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CONCLUSION

In sum, protestants evidence will demonstrate that

the ICC Section 19a valuation should be rejected as a rate

base for TAPS in favor of an original cost less depreciation

measure.

We will further show that the carriers are only en

titled to a return on that rate base commensurate with the ac

tual financial and business risks associated with the ownership

and operation of TAPS, and not with those attending the more

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FOR THE ARCTIC SLOPE REGIONAL CORPORATION

William W. Becker ist

0. Yale Lewis, Jr. Charles Goldmark Wickwire, Lewis, Goldmark

Dystel & Schoor 500 Maynard Building Seattle, Washington 98104

William W. Becker
Becker & French
1819 H Street, N.W.
Washington, D. C. 20006

Harold C. Petrowitz
Becker & French
1819 H Street, N.W.
Washington, D.C. 20006

CERTIFICATE OF SERVICE

I hereby certify that on this 15th day of December, 1977, I have caused to be served, a copy of the foregoing Joint Pre-Hearing Brief of the United States Department of Justice, the State of Alaska, and Arctic Slope Regional Corporation, and the Appendix thereto, upon all parties of record, by hand or by first class mail postage prepaid.

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JOINT PRE-HEARING BRIEF OF
THE UNITED STATES DEPARTMENT OF

JUSTICE, THE STATE OF ALASKA,
AND THE ARCTIC SLOPE REGIONAL CORPORATION

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