The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), GPA Midstream Association, Interstate Natural Gas Association of America (INGAA), and NACE International Institute (jointly “the Associations”) submit these comments for consideration by the Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding the Agency’s Notice of Proposed Rulemaking, “Pipeline Safety: Class Location Change Requirements” (“Proposed Rule” or “NPRM”). Pipeline safety is the top priority of the Associations and our members, including minimizing releases of natural gas. The Associations strongly support regulations that advance improvements in pipeline safety practices and that embrace modern integrity management processes and technologies, with the intent of continuously improving the safety and reliability record for our nation’s natural gas pipeline network…
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