The attached joint letter from the Interstate Natural Gas Association of America and the American Gas Association restates our serious concerns with various technical and methodological aspects of the Oak Ridge National Laboratory study concerning automatic and remote valves and the Kiefner and Associates study concerning leak detection systems. To deliberate further on the important technical issues involving automated and remote valves and leak detection systems, Congress must receive the best available information possible, and any new PHMSA requirements in these areas must be based on accurate and comprehensive analysis. The Oak Ridge and Kiefner studies do not meet this standard fully, and if the flaws identified in our letter are not remedied, these studies could lead to policy decisions and regulations that not only do not improve pipeline safety, but actually degrade it by diverting resources better spent elsewhere.
INGAA and AGA urge immediate correction of the flaws identified in our letter, and we would welcome additional reports, research, and discussion on strategies and technologies to ensure legislative, regulatory and industry efforts are truly focused on the best possible approaches to improving pipeline safety.
In the interest of transparency, and to maintain as complete a record as possible, copies of this letter are being filed in the docket PHMSA assigned when the Oak Ridge and Kiefner studies were opened for public comment last October (PHMSA–2012–0021).