Pursuant to the Notice of Proposed Rulemaking issued September 21, 2006, the Interstate Natural Gas Association of America (“INGAA”) submits the following comments on the Commission’s proposals to amend its regulations pertaining to critical energy infrastructure information (“CEII”). INGAA represents the interstate and interprovincial natural gas pipeline industry operating in North America. INGAA’s United States members, which account for virtually all natural gas transported and sold in domestic interstate commerce, are regulated by the Commission pursuant to the Natural Gas Act, 15 U.S.C. §§ 717-717w.In the NOPR, the Commission proposes a number of changes designed to render its process for handling CEII requests more efficient, and offers some guidance to those who submit CEII materials on what the Commission accepts as CEII. INGAA offers the following comments on several of the specific Commission proposals.