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INGAA and the DEGT Pipelines, the Intervenors in Support of Respondent (hereinafter “Intervenors”), adopt the Commission’s statement of the ROFR issue:
Whether the Commission reasonably concluded that no term-matching cap was necessary for the right of first refusal because existing regulatory controls prevent the exercise of pipeline market power, and a term cap would distort the market and preclude the efficient allocation of capacity to the shipper valuing it the most.