Sierrita is hereby submitting its responses to the April 3, 2018 OEMR Data Request questions.

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1 April 10, 2018 Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC Attention: Re: Ms. Kimberly D. Bose, Secretary Office of Energy Market Regulation Letter Order Pursuant to Sierrita Gas Pipeline LLC Docket No. CP Issued: April 3, 2018 Data Request Responses Commissioners: On April 3, 2018, Sierrita Gas Pipeline LLC ("Sierrita") received a data request ("Data Request") in Docket No. CP from the Office of Energy Market Regulation ( OEMR ) seeking information related to the Sierrita Compressor Expansion Project. Sierrita is herein filing with the Federal Energy Regulatory Commission ( Commission ) its responses to the Data Request. Description of Proceeding On December 21, 2017, Sierrita submitted its application, pursuant to Section 7(c) of the Natural Gas Act requesting a certificate of public convenience and necessity for authorization to construct, install, and operate a new compressor ( Sierrita Compressor Station ) to be located in Pima County, Arizona. The project is referred to as the "Sierrita Compressor Expansion Project." Description of Information Being Filed Sierrita is hereby submitting its responses to the April 3, 2018 OEMR Data Request questions. Filing Information Sierrita is e-filing this letter and response with the Commission's Secretary in accordance with the Commission's Order No. 703, Filing Via the Internet, guidelines issued on November 15, 2007 in Docket No. RM

2 Federal Energy Regulatory Commission -2- April 10, 2018 Respectfully submitted, SIERRITA GAS PIPELINE LLC /s/ William D. Wible Vice President, Regulatory Attachment

3 SIERRITA GAS PIPELINE LLC Response to OEMR Data Request Dated April 3, 2018 in Docket No. CP Sierrita Compressor Expansion Project Data Request: 1. On March 15, 2018, the Commission revised the 2005 Policy Statement on Income Tax Allowances (Revised Policy Statement, 162 FERC 61,226). Please update Sierrita s February 1 Data Response by addressing its proposed income tax allowance in the context of the Revised Policy Statement. 2. Identify Sierrita s proposed income tax allowance as part of its proposed cost of service. 3. If Sierrita is still proposing an income tax allowance as part of its proposed cost of service: a. Is Sierrita a Master Limited Partnership as the term is used in the Revised Policy Statement? b. Will Sierrita incur the proposed income tax allowance in its own name? c. If Sierrita will incur an income tax liability in its own name, please identify the state and federal tax codes under which the income tax liability will be incurred and business tax forms that Sierrita will use to report and pay its income tax liability. d. If Sierrita is a pass-through entity for income tax purposes, please explain why its proposal to include an income tax allowance will not result in a double recovery of income taxes. Response: 1. The Commission s Revised Policy Statement, issued March 15, 2018, addresses only Master Limited Partnerships ( MLPs ). Given that Sierrita is a limited liability company and that none of its parent companies are MLPs, the company has no updates to offer at this time. By way of further response (and as previously stated), Sierrita is proposing to utilize its existing recourse rates as initial maximum recourse rates for its proposed expansion of mainline capacity. It is for this reason that Sierrita demonstrated in its original December 21, 2017 filing that the estimated, negotiated rate transportation revenues associated with the proposed expansion (which are at or below the existing maximum recourse rates on a component basis) exceed the estimated costs associated with the expansion in each of the first three years of operation.

4 SIERRITA GAS PIPELINE LLC Response to OEMR Data Request Dated April 3, 2018 in Docket No. CP Sierrita Compressor Expansion Project As such, illustrative cost based rates for the expansion would remain less than the maximum recourse rates regardless of whether the December 21, 2017 estimated costs or the February 1, 2018 estimated costs are used. Therefore, as noted in Sierrita s February 1, 2018 data response, the updated lower cost estimates provided with that response have no impact on the merits of Sierrita s proposal to use the maximum recourse rates for the initial recourse rates of the expansion under the circumstances of this proceeding. 2. See response to Question No. 1 above. 3. a. See response to Question No. 1 above. Notwithstanding Sierrita s response to Question No. 1, Sierrita is not a Master Limited Partnership as the term is used in the Revised Policy Statement. b. See response to Question No. 1 above. c. See response to Question No. 1 above. d. See response to Question No. 1 above. Response prepared by or under the supervision of: William D. Wible Vice President, Regulatory

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6 Certificate of Service I hereby certify that I have this day caused a copy of the foregoing documents to be served upon each person designated on the official service list compiled by the Commission's Secretary in this proceeding in accordance with the requirements of Section of the Federal Energy Regulatory Commission's Rules of Practice and Procedure. Dated at Colorado Springs, Colorado as of this 10th day of April, /s/ Francisco Tarin Two North Nevada Avenue Colorado Springs, Colorado (719)