American Forest & Paper Association and Process Gas Consumers Group
Trade associationSupport
Cost-benefit analysis
Pipeline Safety: Repair Criteria for Hazardous Liquid and Gas Transmission Pipelines
PHMSA-2025-0019-0001Proposed Rule
Comments
27
Last activity Jun 26, 2026
Deadline
Closed on Jul 22, 2025
Closed Jul 22, 2025
Net supportiSupport minus oppose · campaigns included
+88%
+88% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Pipeline Safety: Repair Criteria for Hazardous Liquid and Gas Transmission Pipelines
- Posted
- May 21, 2025
- Comment period
- May 21, 2025 – Jul 22, 2025
- FR Doc
- 2025-09078
- CFR
- 49 CFR Parts 191, 192 and 195
- Topics
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Analyzed 26 of 27 comments
96%· analysis in progress
Stance breakdown
+88%
Net support
Support23Other3Not yet analyzed1
Aggregates include form-letter campaigns. Excluding them, net support is +88% across organic comments.
Who commented
Breakdown by commenter type.
Business
11
Individual
1
Advocacy
6
Trade association
7
Other
1
Not yet analyzed
1
Comments over time
Weekly arrivals, stacked by stance.
Posted May 21, 2025Deadline Jul 22, 2025
May 19Jul 14Jul 28Dec 8Jun 22
Support23Oppose0Other3
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Business
100%
0%
0%
Trade association
100%
0%
0%
Advocacy
83%
0%
17%
Individual
0%
0%
100%
Other
0%
0%
100%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Choose up to five.
| Organization | Modernize repair criteria | Cost-benefit analysis | Trenchless rehabilitation technologies |
|---|---|---|---|
American Forest & Paper Association and Process Gas Consumers Group Trade associationSupport The American Forest & Paper Association and the Process Gas Consumers Group, representing manufacturing trade associatio | · | · | |
API, LEPA, GPA Midstream Association, and AFPM Trade associationSupport The American Petroleum Institute, Liquid Energy Pipeline Association, GPA Midstream Association, and American Fuel & Pet | · | · | |
Energy Transfer LP BusinessSupport Energy Transfer LP argues that current PHMSA repair criteria and remediation timelines are outdated, overly prescriptive | · | · | |
GPA Midstream Association Trade associationSupport The GPA Midstream Association supports the modernization of pipeline repair criteria regulations to reflect current tech | · | · | |
Progressive Pipeline Management BusinessSupport Progressive Pipeline Management, a trenchless pipeline rehabilitation contractor, supports the rulemaking by advocating | · | · |
API, LEPA, GPA Midstream Association, and AFPM
Trade associationSupport
Modernize repair criteria
Energy Transfer LP
BusinessSupport
Modernize repair criteria
GPA Midstream Association
Trade associationSupport
Modernize repair criteria
Progressive Pipeline Management
BusinessSupport
Trenchless rehabilitation technologies
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
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- Jun 26, 2026American Forest & Paper Association and Process Gas Consumers GroupSupportTrade association📎 Attachment
The American Forest & Paper Association and the Process Gas Consumers Group, representing manufacturing trade associations, support the proposed action but request specific modifications to balance safety with economic impacts. They advocate for a minimum safety standard requiring six months of advance notice for pipeline service disruptions, the inclusion of end-user disruption costs in risk assessments, and the issuance of guidance for interactive communication and mitigation plans.
Read comment → - Dec 2, 2025American Petroleum Institute (API) and Liquid Energy Pipeline Association (LEPA)SupportTrade association📎 Attachment
The American Petroleum Institute (API) and the Liquid Energy Pipeline Association (LEPA) submitted a cost-benefit analysis supporting their proposed revisions to pipeline repair criteria. They argue that modernizing the regulations to allow for risk-based assessments and longer remediation timelines for certain dents and corrosion anomalies will result in over $1 billion in industry cost savings while maintaining safety.
Read comment →