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AGA's Preliminary TIMP ANPRM Comments (Dec. 2, 2011)
Supplement to AGA's Comments to the April 18 Pipeline Safety Forum (July 14, 2011)
AGA request for Clarification of NTSB Recommendations P-10-1 through P-10-4 (June 14, 2011)
AGA submittal to NTSB following San Bruno hearing (April 4, 2011)
AGA Comments on Regulatory Review of Existing DOT Regulations (April 1, 2011)
AGA response to PHMSA MAOP Advisory Bulletin (Feb. 4, 2011)
AGA Response to PHMSA
AGA Letter to NTSB Seeking Clarification on Recommendations
AGA Request for Waiver from Final Rule in Docket No. FMCSA-2010-0096: Drivers of CMVs: Restricting the Use of Cellular Phones

 AGA's Preliminary TIMP ANPRM Comments (Dec. 2, 2011) 

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.


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