Regency Intrastate Gas, LLC v. Louisiana Tax Commission and Scott Meredith, Assessor of Caldwell Parish ( 2021 )

STATE OF LOUISIANA
COURT OF APPEAL
FIRST CIRCUIT
NUMBER
2021 CA 0271
REGENCY INTRASTATE GAS, LLC
VERSUS
LOUISIANA TAX COMMISSION AND
SCOTT MEREDITH, ASSESSOR OF CALDWELL PARISH
consolidated with
A
1
2021 CA 0272
t
REGENCY INTRASTATE GAS, LLC
l VERSUS
V LOUISIANA TAX COMMISSION AND
ROY ELROD, ASSESSOR OF FRANKLIN PARISH
consolidated with
2021 CA 0273
REGENCY INTRASTATE GAS, LLC
VERSUS
LOUISIANA TAX COMMISSION AND
GLEN KIRKLAND, ASSESSOR OF JACKSON PARISH
Decision Rendered: SEP 2 7 2021
APPEALED FROM THE
19th JUDICIAL DISTRICT COURT, SECTION 24
EAST BATON ROUGE PARISH, LOUISIANA
DOCKET NUMBERS 687, 353; 687, 354; 687, 355
HONORABLE DONALD JOHNSON, JUDGE
Angela W. Adolph Attorney for Plaintiff/Appellant
Baton Rouge, Louisiana Regency Intrastate Gas, LLC
Brian A. Eddington Attorney for Defendant/ Appellees
Baton Rouge, Louisiana Scott Meredith, Caldwell Parish
Assessor; Rod Elrod, Franklin Parish
Assessor; and Glen Kirkland, Jackson
Parish Assessor
Robert D. Hoffman, Jr. Attorneys for Louisiana Tax Commission
Drew Hoffman
Baton Rouge, Louisiana
BEFORE: McDONALD, THERIOT, AND HESTER, 33.
McDONALD, J.
In these consolidated cases, a taxpayer challenges the Louisiana Tax Commission' s
denial of the taxpayer's request for a reduction in the fair market value of the taxpayer's
pipeline property for tax year 2018 based on economic obsolescence. The taxpayer
appeals two district court judgments, which affirmed three Louisiana Tax Commission
decisions, which in turn affirmed three parish Board of Review decisions, which in turn
upheld the correctness of ad valorem property tax assessments by three parish assessors.
After review, we affirm one judgment, and affirm in part and vacate in part a second
judgment.
FACTUAL AND PROCEDURAL BACKGROUND
In 2018, Regency Intrastate Gas, LLC ( RIG) owned pipeline property that traversed
Caldwell, Franklin, and Jackson Parishes. When RIG filed its 2018 property tax returns in
these three parishes, it requested a 31. 04% reduction in its pipeline property's fair market
value based on economic obsolescence. Caldwell Parish Assessor Scott Meredith, Franklin
Parish Assessor Rod Elrod, and Jackson Parish Assessor Glen Kirkland ( the Assessors) each
denied RIG' s obsolescence reduction request.' The Caldwell, Franklin, and Jackson Parish
Boards of Review ( Boards of Review) 2 each rejected RIG' s challenge to the assessments.
RIG then appealed to the Louisiana Tax Commission ( LTC). After a hearing where the
parties presented documentary evidence and live testimony, the LTC issued three
decisions affirming the Boards of Review decisions upholding the Parish Assessors' 2018
assessments.
On September 3, 2019, RIG filed three petitions for judicial review of LTC' s
decisions in the district court, naming the LTC and the Assessors as defendants/ appellees.
The petitions were assigned Docket Number 687, 353 ( Caldwell suit); Docket Number
687, 354 ( Franklin suit); and, Docket Number 687, 355 ( Jackson suit). The Assessors filed
1 The Louisiana Tax Commission decisions note that the Caldwell Assessor applied a — 3. 97% reduction for
obsolescence to RIG' s Canehill compressor station but applied no reduction for RIG' s Caldwell Parish -sited
pipeline.
z The record shows the Caldwell, Franklin, and Jackson Parish Police Juries act as their respective parishes'
Boards of Review when a taxpayer protests the Parish Assessors' property assessments. See La. R.S.
47: 1931; 47: 1992( B), ( C), and ( D); accord TBM- WC Sabine, LLC v. Sabine Parish Board of Review, 17- 1189
La. App. 3 Cir. 7/ 18/ 18), 250 So. 3d 1075, 1077, n. 2.
2
an unopposed motion to transfer and consolidate the proceedings, which the district court
granted. The administrative record was filed into the consolidated district court record,
the parties filed briefs, and the district court held a review hearing.
On October 20, 2020, the district court signed a judgment in favor of the LTC,
captioned with only the Caldwell suit docket number, against the " petitioner," denying and
dismissing the petition for judicial review ( October judgment). The October judgment
pertinently stated:
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
Court finds in favor of the appellee/ respondent, Louisiana Tax Commission,
and against the petitioner. As such, the Petition for Judicial Review is
DENIED. The court finds that the Commission' s decision was neither
arbitrary nor capricious.
IT IS FURTHER ORDERED that the Petition for Judicial Review is
hereby DISMISSED, at Petitioner' s costs.
The district court granted RIG' s motion for appeal from the October judgment, and
signed the order of appeal without the necessity for posting bond on November 20, 2020.
On December 4, 2020, the district court signed a second ' amended and restated"
judgment in favor of the LTC, captioned with the Caldwell, Franklin, and Jackson suit
docket numbers, adding that the judgment was also in favor of the Assessors, specifically
against RIG as the petitioner, and denying and dismissing RIG' s petitions for judicial
review ( December judgment). The December judgment pertinently stated:
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
Court finds in favor of Appellees/ Respondents, Caldwell Parish Assessor Scott
Meredith, Franklin Parish Assessor Rod Elrod, Jackson Parish Assessor Glen
Kirkland, and the Louisiana Tax Commission, and against the
Appellant/ Petitioner, Regency Intrastate Gas, LLC. As such, the Petitions for
Judicial Review are DENIED. The Court finds the Louisiana Tax
Commission' s decisions were neither arbitrary nor capricious.
IT IS FURTHER ORDERED that the Petitions for [ Judicial] Review
are hereby DISMISSED, at Petitioner's costs.
RIG also appealed from the December judgment, and the district court granted the
second appeal.
3
APPELLATE JURISDICTION
Louisiana Constitution article VII, § 18( E) provides that the correctness of
assessments by the assessor shall be subject to review first by the parish governing
authority, then by the LTC or its successor, and finally by the courts, all in accordance with
procedures established by law. See La. R. S. 47: 1931; 47: 1992; 47: 1989; 47: 1998.
Louisiana Revised Statutes 47: 1998 authorizes judicial review of the correctness of a tax
assessment, and the Administrative Procedure Act, specifically La. R. S. 49: 964( F) and ( G),
govern the extent of that review. La. R. S. 49: 967( A); D90 Energy, LLC V. Jefferson Davis
Parish Bd. of Review, 20- 00200 ( La. 10/ 20/ 20), So. 3d , 2020 WL 6145158,
5. When reviewing a final decision of an agency, the district court functions as an
appellate court. Blue Cube Operations, LLC v. Assumption Parish Bd. of Review, 20- 0157
La. App. 1 Cir. 11/ 6/ 20), 315 So. 3d 887, 890. An aggrieved party may obtain review of
any final judgment of the district court by appeal to the appropriate court of appeal. La.
R. S. 49: 965.
Although the district court functions as an appellate court in reviewing tax
assessments, certain procedural rules applicable to a district court sitting in its original
capacity also apply to a district court when it functions in an appellate capacity under La.
R. S. 49: 965. E.g., see Bennett v. Louisiana Department of Insurance, 20- 0666 ( La. App. 1
Cir. 5/ 12/ 21), 2021 WL 1904583, * 2, n. 1 ( noting the First Circuit has consistently defined
a final judgment under La. R. S. 49: 965 according to Book II of the Louisiana Code of Civil
Procedure); Perdido Energy La., LLC v. Acadia Parish Bd. of Review, 20- 0962 ( La. App. 1
Cir. 3/ 30/ 21), 2021 WL 1207818, * 2 ( converting an appeal from an interlocutory judgment
rendered under La. R. S. 49: 965 to an application for supervisory writs). Generally, the
district court's jurisdiction over all matters in the case reviewable under the appeal is
divested, and that of the appellate court attaches, on the granting of the order of appeal
and the timely filing of the appeal bond. La. C. C. P. art. 2088( A). 3 Any judgment rendered
after the order granting the appeal is null if that judgment purports to address a matter
3 Although the legislature recently amended La. C. C. P. art. 2088, the amendment does not apply herein.
See 2021 La. Sess. Law Serv. Act 259, § 2.
0
which is at that time reviewable under the appeal. Hernandez v, Excel Contractors, Inc.,
18- 1091 ( La. App. 1 Cir. 3/ 13/ 19), 275 So. 3d 278, 283.
In this case, the district court rendered the October judgment in favor of only the
LTC and only in the Caldwell suit. Under La. C. C. P. art. 2088( A), after signing the order of
appeal from the October judgment, the district court was divested of jurisdiction over the
matter as it pertained to the LTC in the Caldwell suit. But, after signing the order of
appeal from the October judgment, the district court thereafter rendered the December
judgment purportedly in favor of the LTC and all three Assessors, and in the Caldwell,
Franklin, and Jackson suits. As to the LTC in the Caldwell suit, the district court had no
jurisdiction to render the December judgment. Thus, to the extent the December
judgment purports to again rule in favor of the LTC in the Caldwell suit, it is null as it
purports to address a matter already reviewable under the appeal of the October
judgment. See Hernandez, 275 So. 3d at 285 ( nullifying a district court order purporting to
dismiss claims under review in a then -pending appeal).
However, as to the Caldwell Assessor in the Caldwell suit, the district court retained
jurisdiction to render the December judgment, because that matter was not reviewable
under the appeal of the October judgment. See Damond v. Maru//o, 19- 0675 ( La. App. 1
Cir. 6/ 22/ 20), 307 So. 3d 234, 239, writ denied, 20- 01243 ( La. 3/ 23/ 21), 312 So. 3d 1104noting the district court retained jurisdiction over claims against one defendant after an
appeal was granted from a judgment ruling on claims against other defendants).
Similarly, as to the LTC in the Franklin and Jackson suits, and as to the Caldwell,
Franklin, and Jackson Assessors in those suits, the district court retained jurisdiction to
render the December judgment, because these matters were not reviewable under the
appeal of the October judgment. Accordingly, we conclude the October judgment is
properly before us as to the LTC in the Caldwell suit.4 The December judgment is properly
before us as to: ( 1) the Caldwell Assessor in the Caldwell suit; ( 2) the LTC and the
4 The October judgment is a partial final judgment immediately appealable under La. C. C. P. art. 1915( A)( 1),
because it dismissed a party ( the LTC) from the principal demand in the Caldwell suit and resolved all issues
between RIG and the LTC in that suit. Herrera v. First National Insurance Company of America, 15- 1097
La. App. 1 Cir. 6/ 3/ 16), 194 So. 3d 807, 811. The October judgment's failure to identify RIG as the
petitioner" against whom it is rendered is not fatal to the judgment's certainty, because RIG is easily
identifiable as the sole petitioner in the Caldwell suit. Accord Micken v. DHC OPCO-Napoleonville, LLC, 18-
0140 ( La. App. 1 Cir. 11/ 2/ 18), 2018 WL 5732482 * 2.
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Franklin Assessor in the Franklin suit; and, ( 3) the LTC and the Jackson Assessor in the
Jackson suit. Concomitantly, we vacate the December judgment insofar as it purports to
rule in favor of the LTC in the Caldwell suit. We now address the merits of RIG' s appeals.
STANDARD OF REVIEW
On review of a district court judgment rendered under La. R. S. 49: 965, the
appellate court owes no deference to the district court' s factual findings or legal
conclusions. Blue Cube Operations, LLC, 315 So. 3d at 890. Rather, the appellate court
conducts its own independent review of the administrative record and reviews the
administrative agency's decision and findings using the standards found in La. R. S.
49: 964( G). Id. Thus, we may affirm or remand the agency decision for further
proceedings. We may reverse or modify the decision if substantial rights of the appellant
have been prejudiced because the administrative findings, inferences, conclusion, or
decisions are: in violation of constitutional or statutory provisions; in excess of the
agency's statutory authority; made upon unlawful procedure; affected by other error of
law; arbitrary or capricious or characterized by an abuse of discretion or a clearly
unwarranted exercise of discretion; or, not supported by a preponderance of the evidence.
La. R. S. 49: 964( G)( 1)-( 6). This court shall make its own factual determinations by a
preponderance of the evidence based on its own evaluation of the record reviewed in its
entirety upon judicial review. La. R. S. 49: 964( G)( 6). In conducting this review, however,
this court affords considerable weight to an administrative agency' s construction and
interpretation of its rules and regulations, and the agency's construction and interpretation
should control unless found to be arbitrary, capricious, or manifestly contrary to its rules
and regulations. D90 Energy, LLC, So. 3d at ; 2020 WL 6145158 at * 5. Further,
this court shall give due regard to the administrative agency' s determinations regarding
witness credibility, where the agency had first-hand observation of a witness' s credibility
on the witness stand. La. R. S. 49: 964( G)( 6).
2
APPLICABLE LAWS AND ANALYSIS
Each assessor is charged with the responsibility of determining the fair market
value of all property subject to taxation within his parish or district at intervals of not more
than four years. Fair market value is determined in accordance with criteria established by
law and applied uniformly throughout the state. La. Const. art. VII, § 18( D). Fair market
value is the price for property which would be agreed upon between a willing and
informed buyer and a willing and informed seller under usual and ordinary circumstances;
it shall be the highest price estimated in terms of money which property will bring if
exposed for sale on the open market with reasonable time allowed to find a purchaser
who is buying with knowledge of all uses and purposes to which the property is best
adapted and for which it can be legally used. La. R. S. 47: 2321; LAC 61: V. 109. To ensure
uniformity, the LTC has adopted guidelines, procedures, rules, and regulations, which each
assessor shall follow in determining fair market value. La. R. S. 47: 2323( A) and ( B).
Louisiana Administrative Code Title 61, Pt. V, Chapter 13 contains the " Guidelines for
Ascertaining the Fair Market Value of Pipelines." LAC 61: V. 1301. Here, the parties do not
dispute that the subject pipeline property is valued using a cost approach based on
schedules found in LAC 61: V. 1307. See LAC 61: V. 1301( A). In using the cost approach,
the assessor values the property by estimating the replacement or reproduction cost of the
improvements and then deducting the estimated depreciation. La. R. S. 47: 2323( C)( 2);
LAC 61: V. 1301( A)( 2). The assessor shall also consider functional and/ or economic
obsolescence in the fair market value analysis, as substantiated by the taxpayer in writing.
LAC 61: V. 1301( A)( 2); LAC 61: V. 1305( F).
Although La. R. S. 47: 2324 requires the assessor to gather all data necessary to
properly determine fair market value of property in his jurisdiction, it is the party seeking a
fair market value reduction for its pipeline property based on obsolescence who has the
burden of producing sufficient data and information to substantiate its claim. TSM -WC
Sabine, LLC v. Sabine Parish Bd. of Review, 17- 1189 ( La. App. 3 Cir. 7/ 18/ 18), 250 So. 3d
1075, 1079. Consistent with La. R. S. 47: 1957, the assessor may request additional
5 Although the legislature recently amended several statutory provisions relevant to ad valorem taxation,
those amendments do not apply herein. See 2021 La. Sess. Law Serv. Act 343, § 3, approved June 15, 2021.
7
documentation. LAC 61: V. 1301( A)( 2).
The dispute in this case involves the Assessors' rejection of RIG' s request for a
31. 04% reduction in its pipeline property' s fair market value based on economic
obsolescence. In support of its request, RIG provided the Assessors with three
documents: RIGS Haynesville Partnership Co. 2017 financial statements ( 2017 Financial
Statements); an October 2017 Impairment Analysis performed by Pricewaterhouse
Coopers LLP for RIGS Haynesville Partnership Co. ( Impairment Analysis); and, an April
2018 sale agreement whereby two partners, Alinda Gas Pipeline I, LP, and Alinda Gas
Pipeline II, LP, ( Alinda I and II) sold their interest in RIGS Haynesville Partnership Co. for
25 million to a third partner, Regency Haynesville Intrastate Gas LLC ( April 2018
6
partnership interest sale). At the LTC hearing, the Assessors all testified that they
received and reviewed RIG' s evidence but considered it insufficient to warrant the
reduction for the 2018 tax year; they also presented the testimony of a property tax
appraisal witness, Rodney Kret. RIG presented the testimony of Mike Smith, its tax
representative, and of Brian Riley, a corporate official involved in RIG' s Texas and
Louisiana operations.'
On appeal to this court, RIG contends the LTC's decision was arbitrary and
capricious, because the LTC disregarded " competent evidence" showing that RIG' s 2018
valuation of its pipeline property, including the 31. 04% fair market value reduction, was
proper. RIG argues that the best evidence of the fair market value of any property is the
purchase price paid in a recent sale, and the 2018 purchase price of RIG' s property in this
case showed that its pipeline system' s throughput was significantly below capacity,
Pricewaterhouse Coopers LLP had written off about two-thirds of the value of RIG' s
property and doubted RIG' s viability as an ongoing concern, and RIG' s firm transportation
contracts with producers would expire in about two years.
6 Notes to the 2017 Financial Statements indicate that RIG is a wholly-owned subsidiary of RIGS Haynesville
Partnership Co., a Delaware partnership, formed in 2009 by Alinda I and II; Regency Haynesville Intrastate
Gas LLC, a wholly- owned subsidiary of Regency Gas Services LP; and EFS Haynesville, LLC. Regency Gas
Services LP is a wholly-owned subsidiary of Energy Transfer Partners, LP. As of December 31, 2017, RIGS
Haynesville Partnership Co. was 50% owned by Alinda I and II, 49. 99% owned by Regency Haynesville
Intrastate Gas LLC, and 0. 01% owned by EFS Haynesville, LLC.
On appeal, the LTC can accept additional evidence. La. R. S. 47: 1989; LAC 61: V. 3103; D90 Energy, LLC,
So. 3d at _; 2020 WL 6145158 at * 4.
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In its decisions, the LTC defined economic obsolescence as "'a diminution in value or
usefulness from economic factors, such as decreased demand or changed governmental
regulations." The LTC determined RIG' s economic obsolescence request was ' almost
entirely" based on the book value of the subject pipeline property. The LTC further
determined, however, that RIG' s reliance on book value as a measure of its pipeline
property' s fair market value was flawed, explaining:
Importantly, book value does not equate to fair market value.
Indeed, book value is the value at which an asset is carried on a balance
sheet, while fair market value is what a willing and informed buyer would
pay a willing and informed seller under usual and ordinary circumstances for
the asset. [ RIG' s] representative correctly stated during oral testimony that
book value is the Taxpayer' s viewpoint of what [ its] assets are worth."
From an appraisal or assessment perspective, there is no relationship
between book value, except by coincidence, and fair market value of an
individual asset, such as a pipeline system. As such, the [ LTC] finds that
RIG' s] request for a 31. 04% reduction for economic obsolescence based on
the book value of the subject pipeline to be unsubstantiated.
The LTC also discounted RIG' s alternative arguments that the upcoming expiration
of its firm transportation contracts in 2020 and the April 2018 partnership interest sale
supported its economic obsolescence request.
After our own evaluation of the record under La. R. S. 49: 964( G), we conclude the
LTC did not arbitrarily and capriciously disregard RIG' s obsolescence evidence. Rather, we
agree with the LTC and the Assessors that RIG' s data and information was insufficient to
warrant the 31. 04% reduction for the 2018 tax year. At the LTC hearing, RIG' s tax
representative, Mike Smith, while admitting the evidence was " hard to follow," earnestly
attempted to explain how the Impairment Analysis, which purportedly showed a 31. 04%
reduction in the value of RIG' s assets as of October 2017, justified using RIG' s book value
to determine the fair market value of its pipeline property for 2018. In contrast, the
Assessors' property tax appraisal witness, Rodney Kret, testified that book value rarely
equals fair market value, primarily because accountants and appraisers calculate
depreciation differently for the two values. Further, Mr. Kret questioned the
independence" of the Impairment Analysis and testified that an " impairment expense
was] not something [ he had seen] very often in the ... property tax appraisal world."
Apparently, the LTC relied upon Mr. Kret's professional opinion as a sound reason for
9
refusing to equate RIG' s internal book value with fair market value. We find no basis to
reverse this determination. See La. R. S. 49: 964( G).
Regarding the then upcoming expiration of RIG' s firm transportation contracts in
2020, RIG argues that the 2017 Financial Statements project a 50% drop in revenue as
soon as the contracts expire. According to RIG, a hypothetical willing buyer in 2018 would
have considered the imminent termination of the contracts in assessing the value of RIG' s
pipeline property, and the LTC ignored this fact in its denial of the economic obsolescence
request. At the LTC hearing, at least one LTC Commissioner questioned how future
revenue losses projected to occur in 2020 justified an economic obsolescence reduction for
the 2018 tax year. Further, the Assessors all generally testified that projected 2020
revenue losses would not impact 2018 property tax assessments. Although RIG argues
that the Uniform Standards of Professional Appraisal Practice rules require an assessor to
consider future economic conditions, RIG has provided no controlling authority that
requires Louisiana assessors or the LTC to follow these uniform standards. Giving
considerable weight to the LTC' s construction and interpretation of its rules and
regulations, we cannot find that the LTC acted arbitrarily, capriciously, or manifestly
contrary to its rules, based on the evidence before it, in refusing to consider RIG' s future
revenue losses in the determination of its pipeline property's 2018 fair market value.
Regarding the April 2018 partnership interest sale, RIG correctly points out that,
under LAC 61: V. 1305( G), an assessor should consider " properly documented" pipeline
sales as fair market value, provided the sale meets all tests relative to it being a valid sale.
The LTC determined RIG' s evidence was insufficient to prove that a " valid, arms -length
sale" of the pipeline property occurred for purposes of determining its fair market value.
After our own review of the sale contract, we agree. The April 2018 partnership interest
sale is not a pipeline sale at all; rather, it is the sale of a partnership interest in an entity of
which RIG apparently is a wholly-owned subsidiary. The sale contract does not clearly
indicate exactly what Alinda I and II sold to Regency Haynesville Intrastate Gas LLC for
25 million, and, as relevant herein, does not specifically indicate that RIG' s Caldwell,
Franklin, and Jackson Parish pipeline property was being sold at a specific value. Although
10
the sale did include the transfer of general partnership units, the sale document does not
define that term, but references a separate document not in the appellate record. Without
more information, we are unable to determine the value of the ' property" sold. Thus, we
conclude the sale of an undefined partnership interest does not establish fair market value
of pipelines as defined in La. R. S. 47: 2321 and LAC 61: V. 109. Contrast D90 Energy, LLC,
So. 3d at ; 2020 WL 6145158 at * 1, * 6, wherein the taxpayer proved the fair
market value of gas and salt water disposal wells with clear, documentary evidence and
live testimony establishing a valid, arms -length sale of the wells themselves.
In sum, based on the administrative record, and giving due regard to the LTC's
interpretation of its rules and to its witness credibility determinations, we conclude RIG
failed to carry its burden of proving entitlement to a fair market value reduction for its
pipeline property based on economic obsolescence for the 2018 tax year. See D90
Energy, LLC, So. 3d at; 2020 WL 6145158 at * 5; TBM- WC Sabine, LLC, 250 So. 3d
at 1079. We find no basis in La. R. S. 49: 964( G) requiring reversal of the LTC' s decisions.
The LTC' s decisions are legally supported by applicable statutory and administrative
authority and are factually supported by the record evidence.
CONCLUSION
We affirm the October 20, 2020 judgment in favor of the Louisiana Tax
Commission, and dismissing petitioner Regency Intrastate Gas, LLC' s petition for judicial
review against the Louisiana Tax Commission, in 19th Judicial District Court Number
687, 353.
We affirm the December 4, 2020 judgment insofar as it ruled in favor of Caldwell
Parish Assessor Scott Meredith, and dismissed Regency Intrastate Gas, LLC' s petition for
judicial review against Caldwell Parish Assessor Scott Meredith, in 19th Judicial District
Court Number 687, 353.
We also affirm the December 4, 2020 judgment insofar as it ruled in favor of the
Louisiana Tax Commission, Franklin Parish Assessor Rod Elrod, and Jackson Parish
Assessor Glen Kirkland, and dismissed Regency Intrastate Gas, LLC' s petitions for judicial
review in 19th Judicial District Court Numbers 687, 354 and 687, 355.
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We vacate the December 4, 2020 judgment insofar as it purported to rule in favor
of the Louisiana Tax Commission in 19th Judicial District Court Numbers 687, 353.
We assess appeal costs to Regency Intrastate Gas, LLC.
OCTOBER 20, 2020 JUDGMENT AFFIRMED; DECEMBER 4, 2020
JUDGMENT AFFIRMED IN PART AND VACATED IN PART.
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