The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), and Interstate Natural Gas Association of America (INGAA) (jointly “the Associations”) submit these comments for consideration by the Pipeline and Hazardous Materials Safety Administration (PHMSA) concerning the draft Farm Taps Frequently Asked Questions (FAQs).
Pipeline safety is the top priority of the Associations and our members. The Associations support PHMSA’s efforts to provide clarity regarding the pipeline safety requirements applicable to individual service lines directly connected to transmission pipelines, commonly referred to as “farm taps.” The Associations’ comments only address gas transmission and distribution pipeline considerations affected by the draft FAQs—these comments do not address considerations related to individual service lines directly connected to production or gathering pipelines. The Associations’ comments also do not reflect the changes to 49 C.F.R. § 192.740 proposed in PHMSA’s Notice of Proposed Rulemaking on Gas Pipeline Regulatory Reform, which was published subsequent to the publication of these draft FAQs.
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