PUCAH INGAA Request for Clarification 5-24-06

December 8, 2005, the Commission issued Order No. 667,1 in which it amended its regulations to implement the repeal of the Public Utility Holding Company Act of 1935 and the enactment of the Public Utility Holding Company Act of 2005. On April 24, 2006, the Commission issued Order No. 667-A, its “Order on Rehearing.”2 The Commission’s new regulations impose certain requirements on those companies that fall within the definition of “holding company” as set forth therein.

In this filing INGAA requests clarification that a company that owns an interstate natural gas pipeline company, which pipeline makes deliveries to industrial customers and power plants and/or de minimis deliveries to farmers and/or ranchers located adjacent to the pipeline’s rights of way is not, due to such ownership, a “holding company” under the Commission’s PUHCA regulations.