Gas Gathering Pipelines

Editor’s Note: This blog post is the first in a three-part series.

UPDATE 10/6/22: Following the 2021 PHMSA gas gathering rule, over 350,000 miles of gas gathering pipelines operate without any regulated safety standards, though all need to file incident and annual reports.

Over the course of the next few weeks, we’ll take a look at each category of natural gas pipeline and explain why it’s important that every pipeline be sufficiently regulated. 

The three main types of natural gas pipelines are gas gathering, gas distribution, and gas transmission.

This week, we’ll start off with gas gathering pipelines, an extremely important and relevant topic as the federal regulator, the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) has recently put crucial safety measures in place for gas gathering lines. As of the effective date of May 16, 2022, with the implementation of PHMSA’s Final Rule, “Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments,” certain gas gathering lines have become regulated for the first time. 

What is a Gas Gathering Pipeline? 

Natural gas gathering pipelines move unprocessed natural gas, comprised almost entirely of methane, away from the point of production, such as a well pad, to another facility for further refinement or to a transmission pipeline. All sections of transportation, from production to the end user, have had to meet some level of state or federal safety and environmental regulation, except the gathering portion. 

Historically, gathering lines were small diameter, low pressure pipelines in very rural areas – therefore they posed a relatively small threat to people, hence these pipelines being almost entirely unregulated. However, as the shale and fracking boom took hold, gathering pipelines grew in size and pressure and are now at times difficult to distinguish from large gas transmission pipelines. Along with this growth in mileage, size, and pressure came a large increase in the risk this almost entirely unregulated system of pipelines poses to people and the environment. 

PHMSA has been working on gas gathering pipeline regulations for 11 years, including multiple public comment periods and approval by an industry-advantaged advisory committee. The pipeline industry has been fighting hard against these much-needed rules and GPA Midstream recently brought that fight to the courts. 

Why Gas Gathering Lines Need to be Regulated 

PHMSA roughly estimates over 450,000 miles of gas gathering lines in the country fall outside of any federal or state pipeline safety regulation, meaning they are completely unregulated. 

Due to their lack of regulation, pipeline operators are not required to file annual reports or incident reports. This means the full extent of the risks they pose, or even how many lines there are, or where they are, is unknown. However, multiple high-profile incidents can be traced back to gas gathering lines, including the 2018 death of three-year-old Delaney Tercero, who was killed when a 10-inch diameter, non-odorized, gas gathering pipeline exploded about 20 feet from her home. 

The regulation of these lines has been one of Pipeline Safety Trust’s (PST) top priorities for years, in addition to being a major priority for state pipeline safety regulators, as demonstrated by a resolution the National Association of Pipeline Safety Representatives (NAPSR) passed in 2010. 

Gathering Lines Leak Massive Amounts of Methane:

• Recent reports have identified gas gathering lines as playing an outsized role in methane emissions. The White House’s Methane Emissions Reduction Action Plan calls out the importance of PHMSA’s new rule “Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High- Pressure Lines, and Other Related Amendments,” in reducing greenhouse gas emissions. 
• According to the Environmental Defense Fund (EDF), several studies identify gathering pipelines in particular as significant sources of methane emissions. EDF found that one study by Stanford University surveyed parts of the Permian Basin in New Mexico and evaluated medium-to-large point-source emissions, with the majority of emissions coming from well sites, which include gas gathering pipelines. 
• Just one leak in March 2022 from a gathering line owned by Energy Transfer emitted an estimated 900 metric tons of methane in about an hour. That’s the GHG equivalent of annual emissions from 16,000 cars.

PST Thoughts on the Final Rule:

PST believes this is a great first step and recognizes that PHMSA’s final rule does address some of the important regulatory gaps that exist with gas gathering lines; as this rule brings some safety regulations to nearly 100,000 miles of the 450,000+ miles of previously unregulated gas gathering lines. Also, the rule, for the first time, requires annual and incident reporting on all gas gathering pipelines.  That’s right, until this rule operators didn’t have to file any reports, even when a gas gathering line exploded. These rules will help the regulators and the public learn more about the risks these lines pose. The Pipeline Safety Trust will continue to fight to ensure that all gathering lines are brought under some level of regulation.