Introduction
In accordance with 49 C.F.R. § 190.335(a), the American Gas Association (AGA), 1 American Petroleum Institute (API), 2 American Public Gas Association (APGA),3 and Interstate Natural Gas Association of America (INGAA) 4 (jointly “the Associations”) submit this Petition for Reconsideration (“Petition”) regarding PHMSA’s “Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments” Final Rule (“the Final Rule”), published in the Federal Register on October 1, 2019. 5 Pipeline safety is the top priority of the Associations and our members. The Associations strongly support the Final Rule, which will enhance pipeline safety and help advance our industry’s efforts to achieve a perfect safety and reliability record for our nation’s natural gas pipelines. The Associations have publicly championed PHMSA’s efforts to finalize this important rulemaking based on the consensus built through the Gas Pipeline Advisory Committee (“GPAC”) process.6 The Associations file this Petition to seek reconsideration of two specific issues regarding § 192.5(d) and § 192.624(a)(1) in order to ensure that the requirements of the Final Rule are clear.7