Comment from AFPM

Summary: The American Fuel & Petrochemical Manufacturers (AFPM), a trade association representing the refining and petrochemical sector, supports the proposed rule to clarify and harmonize the definition of "property damage" for pipeline incident reporting. They argue that the proposal improves regulatory clarity by focusing on direct damage costs and incorporating inflation-based adjustments, though they suggest further refinements to ensure the definition of "undamaged infrastructure" is objective and consistent.