Comments to OMB on National Pipeline Mapping System

Policy July 22, 2016

AGA submitted comments to the Office of Management and Budget (OMB) on the revisions PHMSA intends to make to information collected under OMB Control Number 2137-0596 titled “National Pipeline Mapping System (NPMS) Program.” AGA is supportive of efforts to improve pipeline safety through the modernization of the NPMS and appreciates the revisions that PHMSA made in this latest iteration of the revised NPMS in response to some of AGA’s concerns. However, many of AGA’s concerns remain in PHMSA’s final revised NPMS that has been forwarded to OMB for review.

PHMSA’s revisions to the NPMS represent a complete overhaul of the NPMS. PHMSA’s revised NPMS collection identifies twenty-five unique pipeline attributes, including the five existing mandatory attributes, that are to be provided by operators to PHMSA in a specific geospatial format, requiring a significant investment in time and resources to develop new data gathering systems and methods to maintain, format, and submit data. In addition, PHMSA has broadened the scope of the NPMS to include geospatial information for three new facility types: Pump and Compressor Stations, Gas Storage Facilities, and Breakout Tanks. The revised NPMS would significantly expand the scope of data collected for the NPMS and would impose substantial burdens on regulated parties to manipulate the data to be geospatially-referenced and to conform to the format requirements of PHMSA. These burdens are not adequately estimated or justified and serve to limit the practical utility and value of the information collected.

Information collection requirements that do not benefit pipeline safety are an unreasonable burden on pipeline operators, a misuse of valuable government and natural gas customer resources, and do not further the goals of the NPMS. AGA member utilities are spending significant resources on the modernization of aging pipeline infrastructure through activities that not only include the replacement and installation of pipeline assets, but also regulator stations, compressor stations, and automated valves. The resources of pipeline operators must be managed prudently by focusing on activities and actions that have a beneficial impact on pipeline safety performance. In addition, the costs to comply with the increased reporting requirement under the NPMS will primarily be borne by natural gas customers. Adding cost to a customer’s bill should only be done when it benefits the customer through increased safety or reliability. PHMSA’s revisions to the NPMS will not increase the safety or reliability of the pipeline that is used to transport gas to customer homes and businesses.

AGA is committed to working with PHMSA and other key stakeholders on modernizing the NPMS and fully supports PHMSA bringing these stakeholders together to develop a viable path forward. An overhaul of this magnitude warrants substantial dialogue among industry, emergency responders, and Federal and State Regulators. While this dialogue began in PHMSA’s public workshops, the workshops only allowed for a limited exchange of information and did not provide for the type of substantive conversation necessary to work through the complexities of collecting, maintaining, and submitting data to the NPMS in a manner that provides practical utility. The stakeholders that will be required to submit information and those that will use the information should all participate in the conversation to ensure that the overhaul of the NPMS enhances pipeline safety, while avoiding duplicative reporting requirements or introducing unwarranted national critical infrastructure security risks.

The magnitude of PHMSA’s revisions to the NPMS more closely resemble a substantive rulemaking and have the potential to impose significant obligations and duties on the regulated community. AGA recognizes that the public has had the opportunity to comment on these revisions; however, AGA is concerned that PHMSA has bypassed its statutory obligation to consider the practicability, appropriateness and reasonableness of the proposed revisions to the NPMS, as well as the associated benefits and costs.

There is universal support for the modernization of the NPMS. However, PHMSA’s notice in the June 22, 2016 Federal Register continues to impose substantial burdens on operators to submit data that will have minimal practical utility, do not advance pipeline safety, and are not necessary for PHMSA to perform its functions. AGA respectfully requests that OMB deny PHMSA’s request to revise the information collection for the NPMS until AGA’s concerns have been addressed. PHMSA has revised the NPMS in a manner that is not “the least burdensome necessary for the proper performance of the agency’s functions to comply with legal requirements and achieve program objectives,” “not duplicative of information otherwise accessible to the agency;” and will not have “practical utility.”

AGA Comments - NPMS (July 2016)562.06 KB