Natural Gas Utilities Express Concern and Submit Alternative Approaches to PHMSA’s Gas Transmission and Gathering Pipelines Proposed Rule
Washington, D.C. – The American Gas Association (AGA) expressed the deep commitment of natural gas utilities to improving natural gas pipeline safety and working collaboratively with the Pipelines and Hazardous Materials Safety Administration (PHMSA) and other stakeholders to develop regulations and initiatives that provide meaningful advancements in pipeline safety. In comments submitted today on the Safety of Gas Transmission and Gathering Pipelines Proposed Rule, AGA voiced support for the intended pipeline safety benefits behind many of the proposed modifications to pipeline safety regulations. However, AGA and its members believe that PHMSA’s proposal fails to consider the extensive existing regulatory and voluntary safety initiatives in place and imposes prescriptive and burdensome requirements on operators that, in the end, will likely not address the perceived regulatory pipeline safety benefits.
The Proposed Rule represents a shift away from performance-based regulations, which recognize the unique characteristics of each pipeline system, to prescriptive regulations, which define how an activity is to take place regardless of the circumstances or the characteristics of the system. Natural gas utilities are concerned that these overly prescriptive and onerous requirements result in a Proposed Rule that is largely unworkable, would significantly increase costs to residential customers, and would significantly reduce the opportunities for operators to undertake voluntary initiatives targeted at advancing pipeline safety.
If the enormity of the Proposed Rule cannot be understated, neither can the commitment level of the resources that have been devoted to analyzing it and providing PHMSA with the most meaningful substantive comments within the limited time allotted and in the absence of explanation or reasoned justification.
AGA sponsored multiple workshops and weekly calls and worked with its members to review and evaluate the Proposed Rule and provide meaningful comments. Minimal or, in many areas, no descriptions and justification, inconsistent statements, and convoluted proposed regulatory modifications made this no easy task. AGA’s comments are the culmination of this effort, and are intended to provide PHMSA with the feedback and suggestions necessary to develop the Proposed Rule into a regulation that will make a meaningful enhancement in pipeline safety.
AGA included in its comments a number of alternative approaches. This approach is meant to be considered separately from the balance of the comments which are dedicated to PHMSA’s proposal. AGA’s approach recognizes PHMSA’s concerns and provides tangible and workable actions that AGA members are committed to taking to address these concerns.
The full text of AGA’s comments are available upon request.
The American Gas Association, founded in 1918, represents more than 200 local energy companies that deliver clean natural gas throughout the United States. There are more than 72 million residential, commercial and industrial natural gas customers in the U.S., of which 95 percent — just under 69 million customers — receive their gas from AGA members. Today, natural gas meets more than one-fourth of the United States' energy needs.