On February 17, 2017, November 20, 2017 and March 2, 2018, the Associations, along with the American Public Gas Association, filed comments relating to PHMSA’s Pipeline Safety: Safety of Underground Natural Gas Storage Facilities Interim Final Rule (Docket No. PHMSA-2016-0016). The Associations seek to supplement these comments to include additional considerations for the Underground Natural Gas Storage Facility Annual Report Instructions.1
The Associations support advancing pipeline and underground storage safety and providing transparency into the operations of these facilities through periodic reporting. On or before March 15, 2018, operators filed their first annual reports for underground natural gas storage facilities2, as required by § 191.17. In developing their first annual report submissions, the Associations’ members identified certain areas of the annual report form that warrant further clarification from PHMSA. The Associations request that PHMSA consider providing clarification within their Underground Natural Gas Storage Annual Report Instructions to ensure clarity and consistency in future reporting.
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