AGA Comments


AGA Comments

AGA Comments from 2014, 2013, and 2012


AGA Comments to U.S. DOT on Buy America Waiver Request

AGA submitted a letter to the Federal Highway Administration (FHWA) docket strongly supporting the request from the California Department of Transportation (Caltrans) for a limited waiver from provisions in the Buy America , Moving Ahead for Progress in the 21st Century Act. The waiver was necessary for a subset of Pacific Gas & Electric (PG&E) utility materials necessary for relocation project referred to as the Cordelia I-80/I-680/State Route (SR) 12 Project which is designed to reduce congestion, accommodate increases in traffic and address safety concerns.
AGA Response to NTSB Safety Recommendation P-11-32 (March 26, 2012)

On March 26 the American Gas Association and the Interstate Gas Association of American (INGAA) met with NTSB Board members to review the progress the trade associations have made in completing Safety Recommendation P-11-32 from the San Bruno investigation. The recommendation states:
Class Location Requirements (Nov 2013)

AGA Comments on the PHMSA Request for Information on Class Locations
Final Comments on Pipeline Damage Prevention Programs

AGA Final Comments - Notice of Proposed Rulemaking - Pipeline Safety: Pipeline Damage Prevention Programs: AGA final comments submitted to the docket in response to the Pipeline and Hazardous Materials Safety Administration (PHMSA) Notice of Proposed Rulemaking (NPRM), as published in the Federal Register on April 2, 2012.
Gas Transmission Integrity Management ANPRM

Gas Transmission Integrity Management ANPRM: AGA filed comments to the PHMSA docket for the Gas Transmission Advance Notice of Proposed Rulemaking (ANPRM).  The first comments refer to sections A through O, with the exception of Section K, “Establishing requirements applicable to underground gas storage.” Section K was submitted separately, because the issue is not related to gas transmission integrity management and PHMSA may want to transfer the comments to a separate docket.
Joint AGA-INGAA Letter Restating Comments on Leak Detection Systems Studies

A joint letter from the American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA) restating our serious concerns with various technical and methodological aspects of the Oak Ridge National Laboratory study concerning automatic and remote valves and the Kiefner and Associates study concerning leak detection systems, was sent this week to PH
One Call Exemption (July 2013)

AGA filed comments on the PHMSA study on the impact of excavation damage on pipeline safety (Docket# PHMSA-2013-0029).
AGA Comments to PHMSA DOcket on One Call Exemptions - July 30, 2013 
Distribution Annual Report Changes (June 25, 2014)

Final comments submitted to the docket by AGA on revisions to PHMSA Form 7100.1-1 and Instructions to PHMSA Form 7100.1-1. The sections covered in this round of comments covered PART C, D, H, and PART B, C, and D respectively.
Liquid IVP Comments (February 2015)

AGA submitted comments on PHMSA’s draft Hazardous Liquid Pipeline Integrity Verification Process chart. The comments reiterated many of the concerns that were outlined by AGA’s four previous sets of comments submitted on the Gas Transmission Pipeline IVP chart. Those areas include: separation of MAOP verification from expansion of integrity management, delineation of low stress pipelines at 30% SMYS, and the ambiguous introduction of new terms such as moderate consequence areas, engineering critical assessments and spike testing. 
Revisions to National Pipeline Mapping System (NPMS)

In late July, PHMSA published proposed revisions to its National Pipeline Mapping System (NPMS) Program. The NPMS is a geospatial dataset that contains information about PHMSA regulated gas transmission and hazardous liquid pipelines, LNG plants and breakout tanks. Regulated operators of these facilities are required to submit geospatial data to PHMSA on an annual basis.