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 “Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments” rule (“final rule”). On March 26, 2018, PHMSA announced that this would be the second of two rules addressing the gas transmission pipeline topics raised in the 2016 “Safety of Gas Transmission and Gathering Lines” Notice of Proposed Rulemaking (NPRM) , and that this final rule would address important safety topics not included in the 2011 Pipeline Safety Act.
The Associations previously submitted comments to address the first set of topics that PHMSA announced it will include in its first gas transmission rule, the “Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments” rule, which will address the mandates from the 2011 Pipeline Safety Act. Those comments included markups to PHMSA’s proposed regulatory text that were intended to mirror the votes and discussions held by the Gas Pipeline Advisory Committee (GPAC) and also identified outstanding concerns. These comments are similar in content and structure. The Associations hope that these comments will assist PHMSA as it drafts a final rule that advances pipeline safety.