determination of rolled-in rate treatment.

Under Commission precedent and policy, a predetermination of rolled-in rate treatment for a proposed project’s costs is generally appropriate when the revenues to be generated by a project’s services exceed the costs of the project.5 In calculating these revenues, the Commission compares the cost of a project to the revenues that would be generated using actual contract volumes and either the maximum recourse rate or the actual negotiated rate, whichever is lower.6

The incremental cost-based transportation rates calculated on a stand-alone basis for the Legacy

System Facilities would be less than Gulf South’s existing approved maximum transportation rate for Rate Schedule FTS. As outlined in Exhibit N – Legacy System Facilities, the revenues of the Rate Schedule FTS contract associated with the Legacy System Facilities exceed the calculated cost of service. A predetermination of rolled-in rate treatment will lower rates for all of Gulf South’s Rate Schedule FTS customers across the system in a future rate proceeding since

Gulf South’s system-wide rates will be reduced as a result of rolling-in the costs of the Legacy

System Facilities into the currently approved system-wide rates. The proposed Legacy System

Facilities are physically integrated with the Gulf South Legacy System. Rolling the costs of the

Legacy System Facilities into the system-wide rates will not adversely affect any customer.

Gulf South proposes to use its existing system-wide fuel rate for service on the Legacy

Facilities and requests a predetermination for rolled-in rate treatment for fuel and lost and unaccounted for gas. Based on operational expectations, Gulf South has compared the projected

5 See, e.g., Gulf South Pipeline Co., LP, 155 FERC ¶ 61,287, at P 28 (2016) and Gulf South Pipeline Co., LP, 161, FERC ¶ 61,032, at P 19 (2017). 6 Id.

fuel rate for the Legacy System Facilities against the most recent fuel rate for Gulf South’s

Legacy System that was filed in Gulf South’s Fuel Tracker and approved in Docket No. RP19-

224-000. As demonstrated in the table below, Gulf South projects that the Legacy System

Facilities will have the effect of reducing the general system fuel rate to the benefit of all system shippers.

Compared Projected Fuel Rate Against Fuel Rate For Gulf South Legacy System Projected Fuel Add: Gulf South System Fuel Consumption Retention Legacy & Throughput RP19-224 Percentage System Adjusted (in Dth) Schedule B (PFRP) Facilities PFRP Total In-Kind System Fuel, Company-Used Gas and Gas Equivalent Quantities Line 7 15,261,119 650,430 15,911,549 Throughput Eligible for Fuel and Company- Used Gas Line 8 1,069,561,060 62,196,000 1,131,757,060 Total System Fuel and Company-Used Gas Line 9 1.43% 1.05% 1.41%

To calculate fuel, Gulf South utilized Throughput and Fuel data from page 4 of 4 of the Exhibit G provided in Volume III.

The Commission should authorize Gulf South to utilize its existing system transportation and fuel rates for the Legacy System Facilities and make a predetermination that Gulf South may roll the costs of the Legacy System Facilities into Gulf South’s system-wide rates in a future rate proceeding.

VI. ENVIRONMENTAL MATTERS

Environmental Impacts

Gulf South has designed the Project to minimize any adverse environmental impacts, as further detailed in the Environmental Report, attached as Exhibit F-I, Volume I-A. The proposed construction will incorporate proven construction techniques and mitigation procedures and will result in no significant impact to the quality of human health, the environment, or affected

landowners. Gulf South has designed the proposed facilities to avoid or minimize adverse impacts on landowners and sensitive resources, such as streams, wetlands, forests, threatened or endangered species, or any cultural resources, to the extent possible. As a method to avoid or minimize impacts, Gulf South will utilize horizontal directional drillings (“HDD”) under waterbody crossings that may contain threatened or endangered species and will avoid areas in which constructability by conventional means is not feasible.

Utilizing construction and restoration methods that comply with the Commission’s May

2013 Upland Erosion Control Revegetation and Maintenance Plan (“Plan”), Wetland and

Waterbody Construction and Mitigation Procedures (“Procedures”), and Guidance for HDD

Monitoring, Inadvertent Return Response, and Contingency Plan (“HDD Plan Guidance”) will ensure that any adverse impacts will be limited and temporary. Copies of the applicable agency consultation letters necessary under the Endangered Species Act, the National Historic

Preservation Act, the Clean Air Act, and the Clean Water Act are included in the attached

Environmental Report. Gulf South has engaged in consultations and coordination with the affected federal, state, and local government agencies, and appropriate federally-recognized tribes in Mississippi concerning the proposed construction activities associated with the Project, and will continue to discuss specific concerns or requirements should they be raised.

Construction of the proposed Project will require the use of a total of 139.03 acres of land, resulting in both temporary and permanent land disturbance. Gulf South has selected the current pipeline route and compressor station location so that all Project facilities will be located on only three landowners’ property. The three landowners are Cooperative, a railroad company, and a private landowner. The private landowner has agreed to have the compressor station and 3 miles of the proposed route on their property. Gulf South will acquire an approximately 40-acre

site for the new compressor station. Construction of the proposed compressor station will affect approximately 35.65 acres of land, with 8.55 acres utilized for operation. Gulf South proposes to co-locate the proposed 20-inch pipeline for approximately 4,140 feet within an existing utility corridor. The total acreage of land that will be affected by pipeline construction (not including additional temporary workspace (“ATWS”), contractor/pipe yards, and access roads) is approximately 31.65 acres, of which approximately 20.33 acres are associated with the new permanent easement and 11.32 acres are associated with the temporary construction right-of-way

(“ROW”). Following construction, approximately 98.22 acres of land consisting of those areas necessary to facilitate construction, including the construction ROW, and ATWS will be restored to preconstruction conditions. Permanent impact areas associated with the operation of the proposed facilities, totaling approximately 40.81 acres, will include the new Black Creek

Compressor Station, new maintained pipeline ROW, the delivery meter station, and two new permanent access roads and maintained power line ROW.

Gulf South conducted detailed analyses to determine the potential impacts the Project would have on air and noise quality in the Project area. To minimize and mitigate for the impacts identified in the analyses, Gulf South would implement measures designed to reduce air and noise emissions during construction and operation of the Project facilities. All measures would be implemented in accordance with all applicable federal, state, and local regulations.

Alignment sheets for the pipeline, site plan of the compressor station and aerial photographs are included in Appendix 1A, in Resource Report 1. The compressor station plot plan is depicted in

Appendix 1B, Resource Report 1. Due to the engineering specifics and building identification, the compressor station site plot plan has been designated and labeled as “CUI//CEII” and

“Contains Critical Energy Infrastructure Information-Do Not Release” and included in

Volume III of this Application. In accordance with Section 388.112 of the Commission’s regulations, 18 C.F.R. § 388.112 (2019), Gulf South is seeking confidential treatment of this information.

Air Emissions

The Black Creek Compressor Station will be located in an attainment area, will be below the threshold requirements for Prevention of Significant Deterioration (“PSD”) permitting, and will not be a Title V major source. As reflected in Resource Report 9, Volume I-A, the potential emissions of all criteria pollutants from the Black Creek Compressor Station are below the PSD major source threshold of 250 tons per year. The Black Creek Compressor Station is not subject to PSD review. Gulf South will continue to coordinate with Mississippi Department of

Environmental Quality to ensure that all permitting requirements for the Project facilities are met. Since the potential emissions of criteria pollutants, and hazardous air pollutant are all below the Title V major source thresholds, the Black Creek Compressor Station will not require a Title V permit. The Black Creek Compressor Station units will not have significant impacts on the overall facility emissions estimates.

Cooperative is proposing to repower its existing coal-fired power plant. One of the primary drivers for the Morrow Repower Project is the ability to reliably generate electricity with lower air emissions by burning natural gas instead of coal. As detailed in Resource Report 9,

Volume I-A, the coal-fired electric generation units previously in service at Plant Morrow accounted for significant greenhouse gas emissions. As a result of the Morrow Repower Project, there will be drastically lower nitrogen oxides emissions on an hourly basis as well as a pounds per million British Thermal Units (“lb/MMBtu”) basis and there will be a 43% reduction in carbon dioxide emissions from the Morrow Repower Project on a lb/MMBtu basis.

Public Outreach

Gulf South commenced project development activities in Spring 2019, in order to evaluate various routes for the Project. Gulf South held discussions with Cooperative regarding the location of its new Morrow Repower Project, as well as discussions with eleven landowners along an initial route which assisted with Gulf South selecting its current proposed route.

Working with landowners, Gulf South has selected the current pipeline route and compressor station location so that all Project facilities will be located only on the three landowners’ property: Cooperative, a railroad company, and a private landowner. Selecting the proposed route and location of the compressor station will lessen environmental and landowner impacts.

To introduce stakeholders to the Project and facilitate stakeholder communication, in summer 2019, Gulf South commenced contacting elected officials at the local and state level to discuss the Project. The discussions covered the pipeline system, engineering and construction, environmental protection, the regulatory process, and survey/route information. Gulf South has kept public officials apprised of the Project and will continue to do so for the duration of the

Project.

Gulf South has developed a Project-specific website which can be accessed at

(www.gulfsouthpl.com/LamarExp). The website addresses general information about the

Project, landowners’ Frequently Asked Questions, and information about the regulatory process, environmental protection, and safety. The website will also provide information about how to contact Gulf South and how to access the FERC’s website to review, comment on, and obtain copies of public filings.

VII. LANDOWNER UPDATES

Gulf South mailed survey permission letters to potentially affected landowners of the initial Project route during June and July of 2019. After further evaluation and consideration of the Project, Gulf South has been actively engaged with the three landowners along the proposed route and compressor station location. Gulf South met with the private landowner to discuss parcel-specific plot plans illustrating the location of the pipeline, compressor station, and workspaces on the property. An agreement in principal has been made with the private landowner, of which terms and conditions, and relevant cost, have been predetermined. Gulf

South anticipates executing an easement agreement and purchase and sale agreement with the private landowner by October 31, 2019. Gulf South has executed the easement agreement with

Cooperative. Gulf South is coordinating with the railroad company for Right of Entry and will follow with permitting / acquisition.

VIII. PUBLIC CONVENIENCE AND NECESSITY

A. Lamar County Expansion Project

The Project satisfies the criteria for justifying a new project under the Commission’s

Certification of New Interstate Natural Gas Pipeline Facilities Policy Statement (“Certificate

Policy Statement”).7 The Project will provide the following public benefits: meeting unserved demand, providing new transportation capacity to serve demonstrated electric generation demand, providing natural gas to Cooperative to allow a coal plant to be retired, constructing new interconnects and facilities that improve the interstate grid, and providing competitive interstate alternatives. The Precedent Agreement with a non-affiliated entity and the obligation

7 Certification of New Interstate Natural Gas Pipeline Facilities, Statement of Policy, 88 FERC ¶ 61,227, at p. 61,748 (1999), Order Clarifying Statement of Policy, 90 FERC ¶ 61,128 (2000), Order Further Clarifying Statement of Policy, 92 FERC ¶ 61,094 (2000).

to enter into long-term firm transportation contracts for essentially all of the Project’s capacity demonstrates the strong public need for a proposed project.8 The Project satisfies the requirements of the Certificate Policy Statement, as demonstrated below, and is required by the present and future public convenience and necessity.

B. Compliance with the Commission’s Certificate Policy Statement

The Commission’s Certificate Policy Statement provides guidance regarding how the

Commission will evaluate pipeline construction proposals under Section 7(c) of the NGA to determine if the requested construction is necessary and will serve the public interest. In deciding whether to authorize the construction of major new pipeline facilities, the Commission will balance the public benefits created by the proposed project against potential adverse consequences. The Commission will give appropriate consideration to the enhancement of competitive transportation alternatives, the possibility of overbuilding, subsidization by existing customers, the Applicant’s responsibility for unsubscribed capacity, the avoidance of unnecessary disruptions of the environment, and the unneeded exercise of eminent domain in evaluating new pipeline construction.

Pursuant to the Certificate Policy Statement, the threshold requirement for a pipeline proposing a new project is that the pipeline must be prepared to financially support the project without relying on subsidization from its existing customers. Once the no-subsidization requirement has been met, the next inquiry is whether the Project has adverse effects on (i) the

Applicant’s existing customers, (ii) existing pipelines in the market and their captive customers, or (iii) landowners and communities affected by the route of the new pipeline. If residual adverse effects on these interest groups are identified after efforts have been made to minimize

8 88 FERC at pp. 61,744-48.

them, the Commission will evaluate the project by balancing the evidence of public benefits to be achieved against these residual adverse effects. The Commission has stated that this essentially is an economic test.9 Only when the benefits outweigh the adverse effects on economic interests will the Commission proceed to complete the environmental analysis. Gulf

South’s proposed Lamar County Expansion Project satisfies all of the requirements of the

Certificate Policy Statement.

1. Existing Shippers Will Not Subsidize the Project

Under the Certificate Policy Statement, the threshold requirement for applicants proposing new construction projects is that the applicant must be prepared to financially support the project without relying on subsidization from existing customers.10

As explained in Section V, existing Gulf South customers will not subsidize the costs of the Project. The Precedent Agreement commits Cooperative to enter into firm transportation agreements for a period twenty (20) years and will cover the costs of the Project. Existing transportation customers on Gulf South’s system will not subsidize the costs of the Project because (i) Gulf South intends to charge a separate, lateral rate under Rate Schedule FLS to recover the costs of the Lamar County Lateral Facilities that will apply only to service on the lateral, and (ii) Gulf South will charge its existing system-wide rates for the expanded service on its Legacy System Facilities, as the cost-based rates of the new expansion service would be lower than the system-wide rates and, as illustrated in Exhibit N – Legacy System Facilities, the expected revenues exceed Project costs. Gulf South is not relying on subsidization from existing transportation customers for the Project facilities and has satisfied this threshold element of the

Certificate Policy Statement.

9 Id. at p. 61,745. 10 Id. at p. 61,745.

2. The Project Will Have No Adverse Impacts on Gulf South’s Existing Customers and Existing Pipelines in the Market and Their Captive Customers.

The Project will have no adverse impacts on Gulf South’s existing customers and existing pipelines in the area or their captive customers. The Project is fully supported by the Precedent

Agreement and is being constructed to provide firm service to Cooperative’s Morrow Power

Station, Moselle Power Plant, and Benndale Power Plant. The Project will not impact Gulf

South’s ability to continue to provide natural gas transportation or storage service to its existing shippers. Rather than adversely impacting its existing customers and other pipelines in the area and their captive customers, the proposed facilities will enhance Gulf South’s infrastructure in central and southern Mississippi, improve access to new supplies of natural gas, serve new market demand, enhance competition within the U.S. for natural gas transportation and supply, and provide additional receipts, transportation, and outlets for Gulf Coast natural gas supplies.

The refunctionalization of the Hattiesburg 20-inch pipeline to transmission furthers the benefits of the Project without impacting storage customers or deliverability.

The expansion of Gulf South’s infrastructure through the construction and operation of the Lamar County Expansion Project will not have adverse effects on existing pipelines or their captive customers. For these reasons, the Project meets these elements of the Policy Statement.11

3. Gulf South Has Minimized Potential Impact on Landowners and Surrounding Communities.

The Lamar County Expansion Project has been designed to minimize impact on affected landowners, residences, and communities. An initial route that Gulf South was evaluating included eleven landowners and was close to residential structures although it paralleled an electric line corridor. Working with local landowners, Gulf South has sited the location of the

11 The Commission has recognized that it need not protect competitors from competition. Instead the goal is to ensure fair competition. Id at p. 61,748.

proposed 20-inch delivery lateral and new compressor station solely on three landowners’ property in order to minimize the Project’s impact on other landowners. Gulf South has been working with, and will continue to work with, landowners, community representatives, and other stakeholders to minimize any concerns regarding the access, easements, and temporary workspace needed to construct this Project. Gulf South has secured survey permission and is in the process of acquiring the property rights for the Project as discussed herein. Gulf South has taken steps to minimize impacts to landowners and communities. Gulf South is committed to securing needed easements through good faith negotiations, wherever possible, to minimize the need for condemnation proceedings.

4. Project Benefits Outweigh Residual Adverse Impacts

Through the design of the Project, Gulf South has minimized potential impacts of the facilities on its existing customers, other pipelines and their captive customers, and landowners and communities. To the extent that adverse impacts still occur, the benefits of the Project outweigh these impacts. The Lamar County Expansion Project:

(i) will meet unmet market demand and is supported by a customer that has signed a

binding, long-term Precedent Agreement for firm transportation service for the full

capacity created by the Project;

(ii) will enhance Gulf South’s ability to provide firm transportation service to its

customers;

(iii) will not be subsidized by Gulf South’s existing customers;

(iv) will have minimal adverse effect on landowners; and

(v) will not have a significant impact on the environment.

The Project is necessary to provide firm transportation service to Cooperative’s new and existing natural gas-fired power plants. Cooperative is constructing the Morrow Repower

Project in an effort to have the required supply of power to serve the present and immediately foreseeable requirements of its members, and increasing efficiency, while reducing air emissions rates at the site. The Lamar County Expansion Project is required to expand the capabilities of

Gulf South’s infrastructure to serve its customers and meet this currently unmet demand for natural gas transportation service. The new compressor station is needed to increase the daily and maximum capability of Gulf South’s Index 299 in order to transport the 200,000 Dth per day requested for the Morrow, Moselle, and Benndale Power Plants and the new delivery lateral and delivery meter station is needed to deliver the required natural gas needed by the gas-fired combined cycle power plant, the Morrow Repower Project.

Gulf South’s proposed Lamar County Expansion Project is required by the present and future public convenience and necessity. The Project will serve demand for natural gas transportation by allowing Gulf South to provide up to 200,000 Dth/d of new and existing firm transportation service under Rate Schedules FTS and FLS to Cooperative to satisfy its growing demand for natural-gas fired electric generation in central and southern Mississippi.

Gulf South requests the Commission authorize the construction and operation of the

Project and issue a certificate of public convenience and necessity by September 17, 2020. This will allow Gulf South to place the Project in service by January 1, 2022, as required by

Cooperative.

IX. ENERGY EFFICIENCY

Gulf South considers the potential for energy efficiency in connection with major pipeline infrastructure projects. Gulf South has designed the Project to enhance operational

efficiencies to the extent practical. Gulf South has selected compressor units for overall efficiency and that meet applicable air and noise regulatory requirements. Gulf South will employ a rigorous maintenance schedule to maintain pipeline efficiency.

Gulf South has considered waste heat and co-generation opportunities, in light of the white paper on waste heat published by the Interstate Natural Gas Association of America

(“INGAA”) in February 2008. The INGAA white paper identifies initial threshold criteria for determining whether waste heat generation is feasible. Candidate compressor stations should have a total of 15,000 HP provided by gas turbine compressor units and these units should operate for a total of 5,250 hours per year (60 percent load factor). Gulf South’s proposed compressor station, consisting of 5,000 HP, is less than the initial threshold criteria. Based on the INGAA white paper recommendations, the Black Creek Compressor Station would not qualify to economically recover heat or support a co-generation facility due to the size of the facility.

Gulf South cannot state with certainty whether waste heat cogeneration is feasible or not.

It is not part of Gulf South’s business plan to study, develop, construct, own, or operate waste heat recovery facilities as waste heat generated is not useful for any of the processes or operational parameters of a typical gas transmission facility. Actual operating data, after the facilities are placed into service and operating under normal conditions, is needed to further evaluate potential waste heat cogeneration. After operation of these facilities for a period of time, data can be reviewed to determine the economic viability of the cogeneration. Gulf South provides information in Gulf South’s waste heat recovery posting located on its website.

X. OTHER APPLICATIONS AND FILINGS

As discussed in Section II, Gulf South submitted a tariff filing to implement Rate

Schedules FLS and ILS for firm and interruptible lateral transportation services and requested that the Commission approve the submittal as just and reasonable effective October 4, 2019.

Gulf South received comments from the Indicated Shippers. Gulf South addressed the comments and is awaiting an order from the Commission on this filing.

Gulf South is not aware of any other application to supplement or effectuate this

Application that must or will be filed by Gulf South, its customers, or any other person with any

Federal, State, or regulatory body in order to complete the Project.

XI. NOTICES

Pursuant to 18 C.F.R. §§ 157.6 and 157.9 of the Commission’s Regulations, a form of notice of this Application, suitable for publication in the Federal Register, is attached. Pursuant to 18 C.F.R. § 157.10 of the Commission’s Regulations, Gulf South will provide a complete copy of this Application to a central public library in each county in the Project area within three business days of the filing of this Application.

Pursuant to 18 C.F.R. § 157.6(d), Gulf South will make a good faith effort to notify all landowners, towns, communities, and local, state, and federal governments and agencies involved in the project in accordance with this section.

XII. DESCRIPTION OF EXHIBITS

This is an abbreviated application filed pursuant to Section 157.7 of the Commission’s regulations under the NGA. Listed are the exhibits required under 18 C.F.R. § 157.14(a). Gulf

South has omitted the exhibits and data that are inapplicable or are unnecessary for this

Application. The following exhibits relevant to this Application are attached, incorporated by reference, or omitted for the reasons stated.

Exhibit A Articles of Incorporation and By-laws Omitted. Gulf South filed as Exhibit A in Docket No. CP19-490 and incorporated herein by reference.

Exhibit B State Authorization Omitted. Gulf South filed as Exhibit B in Docket No. CP02-155 and incorporated herein by reference.

Exhibit C Company Officials Omitted. Gulf South filed as Exhibit A in Docket No. CP19-490 and incorporated herein by reference.

Exhibit D Subsidiaries and Affiliation Omitted. Gulf South filed as Exhibit D in Docket No. CP19-3 and incorporated herein by reference.

Exhibit E Other Pending Applications and Filings Omitted. Gulf South submitted, in a separate limited NGA Section 4 proceeding, in Docket No. RP19-1539-000, a tariff filing to implement Rate Schedules FLS and ILS for firm and interruptible lateral transportation services.

Exhibit F Location of Facilities Submitted herewith.

Exhibit F-I Environmental Report Submitted herewith in Volume I-A.

Exhibit G,G-I Flow Diagrams Submitted herewith. Information for Exhibits G, and G-I is included in Volume III, and labeled as “CUI//CEII” and “CONTAINS CRITICAL ENERGY INFRASTRUCTURE INFORMATION – DO NOT RELEASE” as defined in 18 C.F.R. §388.113(c).

Exhibit G-II Flow Diagram Data Submitted herewith. Information for Exhibit G-II is included in Volume III, and labeled as “CUI//CEII” and “CONTAINS CRITICAL ENERGY INFRASTRUCTURE INFORMATION – DO NOT RELEASE” as defined in 18 C.F.R. §388.113(c).

Exhibit H Total Gas Supply Data Omitted.

Exhibit I Market Data Submitted herewith. The Precedent Agreement is submitted in Volume II and designated as “CUI//PRIV” and “PRIVILEGED INFORMATION – DO NOT RELEASE” as it contains sensitive commercial information.

Exhibit J Federal Authorizations Submitted herewith.

Exhibit K Cost of Facilities Submitted herewith.

Exhibit L Financing Omitted. Gulf South will finance the proposed construction with funds generated internally, through borrowings, bond offerings, and/or equity offerings.

Exhibit M Construction, Operation and Management Omitted. Gulf South will construct or cause to be constructed, owned, operated, and maintained the proposed facilities.

Exhibit N Revenues - Expenses - Income Submitted herewith.

Exhibit O Depreciation and Depletion Omitted. Depreciation is reflected in Exhibit N.

Exhibit P Tariff Submitted herewith.

XIII. WAIVER

Pursuant to Rules 801 and 802 of the Commission’s Rules of Practice and Procedure,12

Gulf South requests that the intermediate decision procedure be omitted, and waives oral hearing and opportunity for filing exceptions to the decision of the Commission. Under these procedures, the decision of the Commission will be final, but subject to reconsideration by the Commission upon request for rehearing, as provided by statute.

12 Id. at §§ 385.801 and 385.802.

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Gulf South Pipeline Company, LP Docket No. CP19-___-000

NOTICE OF APPLICATION

(October __, 2019)

Take notice that on September 30, 2019, Gulf South Pipeline Company, LP (“Gulf South”), 9 Greenway Plaza, Suite 2800, Houston, Texas 77046, filed in the above referenced docket, pursuant to section 7(c) of the Natural Gas Act (NGA) this abbreviated application for a certificate of public convenience and necessity.

Gulf South proposes to construct, operate, and maintain (i) an approximately 3.4 mile 20-inch diameter natural gas delivery lateral, (ii) a new delivery meter station, and (iii) a new compressor station with approximately 5,000 horsepower and other associated auxiliary appurtenant buildings and facilities, all located in Lamar and Forrest counties, Mississippi, (“Lamar County Expansion Project”). The proposed Lamar County Expansion Project will allow Gulf South to provide up to 200,000 dekatherm per day of firm transportation service to Cooperative Entergy Texas, Inc.’s proposed 550 megawatt combined cycle gas turbine generation facility to be located in Lamar County, near Purvis, Mississippi. Gulf South also requests as part of its Application that the Commission approve the refunctionalization of its Hattiesburg 20-inch pipeline.

Any questions regarding this application may be directed to Juan Eligio Jr., Supervisor of Regulatory Affairs, Gulf South Pipeline Company, LP, 9 Greenway Plaza, Suite 2800, Houston, Texas 77046; by telephone at (713) 479-3480 or by email at [email protected] or Payton Barrientos, Senior Regulatory Analyst, Gulf South Pipeline Company, LP, 9 Greenway Plaza, Suite 2800, Houston, Texas, 77046; by telephone at (713) 479-8157 or by email at [email protected].

Pursuant to section 157.9 of the Commission's rules, 18 CFR 157.9, within 90 days of this Notice the Commission staff will either: complete its environmental assessment (EA) and place it into the Commission’s public record (eLibrary) for this proceeding; or issue a Notice of Schedule for Environmental Review. If a Notice of Schedule for Environmental Review is issued, it will indicate, among other milestones, the anticipated date for the Commission staff's issuance of the final environmental impact statement (FEIS) or EA for this proposal. The filing of the EA in the Commission’s public record for this proceeding or the issuance of a Notice of Schedule for Environmental Review will serve to notify federal and state agencies of the timing for the completion of all necessary reviews, and the subsequent need to complete all federal authorizations within 90 days of the date of issuance of the Commission staff's FEIS or EA.

There are two ways to become involved in the Commission's review of this project. First, any person wishing to obtain legal status by becoming a party to the proceedings for this project should, on or before the comment date stated below file with the Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC 20426, a motion to intervene in accordance with the requirements of the Commission's Rules of Practice and Procedure (18 CFR 385.214 or 385.211) and the Regulations under the NGA (18 CFR 157.10). A person obtaining party status will be placed on the service list maintained by the Secretary of the Commission and will receive copies of all documents filed by the applicant and by all other parties. A party must submit 7 copies of filings made in the proceeding with the Commission and must mail a copy to the applicant and to every other party. Only parties to the proceeding can ask for court review of Commission orders in the proceeding. The Commission strongly encourages electronic submissions of comments, 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 5 copies of the protest or intervention to the Federal Energy regulatory Commission, at the address above. Only parties to the proceeding can ask for court review of Commission orders in the proceeding.

However, a person does not have to intervene in order to have comments considered. The second way to participate is by filing with the Secretary of the Commission, as soon as possible, an original and two copies of comments in support of or in opposition to this project. The Commission will consider these comments in determining the appropriate action to be taken, but the filing of a comment alone will not serve to make the filer a party to the proceeding. The Commission's rules require that persons filing comments in opposition to the project provide copies of their protests only to the party or parties directly involved in the protest.

Persons who wish to comment only on the environmental review of this project should submit an original and two copies of their comments to the Secretary of the Commission. Environmental commenters will be placed on the Commission's environmental mailing list, will receive copies of the environmental documents, and will be notified of meetings associated with the Commission's environmental review process. Environmental commenters will not be required to serve copies of filed documents on all other parties. However, the non-party commenters will not receive copies of all documents filed by other parties or issued by the Commission (except for the mailing of environmental documents issued by the Commission) and will not have the right to seek court review of the Commission's final order.

The filing may also be viewed 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, DC. 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. For assistance with any FERC Online service, please email FERC at [email protected] or call toll-free, (866) 208-3676 or for TYY, (202) 502-8659.

Comment Date: 5:00 pm Eastern Time on , 2019.

Kimberly D. Bose Secretary

GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-___-000 EXHIBIT F

LOCATION OF FACILITIES

SMITH CLARKE Heidelberg JASPER Gilbertown

JASPER Shubuta CLARKE Magee Mize SIMPSON Taylorsville CHOCTAW

Sharon Silas

Mount COVINGTON Soso Olive Cullomburg

Laurel Waynesboro

WAYNE Millry Collins 1 0 0 - 0 JONES 0 1 Ellisville S Clara

Buckatunna JEFFERSON Seminary DAVIS Moselle Hobson Chatom Bassfield Hattiesburg 20" Pipeline State 3 0 Line 1 - 6 WASHINGTON - 3

Sumrall 2 0 0 - Tibbie Rawls 0 MS100-003 0 Springs 1 S Fruitdale M MS100-009 Richton Arnold Petal Line West Hattiesburg Hattiesburg Vinegar Index 299 Bend

Morrow Power Station Deer Columbia Park

New GREENE MARION Augusta 9 9 LAMAR 2 Beaumont FORREST Leakesville Proposed Delivery Lateral PERRY Purvis Citronelle Proposed Black Creek Compressor Station McLain 133 Baxterville Junction Map Items Gulfcrest WALTHALL Convert Hattiesburg 20” to Transm ission S ervice Water Body Lumberton MOBILE Morrow Pow er S tation Arm y Guard National Forest Proposed Meter S tation Chunchula Angie Lucedale County

PropGosEeOdR BGlEack Creek Com pressor S tation Active Com pressor WASHINGTON PEARL Benndale RIVER Boardwalk System Com m on Junction Varnado Gulf S outh S ystem Wiggins Pow er Plant STONE Proposed Delivery Lateral Date: 9/27/2019 0 3.5 7 14 Poplarville Petal S torage Com plex Miles

Docum ent Path: O:\AppData\GIS \Cloud\Data\Com m ercial\GIS \Pow er Plants\Morrow \Lam ar_County\Regulatory\BWP-GIS -1869 - Lam ar County Expansion Project Regulatory Map 1.m xd 98

Morrow Power Station k

L Proposed Black Creek Compressor Station s

FORREST 59

1 1 LAMAR y 11 w

d l

Proposed Delivery Lateral

Index 299

Map Items

Morrow Power Station

Proposed Meter Station

Proposed Black Creek Compressor Station

Proposed Delivery Lateral Date: 9/27/2019 0 0.25 0.5 1 County Miles

Document Path: O:\AppData\GIS\Cloud\Data\Commercial\GIS\Power Plants\Morrow\Lamar_County\Regulatory\BWP-GIS-1869 - Lamar County Expansion Project Regulatory Map 3.mxd 1

503 8

528 JASPER 1

8 32 1-2 818 CLARKE 35 Heidelberg 145 531 3 JASPER 21-7 Shubuta 510 SMITH -1 1 Mize -6 0- 21 3 9 3 21 37 45 28 1 -6 32

1 21-1 - 3 3 Taylorsville 533 1

28 4

8 3 8 15 2 10 6 - 8 8 3-4 67 -1 8681- 841 4 -1 1 1 - 68 9 Sharon Sandersville 8 8681-18

537 11 Soso 37 532 529

59 84 184 184

0 1 3 3 301-5-2 01 -4 -9 9 3 0 0 4 WAYNE 1 5 1 L - 0 - 1 5 0 - - 1 184 0 0 3 0 1 4 COVINGTON 588 S - 1 M 0 Ellisville Clara 3 JONES 535

30 1- 29 590 5-3 Seminary -5 1 0 3

4 1 8 15 49 3 M 8 7 S 1 0 0 5 - 63 87- 0 3 0 4 598 JEFFERSON DAVIS Hattiesburg 20" Pipeline

3 46 589 0 8 1 3 - Map Items 01 6 -4 - -8 3 Co n vert Hattiesburg 20” to Tran smissio n Service 6 - 1 Index 299 Sumrall 0 Boardwalk System 42 3 FORREST PERRY Gulf So uth System GREENE 44 LAMAR Active Co mp resso r 009 Rawls S100- Springs M Petal Sto rage Co mp lex 311-2 42 42 2 6 Date: 9/25/2019 0 1.75 3.5 7 9 42 Co un ty Miles 9 Richton

Do cumen t Path: O:\Ap p Data\GIS\Clo ud\Data\Co mmercial\GIS\Po w er Plan ts\Mo rro w \Lamar_ Co un ty\Regulato ry\BWP-GIS-1869 - Lamar Co un ty Exp an sio n Pro ject Regulato ry Map 2.mxd GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-_____-000 EXHIBIT G & G-I

FLOW DIAGRAMS

CONTAINS CRITICAL ENERGY INFRASTRUCTURE INFORMATION CEII

SEE VOLUME III

GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-_____-000 EXHIBIT G-II

FLOW DIAGRAM DATA

CONTAINS CRITICAL ENERGY INFRASTRUCTURE INFORMATION CEII

SEE VOLUME III

GULF SOUTH PIPELINE COMPANY LP DOCKET NO. CP19-_____-000 EXHIBIT I

MARKET DATA

CONTAINS PRIVILEGED INFORMATION

SEE VOLUME II GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-___-000 EXHIBIT J

FEDERAL AUTHORIZATIONS

Exhibit J

Federal and State Permits and Approvals

Submittal/ Agency or Organization Permit/Approval Anticipated Anticipated Receipt Submittal Federal Certificate of Public Federal Energy Regulatory September 27, Convenience and September 2020 Commission 2019 Necessity

U.S. Fish and Wildlife Service Endangered Species September 27, – Mississippi Ecological Field Act, Section 7 1st Quarter 2020 2019 Office Consultation

Section 404 – U.S. Army Corps of Engineers, September 27, Nationwide Permit 1st Quarter 2020 Mobile District 2019 (NWP) 12

State Section 401 Water September 27, Quality Certification 1st Quarter 2020 2019 (Automatic with NWP 12)

State Permit to Construct September 27, 2nd Quarter 2020 (Air Permit) 2019 Mississippi Department of Environmental Quality State Permit to Operate 1st Quarter 2021 4th Quarter 2021 (Air Permit)

Hydrostatic Test General 4th Quarter 2020 4th Quarter 2020 Permit (MSG13)

Threatened and Mississippi Department of September 27, Endangered Species 1st Quarter 2020 Wildlife, Fisheries, and Parks 2019 Consultation/Clearance National Historic Mississippi Department of September 27, Preservation Act Section 4th Quarter 2019 Archives and History 2019 106 Consultation

Mississippi Department of Driveway Permits 1st Quarter 2020 3rd Quarter 2020 Transportation Exhibit J

Federal and State Permits and Approvals

Submittal/ Agency or Organization Permit/Approval Anticipated Anticipated Receipt Submittal Local

Flood Plain Development 2nd Quarter 2020 4th Quarter 2020 Permit Forrest County Planning Department Building Permit 2nd Quarter 2020 4th Quarter 2020

Lamar County Planning Site Plan Development 2nd Quarter 2020 4th Quarter 2020 Department Permit

GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-___-000 EXHIBIT K

COST OF FACILITIES

GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-__-000 EXHIBIT K

Lamar County Expansion Project

Plant Morrow Gulf South Total Plant Morrow Plant Morrow Total Black Creek Gulf South Delivery Lateral Meter Station Plant Morrow Compressor Facilities Total

RIGHT OF WAY $ 693,900 $ - $ 693,900 $ 596,000 $ 596,000 $ 1,289,900

MATERIALS PIPE, VALVES, & FITTINGS 1,578,333 318,159 1,896,492 2,080,000 2,080,000 3,976,492 BUILDING & STRUCTURES - - - 1,225,000 1,225,000 1,225,000 UNIT - - - 5,128,200 5,128,200 5,128,200 OTHER 519,677 86,510 606,187 1,833,568 1,833,568 2,439,755 FILTER & SEPARATOR - 244,028 244,028 155,000 155,000 399,028 COMMUNICATION - 654,682 654,682 300,000 300,000 954,682

LABOR 149,800 122,430 272,230 687,400 687,400 959,630

ENGINEERING 610,000 344,849 954,849 1,575,750 1,575,750 2,530,599

ENVIRONMENTAL 1,017,700 9,419 1,027,119 127,500 127,500 1,154,619

CONSTRUCTION 8,222,940 2,987,890 11,210,830 22,998,975 22,998,975 34,209,805

AFUDC 117,288 21,874 139,162 172,684 172,684 311,846

TOTAL $ 12,909,638 $ 4,789,841 $ 17,699,479 $ 36,880,077 $ 36,880,077 $ 54,579,556 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-___-000 EXHIBIT N

REVENUES – EXPENSES – INCOME

GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N

GULF SOUTH PIPELINE COMPANY, LP LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

EXHIBIT N GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 1 OF 8

GULF SOUTH PIPELINE, LP REVENUES AND COST OF SERVICE - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. Description Reference Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Transportation Revenues Page 8 $2,737,500 $2,737,500 $2,737,500 $2,737,500 $2,737,500 $2,737,500 $2,737,500 $2,737,500 $2,737,500 $2,737,500

2 Cost of Service Page 3 $3,027,517 $2,946,112 $2,854,569 $2,768,580 $2,687,625 $2,602,889 $2,513,093 $2,424,575 $2,336,350 $2,248,455

3 Difference ($290,017) ($208,612) ($117,069) ($31,080) $49,875 $134,611 $224,407 $312,925 $401,150 $489,045 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 2 OF 8

GULF SOUTH PIPELINE COMPANY, LP CALCULATED UNIT RATES - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. Cost of Service / Rate Calculation

1 LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL - Cost of Service$ (See 3,027,517 Page 3)

2 Allocation of Incremental Cost of Service to Interruptible Transportation $ 75,688

3 Net Incremental Cost of Service for Firm Transportation $ 2,951,829

4 Maximum Design Capacity 200,000 MMBtu/d

5 Annual Throughput at Full Capacity 73,000,000 MMBtu

6 Calculated Daily FLS-FT Demand Rate (per MMBtu) $ 0.0404

7 Gulf South is proposing to implement the rate associated with this project under Rate Schedule FLS (see Application at Page 11). As a result, Gulf South is not providing a roll-in analysis as this lateral is not an integrated expansion of Gulf South's existing system. GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 3 OF 8

GULF SOUTH PIPELINE COMPANY, LP COST OF SERVICE - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. Cost of Service Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Operation and Maintenance Expenses$ 55,804 $ 57,478 $ 59,202 $ 60,979 $ 62,808 $ 64,692 $ 66,633 $ 68,632 $ 70,691 $ 72,812 2 Depreciation Expense 506,205 506,205 506,205 506,205 506,205 506,205 506,205 506,205 506,205 506,205 3 Other Taxes 243,225 250,522 258,037 265,779 273,752 281,964 290,423 299,136 308,110 317,353 4 Income Taxes 411,316 394,614 375,989 358,339 341,566 324,041 305,524 287,186 268,842 250,498 5 Return 1,810,967 1,737,292 1,655,135 1,577,279 1,503,294 1,425,987 1,344,307 1,263,416 1,182,501 1,101,587

6 Total Cost of Service $ 3,027,517 $ 2,946,112 $ 2,854,569 $ 2,768,580 $ 2,687,625 $ 2,602,889 $ 2,513,093 $ 2,424,575 $ 2,336,350 $ 2,248,455 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 4 OF 8

GULF SOUTH PIPELINE COMPANY, LP RATE BASE - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. Rate Base Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Gas Plant In Service (See Exhibit K)$ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 2 Accumulated Depreciation /1 (253,103) (759,308) (1,265,513) (1,771,718) (2,277,923) (2,784,128) (3,290,333) (3,796,538) (4,302,743) (4,808,948)

3 Net Plant In Service 17,446,376 16,940,171 16,433,966 15,927,761 15,421,556 14,915,351 14,409,146 13,902,941 13,396,736 12,890,531

4 Accumulated Deferred Taxes /1 (49,126) (250,682) (533,732) (775,461) (980,001) (1,216,450) (1,494,909) (1,765,793) (2,036,906) (2,308,019)

5 Total Rate Base $ 17,397,250 $ 16,689,489 $ 15,900,234 $ 15,152,300 $ 14,441,555 $ 13,698,901 $ 12,914,237 $ 12,137,148 $ 11,359,830 $ 10,582,512

6 Overall Rate of Return 10.41% 10.41% 10.41% 10.41% 10.41% 10.41% 10.41% 10.41% 10.41% 10.41%

7 Total Return $ 1,810,967 $ 1,737,292 $ 1,655,135 $ 1,577,279 $ 1,503,294 $ 1,425,987 $ 1,344,307 $ 1,263,416 $ 1,182,501 $ 1,101,587

Notes: /1 Amount is an average of beginning and ending balances. GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 5 OF 8

GULF SOUTH PIPELINE COMPANY, LP CALCULATION OF COST OF SERVICE ITEMS - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. O&M Expenses Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Transmission $ 55,804 $ 57,478 $ 59,202 $ 60,979 $ 62,808 $ 64,692 $ 66,633 $ 68,632 $ 70,691 $ 72,812

2 Total O&M Expenses $ 55,804 $ 57,478 $ 59,202 $ 60,979 $ 62,808 $ 64,692 $ 66,633 $ 68,632 $ 70,691 $ 72,812

Depreciation Expense

3 Gas Plant In Service$ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479

4 Depreciation Rate 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86%

5 Depreciation Expense $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205

Other Taxes

6 Ad Valorem Taxes$ 243,225 $ 250,522 $ 258,037 $ 265,779 $ 273,752 $ 281,964 $ 290,423 $ 299,136 $ 308,110 $ 317,353

7 Total Other Taxes $ 243,225 $ 250,522 $ 258,037 $ 265,779 $ 273,752 $ 281,964 $ 290,423 $ 299,136 $ 308,110 $ 317,353 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 6 OF 8

GULF SOUTH PIPELINE COMPANY, LP CALCULATION OF INCOME TAXES - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. Income Taxes Rate Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Rate Base $ 17,397,250 $ 16,689,489 $ 15,900,234 $ 15,152,300 $ 14,441,555 $ 13,698,901 $ 12,914,237 $ 12,137,148 $ 11,359,830 $ 10,582,512 2 Total Overall Return 10.41% 1,810,967 1,737,292 1,655,135 1,577,279 1,503,294 1,425,987 1,344,307 1,263,416 1,182,501 1,101,587 ADD: 3 Amortization of AFUDC equity 2,189 2,189 2,189 2,189 2,189 2,189 2,189 2,189 2,189 2,189

LESS: 4 Interest and debt expense 8.16% (638,827) (612,838) (583,857) (556,392) (530,294) (503,024) (474,211) (445,676) (417,133) (388,590)

5 Adjusted Return 1,174,329 1,126,643 1,073,467 1,023,075 975,189 925,152 872,286 819,929 767,558 715,186

6 Income Taxes (at Composite Tax Rate) 25.94% $ 411,316 $ 394,614 $ 375,989 $ 358,339 $ 341,566 $ 324,041 $ 305,524 $ 287,186 $ 268,842 $ 250,498 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 7 OF 8

GULF SOUTH PIPELINE COMPANY, LP CALCULATION OF DEFERRED INCOME TAXES - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Line No. Deferred Income Taxes Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Gas Plant In Service$ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 $ 17,699,479 2 Book Depreciation Rate 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 2.86% 3 Book Depreciation Expense$ 506,205 $ 506,205 $ 506,205 $ 506,205 $ 506,205 $ - $ - $ - $ - $ -

4 Tax Depreciation Rate 5.00% 9.50% 8.55% 7.70% 6.93% 6.23% 5.90% 5.90% 5.91% 5.90% 5 Tax Depreciation$ 884,974 $ 1,681,451 $ 1,513,305 $ 1,362,860 $ 1,226,574 $ 1,102,678 $ 1,044,269 $ 1,044,269 $ 1,046,039 $ 1,044,269

6 Difference$ (378,769) $ (1,175,245) $ (1,007,100) $ (856,655) $ (720,369) $ (1,102,678) $ (1,044,269) $ (1,044,269) $ (1,046,039) $ (1,044,269) 7 Composite Income tax rate 25.9400% 25.9400% 25.9400% 25.9400% 25.9400% 25.9400% 25.9400% 25.9400% 25.9400% 25.9400%

8 Deferred Taxes$ (98,253) $ (304,859) $ (261,242) $ (222,216) $ (186,864) $ (286,035) $ (270,883) $ (270,883) $ (271,343) $ (270,883) 9 Accumulated Deferred Income Taxes $ (98,253) $ (403,111) $ (664,353) $ (886,569) $ (1,073,433) $ (1,359,468) $ (1,630,351) $ (1,901,234) $ (2,172,577) $ (2,443,461) GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 8 OF 8

GULF SOUTH PIPELINE COMPANY, LP REVENUES - LAMAR COUNTY EXPANSION PROJECT, LAMAR COUNTY CUSTOMER LATERAL

Daily Demand Line MDQ Primary Term Rate / MMBtu Commodity No. Shipper Service Type (MMBtu/day) (Yrs) (Negotiated) Rate Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Cooperative Energy FTS 200,000 20 $ 0.0375 $ - $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500

2 Total Revenues $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 $ 2,737,500 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N

GULF SOUTH PIPELINE COMPANY, LP LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

EXHIBIT N GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 1 OF 7

GULF SOUTH PIPELINE COMPANY, LP CALCULATED UNIT RATES - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Line No. Cost of Service / Rate Calculation

1 LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES - Cost of Service (See Page 3)$ 6,364,143

2 Allocation of Demand Cost of Service to Interruptible Transportation $ 159,104

3 Net Cost of Service for Firm Transportation $ 6,205,039

4 Demand Cost of Service $ 6,163,853

5 Maximum Design Capacity 200,000 MMBtu/d

6 Annual Throughput at Full Capacity 73,000,000 MMBtu

7 Calculated Daily FTS Demand Rate (per MMBtu) $ 0.0844

8 Commodity Cost of Service $ 41,187

9 Commodity Billing Determinants 51,100,000 MMBtu

10 Calculated Commodity Rate (per MMBtu) $ 0.0008

11 Calculated Daily 100% Load Factor Rate (per MMBtu) $ 0.0852

Currently Approved FTS Rates GULF SOUTH PIPELINE COMPANY, LP - EXHIBIT N PAGE 2 OF 7

GULF SOUTH PIPELINE COMPANY, LP COST OF SERVICE - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Line No. Cost of Service Year 1 Year 2 Year 3

1 Operation and Maintenance Expenses$ 411,866 $ 424,222 $ 436,949 2 Depreciation Expense 803,986 803,986 803,986 3 Other Taxes 506,775 521,978 537,638 4 Income Taxes 858,371 827,952 793,526 5 Return 3,783,145 3,648,965 3,497,108

6 Total Cost of Service $ 6,364,143 $ 6,227,103 $ 6,069,206 GULF SOUTH PIPELINE COMPANY, LP - EXHIBIT N PAGE 3 OF 7

GULF SOUTH PIPELINE COMPANY, LP RATE BASE - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Line No. Rate Base Year 1 Year 2 Year 3

1 Gas Plant In Service (See Exhibit K)$ 36,880,077 $ 36,880,077 $ 36,880,077 2 Accumulated Depreciation /1 (401,993) (1,205,979) (2,009,964)

3 Net Plant In Service 36,478,084 35,674,098 34,870,113

4 Accumulated Deferred Taxes /1 (134,890) (619,922) (1,274,762)

5 Total Rate Base $ 36,343,194 $ 35,054,177 $ 33,595,351

6 Overall Rate of Return 10.41% 10.41% 10.41%

7 Total Return $ 3,783,145 $ 3,648,965 $ 3,497,108

Notes: /1 Amount is an average of beginning and ending balances. GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 4 OF 7

GULF SOUTH PIPELINE COMPANY, LP CALCULATION OF COST OF SERVICE ITEMS - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Line No. O&M Expenses Year 1 Year 2 Year 3

1 Transmission $ 411,866 $ 424,222 $ 436,949

2 Total O&M Expenses $ 411,866 $ 424,222 $ 436,949

Depreciation Expense

3 Gas Plant In Service $ 36,880,077 $ 36,880,077 $ 36,880,077

4 Depreciation Rate 2.18% 2.18% 2.18%

5 Depreciation Expense $ 803,986 $ 803,986 $ 803,986

Other Taxes

6 Ad Valorem Taxes $ 506,775 $ 521,978 $ 537,638

7 Total Other Taxes $ 506,775 $ 521,978 $ 537,638 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 5 OF 7

GULF SOUTH PIPELINE COMPANY, LP CALCULATION OF INCOME TAXES - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Line No. Income Taxes Rate Year 1 Year 2 Year 3

1 Rate Base $ 36,343,194 $ 35,054,177 $ 33,595,351 2 Total Overall Return 10.41% 3,783,145 3,648,965 3,497,108 ADD: 3 Amortization of AFUDC equity 2,070 2,070 2,070

LESS: 4 Interest and debt expense 8.16% (1,334,522) (1,287,189) (1,233,621)

5 Adjusted Return 2,450,693 2,363,846 2,265,557

6 Income Taxes (at Composite Tax Rate) 25.94% $ 858,371 $ 827,952 $ 793,526 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 6 OF 7

GULF SOUTH PIPELINE COMPANY, LP CALCULATION OF DEFERRED INCOME TAXES - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Line No. Deferred Income Taxes Year 1 Year 2 Year 3

1 Gas Plant In Service $ 36,880,077 $ 36,880,077 $ 36,880,077 2 Book Depreciation Rate 2.18% 2.18% 2.18% 3 Book Depreciation Expense $ 803,986 $ 803,986 $ 803,986

4 Tax Depreciation Rate 5.00% 9.50% 8.55% 5 Tax Depreciation $ 1,844,004 $ 3,503,607 $ 3,153,247

6 Difference $ (1,040,018) $ (2,699,622) $ (2,349,261) 7 Composite Income tax rate 25.9400% 25.9400% 25.9400%

8 Deferred Taxes $ (269,781) $ (700,282) $ (609,398) 9 Accumulated Deferred Income Taxes $ (269,781) $ (970,063) $ (1,579,461) GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19- -000 EXHIBIT N PAGE 7 OF 7

GULF SOUTH PIPELINE COMPANY, LP REVENUES - LAMAR COUNTY EXPANSION PROJECT, LEGACY FACILITIES

Daily Demand Line MDQ Primary Term Rate / MMBtu Commodity No. Shipper Service Type (MMBtu/day) (Yrs) (Negotiated) Rate Year 1 Year 2 Year 3

1 Cooperative Energy FTS 200,000 20 $ 0.1550 $ 0.0125 $ 11,953,750 $ 11,953,750 $ 11,953,750

2 Total Revenues $ 11,953,750 $ 11,953,750 $ 11,953,750 GULF SOUTH PIPELINE COMPANY, LP DOCKET NO. CP19-___-000 EXHIBIT P

TARIFF

TARIFF SHEETS – CLEAN Gulf South Pipeline Company, LP Section 4.17 FERC NGA Gas Tariff Currently Effective Rates – FLS Seventh Revised Volume No. 1 Pro Forma Version 2.0.0 Effective On:

This section includes effective rates for customer laterals, as described.

Gulf South Pipeline Company, LP Section 4.17.1 FERC NGA Gas Tariff Currently Effective Rates – FLS - Lamar County Customer Lateral Seventh Revised Volume No. 1 Pro Forma Version 0.0.0 Effective On:

Currently Effective Incremental Transportation Rates ($ per MMBtu) Rate Schedule FLS Lamar County Customer Lateral

Maximum Daily Reservation Charge (per Dth of MDQ) $0.0404 Minimum Daily Reservation Charge (per Dth of MDQ) $0.0000

Daily Commodity Charge (per Dth) $0.0000

Discounts cannot be granted on commodity charges.

The applicable 100% load factor rate shall be the applicable Maximum Daily Reservation Charge plus the applicable commodity charge.

The above charges shall be increased to include the incremental daily transportation charge(s) for utilization of any other Gulf South facilities, including charges for other Customer Laterals and/or charges identified in Section 4.1.

All of the above charges shall be increased to include the ACA unit charge pursuant to Section 6.9.1 of the General Terms and Conditions of this Tariff. Gulf South Pipeline Company, LP Section 4.18 FERC NGA Gas Tariff Currently Effective Rates - ILS Seventh Revised Volume No. 1 Pro Forma Version 2.0.0 Effective On:

This section includes currently effective rates for customer laterals, as described.

Gulf South Pipeline Company, LP Section 4.18.1 FERC NGA Gas Tariff Currently Effective Rates – ILS – Lamar County Customer Lateral Seventh Revised Volume No. 1 ProForma Version 0.0.0 Effective On:

Currently Effective Incremental Transportation Rates ($ per MMBtu) Rate Schedule ILS Lamar County Customer Lateral

Maximum Daily Commodity Charge (per Dth of MDQ) $0.0404 Minimum Daily Commodity Charge (per Dth of MDQ) $0.0000

Discounts cannot be granted below the Minimum Commodity Charge.

The above charges shall be increased to include the ACA unit charge pursuant to Section 6.9.1 of the General Terms and Conditions of this Tariff.

TARIFF SHEETS – MARKED

Gulf South Pipeline Company, LP Section 4.17 FERC NGA Gas Tariff Currently Effective Rates – FLS Seventh Revised Volume No. 1 Pro Forma Version 2.0.0 Effective On:

This section includes effective rates for customer laterals, as described.

Currently Effective Incremental Transportation Rates ($ per MMBtu) Rate Schedule FLS Customer Lateral

Maximum Daily Reservation Charge (per Dth of MDQ) $0.0000 Minimum Daily Reservation Charge (per Dth of MDQ) $0.0000 Daily Commodity Charge (per Dth) $0.0000

Discounts cannot be granted on commodity charges.

The applicable 100% load factor rate shall be the applicable Maximum Daily Reservation Charge plus the applicable commodity charge.

The above charges shall be increased to include an incremental daily transportation charge for the use of the remainder of the Gulf South system identified in Section 4.1.

All of the above charges shall be increased to include the ACA unit charge pursuant to Section 6.9.1 of the General Terms and Conditions and the applicable Fuel and Company-Used Gas allowance (inclusive of LAUF) as set forth in Section 4.22 of this Tariff.

Gulf South Pipeline Company, LP Section 4.17.1 FERC NGA Gas Tariff Currently Effective Rates – FLS - Lamar County Customer Lateral Seventh Revised Volume No. 1 Pro Forma Version 0.0.0 Effective On:

Currently Effective Incremental Transportation Rates ($ per MMBtu) Rate Schedule FLS Lamar County Customer Lateral

Maximum Daily Reservation Charge (per Dth of MDQ) $0.0404 Minimum Daily Reservation Charge (per Dth of MDQ) $0.0000

Daily Commodity Charge (per Dth) $0.0000

Discounts cannot be granted on commodity charges.

The applicable 100% load factor rate shall be the applicable Maximum Daily Reservation Charge plus the applicable commodity charge.

This section includes currently effective rates for customer laterals, as described.

Currently Effective Incremental Transportation Rates ($ per MMBtu) Rate Schedule ILS Customer Lateral

Maximum Daily Commodity Charge (per Dth of MDQ) $0.0000 Minimum Daily Commodity Charge (per Dth of MDQ) $0.0000

Discounts cannot be granted below the Minimum Commodity Charge.

The above charges shall be increased to include the ACA unit charge pursuant to Section 6.9.1 of the General Terms and Conditions and the applicable Fuel and Company-Used Gas allowance (inclusive of LAUF) as set forth in Section 4.22 of this Tariff.

Currently Effective Incremental Transportation Rates ($ per MMBtu) Rate Schedule ILS Lamar County Customer Lateral

Maximum Daily Commodity Charge (per Dth of MDQ) $0.0404 Minimum Daily Commodity Charge (per Dth of MDQ) $0.0000

Discounts cannot be granted below the Minimum Commodity Charge.

The above charges shall be increased to include the ACA unit charge pursuant to Section 6.9.1 of the General Terms and Conditions of this Tariff.