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.

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.

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.

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.

Southwest Gas Corporation opposes several aspects of the proposed rule, arguing that PHMSA significantly underestimates the costs and labor hours required for compliance. The company specifically requests a continued stay of enforcement for certain provisions, the exclusion of certain activities from the Management of Change process, and an extension of the final rule's effective date to two years.

Consolidated Edison Company of New York, Inc. argues that the proposed regulatory timelines for upgrading low-pressure regulator stations and implementing emergency communication requirements are unachievable within the proposed one-year timeframe. The company highlights the high costs and logistical complexities involved, requesting that PHMSA adopt more realistic timelines and the recommendations provided by the Northeast Gas Association and Joint Industry Associations.

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.