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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.