INGAA comments on PHMSA’s Public Workshop on Class Location Methodology

The Interstate Natural Gas Association of America (INGAA), a trade organization that

advocates regulatory and legislative positions of importance to the interstate natural gas pipeline 

industry in North America, welcomes the opportunity to submit comments in response to the Pipeline 

and Hazardous Materials Safety Administration’s (PHMSA) Class Location Methodology Public 



During the workshop, PHMSA requested comments on whether elements of the integrity management 

program should be applied beyond high consequence areas (HCAs), thereby mitigating the need for 

class location requirements for natural gas transmission pipelines.2  Consistent with its 

commitments, INGAA believes that integrity management principles should be extended beyond HCAs.3


On November 1, 2013, INGAA filed comments on this issue in response to PHMSA’s Notice of Inquiry

See Appendix A. As part of these comments, INGAA raised the issue of class location change outs and 

proposed that an operator should not have to change out pipe if it can prove the segment meets 

certain requirements. INGAA raised this same issue during the April 2014 workshop and provides 

additional comments on this topic in this filing.


INGAA continues to support a bifurcated approach that would retain the current class location 

system for existing pipelines and permit the use of the Potential Impact Radius (PIR) for new or 

entirely replaced pipelines.4  This approach would retain the class location scheme that operators, 

PHMSA personnel, and state partners have used for over 40 years (the “traditional approach”) and 

introduce an approach using the PIR for new or entirely replaced pipelines (the “alternative 



Specifically, INGAA advocates the following high-level concepts:

1.   INGAA recommends that PHMSA consider a different approach to the current

regulations that may require a pipe replacement when a population density increase occurs. This new 

approach would utilize integrity management principles and new technology to determine if a pipeline

segment requires replacement.

2.   INGAA recommends a reassessment of the class location design criteria for new pipelines given 

technological advances in design, materials, engineering and construction (Alternative Class 

Location Approach).


INGAA believes these proposals address the concerns discussed at the workshop and

provide a path forward.