INGAA Topic-by-Topic Comments on PHMSA’s ANPRM

The advance notice of proposed rulemaking in this docket asks 120 questions, most with multiple sub-parts, spanning a wide array of topics related to natural gas pipeline safety. The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, signed into law earlier this month, creates new statutory requirements in areas such as integrity management, verification of maximum allowable operating pressure, improvements to damage prevention efforts, and the continuation of efforts in pipeline safety research and development. These two initiatives — one regulatory, one legislative — are rooted in a common, central question: What is the best way to enhance and assure the safety of the nation’s pipelines?

For America’s interstate natural gas pipelines, no question is more important.

Attached are INGAA’s comments for the PHMSA docket.