The American Gas Association (AGA)1 , American Petroleum Institute (API)2 , American Public Gas Association (APGA)3 and Interstate Natural Gas Association of America (INGAA)4 (jointly “the Associations”) submit these comments for consideration by the Department of Transportation concerning the “Notice of Review of Guidance.” These comments pertain to guidance issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) and are limited to PHMSA’s regulations governing natural gas pipeline and storage facilities.5 Pipeline safety is the top priority of the Associations and their members. The Associations strongly support regulations and guidance materials that advance improvements in pipeline safety practices and that embrace modern integrity assessment processes and technologies, with the intent of achieving a perfect safety and reliability record for our nation’s natural gas pipeline and storage network. The Associations commend the Department of Transportation for taking steps to reevaluate existing guidance documents “to reflect developments, such as technological changes, that took place after the guidance was issued.”6 In recent decades, there have been dramatic engineering and technological advances which may warrant changes to past guidance. The Associations believe that the recommendations outlined below will support PHMSA in its objective to promulgate pipeline safety and storage regulations that are “straightforward, clear, and designed to minimize burdens.”7 The reevaluation of certain PHMSA guidance that is recommended by the Associations will enable operators to reallocate resources to activities and programs that would benefit system integrity and public safety, including activities that may be required by pending new regulations.
Read the full comments here.