AGA Submits Comments on PHMSA’s Proposed Farm Tap FAQs

On June 19, AGA, INGAA, APGA, and API jointly filed comments regarding PHMSA’s draft Farm Taps Frequently Asked Questions (FAQs). The Associations support PHMSA’s efforts to provide clarity regarding the pipeline safety requirements applicable to individual service lines directly connected to transmission pipelines, and noted that additional changes are needed to FAQ #3 and other FAQs that address the point on PHMSA-jurisdictional piping at which the transmission line ends and the distribution service line begins. Specifically, The Associations noted that it was not practicable or necessary for safety to establish a uniform service line starting point for every transmission line farm tap, and that operators should be allowed to designate the start of distribution service line piping at the first isolation point off of the source piping (as proposed in the draft FAQs), the first fitting off of the source piping, or another reasonable point, such as a downstream valve, regulator, meter, fitting, or custody transfer point, including the connection to customer piping. These comments do not address considerations related to individual service lines directly connected to production or gathering pipelines.