Pursuant to the Environmental Staff of the Federal Energy Regulatory Commission (“FERC” or “Commission”) Office of Energy Projects’ October 26, 2018 Notice of Availability of Draft Guidance for Horizontal Directional Drill Monitoring, Inadvertent Return Response, and Contingency Plans, the Interstate Natural Gas Association of America (“INGAA”) respectfully submits the following comments. INGAA supports FERC staff’s efforts to improve the quality and consistency of horizontal directional drill (“HDD”) plans filed with the Commission, and INGAA believes the FERC staff’s Draft Guidance document is a step in the right direction towards meeting this goal. INGAA is providing these targeted comments to help refine the Draft Guidance.