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On February 5, the Department of Transportation (DOT) requested public comment on agency guidance documents. The DOT is “reviewing its existing guidance documents to evaluate their continued necessity and determine whether they need to be updated or revised.” The request summarizes guidance as documents that “can serve a number of purposes including: (1) Clarifying the pertinent statutory and regulatory requirements; (2) assisting with statutory and regulatory compliance; and (3) communicating the Department’s position on an issue.” APGA worked collaboratively with the Interstate Natural Gas Association of America, the American Gas Association, and the American Petroleum Institute on joint natural gas pipeline comments focused on guidance provided by the Pipeline and Hazardous Materials Safety Administration (PHMSA).

APGA contributed to the industry comments by requesting PHMSA align their inspection guidance for state regulators with regulatory requirements. Specifically, APGA pointed out a discrepancy related to Distribution Integrity Management Program implementation. Distribution pipeline operators are required to collect information on new pipelines when they are installed. The regulatory code language says that “at a minimum, the location where the new pipeline is installed and the material of which it is constructed,” must be captured. However, guidance provided by PHMSA to state pipeline safety inspectors goes on to include several other attributes including wall thickness, manufacturer, and lot number. APGA asked that PHMSA align the guidance with the regulatory requirement so as to not create points of contention between regulators and operators.
These comments will be shared with PHMSA for their consideration on regulatory reform initiatives.

For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at ekurilla@apga.org.