INGAA offers these comments in response to FERC’s Request For Comments (“Request”), issued December 2, 2004, in Docket No. PL05-5-000. INGAA is a national, non-profit trade association that represents virtually all of the major interstate natural gas transmission companies operating in the United States. The issues being considered by the Commission in this docket can have a significant impact on the ability of the natural gas pipeline industry to continue to attract capital to finance infrastructure development. The primary purpose of this submission is to provide the Commission with some technical tax and economic considerations about partnerships that it may not have considered previously.For the reasons set forth in this filing, INGAA respectfully requests the Commission to issue a policy statement clarifying that partnership pipelines, no matter the type of entities (i.e., LLC, LP, GP, LLP or MLP), are entitled to a tax allowance to recover the tax liability on the income generated by the regulated operations. The alculation of the tax allowance, specifically the tax rate to use for the partners, is a matter that can and should be resolved based on the specific facts of each pipeline partnership.