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

Rhode Island Energy, a natural gas distribution company, supports the proposed overpressurization requirements but advocates for implementation timelines that account for the practical challenges of modernizing legacy infrastructure. They argue that the company needs flexibility to develop risk-based plans due to the high costs, engineering complexities, and the need to balance these upgrades with ongoing leak-prone pipe replacement programs.

The National Association of Pipeline Safety Representatives (NAPSR), representing state agency pipeline safety managers, supports the proposed rule but requests the inclusion of three specific provisions. They argue for clarifying construction inspection responsibilities, requiring lifetime retention of pressure test records for consistency with transmission pipelines, and clarifying the coordination between PHMSA and state agencies for certified programs.

New Jersey Natural Gas (NJNG) supports the proposed rule on the Safety of Gas Distribution Pipelines, aligning with industry associations to enhance pipeline safety. They advocate for a performance-based framework that allows for risk-informed, system-specific solutions while proposing specific revisions to ensure the rule is technically feasible and operationally practical.

Spire Inc., a natural gas utility, opposes the proposed rule due to concerns over the feasibility of the one-year implementation timeline and the potential for significant cost increases to customers. The company argues that the requirements for overpressure protection, telemetry, and management of change (MOC) processes would divert resources from existing pipeline replacement programs and that the proposed emergency notification thresholds are excessive.

The Distribution Contractors Association (DCA) supports the proposed rule because it includes an exception for small gas distribution operators with limited staffing who might otherwise be forced to hire third-party inspectors. While the association opposes regulations that single out contractors for additional requirements, they appreciate PHMSA's decision to apply the new inspection rules consistently to both operator and contractor personnel, while maintaining the necessary exception for small operators.

Renegade Energy Advisors, LLC, a consulting company for the energy industry, provides specific technical recommendations regarding the proposed rule. They request a longer compliance timeline for TVC records, the removal of certain engineer requirements, and the standardization of geohazard language.

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.

Southern Company Gas opposes the proposed rule in its current form, arguing that it exceeds Congressional intent and significantly underestimates the costs of compliance for operators and ratepayers. The company requests that PHMSA refine the scope of the regulations, provide longer implementation timelines, and adopt specific alternatives for inspections and emergency communications.

National Grid, a gas and electric distribution company, supports the proposed safety regulations but requests a phased-in implementation timeframe and more flexible, performance-based requirements. They argue that the current 12-month timeline is unrealistic due to the complexity of urban infrastructure, high costs, and the need to balance safety with reliable gas delivery.