The page contains information on comment opportunities that have passed. We retain it here for a record in order to continue to monitor the implementation of these initiatives.


FEDERAL PROCEEDINGS

Safety of Hazardous Liquid Pipelines – comments due January 8, 2015

Pipeline Safety Trust final comments can be downloaded here (and draft comments are here).

You can also download our Talking Points about this proposed rule.

This proposed rule has been in the works for over five years, and the docket folder is quite large. See the Trust press release for our first reaction to this proposed rule. Here is an abbreviated list of what this rule covers:

  • Extends all hazardous liquid reporting requirements to gathering lines and gravity lines.
  • Requires inspections of hazardous liquid pipelines in areas affected by extreme weather, natural disasters, and other similar events within 72 hours.
  • Extends the requirement to do inline inspections of hazardous liquid pipelines outside of high consequence areas (HCAs), with an inspection frequency of every 10 years.
  • Requires the use of leak detection systems on hazards liquid pipelines in all locations.
  • Changes the criteria and timing for hazards liquid pipeline repairs.
  • Requires pipelines in HCAs to be able to accommodate inline inspection tools within 20 years, unless the basic construction prevents it.

See our Fall 2015 newsletter for more analysis of the rule.

Step-by-step instructions for commenting

We recommend you prepare your own comments in a document ahead of time, then follow the instructions below to either attach or paste your comments to the website:

1. Go to www.regulations.gov and type PHMSA-2010-0229 into the search box, then click on the ‘Featured Result’ which should be the Docket for “Pipeline Safety: Safety of Hazardous Liquid Pipelines” (or click here to go directly to this Docket).  This Docket contains many documents because the process started over five years ago, and PHMSA solicited comments on their advanced notice of proposed rulemaking back in 2011. You can read the documents and the old comments by browsing through files in this folder if you’d like.

2. ClickNPRM-HLSafety-comment-image on the “Comment Now!” blue button that is next to the letters “PR” and the text “Pipeline Safety: Safety of Hazardous Liquid Pipelines” (due date underneath the blue button says Jan 08, 2016).

3. Either copy and paste your comment text from your document into the comment box, or say “See attached” or something similar in the box (it cannot be blank). If attaching a file, click on the “Choose file” button and browse your computer to attach your comment file.

4. Fill out the required information and click the “Continue” button.

5. On the next page “Your Preview” shows how your comment and info will appear. Verify things, click the check box, and then click the blue “Submit Comment” button and you’re done. A receipt will be generated that verifies your comments have been received, though sometimes it takes a day or two for them to be posted online.

Let us know if you need more information or any help!

 

National Pipeline Mapping System, Information Collection – comments due November 25, 2015

This information collection proposes to make broad changes to the geographic information collected from pipeline operators, and the way in which PHMSA’s National Pipeline Mapping System (NPMS) presents that information. It will result in more accurate map locations, and more information collected about the pipelines. Unfortunately, most of the new information will be kept from the public as it’s being classified as PIMMA (government-only) or SSI (security sensitive) access.

For more information on NPMS, see:

Here is a brief summary of the Trust’s comments about the NPMS proposed changes. Please contact us if you would like help developing and/or submitting your own comments:

  • Most importantly, information about pipelines should be accessible to the public, not just PHMSA or governments, but also local planners, emergency personnel and the general public. Congress and the National Transportation Safety Board agree that information such as whether or not a pipeline segment is within a ‘high consequence area’ is information the public should have access to, as well as specifics about the pipeline size, pressure, and product. PHMSA proposed three levels of information sharing and security: SSI (highly secure, available only to PHMSA and certain other federal agencies), PIMMA (somewhat secure, available only in limited geographies to government officials with credentials), and public (available to all). Currently the NPMS proposal keeps most of the information as SSI – highly secure, not even revealing it to local government officials, with only a very limited amount proposed to be public. Other federal agencies routinely release nationwide geographic data to the public – including US Fish & Wildlife (critical habitat, endangered & threatened species); US EPA (sole source aquifers); Dept of Interior’s Bureaus of ocean Energy Management and Environmental Enforcement (energy pipeline details such as size, product, leak detection, testing history, operating pressure). PHMSA should view the public as allies in pipeline safety, not adversaries.
  • We support the change in mapping accuracy to +/-100 feet, or +/-50 feet in high population areas. While we would prefer something even more accurate, this proposed change is a big improvement from the current +/-500 feet accuracy.
  • PHMSA should institute a feedback loop so that communities can clearly see ‘high consequence areas’ (generally higher population or more environmentally sensitive areas like drinking water sources) on the maps, and that any changes noted to these areas by pipeline operators, their contractors, or communities be returned to PHMSA within a certain timeframe and added to the NPMS.
  • Certain pipeline attributes NOT proposed to be included on NPMS, should be, including: where pipelines cross waterbodies over 100′; what type of leak detection is present; pipeline seam type (proposed to be collected for only some pipeline areas); and age of pipe construction.

Please submit your own comments on this important issue by clicking “comment now” on this link, or contact us for help.

 

FEDERAL SPECIAL PERMITS

These are permits requested by individual pipeline operators to waiver from particular pipeline safety regulations. PHMSA has latitude with these special permits to impose conditions (you can see existing special permits that have been granted by PHMSA in the past here). We list them here by the state or region they apply to. You really have to download the operator’s permit request and other documents that are posted on the docket to get an understanding of what is being requested, as they can vary widely. Many have to do with changes to population density near the pipelines, triggering the need for the operator to follow different rules and sometimes replace pipe, or ask for an alternative through this special permit process.

North Dakota; HESS North Dakota Pipelines (comments due Jan 25, 2016) – see docket PHMSA-2015-0210 (subject: pipe material)

 

STATE PROCEEDINGS

Pennsylvania

The Governor-appointed Pipeline Infrastructure Task Force released a draft report of their recommendations, and comments are being accepted on this draft through December 29 (extended from Dec 14), 2015. To comment, use the PA Department of Environmental Protection eComment tool, or submit them in writing to DEP Policy Office, Rachel Carson State Office Building, P. O. Box 2063, Harrisburg, PA 17105-2063.