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PHMSA Considers Expanding Integrity Management and Eliminating Class Location Requirements for Gas Pipelines

On August 1, 2013, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice in the Federal Register seeking public comment on whether to apply its integrity management (IM) program requirements to pipelines located outside of high consequence areas (HCAs) and, if so, whether that decision would obviate the need for its class location requirements.  A mandate in the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, the most recent reauthorization of the federal pipeline safety laws, requires PHMSA to evaluate these issues and provide a report to the U.S. Congress with its findings by January 2014.  After providing an overview of the current requirements, the notice discusses the comments that PHMSA received on its proposal to expand its IM requirements in an August 25, 2011 advance notice of proposed rulemaking, which the agency issued in response to the September 2010 gas transmission line failure that occurred in San Bruno, California.  The notice also requests public comment on a series of additional questions, particularly with respect to whether its class location requirements should be eliminated and replaced with a single design factor that would apply to all (or certain) levels of population density and categories of pipelines.  The deadline for submitting comments on the notice is September 30, 2013.