INGAA responds to the argument made by commenters that the elimination of a tax allowance for MLPs and potentially other pass-through entities must result in the expeditious return of excess ADIT to customers of such pipelines. For the reasons stated in INGAA’s comments, ADIT issues relating to MLPs and other pass-through entities should be deferred until the Commission rules on parties’ rehearing requests of the Revised Policy Statement and applies any new policy resulting from a rehearing order in individual pipeline rate proceedings. However, if the Commission chooses to render a ruling on this issue in this rulemaking proceeding, it should hold that to the extent MLPs or other pass-through entities are not permitted a tax allowance, current shippers are not entitled to any of the remaining accumulated deferred income taxes (“ADIT”) and related regulatory liabilities held by such entities. As discussed below, a mandatory return of these rate base credits as a tracked.
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