Comment from Pipeline Safety Trust
Pipeline Safety TrustOpposeAdvocacy
Summary: Pipeline Safety Trust, a nonprofit watchdog organization, opposes the rule because it allows operators to rely exclusively on electronic versions of spill response plans, which could be inaccessible during emergencies like power outages or cyberattacks. They argue that the rule changes the content, not just the form, of the plans and therefore should have undergone a full notice and comment rulemaking process.
Please see attached for a comment submitted on behalf of Pipeline Safety Trust.