At the January 23, 2008 technical conference, the Commission Staff stated its intent to seek Commission approval for a round of reply comments in addition to the round of initial comments scheduled by the Commission. On January 31, 2008, the Commission issued its Notice of Opportunity for Filing Reply Comments. On February 11, 2008, all parties represented at the technical conference, except the State of Alaska, filed initial comments supporting their position, and opposing other parties’ positions. On February 20, 2008, the State of Alaska filed reply comments. In these comments, the State of Alaska critiqued the positions taken by INGAA, as well as the National Association of Publicly Traded Partnerships (“NAPTP”). The State of Alaska attached an affidavit from the same witness that appeared at the technical conference, Dr. Thomas Horst, who inter alia, purports to explain why the Benchmark Model submitted by INGAA’s expert, Dr. Vilbert, does not reliably estimate a Master Limited Partnership’s (“MLP”) return on equity.
By failing to provide its comments in the initial round of testimony, and instead waiting to file its critique of INGAA’s position in reply comments, the State of Alaska will have prevented INGAA from addressing its criticisms of Dr. Vilbert’s Benchmark Model unless INGAA is permitted to respond herein. In the interest of allowing all parties a fair opportunity to respond to criticisms of their positions and supporting expert opinions, INGAA requests the Commission to allow the filing of this response and the attached affidavit of Dr. Vilbert.
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