Section 5 of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 requires the Secretary of Transportation to evaluate and issue a report on whether Integrity Management Program (IMP) requirements, or elements thereof, should be expanded beyond High Consequence Areas (HCAs) and whether such expansion would mitigate the need for class location requirements. AGA submitted comments to the docket today. Due to the integral role of Class Location-related risk factors in the regulations, AGA does not support the revision, replacement or complete removal of the use of Class Location-driven requirements for gas transmission pipelines, nor does it support adding additional Class Locations or revising the currently specified factors as their use throughout Part 192 is an integral part of pipeline safety. AGA encouraged PHMSA to continue to allow the use existing Class Location-related factors as currently prescribed in Part 192 for the design, construction, operation and maintenance of natural gas transmission pipelines. AGA supports the investigation and development of a second and parallel methodology for transmission pipelines that experience a change in Class Location outside of the original design and pressure testing which potentially affects the MAOP. This methodology would utilize a PIR approach and incorporate elements of transmission integrity management program. AGA believes that regardless whether an operator uses PIR or Class Location the change-out criteria should be modified to acknowledge that if certain integrity management criteria are met perfectly good pipe should not have to be replaced because of an increase in the population density.