How to Comment on Pipeline Safety
Frequently, opportunities arise for citizens, local governments, and community groups or agencies to provide public comment and participate in proceedings related to pipeline safety. Often, voices from the pipeline industry are the only ones heard by state and federal legislators and regulators when pipeline safety related laws or rules are proposed. If you care about these issues, it’s important to weigh in and make your voice heard.
There are many different types of opportunities to participate in decision making related to pipeline safety. The two most common ways are through proposed legislation and rulemaking at both the federal and state levels. Often legislation will direct agencies to write new regulations or update existing ones; however, rulemaking can and sometimes does happen without a specific legislative directive.
Legislation
Whether it is federal or state legislation, one of the most impactful ways to engage and have your opinion known is to reach out directly to the office of the author or sponsor of that legislation. There are also sometimes opportunities to provide written or oral public comment and/or testimony when legislation is heard in committees. The Pipeline Safety Trust has commented on, submitted letters of support and opposition, and provided testimony on numerous pipeline safety related bills at both the federal and state level. You can view these on PST’s legislative advocacy page.
Regulation
Similar to legislation, updates to pipeline safety regulations happen at both federal and state levels. While the federal rulemaking process is relatively straightforward, every state has different administrative laws and procedures when it comes to the rulemaking process. You can often find more information on this by searching “(insert state here) rulemaking process” via a search engine. You will often be directed to a page explaining the rulemaking process hosted by a state regulatory body. If you cannot find information related to the regulatory process for pipeline safety in your state, please reach out to PST’s State Policy Advisor, Amanda McKay (). Below is an explanation of the federal rulemaking process.
What Is Federal Rulemaking?
Federal agencies develop rules to implement laws passed by Congress. An agency, such as the Pipeline and Hazardous Materials Safety Administration (PHMSA), cannot issue a rule unless it is granted authority to do so by law. This process, known as rulemaking, includes multiple stages designed to include public input. Understanding how each stage works helps individuals and organizations know when and how to engage effectively. The three main stages of rulemaking are:
- Advanced Notice of Proposed Rulemaking (ANPRM)
- Notice of Proposed Rulemaking (NPRM)
- Final Rule
Advanced Notice of Proposed Rulemaking (ANPRM)
An ANPRM is an optional, early-stage notice that agencies use when they’re considering creating a new rule or revising an existing one. At this point, they typically haven’t drafted any formal rule language. Instead, the agency publishes an ANPRM in the Federal Register to ask for public input, data, or perspectives that can help shape the direction of the potential rule or whether a rulemaking should be initiated.
This is one of the opportunities for the public to influence the rulemaking process. By engaging early, stakeholders can help identify issues the agency may not have considered, propose alternative approaches, or share technical or community-based insights.
Notice of Proposed Rulemaking (NPRM)
An NPRM is the formal announcement of an agency’s intent to address an issue through a rulemaking and includes draft rule language. This is published in the Federal Register for the public to comment on. An NPRM also opens a public comment period, typically lasting 30 to 60 days.
During this time, the public is invited to submit written feedback. This can include support for the rule, opposition, suggested changes, new data, or questions. Comments are reviewed by the agency and can lead to significant revisions before the rule is finalized. It’s critical for the public and stakeholders to participate at this stage, as the agency is legally required to consider and respond to relevant comments before moving forward.
Final Rule
Once the agency has reviewed all public comments and conducted a comment analysis, the agency decides whether it would like to proceed with the rulemaking process, submit a new or modified proposal, or withdraw the proposal.
Once the agency has made its final revisions on the proposed rule, it publishes a Final Rule. This version includes the final text of the rule, an explanation of how comments were addressed, and an effective date for when the rule will take effect.At this point, the formal public comment period has ended, but many agencies will accept comments on the Final Rule for a short period of time, but does not have the same legal obligation to consider these comments as it did during the NPRM stage. Engagement can still continue in other ways. Individuals can monitor the rule’s implementation, suggest regulatory amendments through petitions for rulemaking, or, in some cases, pursue legal challenges if the rule is believed to be unlawful.
When and How the Public Can Engage in Federal Rulemaking
The public can engage during the ANPRM, NPRM, and FR stages by submitting comments through Regulations.gov. Comments can include personal stories, data, technical analysis, or legal arguments. Participation from the public ensures that diverse viewpoints are considered and helps agencies create more informed and equitable rules. It is important to remember that these comments are indeed “public,” so private information should not be shared.
Even after a rule is finalized, the public can remain involved by tracking how it’s enforced or advocating for changes. The rulemaking process is designed to be participatory, and public engagement plays a critical role in shaping the policies that govern everything from environmental protection to public safety.
How to Track & Comment on Pipeline Safety Rules
1. Search for pipeline-related rules
Federal rulemakings are posted at:
https://www.regulations.gov/
PHMSA’s agency page:
https://www.regulations.gov/agency/PHMSA
2. Sign up for email notifications
You can “Follow” PHMSA dockets to receive alerts when rules open for comment.
Create a free account on Regulations.gov to:
- Track specific dockets
- Get notified about new documents
- Submit written comments electronically
3. Monitor the Federal Register
Daily publication of federal rules:
https://www.federalregister.gov/
Tip: Search terms like “pipeline safety,” “PHMSA,” “gas transmission,” “hazardous liquids,” or specific rule topics.
4. Email Notification Setup
- Make an account at Regulations.gov
- Navigate to PHMSA’s agency page
- Select a rulemaking docket of interest
- Click “Follow” to receive updates via email
Resources:
- Learn about the regulatory process at regulations.gov
- PST Guide to Public Comment: PHMSA’s Advanced Leak Detection Rulemaking (example resource)
- https://www.utc.wa.gov/sites/default/files/2021-02/PST Guide to Pipeline Safety Rulemaking First edition%252C 2016.pdf Pipeline Safety Trust Guide to Pipeline Safety Rulemaking
Read some of our own comments submitted over the years by viewing our Policy Library.
If you want more information about how the rulemaking process works, please read our Guide to Pipeline Safety Rulemaking
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