On September 29, 2003 AGA submitted comments on the Office of Pipeline Safety (OPS) Best Management Practices for Pipeline Repairs (“Draft Repair BMP”). AGA expressed concerns that the Draft Repair BMP and associated guidance could actually complicate and slow down the process of obtaining the permits needed to perform the large volume of pipeline integrity testing and repairs that required by the Natural Gas Pipeline Integrity Final Rule. This is because federal and especially state environmental agencies often require natural gas pipeline projects to use BMP’s that are quite different from those described in Draft Repair BMP. AGA urged OPS to coordinate with the states to streamline state approvals. In addition, AGA identified several ambiguous or overly broad terms that could lead to debate, delay and confusion. AGA posed questions regarding the facilities that are intended to be affected by the Draft Repair BMP as well as the streamlining OPS expects the Draft Repair BMP to provide.