Proxy Group INGAA Reply Comments 9-19-07

In response to the Commission’s “Proposed Policy Statement,” issued on July 19, 2007, the Interstate Natural Gas Association of America (“INGAA”) hereby submits comments in reply to other parties that have filed initial comments in this proceeding.  Specifically, INGAA responds primarily to parties that (1) oppose the Commission’s proposal to include Master Limited Partnerships (“MLPs”) in the proxy group used to establish rates of return on equity (“ROE”) for natural gas pipelines under the Discounted Cash Flow (“DCF”) methodology; and/or (2) support the Commission’s proposal to cap MLP distributions included in the DCF formula at or below an MLP’s earnings.