Comment from Anonymous

Public Comment for PHMSA-2025-0113 - for Part 192.8(a)(5) - Incidental Gas Gathering Pipelines: PHMSA should not change the incidental gas gathering regulation in 49 CFR Part 192.8(a)(5) as noticed in docket PHMSA-2025-0113. The "Preliminary Regulatory Impact Analysis for Pipeline Safety: Incidental Gathering" (PRIA) in the docket for public review is flawed and incomplete. The PRIA does not address the effects on public safety and the environment for the proposed change to Part 192.8(a)(5) for incidental gas gathering pipelines over 10 miles in length in the following areas: (a) risk and (b) consequences for a large diameter, high operating pressure, long length (over 10 miles in length), not constructed, designed, operated, or maintained per 49 CFR Part 192 (in a Class 1, 2, 3, or 4 locations, or high consequence and moderate consequence areas that may affect schools, nurseries, retirement homes, hospitals, churches, shopping areas, and other high populated areas) with a large radius potential impact radius (PIR) in the event of a leak or rupture. The "Costs and Savings" in Paragraph 3.5 of the PRIA only addresses operator costs in "Table 1. Inputs for Calculating Annual Costs". The annual cost in Table 1 is $505,886 per year which is probably lower than the public and environmental costs of 1 large leak or rupture of these type pipelines in a 10- or 20-year period, especially since they have not been operated by an accepted regulatory standard. Also, the PIR of incidental gas gathering lines from a rupture would be from over 300 feet to over 1,000 feet depending upon the diameter and operating pressure of the pipeline. An incidental gas gathering pipeline failure would affect people and dwellings in the PIR, since they would only have seconds to get out of the PIR or would be harmed or killed. The PRIA does not address these type costs to the public and environment. A large gas leak or rupture on an incidental gas gathering pipeline would cost more than the 10-year discounted costs in Table 1 and Section 7. Sensitivity and Uncertainty Analysis of the PRIA. The PRIA is flawed and incomplete from a safety and environmental standpoint. The PRIA is not correct and changing the requirements in Part 192.8(a)(5) for incidental gas gathering would be not in the public safety interest. The PRIA states that "PHMSA is not aware of any incidents or safety related conditions on gathering lines currently subject to the enforcement discretion", which is due to gas gathering pipeline until 2022 did not have to report this information to PHMSA, it does not mean that there were no leaks or ruptures of these type pipelines. PHMSA should review all costs (operator, public and environmental) and "if any changes" for incidental gas gathering pipeline should be "limited to short replacements (100 feet or less in X miles for replacements or relocations)". Based upon docket PHMSA-2025-0113 and PRIA information, the proposed changes to the current Part 192.8(a)(5) requirements should be denied based upon flawed and incomplete information provided to the public.