UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION DOCKET NO. CP19-__-000 APPLICATION Exhibit F Location of Facilities Exhibit I Market Data Exhibit Y Accounting Treatment of Abandonment VOLUME I PUBLIC INFORMATION September 2019 September 23, 2019 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: Gulf South Pipeline Company, LP Enable Gas Transmission, LLC Abbreviated Application for a Certificate of Public Convenience and Necessity, Abandonment, Acquisition, and Related Authorizations Docket No. CP19-___-000 Dear Ms. Bose: Enable Gas Transmission, LLC (“Enable”) and Gulf South Pipeline Company, LP (“Gulf South”) (collectively “Applicants”) hereby submit for filing with the Federal Energy Regulatory Commission (“Commission”) an Abbreviated Application for a Certificate of Public Convenience and Necessity, Abandonment, Acquisition, and Related Authorizations (“Application”) pursuant to Section 7 of the Natural Gas Act (“NGA”), as amended, and Part 157 of the Commission’s regulations. Applicants request authorizations necessary for Enable to sell and Gulf South to purchase Enable’s undivided ownership interest (“Enable’s Interest”) in the Bistineau Gas Storage Facility (“Bistineau” or “Bistineau storage”) located in Bienville and Bossier Parishes, Louisiana. The consolidation will serve the public interest by increasing administrative efficiency; providing greater operational flexibility under a single FERC gas tariff; and providing Gulf South more flexibility to provide the marketplace additional storage capacity it desires through the integration of Enable’s Interest. To accomplish this, Applicants request that the Commission: (1) authorize Enable to abandon by sale its Interest in Bistineau to Gulf South; (2) authorize Gulf South to acquire Enable’s Interest by purchase and to operate it as part of its existing facilities, (3) authorize Enable to abandon by sale and Gulf South to acquire by purchase the cushion gas in situ currently owned by Enable at Bistineau; (4) reaffirm Gulf South’s ability to provide storage services in interstate commerce at market-based rates which would include existing Gulf South capacities at Bistineau plus the increased 8 Bcf of working gas capacity and 100,000 Mcf per day of withdrawal capacity purchased from Enable; (5) authorize Enable to abandon jurisdictional storage services provided from Bistineau under its Part 284 subpart G blanket certificate, issued in Docket No. CP82-384. (6) approve the accounting entries included as Exhibit Y which reflect these changes; and 9 Greenway Plaza, Ste. 2800 Houston, TX 77046 Tel. 713.479.8000 Gulf South Pipeline Company, LP Enable Gas Transmission, LLC September 23, 2019 Page 2 (7) (a) issue a waiver of the post and bid provisions of Section 6.8 of Gulf South’s tariff in order to permit the proposed FSS-B service agreement between the Applicants negotiated in the Agreement, to take effect on April 1, 2020 without modification and (b) issue any additional authorizations or waivers necessary to complete the proposed transfer of the Enable Interest. Pursuant to 18 C.F.R. §388.112 of the Commission's regulations, this Application consists of two volumes: VOLUME I: PUBLIC Public information, including the Application and Exhibits, except for Exhibit R which is designated Privileged; VOLUME II: PRIVILEGED Exhibit R1 is provided in Volume II, considered Privileged, and labeled “CUI//PRIV” and “CONTAINS PRIVILEGED INFORMATION – DO NOT RELEASE.” Pursuant to 18 C.F.R. § 388.112 of the Commission’s Regulations, Gulf South respectfully requests privileged treatment of Volume II. In accordance with the regulation, the information contained in Volume II and each page therein is provided and clearly labeled “CUI//PRIV” and “CONTAINS PRIVILEGED INFORMATION – DO NOT RELEASE” is being submitted to the Commission on September 23, 2019 and should maintain such designation for the life of the assets. As permitted by 18 C.F.R. § 388.112 of the Commission’s Regulations, Gulf South respectfully requests privileged treatment of Volume II because it contains certain commercially sensitive information and provides the commercial basis for the sale of the Enable Interest in Bistineau storage. Gulf South respectfully requests privileged treatment as it considers the agreement to be commercially sensitive and proprietary and thus exempt from mandatory public disclosure pursuant to the Freedom of Information Act, 5 U.S.C. 522. Gulf South is submitting the agreement in accordance with 18 C.F.R. Section 388.112 of the Commission’s Regulations. As a result, non- original copies of this application do not have Volume II. In accordance with the Commission’s filing guidelines, Applicants will provide hard copies of this filing to the Commission (two copies to OEP Room 62-46 and one copy to OGC-EP Room 101-56). Applicants have also included a Notice suitable for publication in the Federal Register. 1 Gulf South and Enable are providing the executed Purchase and Sale Agreement (“PSA”). The exhibits and schedules to the PSA have been excluded but will be made available to the Commission upon request. Gulf South Pipeline Company, LP Enable Gas Transmission, LLC September 23, 2019 Page 3 If you have any questions, please contact Kyle Stephens at (713) 479-8033 or by email at [email protected]. Sincerely, /s/ Michael E. McMahon Michael E. McMahon Senior Vice President & General Counsel Attachments UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Enable Gas Transmission, LLC ) Docket No. CP19-_____-000 Gulf South Pipeline Company, LP ) ABBREVIATED APPLICATION FOR CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY, ABANDONMENT AUTHORIZATION AND RELATED AUTHORIZATIONS Pursuant to Sections 7(b) and 7(c) of the Natural Gas Act (“NGA”), 15 U.S.C. §§ 717f(b) & 717f(c), as amended, and Parts 157 and 284 of the regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. Parts 157 and 284, Enable Gas Transmission, LLC (“Enable”) and Gulf South Pipeline Company, LP (“Gulf South”) submit an abbreviated application for a certificate of public convenience and necessity and abandonment authority authorizing Enable to sell and Gulf South to purchase Enable’s undivided ownership interest in the Bistineau Gas Storage Facility (“Bistineau” or “Bistineau storage”) located in Bienville and Bossier Parishes, Louisiana. Enable and Gulf South (collectively “Applicants”) submit this abbreviated application for authorizations necessary for Gulf South to acquire Enable’s undivided ownership interest in Bistineau (“Interest”)1 and consolidate the associated 8 billion cubic feet (“Bcf”) of working gas capacity and 100,000 Mcf per day of withdrawal capacity into Gulf South’s operations at Bistineau. Enable and Gulf South have entered into a Purchase and Sale Agreement dated September 23, 2019 (“Agreement”). A copy of the Agreement is submitted herewith in 1 Enable’s undivided interest includes, but is not limited to, recorded and unrecorded property rights, physical facilities such as wells, meters, pipelines, auxiliary facilities, and compressors, 7 Bcf of injected cushion natural gas and 2.5 Bcf of native cushion natural gas (collectively, “cushion gas”), and other rights as may be necessary to effectuate the transfer. See the Purchase and Sale Agreement in Exhibit R hereto. Exhibit R, Volume II and is marked “CUI//PRIV” and “CONTAINS PRIVILEGED INFORMATION – DO NOT RELEASE.” Gulf South requests pursuant to Section 388.112 of the Commission’s regulations 18 C.F.R. § 388.112, this document be treated as privileged information because it contains commercially sensitive, confidential information. Upon approval from the Commission and closing of the transaction, Gulf South will own and operate all of the Bistineau storage field. The consolidation will serve the public interest by increasing administrative efficiency; providing greater operational flexibility under a single FERC gas tariff; and providing Gulf South more flexibility to provide the marketplace additional storage capacity it desires through the integration of Enable’s Interest. This proposal will have no material effect on Enable’s customers and will not affect the nature or quality of Enable’s services as Enable operates its storage fields in aggregate as a complex. The Applicants have determined that this proposal will not affect the captive customers of Enable, Gulf South, or other pipeline systems. Since this proposal involves no construction or environmental disturbance, Applicants request that the Commission act as expeditiously as possible and approve this Application by January 16, 2020. This will ensure that Gulf South and Enable can complete the transfer by April 1, 2020, which aligns with the start of the storage injection season. Approving the Application in January will provide Gulf South the certainty to offer the new capacity to the marketplace in a timely manner. The traditional injection season on Gulf South begins on April 1 of each year and having an additional 60 days to market the capacity will provide customers the time necessary to align their business needs with the availability of this capacity. Providing enough time to arrange these supply and storage agreements preserves the value of the new capacity for the 2020 storage season. 2 In support of this abbreviated application, the Applicants submit the following information: I. DESCRIPTION OF APPLICANTS Enable’s exact name is Enable Gas