Comment from National Association of Pipeline Safety Representatives (NAPSR)

Summary: The National Association of Pipeline Safety Representatives (NAPSR), representing state agency pipeline safety managers, supports the proposed rulemaking but urges PHMSA to include three specific provisions regarding construction inspection clarification, lifetime pressure test record retention, and coordination with state partners. They argue these additions are necessary to resolve long-standing regulatory ambiguities, ensure consistency between transmission and distribution standards, and avoid duplicative regulatory processes.