Comment from Anonymous

Comment for PHMSA-2025-0113 on proposed updates to Part 192.8(a)(5) - Incidental Gas Gathering Lines: PHMSA should not change the current Part 192.8(a)(5) regulation for incidental gas gathering lines as noticed in docket PHMSA-2025-0113. The "Preliminary Regulatory Impact Analysis for Pipeline Safety: Incidental Gathering" (PRIA) for public review is incomplete (lacks a cost review, risk, and consequences to the public and the environment from a leak or failure) and puts the public at risk to the harmful effects of a gas leak or rupture. The paragraph below is from Section 7. Sensitivity and Uncertainty Analyses of the PRIA in the docket. “As discussed in Section 0, PHMSA assumed that 15 percent of facilities have incidental gathering pipelines affected by the 10-mile limitation, of which 2 percent are replaced, relocated, or otherwise changed in any given year. As an alternative, PHMSA used GIS data to identify a total of seven processing plants with no mapped transmission lines within 10 miles of the facility. While these data points cannot definitively identify affected facilities, if PHMSA were to use this number as the universe of potentially affected facilities while maintaining other analysis assumptions, then the total cost savings would be $49,389 per year, and total savings over the 10-year analysis period of $421,299 at a 3 percent discount and $346,888 at 7 percent discount.” The PRIA states, copied above, that for known affected incidental gas gathering lines the costs of the current requirements in Part 192.8(a)(5) for these affected facilities are $49,389 per year. The PRIA did not address the public costs for leaks and failures of these lines. Incidental gas gathering line failures will harm humans, dwellings, and the environment like gas transmission pipelines (which are large diameter, high pressure) located within or near the potential impact area of a line leak or failure. An incidental gas gathering line can and will be in populated areas, such as Class 1, 2, 3 or 4 locations and high or moderate consequence areas. High consequence areas and Class 3 and 4 locations may include highly populated areas such as shopping areas, sports stadiums, schools, nurseries/day care, hospitals, parks, retirement homes, etc. The PRIA for the proposed change to Part 192.8(a)(5) did not review the safety and harmful effects of a gas leak or failure to the public and environment in human effects or overall cost impact. Questions: 1)If an incidental gas gathering line is not prudently repaired or remediated to prevent a gas leak of failure, will the responsible operator executives, managers, engineers, and maintenance workers who did not conduct these repairs in a responsible manner have criminal, civil, or PHMSA penalties based upon the facts of the incident? 2)Would people in highly populated areas such as shopping areas, sports stadiums, schools, nurseries/day care, hospitals, parks, or retirement homes that are in the impact area of the line leak or failure for incidental gas gathering line (large diameter and high pressure lines) have time to get out of the fire or would they be harmed or killed? For a minimum yearly cost savings that did not include the human, dwelling, environmental, and other cost effects of an incidental gas gathering line leak or failure, PHMSA has proposed to delete Part 192.8(a)(5). -PHMSA’s PRIA is incomplete and was not developed for public safety with no review of leak or failure impacts and costs. PHMSA must not change the current Part 192.8(a)(5) regulation.