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

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.

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.

National Grid, a combined gas and electric distribution company, supports the proposed pipeline safety regulations but requests more realistic implementation timeframes and a phased-in approach. They argue that the current 12-month deadline is insufficient due to the complexity of the required upgrades, regional differences in infrastructure, and the significant costs involved in retrofitting low-pressure systems.

The Northeast Gas Association (NGA), representing natural gas local distribution companies, supports the proposed pipeline safety regulations but requests revisions to the implementation timeline. They argue that the current 12-month timeframe is unrealistic due to labor shortages, supply chain issues, and the complexity of retrofitting thousands of low-pressure systems, and they advocate for a risk-based prioritization schedule instead.

The International Association of Fire Chiefs (IAFC) supports the proposed rule, emphasizing the need to prioritize first responder interests and improve coordination between pipeline operators and emergency management officials. They recommend specific language changes to include property damage and injuries in notification requirements and advocate for mandatory Incident Command System (ICS) training for operators.

The United Steelworkers (USW) union expresses strong support for the proposed rule to improve gas distribution pipeline safety, citing the 2018 Merrimack Valley explosions as a primary reason for the need for stricter regulations. They advocate for additional requirements that mandate meaningful worker engagement in developing safety plans and urge the use of operator-employed personnel over contractors for critical construction monitoring.

Physicians for Social Responsibility (PSR) supports the proposed pipeline safety initiatives, emphasizing the importance of protecting public health and environmental justice. They argue that the proposal should be further strengthened by requiring updated emergency response plans that involve multiple stakeholders and place greater responsibility on operators for maintenance and risk management.

Barbara Gottlieb, representing the advocacy organization Physicians for Social Responsibility, supports the proposed rule but requests specific enhancements. She argues for updated emergency response plans involving local stakeholders, stricter operator accountability for maintenance and record-keeping, and adherence to Justice40 initiatives to protect vulnerable communities.

Dr. Alan Peterson, a medical doctor, supports the proposed pipeline safety rules to protect public health, environmental justice, and worker safety. He emphasizes the need for improved emergency response plans, better operator accountability, and the prevention of disasters like the Merrimack Valley incident.