The Associations (API, AGA, INGAA) and our members are deeply committed to continuing to improve natural gas pipeline safety and to working collaboratively with PHMSA and other stakeholders to develop regulations and initiatives that provide meaningful advancements in pipeline safety. In the past, this constructive relationship has resulted in numerous regulatory developments that have made significant enhancements to pipeline safety and have helped to achieve the excellent safety record of the nation’s natural gas pipeline system. In that spirit, the Associations appreciate the opportunity to provide constructive input to the Department of Transportation as it reviews its existing regulations to “determine whether they are crafted effectively to solve current problems.” These comments only address PHMSA’s regulations governing natural gas pipeline and storage facilities.
The Associations believe that these regulatory review recommendations will support PHMSA in its objective to promulgate pipeline safety regulations that are “straightforward, clear, and designed to minimize burdens.” The Associations believe the suggested modifications will not compromise safety. Instead, the changes to existing regulations recommended by the Associations will enable operators to reallocate resources to activities and programs that would benefit system integrity and public safety for the American communities that enjoy the benefits of natural gas. The Associations’ recommendations may enable operators to reallocate resources to activities that may be required by proposed new regulations.