Standards for Business Practices of Interstate Natural Gas Pipelines Comments of INGAA 1-3-03

INGAA supports the Commission’s proposed adoption of the Version 1.6 Standards developed by the WGQ of NAESB. However, INGAA requests that the Commission modify the implementation timeline so that pipelines would implement the Version 1.6 Standards on the first of the month following 90 days after issuance of a final rule. INGAA notes that there may be individual pipelines that need additional time to implement the Version 1.6 Standards. INGAA asserts that it makes sense for these individual pipelines to file separately to request additional time so that they may ensure an orderly implementation of Version 1.6. INGAA requests that the Commission accommodate these pipelines on an individual basis.