INGAA on July 24 suggested new alternatives to the existing class-location change regulation in response to a request for information as the Department of Transportation reviews “existing regulations to identify unnecessary obstacles to transportation infrastructure projects.” INGAA, in comments, noted its strong support for regulations that advance improvements in pipeline safety practices and that embrace modern integrity management processes and technologies, with the intent of achieving a perfect safety and reliability. In that spirit, INGAA suggested an alternative to existing regulations governing the actions that operators must take when there is a change in the class location designation of a pipeline segment. Alternate processes and technologies are now available for effectively managing pipeline safety in these segments; in fact, many of these processes and technologies are reflected in PHMSA’s 2016 Gas NPRM. INGAA’s proposed alternative, based on recurring Integrity Management assessments, would not alter the existing alternatives for managing class location changes. INGAA estimates that natural gas transmission pipeline operators incur annual costs of $200-$300 million nationwide to replace pipe solely to satisfy the class location change regulations.
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