INGAA requests that the Commission: (1) not impose a definite implementation date at this time to allow time for software development and testing, and continue to provide a testing site after implementation; (2) provide alternate procedures or a waiver of regulations in the event of an electronic system failure; and (3) clarify that interested parties may comment only on matters related to tariff revisions that are “appropriately designated and marked,” i.e., only on proposed changes. INGAA also proposed a number of technical amendments to the proposed regulations.
Related
Natural Gas & Power Industries’ Reliability Alliance:
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
