On May 19, 2008 INGAA submitted comments in response to a Notice of Proposed Rulemaking ("NOPR") issued by the Pipeline and Hazardous Materials Safety Administration ("PHMSA") to promulgate regulations that would establish eligibility standards enabling certain natural gas transmission pipelines to operate at an increased maximum allowable operating pressure (“MAOP”). INGAA supported the rulemaking in concept, but requested that PHMSA (1) accord “grandfather” status to all previously issued “Special Permits”, and (2) allow all pending applications to proceed on their own merits, without exposing currently permitted projects or pending applications to the standards that emerge from this rulemaking proceeding.