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
INGAA believes these proposals address the concerns discussed at the workshop and
provide a path forward.