NRECA filed joint reply comments along with several other trade associations at FERC on July 26, 2019, in the proceeding captioned Inquiry Regarding the Commission's Policy for Determining Return on Equity, FERC Docket No. PL19-4-000. The reply comments are supported by expert testimony of two witnesses, Bradford Cornell and Michael Gorman.
NRECA filed joint opening comments in this proceeding on June 26, also supported by expert testimony. A copy of those comments is available on the NRECA website here or on FERC's eLibrary here.

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