Comment from Philadelphia Gas Works
Philadelphia Gas WorksOpposeBusiness
Summary: Philadelphia Gas Works (PGW) opposes several aspects of the proposed rule, arguing that many requirements exceed Congressional mandates and that the proposed 12-month effective date is insufficient for implementation. They specifically express concerns regarding prescriptive DIMP requirements, the expansion of emergency response plan mandates, and the lack of "if necessary" qualifiers in procedures for responding to overpressurization indications.
Please see attached comments from Philadelphia Gas Works (PGW)