{"operation":"document","citation":"PI-19-0011","title":"Iowa Utilities Board — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-10-17","effective_on":null,"summary":"PI-19-0011 response to Iowa Utilities Board concerning 192.1013.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/72651/iowa-utilities-board-pi-19-0011-10-17-2019-part-1921013.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nOCT }7 2019\nMr. Magid Yousif\nUtilities Regulation Engineer\nSafety and Engineering Section\nIowa Utilities Board\n13 75 E. Court Avenue\nDes Moines, IA 50319-0069\nDear Mr. Yousif:\nIn a July 19, 2019, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you asked whether the Iowa Utilities Board (Board) has the authority to grant a\ndeviation from the atmospheric corrosion inspection frequency requirements in 49 CFR\n§192.481, as provided for in §192.1013.\nIn your letter, you provided that on June 16, 2017, Alliant Energy-Interstate Power and Light\nCompany (IPL) filed a request with the Board to revise its atmospheric corrosion inspection\nfrequency for its gas distribution system. If granted, you stated that IPL requested approval to\ndeviate from the periodic inspection requirements of§ 192.481 by performing atmospheric\ncorrosion inspections from at least once every three calendar years, but with intervals not\nexceeding 39 months to at least once every four calendar years, but with intervals not exceeding\n51 months. You further stated, that IPL also proposed to maintain or improve safety by\naccelerating the frequency of distribution system leak surveys from every five years to every four\nyears.\nAccording to your letter, IPL filed a response with the Board on May 6, 2019, clarifying that it\nsought a deviation to inspection intervals under 49 CFR §192.1013. You stated that IPL noted\nthat § 192.1013 allows the Board to accept a pipeline operator's proposal to reduce the frequency\nof periodic inspections under its own authority. In response to this clarification, the Board issued\nan \"Order Addressing Waiver and Directing Letter to the Pipeline and Hazardous Materials\nSafety Administration\" on June 27, 2019, directing Board staff to send a letter to PHMSA\nrequesting a response regarding the authority of the Board to grant a deviation pursuant to\n§192.1013. You stated that the Board wants to ensure the approved waiver does not violate its\nagreement with PHMSA, nor does the Board want to require IPL to comply with conditions that\nmay not be necessary for the deviation in the frequency of periodic inspections.\nSection 192.1013 states:\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\n§ 192.1013 When may an operator deviate from required periodic inspections under this\npart?\n(a) An operator may propose to reduce the frequency of periodic inspections and tests\nrequired in this part on the basis of the engineering analysis and risk assessment required\nby this subpart.\n(b) An operator must submit its proposal to the PHMSA Associate Administrator for\nPipeline Safety or, in the case of an intrastate pipeline facility regulated by the State, the\nappropriate State agency. The applicable oversight agency may accept the proposal on its\nown authority, with or without conditions and limitations, on a showing that the\noperator's proposal, which includes the adjusted interval, will provide an equal or greater\noverall level of safety.\n( c) An operator may implement an approved reduction in the frequency of a periodic\ninspection or test only where the operator has developed and implemented an integrity\nmanagement program that provides an equal or improved overall level of safety despite\nthe reduced frequency of periodic inspections.\nFirst, the regulations in subpart P of part 192, including §192.1013, prescribe the minimum\nrequirements for a gas distribution integrity management program (DIMP). In connection with\nan operator's DIMP, § 192.1013 ( a) is clear in allowing an operator to propose a reduction in the\nfrequency of inspections and tests required in part 192, provided that the operator completes an\nengineering analysis and risk assessment required by subpart P and ensures an equivalent or\nimproved level of safety through its DIMP. Second, §192.1013(b) specifies that such a proposal\nmust be submitted to PHMSA or the appropriate State agency. In the present case, the Board\nmay accept IPL's proposal on its own authority, with or without conditions or limitations, on a\nshowing that IPL's proposal will provide an equal or greater level of safety and otherwise\ncomplies with§ 192.1013. Third, PHMSA's review of the Board's acceptance of any such\nproposal is not required, differentiating it from the requirements of 49 USC 60118(d).\nTherefore, it is PHMSA's interpretation that as the appropriate State agency for the intrastate\npipeline, the Board may accept or deny ILP's proposal on its own authority in accordance with\n§192.1013(b).\nlfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\n0\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nGeri D. Huser, Chair\nNick Wagner, Board Member\nRichard W. Lozier, Jr., Board Member\nJuly 19, 2019\nMr. Alan K. Mayberry\nAssociate Administrator for Pipeline Safety\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nUnited States\nDear Mr. Mayberry,\nOn June 16, 2017, Alliant Energy-Interstate Power and Light Company (IPL) filed a\nrequest with the Iowa Utilities Board (Board) to revise its atmospheric corrosion\ninspection frequency. IPL requested permission to deviate from the periodic inspection\nrequirements contained in 49 CFR 192.481. In the request, IPL sought approval to\nperform atmospheric corrosion inspections at least once every four calendar years, but\nwith intervals not exceeding 51 months. At the same time, to maintain or improve\nsafety, IPL will accelerate the frequency of distribution system leak surveys from every\nfive years to every four years.\nThe Board is the agency responsible for administering the pipeline safety programs of\nthe State of Iowa, and for enforcement of the natural gas pipeline safety standards of 49\nCFR Parts 192, 193 and 199 under certification granted by the U.S. Department of\nTransportation (DOT) pursuant to 49 U.S.C.S. 60105. Under 49 U.S.C. § 60118(d), the\nBoard must provide the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) with written notice of the waiver and allow at least 60 days for PHMSA review\nand opportunity for objection before the grant of waiver can become effective.\n49 CFR 192.1013 gives the operator an option to reduce the frequency of periodic\ninspections and tests required for atmospheric corrosion inspections on the basis of the\nengineering analysis and the required risk assessment. The operator must submit its\nproposal to PHMSA or to the appropriate state agency. The applicable oversight\nagency may accept the proposal on its own authority, with or without conditions and\nlimitations, on a showing that the operator's proposal, which includes the adjusted\ninterval, will provide an equal or greater overall level of safety.\nOn February 6, 2019, the Board issued an order granting IPL’s atmospheric corrosion\nwaiver request. On April 29, 2019, the Board issued an order stating that the waiver\napproval by the Board was required to be forwarded to PHMSA for review and approval\nin accordance to 49 U.S.C . § 60118(d).\n1375 E. Court Ave. | Des Moines, Iowa 50319-0069 | 515.725.7300 | Email: iub@iub.iowa.gov | Fax 515.725.7399\niub.iowa.gov\nTo see what state Government is accomplishing for Iowans, go to: www.resultsiowa.org\n\n<<<PAGE 4>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nPage 2 of 2\nOn May 6, 2019, IPL filed a response to April 29, 2019 order. In its response, IPL\nstated that it has not requested and does not intend to request a waiver of the federal\npipeline safety rules. IPL states that it sought a deviation to inspection intervals under\n49 CFR 192.1013. According to IPL, the federal rule allows the Board to accept a\npipeline operator’s proposal to reduce the frequency of periodic inspections on its own\nauthority.\nOn June 27, 2019, the Board issued an “Order Addressing Waiver and Directing Letter\nto the Pipeline and Hazardous Materials Safety Administration” directing Board staff to\nsend a letter to PHMSA requesting a response regarding the authority of the Board to\ngrant a deviation pursuant to 49 CFR 192.1013. The Board wants to ensure the\napproved waiver doesn’t violate its agreement with PHMSA, nor does the Board want to\nrequire IPL to comply with conditions that may not be necessary for the deviation in the\nfrequency of periodic inspections.\nThis letter is being sent in compliance with the Board’s June 27, 2019 order. PHMSA is\nrequested to provide a response regarding the Board’s authority to grant a deviation\npursuant to 49 CFR 192.1013. A copy of the Board’s April 29 and June 27, 2019\norders, and the response filed by IPL on May 6, 2019, are attached to this letter for\nreference.\nIf you have any questions, please feel free to contact me at (515) 725-7315 or at\nmagid.yousif@iub.iowa.gov.\nSincerely,\n/s/ Magid Yousif\nMagid Yousif\nUtilities regulation Engineer\nSafety and Engineering Section\nIowa Utilities Board\ncc. Samantha Norris, General Counsel\nAttachments\n\n<<<PAGE 5>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on June 27, 2019, RG-0150\nSTATE OF IOWA\nDEPARTMENT OF COMMERCE\nUTILITIES BOARD\nIN RE:\nINTERSTATE POWER AND LIGHT\nCOMPANY\nDOCKET NO. RG-0150\nORDER ADDRESSING WAIVER AND DIRECTING LETTER TO THE PIPELINE\nAND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n(Issued June 27, 2019)\nPROCEDURAL BACKGROUND\nOn February 6, 2019, the Utilities Board (Board) issued an order in Docket No.\nSPU-2018-0007 and Docket No. RG-0150, and other unrelated dockets, which\nincluded approval of a request filed on June17, 2017, by Interstate Power and Light\nCompany (IPL) to revise IPL’s atmospheric corrosion inspection frequency as\nprovided in 49 CFR 192.1013. On April 29, 2019, the Board issued an order stating\nthat the waiver approval by the Board was required to be forwarded to the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) for review and approval. In\nthe April 29, 2019 order, the Board identified certain conditions that the Board was\nconsidering applying to the waiver when the waiver was sent to PHMSA for review.\nOn May 6, 2019, IPL filed a response to April 29, 2019 order. In its response,\nIPL stated that it has not and does not intend to seek a waiver of the federal pipeline\nsafety rules. IPL states that it sought a deviation to inspection intervals under 49\nCFR 192.1013. According to IPL, the federal rule allows for a state agency, such as\n\n<<<PAGE 6>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on June 27, 2019, RG-0150\nDOCKET NO. RG-0150\nPAGE 2\nthe Board, to accept a pipeline operator’s proposal to reduce the frequency of\nperiodic inspections on the agency’s own authority.\nIPL interprets the language in 49 CFR 192.1013(a) not to require review or\napproval by PHMSA. The language in the federal rule states: “An operator may\npropose to reduce the frequency of periodic inspections and tests required in this part\non the basis of engineering analysis and risk management assessment required by\nthis subpart.” Paragraph 49 CFR 192.1013(b) requires the operator to submit its\nproposal, that involves intrastate facilities, to PHMSA or to a state agency, and the\nstate agency may accept the proposal with or without conditions.\nIPL asserts that the language in 49 CFR 192.1013 allows the Board to grant\nthe deviation without PHMSA approval and IPL does not consider the conditions\ndescribed in the April 29, 2019 order to be appropriate. IPL states if further\ndiscussion is needed, a meeting at which the Office of Consumer Advocate (OCA), a\ndivision of the Iowa Department of Justice, participates would be welcomed, and IPL\nsuggests participation of other natural gas pipeline companies may also be helpful.\nBOARD DISCUSSION\nThe Board has considered the provisions of 49 CFR 192.1013 and its\nrelationship to the provisions in 29 USC § 60118(d) that states:\n“If a certification under section 60105 of this title or an agreement\nunder section 60106 of this title is in effect, the State authority may\nwaive compliance with a safety standard to which the certification or\nagreement applies in the same way and to the same extent the\nSecretary may waive compliance under subsection (c) of this section.\n\n<<<PAGE 7>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on June 27, 2019, RG-0150\nDOCKET NO. RG-0150\nPAGE 3\nHowever, the authority must give the Secretary written notice of the\nwaiver at least 60 days before its effective date. If the Secretary\nmakes a written objection before the effective date of the waiver, the\nwaiver is stayed. After notifying the authority of the objection, the\nSecretary shall provide a prompt opportunity for a hearing. The\nSecretary shall make the final decision on granting the waiver.”\nThis section of the federal statute requires the Board to send any\nwaiver request approved by the Board to PHMSA. The regulation cited by\nIPL, 49 CFR 192.1013, appears to allow the Board to approve a deviation\nfrom periodic inspection requirements without requesting PHMSA approval.\nThe Board does not want to be in violation of the agreement with PHMSA to\nact as an agent for inspections of natural gas pipelines, nor does the Board\nwant to require IPL to comply with conditions that may not be necessary for\nthe deviation in the frequency of periodic inspections.\nTo address this conflict, the Board will direct its Safety & Engineering\nmanager to prepare and send a letter to PHMSA outlining the issue. The\nletter will be filed in this docket, as will any response received from PHMSA.\nOnce the Board has a response from PHMSA, the Board will determine if it\nneeds to make a formal request from PHMSA to approve the waiver, or if the\nissue has been resolved pursuant to 49 CFR 192.1013.\nThe Board does not consider a meeting with OCA and other pipeline\ncompanies necessary at this time since the issue is for PHMSA to address.\n\n<<<PAGE 8>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on June 27, 2019, RG-0150\nDOCKET NO. RG-0150\nPAGE 4\nORDERING CLAUSES\nIT IS THEREFORE ORDERED:\n1. The Utilities Board Safety & Engineering manager shall prepare and\nsend a letter to the Pipeline and Hazardous Materials Safety Administration that\nrequests a response regarding the authority of the Utilities Board to grant a deviation\npursuant to 49 CFR 192.1013 of the frequency of periodic inspections. A copy of this\norder, a copy of the April 29, 2019 order issued by the Utilities Board, and the\nresponse filed by Interstate Power and Light Company on May 6, 2019, shall be\nattached to the letter.\n2. A copy of the letter shall be uploaded into this docket along with any\nresponse.\nUTILITIES BOARD\n/s/ Geri D. Huser\n/s/ Nick Wagner\nATTEST:\n/s/ Kelsie Vanderflute /s/ Richard W. Lozier, Jr.\nDated at Des Moines, Iowa, this 27th day of June, 2019.\n\n<<<PAGE 9>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on April 29, 2019, RG-0150\nSTATE OF IOWA\nDEPARTMENT OF COMMERCE\nUTILITIES BOARD\nIN RE:\nINTERSTATE POWER AND LIGHT\nCOMPANY\nDOCKET NO. RG-0150\nORDER DIRECTING RESPONSE\n(Issued April 29, 2019)\nOn February 6, 2019, the Utilities Board (Board) issued an order which\nincluded approval of a request filed on June17, 2017, by Interstate Power and Light\nCompany (IPL) to revise IPL’s atmospheric corrosion inspection frequency as\nprovided for in 49 CFR 192.1013. To complete the approval process, the Board is\nrequired to provide to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) written notice of the waiver and allow PHMSA 60 days to review and\napprove or object to the waiver.\nIn a similar waiver request approved by the Illinois Commerce Commission\n(ICC), PHMSA approved a waiver request with certain conditions. The conditions\nwere as follows:\n1. Outside of business districts, an atmospheric corrosion inspection must be\nconducted at least once every four calendar years at intervals not\nexceeding 51 months.\n2. Inside of business districts, an atmospheric corrosion inspection must be\nconducted at least once every calendar year at intervals not exceeding 15\nmonths.\n\n<<<PAGE 10>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on April 29, 2019, RG-0150\nDOCKET NO. RG-0150\nPAGE 2\n3. Identify, inspect, and notify the Board of additional areas where there are\ngreater corrosion rates requiring monitoring more frequently than once\nevery three calendar years. These areas include “hot spots” where there\nare greater atmospheric corrosion rates, including:\na. above-ground pipelines where there is greater exposure to road\nsalts and chemicals;\nb. areas where pipelines could have accelerated atmospheric\ncorrosion due to industrial chemicals in the atmosphere;\nc. pipelines that may experience sweating due to pressure drop,\nsuch as regulator stations, metering correctors, and large\ncustomers’ regulator/meter sets;\nd. inside regulator/meter sets that are subject to corrosive\nenvironments;\ne. other areas that show accelerated atmospheric corrosion; and\nf. above-ground facilities under insulation.\n4. Continue to train and qualify meter readers to report atmospheric\ncorrosion as well as any abnormal operating conditions discovered when\nreading gas meters.\nSince PHMSA has approved a similar waiver based upon the conditions listed\nabove, the Board considers it necessary to add these conditions to the waiver\nrequest the Board approved in Docket No. RG-0150. Before adding the conditions\nas part of the waiver request and sending the waiver with the conditions to PHMSA,\nthe Board will provide IPL an opportunity to file a response to the conditions and\naddress whether the conditions are consistent with IPL’s waiver request.\n\n<<<PAGE 11>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on April 29, 2019, RG-0150\nDOCKET NO. RG-0150\nPAGE 3\nIT IS THEREFORE ORDERED:\nInterstate Power and Light Company shall file a response regarding the\nconditions to the waiver request described in this order on or before May 13, 2019.\nUTILITIES BOARD\n/s/ Geri D. Huser\n/s/ Nick Wagner\nATTEST:\n/s/ Kelsie Vanderflute /s/ Richard W. Lozier, Jr.\nDated at Des Moines, Iowa, this 29th day of April, 2019.\n\n<<<PAGE 12>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on May 6, 2019, RG-0150\nSTATE OF IOWA\nBEFORE THE IOWA UTILITIES BOARD\nIN RE:\nINTERSTATE POWER AND LIGHT\nCOMPANY\nDOCKET NO. RG-0150\nRESPONSE TO ORDER\nCOMES NOW, Interstate Power and Light Company (IPL) and submits this\nResponse to the Iowa Utilities Board (Board) Order Directing Response issued on April\n29, 2019.\nProcedural History\nOn June 6, 2017, IPL filed a request with the Board to revise the frequency of\natmospheric corrosion inspections.\nOn March 28, 2018, the Board consolidated IPL’s request in the above-\nreferenced docket with tariff proceedings for IPL’s proposed non-standard meter\nalternatives (NSMA), initially filed in Docket Nos. TF-2018-0029 and TF-2018-0030.\nThe NSMA tariffs and IPL’s atmospheric corrosion inspection request were\nsubsequently consolidated with NSMA-related complaint files (C-2018-0006, C-2018-\n0007, C-2018-0008) into Docket No. SPU-2018-0007, via Board order issued July 30,\n2018.\nOn February 6, 2019, the Board issued its Final Order and Decision in Docket\nNo. SPU-2018-0007 (February 6 Order), which included approval of IPL’s June 17,\n2017 request to revise atmospheric corrosion inspection frequency, as provided for in\n49 CFR § 192.1013. Ordering Paragraph 8 stated:\n\n<<<PAGE 13>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on May 6, 2019, RG-0150\n8. Interstate Power and Light Company’s request to modify its inspection\nfrequency for atmospheric corrosion for intrastate pipelines, as filed in Docket\nNo. RG-0150 on June 16, 2017, is approved.\nThe Board issued a subsequent order on April 29, 2019, in Docket No. RG-0150, (April\n29 Order) seeking additional information from IPL, and indicating the Board’s belief that\nit is required to provide the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) with notice of the waiver and allow PHMSA 60 days to review and approve or\nobject to the waiver.\nResponse\nIPL has not sought, and does not intend to seek a waiver of federal pipeline\nsafety rules; rather IPL sought a deviation to inspection intervals under 49 CFR Subpart\nP, Gas Distribution Pipeline Integrity Management, specifically §192.1013. This federal\nrule allows for an applicable oversight agency (in this case, the Board) to accept a\npipeline operator’s (in this case, IPL’s) proposal to reduce the frequency of periodic\ninspections on its own authority.\n§192.1013 When may an operator deviate from required periodic\ninspections under this part?\n(a) An operator may propose to reduce the frequency of periodic inspections\nand tests required in this part on the basis of the engineering analysis and\nrisk assessment required by this subpart.\n(b) An operator must submit its proposal to the PHMSA Associate\nAdministrator for Pipeline Safety or, in the case of an intrastate pipeline\nfacility regulated by the State, the appropriate State agency. The\napplicable oversight agency may accept the proposal on its own authority,\nwith or without conditions and limitations, on a showing that the operator's\nproposal, which includes the adjusted interval, will provide an equal or\ngreater overall level of safety.\n(c) An operator may implement an approved reduction in the frequency of a\nperiodic inspection or test only where the operator has developed and\nimplemented an integrity management program that provides an equal or\n2\n\n<<<PAGE 14>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on May 6, 2019, RG-0150\nimproved overall level of safety despite the reduced frequency of periodic\ninspections.\n(Emphasis added).\nThe above-referenced federal rule language, codified on December 4, 2009,\nallows a pipeline operator to propose a deviation from required periodic inspections.\nIPL does not interpret 49 CFR §192.1013(a) to require review or approval by PHMSA.\nThe Board’s April 29 Order references a waiver which the Illinois Commerce\nCommission (ICC) obtained from PHMSA to approve a waiver request from Ameren\nCompanies related to atmospheric corrosion surveys. However, that request was\ngranted in 2006, prior to the adoption of the rule language noted above, which provides\nthe option of requesting a deviation from required periodic inspections from the\napplicable state oversight agency.\nIn light of the 2009 rule change, IPL does not believe a waiver from PHMSA is\nrequired. If additional information is needed or further discussion of the federal rule is\nwarranted, IPL respectfully requests that the Board permit a meeting between Board\nStaff and IPL. IPL also welcomes participation by the Office of Consumer Advocate\n(OCA), and suggests that it may also be useful to notice the meeting to other natural\ngas utilities in Iowa.\n3\n\n<<<PAGE 15>>>\n\nFiled with the Iowa Utilities Board on July 19, 2019, RG-0150\nFiled with the Iowa Utilities Board on May 6, 2019, RG-0150\nWHEREFORE, IPL respectfully requests that the Board accept this response to\nits April 29 Order and let the February 6 Order stand; or, in the alternative, permit a\nmeeting between IPL and Board Staff to discuss the federal rule language.\nDated: May 6, 2019.\nRespectfully submitted,\nINTERSTATE POWER AND LIGHT COMPANY\nBy /s/ Lissa Koop\nLissa Koop\nSenior Attorney\nAlliant Energy Corporate Services, Inc.\n4902 N. Biltmore Lane\nMadison, WI 53718\nTelephone: 608.458.4826\nlissakoop@alliantenergy.com\n4","truncated":false,"body_characters":24982}