The American Gas Association (AGA), the Association of Oil Pipe Lines (AOPL), the American Petroleum Institute (API), the Interstate Natural Gas Association of America (INGAA) and GPA Midstream Association (GPA) jointly submit the attached ICF technical report, “Feasibility and Impacts of Domestic Content Requirements for U.S. Oil and Gas Pipelines” (“ICF report”), in response to the Department of Commerce (“Commerce”) Notice and Request for Comments, “Construction of Pipelines Using Domestic Steel and Iron” (“Notice”). The trade associations (“Associations”) filed detailed comments in response to this Notice on April 7. The Associations represent the vast majority of pipeline operators engaged in transporting natural gas, natural gas liquids, crude oil, refined petroleum products and carbon dioxide.
Growth in domestic natural gas and oil production fuels America’s economy, and privately funded energy pipelines are the critical link that brings these domestic energy resources to market. In addition to the hundreds of thousands of jobs supported by the energy production and pipeline sector, domestic energy abundance has driven a resurgence of our manufacturing sector and the broader U.S. economy. As part of the Trump administration’s energy policy and infrastructure plans, new and existing pipelines will play a critical role in connecting growing production and consumer demand.
The Associations support President Trump’s objective to grow domestic jobs and boost the U.S. economy by reinvigorating globally-competitive American manufacturing. At the same time, the Associations continue to urge the Administration to ensure that government action to increase domestic steel and pipe production does not have the unintended result of reducing or significantly delaying new pipeline projects and limiting U.S. pipeline job growth. The attached ICF report identifies factors unique to pipeline-grade steel, line pipe and equipment manufacturing that must be addressed in order to expand competitive domestic pipeline production and manufacturing.
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