In response to the advance notice of proposed rulemaking (ANPRM) for Transmission Integrity Management (TIMP) published in the August 25, 2011, issue of the Federal Register (76 Fed. Reg. 53086), the American Gas Association (AGA) has chosen to file its comments in three separate submissions. AGA's preliminary comments highlight the key issues that AGA believes will enhance the Transmission Integrity Management Program. The cover letter and preliminary comments were submitted to the docket on Friday, December 2.
The second filing will present answers to the many questions that PHMSA presented in the ANPRM in sections A through O. Finally, AGA will submit comments to the ANPRM section on “Establishing requirements applicable to underground gas storage” under a separate cover, because the issue is not related to transmission integrity management and may need to be transferred to a separate docket. The last two filings will occur before the Christmas holiday. The deadline for filing comments is January 15, 2012. This schedule of filing comments will allow AGA member companies to review AGA’s position and file their own comments of support.