Pipeline Safety: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives

A coalition of gas and utility trade associations opposes the proposed rule, arguing that it exceeds congressional mandates, imposes unrealistic implementation timeframes, and lacks an accurate cost-benefit analysis. They request more flexibility and longer timelines to ensure that resources remain focused on the most significant safety threats.

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.

The National Association of Pipeline Safety Representatives (NAPSR), an organization of state agency pipeline safety managers, generally supports the proposed rule changes to improve gas distribution pipeline safety. They provide specific technical recommendations to clarify definitions, ensure consistency across regulations, and refine requirements for inspections, emergency communications, and construction oversight.

The Institute for Policy Integrity at New York University School of Law supports the proposed rule but suggests several ways to strengthen the agency's cost-benefit analysis. They recommend that PHMSA provide more specific evidence regarding the rule's benefits, including more detailed environmental justice data, social costs of methane, and long-term health impacts.

The American Gas Association, American Public Gas Association, and Northeast Gas Association oppose several aspects of the proposed rule, arguing that it exceeds Congressional intent, imposes unreasonable costs, and sets an unfeasible compliance timeline. They specifically argue that the rule is overly prescriptive regarding threat modeling and that the proposed one-year deadline for significant infrastructure upgrades is impractical for the industry.

Jill B supports the proposed pipeline safety rules, arguing that they are necessary to protect public health, the environment, and workers from hazards like fires, explosions, and methane leaks. She emphasizes the importance of updated emergency response plans, operator accountability, and the alignment of the policy with environmental justice goals.