McCombs v. Federal Energy Regulatory Commission

705 F.2d 1177, 78 Oil & Gas Rep. 601, 1980 U.S. App. LEXIS 12496
CourtCourt of Appeals for the Tenth Circuit
DecidedNovember 7, 1980
DocketNo. 75-1829
StatusPublished
Cited by3 cases

This text of 705 F.2d 1177 (McCombs v. Federal Energy Regulatory Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCombs v. Federal Energy Regulatory Commission, 705 F.2d 1177, 78 Oil & Gas Rep. 601, 1980 U.S. App. LEXIS 12496 (10th Cir. 1980).

Opinions

BARRETT, Circuit Judge.

The McCombs Group and E. I. du Pont de Nemours & Company petitioned for review of orders of the Federal Power Commission, now known as the Federal Energy Regulatory Commission. The Commission ordered the McCombs Group to deliver to the intervenor United Gas Pipe Line Company in interstate commerce natural gas produced from certain leases in Texas. In response to du Pont’s motion to dismiss for lack of Commission jurisdiction over du Pont, the Commission ruled it would not address the issue of its jurisdiction. This ruling, as a practical matter, kept du Pont before the Commission.

This Court’s first opinion, McCombs v. Federal Power Commission, 542 F.2d 1144 (10th Cir. 1976) was vacated. Following rehearing, we again set aside the Commission’s orders. McCombs v. Federal Energy Regulatory Commission, 570 F.2d 1376 (10th Cir. 1978) (Circuit Judge William J. Holloway, dissenting). The majority there held that the McCombs Group had abandoned de facto its interstate service and therefore could not be ordered to resume deliveries to the Pipe Line Company in interstate commerce. We did not reach the other issues raised by the petitioners. The United States Supreme Court unanimously re- ■ versed. In United Gas Pipe Line Co. v. McCombs, 442 U.S. 529, 99 S.Ct. 2461, 61 L.Ed.2d 54 (1979) the Supreme Court held that the McCombs Group could not, without .express prior approval from the Commission, abandon the interstate service rendered under the certificate of public convenience and necessity issued by the Commission to the McCombs Group’s predecessors in interest.

The case is before us now on remand from the Supreme Court for consideration of the remaining issues. The material facts relating to those issues are as follows:

In 1953, Bee Quin, as Seller, and the Pipe Line Company, as Buyer, executed a gas purchase contract whereunder the Buyer had rights to purchase the gas produced from wells on the “Butler B” tract, and a portion of the gas produced from any “unitized” lands which included part or all of the Butler B tract.1 Since such gas was to be resold in interstate commerce, Quin applied to the Commission for certificates of public convenience and necessity authorizing her to provide interstate service. The Commission issued certificates to Quin in 1954, and Quin sold gas for resale in interstate commerce under those certificates. In 1963 the Commission terminated the 1954 certificates and issued a new certificate authorizing Quin’s successors in interest to continue the interstate service which Quin had bdT gun.

In 1966 production from the Butler B' tract ceased, as, of course, did the deliveries to the Pipe Line Company. However, the 1953 gas purchase contract remained in effect; it would not expire until 1981. The McCombs Group succeeded to the working interest in Butler B. It pooled or unitized Butler B with the neighboring “Butler A” tract, drilled deep, producing wells on both tracts, and contracted to sell the gas to du Pont in intrastate commerce, du Pont purchased the gas for use in its Texas factories, du Pont did not transport or sell the gas in interstate commerce.

The Pipe Line Company discovered thajt the gas being sold to du Pont was the same» as that committed under the 1953 gas purl chase contract. In 1973 the Pipe Line Company filed a complaint with the Commission alleging a violation of the Natural Gas Act Respondents named in the complaint included the McCombs Group and du Pont. Proceedings before an administrative law judge and the Commission led to Commission Opinions No. 740 (54 F.P.C. 755 (1975)), No. 740-A (54 F.P.C. 2034 (1975)), and No. 740 — B (55 F.P.C. 202 (1976)). The Commission ruled, inter alia, that the McCombs Group violated the Natural Gas Act and [1180]*1180must deliver to the Pipe Line Company a portion of the gas produced from wells on Butler A. The Commission reasoned that because the McCombs Group operated Butler A and Butler B as a unit, a portion of the gas produced on Butler A was attributable to fields underlying Butler B and was dedicated to interstate commerce under the 1963 certificate of public convenience and necessity. The Commission ordered the McCombs Group to deliver or “pay back” to the Pipe Line Company volumes of gas equal to those previously delivered to du Pont.

The McCombs Group objected to these rulings in an application for rehearing. It claimed to have dissolved its unitized operation of Butler A and Butler B into the former, separate tracts, and that the dissolution was retroactive in effect. It argued that, because of the retroactive dissolution of the unit, gas produced from Butler A was not and never had been attributable to Butler B nor dedicated to interstate commerce under the 1963 certificate, and that the Pipe Line Company had no right to such gas. The McCombs Group also challenged the Commission’s authority to order any “paybacks” of gas to the Pipe Line Company. In addition, the McCombs Group made a specific proposal as to how the dispute should be resolved (which it termed a “settlement” even though the Pipe Line Company withdrew support from the proposal). The McCombs Group demanded that the Commission give prompt consideration to the proposal as an alternative to the Commission’s orders.

The Commission ruled that the record was not developed sufficiently to decide whether the McCombs Group’s proposal was a reasonable alternative disposition on the merits. The Commission did not respond to the argument that it lacked authority to order paybacks of gas.

The Commission on its own initiative further ruled that, while the Pipe Line Company made no claim that Butler A was dedicated to interstate commerce, nevertheless it was in the public interest to determine whether this might be so. Therefore the Commission divided the proceedings into Phase I for consideration of the possible dedication of Butler A to interstate commerce, and Phase II, for consideration of all other issues including the effect of the McCombs Group’s purported dissolution of the Butler A-Butler B unit. The Commission directed the administrative law judge to schedule and decide Phase I on an expedited basis. Common sense dictated that Phase I be decided before Phase II, because, as recognized by the Commission, if both Butler A and Butler B were dedicated to the Pipe Line Company in interstate commerce, the difficult issues raised by the McCombs Group’s purported dissolution of the Butler A-Butler B unit were academic.

Even so, the Commission did address the dissolution issues at length without awaiting the decision on Phase I. It ruled it would not recognize the dissolution of the Butler A-Butler B unit for purposes of the Natural Gas Act. Therefore, in the Commission’s view, the Pipe Line Company was entitled to all gas attributable to Butler B, whether such gas was produced from wells located on Butler B or wells on Butler A.

Meanwhile du Pont made motions, first before the administrative law judge and then before the Commission, to be dismissed from the proceedings on the ground that it was not subject to Commission jurisdiction. The Commission ruled that it would not decide whether it had jurisdiction over du Pont. The Commission believed that if events took their expected course, the jurisdictional issue could likely be avoided, du Pont again raised the jurisdictional issue in its application for rehearing. The Commission, however, declined to address it.

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Related

Public Service Co. v. City of Albuquerque
755 F. Supp. 1494 (D. New Mexico, 1991)
McCombs v. Federal Energy Regulatory Commission
710 F.2d 611 (Tenth Circuit, 1983)

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Bluebook (online)
705 F.2d 1177, 78 Oil & Gas Rep. 601, 1980 U.S. App. LEXIS 12496, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccombs-v-federal-energy-regulatory-commission-ca10-1980.