Comment from Ateeq Ur Rehman

PUBLIC COMMENT ON DOCKET NO. PHMSA-2026-0529 Pipeline Safety: Information Collection Activities Submitted by: Ateeq Ur Rehman, AMPP/NACE Cathodic Protection Specialist (Level IV) I. Introduction I am Ateeq Ur Rehman, a Cathodic Protection Specialist and Asset Integrity Engineer with over ten years of field experience designing, commissioning, and monitoring cathodic protection systems for cross-country pipelines, storage tanks, and marine structures across the oil and gas industry. I hold the AMPP/NACE Cathodic Protection Specialist Level IV certification, the highest practitioner credential in the field, and I am a registered member of AMPP (U.S.) and the Institute of Corrosion (U.K.). I submit this comment in response to PHMSA's proposed revisions to incident, accident, and annual report forms for hazardous liquid pipeline facilities. My comment specifically addresses how cathodic protection system performance data, and the remote monitoring infrastructure that supports it, should be standardized and captured in PHMSA's reporting framework. II. Cathodic Protection Reporting Gaps in Current Forms Current PHMSA incident and annual report forms do not require operators to report the operational status of cathodic protection systems at the time of a corrosion-related pipeline failure. In my professional experience, including supervision of over 450 kilometers of CP-protected cross-country pipeline in high-consequence areas, the absence of this data makes it substantially harder for PHMSA to identify patterns of inadequate CP maintenance as a root cause of reportable incidents. I recommend that PHMSA revise the hazardous liquid incident report to include a mandatory field capturing whether the affected pipeline segment was under active cathodic protection at the time of failure, the most recent CP survey date (CIPS or DCVG), and the recorded pipe-to-soil potential at the nearest test point. III. Standardization of Remote Monitoring Data in Annual Reports Remote Monitoring Units (RMUs) integrated with cathodic protection transformer-rectifier systems now allow continuous, real-time tracking of pipe-to-soil potentials and rectifier output across hazardous liquid pipeline networks. However, PHMSA's annual report forms do not currently capture whether an operator uses remote CP monitoring, the percentage of pipeline mileage covered by remote monitoring, or the frequency of data transmission. I recommend that PHMSA add a section to the hazardous liquid annual report requiring operators to disclose: (1) total pipeline mileage under active remote CP monitoring, (2) the monitoring technology or standard used (e.g., NACE SP0169, AMPP SP0207), and (3) the frequency of potential checks performed remotely versus physically. This data would enable PHMSA to evaluate whether remote monitoring adoption correlates with lower corrosion incident rates, informing future regulatory guidance. IV. Recommended Form Revision I recommend that PHMSA's revised forms include a dedicated Cathodic Protection Status section with three standardized fields: (1) CP system type (ICCP, SACP, or hybrid); (2) date and result of most recent close-interval potential survey; and (3) remote monitoring coverage (yes/no, percentage of mileage). These additions would impose minimal burden on operators who already maintain this data under 49 CFR Part 195, while significantly enhancing PHMSA's ability to analyze the relationship between CP performance and pipeline incidents. V. Conclusion Corrosion is among the leading causes of hazardous liquid pipeline failures. Strengthening PHMSA's information collection to include standardized CP performance data and remote monitoring status would meaningfully improve the agency's ability to prevent corrosion-related incidents, protect communities near pipeline corridors, and support the long-term reliability of U.S. energy infrastructure. I appreciate the opportunity to contribute to this important rulemaking. Respectfully submitted, Ateeq Ur Rehman AMPP/NACE Cathodic Protection Specialist (Level IV) | Asset Integrity Engineer