Policy Work
This page provides information on comments and testimony of the Pipeline Safety Trust related to federal pipeline safety legislation, federal agency initiatives, and state agency initiatives. It is ordered chronologically, beginning with comments from the current year and continuing back in time to previous years’ comments.
2023
Federal and State Legislation and Testimony
Federal Agency Comments
PST Letter to PHMSA Requesting Public Meeting on CO2 Pipeline Safety 2-17-2023
PST Letter to PHMSA re Equitrans November 2022 Incident 2-17-2023
PST comment on the Special Permit Application of East Tennessee Natural Gas Transmission, LLC PHMSA-2022-0167 Comments 2-6-2023
State Agency Comments
PST Comment on Proposed South Carolina Gas Regulations 3-13-2023
International
PST Comment on UN Special Rapporteur’s Thematic Report on Detoxification/Decarbonization 3-6-2023
2022
Federal and State Legislation and Testimony
Federal Agency Comments
2021
Federal and State Legislation and Testimony
Federal Agency Comments
Comments of the Pipeline Safety Trust on the Special Permit Application of Sabal Trail Transmission PHMSA-2021-0052 Comments 9-27-2021
Comments of the Pipeline Safety Trust on Docket PHMSA-2021-0039 on PHMSA’s Public Meeting on Pipeline Leak Detection, Leak Repair, and Methane Emission Reductions PHMSA-2021-0039 Comments 5-24-2021
Pipeline Safety Trust presentation at PHMSA Public Meeting on Pipeline Leak Detection, Leak Repair, and Methane Emission Reductions 5-5-21
Comments of the Pipeline Safety Trust on FERC Docket PL18-1-000 on the Certification of New Interstate Natural Gas Facilities FERC policy on certifications Docket PL18-1-000 Comments 5-26-2021
Comments of the Pipeline Safety Trust on FERC Docket AD21-9-000 on the creation of the Office of Public Participation. FERC AD21-9-000 FERC OPP Comments 04-21-2021.
2020
Federal Legislation and Testimony
Federal Agency Comments
Comments of the Pipeline Safety Trust on Regulatory Reform for Hazardous Liquid Pipelines – Docket: PHMSA-2018-0047: US-Docket-PHMSA-2018-0047 Liquid reg reform comments
Comments of the Pipeline Safety Trust on Regulatory Reform for Gas Pipelines – Docket no. PHMSA-2018-0046: US-docket-PHMSA-2018-0046-Gas rollback comments-08102020
2019
Federal Legislation and Testimony
PST Testimony to House Transportation and Infrastructure Committee, Subcommittee on Railroads, Pipelines, and Hazardous Materials, Hearing on Pipeline Safety:Reviewing the Status of Mandates and Examining Additional Safety Needs, April 2, 2019.
Federal Agency Comments
PST comments on PHMSA information collection: Gas and Liquid Pipeline Safety Program Certification: PHMSA-2018-0109
2018
Federal Legislation and Testimony
PST testimony to the House Transportation and Infrastructure Committee, Subcommittee on Railroads, Pipelines, and Hazardous Materials, on the oversight of implementation of the PIPES act of 2016; 6/21/2018.
Hearing video here: https://youtu.be/ZujvtKbnLVo
Federal Agency Comments
PST comments on Class location requirements ANRM: PHMSA-2017-0151
PST comments on Pipeline Safety: Safety of Gas Gathering Pipelines (one third of the original gas pipelines proposed rule) original docket number PHMSA-2011-0023; RIN number for gathering lines RIN 2137-AF38
2017
Federal Agency Comments
PST comments on US Department of Transportation Regulatory Review: DOT-OST-2017-0069
2016
Federal Legislation and Testimony
PST testimony to the House Transportation & Infrastructure Committee on the Reauthorization of DOT’s Pipeline Safety Program – 2/25/16
PST testimony to the House Energy and Commerce Committee on the Reauthorization of DOT’s Pipeline Safety Program – 3/1/2016
Federal Agency comments
PST Comments regarding Hazardous Liquid Pipeline Safety, docket number PHMSA-2010-0229; submitted January 7, 2016.
Text of final Hazardous Liquid Rule submitted to Federal Register for publication but not published, and therefore not in effect in PHMSA-2010-0229.
PST Comments on four special permit applications seeking exemption from pressure testing or pipe replacement because of a change in class location PHMSA-2016-0004, -0006,-0007,-0008. TGP special permit comments; Southern special permit comments; ElPaso special permit comments; Colorado gas spec permit app
PST Comments regarding Safety of Gas Transmission and Gathering Pipelines (Docket PHMSA-2011-0023), submitted July 6, 2016
Appendices
A Review, Analysis and Comments on Engineering Critical Assessments as proposed in PHMSA’s Proposed Rule on Safety Of Gas Transmission and Gathering Pipelines, by Richard Kuprewicz, Accufacts, Inc.
Pipeline Blowdown Emissions and Mitigation Options, by MJ Bradley and Associates
Report to the Secretary: Pipeline Integrity Management, an Evaluation to Help Improve PHMSA’s Oversight, Rick Kowalewski
State Agency comments
PST comments on Washington State Department of Ecology preliminary draft language for spill response planning rule changes
2015
Federal Legislation and Testimony
Trust Testimony from the July 14, 2015 House Subcommittee Hearing on Oversight of Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 and Related Issues. The video of the hearing is available here.
State Legislation and Testimony
Federal Agency comments
PST Comments regarding the National Pipeline Mapping System, docket number PHMSA-2014-0092; submitted November 24, 2015.
2014
Federal Legislation and Testimony
Trust Testimony from the May 20, 2014 House oversight hearing on the implementation of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, before the Subcommittee on Railroads, Pipelines and Hazardous Materials of the Committee on Transportation and Infrastructure. After the hearing we were asked some follow up questions for the record regarding the proper authority for siting oil and gas pipelines. Our answers to those question can be found here. The hearing can be viewed through the subcommittee website, and written testimony from others can be downloaded there as well.
Federal Agency comments
PST comments regarding the National Pipeline Mapping System, docket number PHMSA-2014-0092; submitted December 1, 2014.
PST comments regarding annual data collection for state program certifications (both gas and hazardous liquid), docket number PHMSA 2014-0005; submitted June 5, 2014
PST comments regarding pipeline operator data collection, docket number PHMSA 2014-0018; submitted May 30, 2014
PST comments regarding gas gathering line definition, docket number PHMSA 2014-0004; submitted Feb 11, 2014
2013
Federal Legislation and Testimony
Trust Testimony from 7/9/2013 U.S. House hearing on H.R. 1900, the Natural Gas Pipeline Permitting Reform Act.
Pipeline Safety Trust Board President Rick Kessler testified in front of the U.S. House of Representatives, Energy & Commerce Committee on Tuesday, July 9, against H.R. 1900. View the hearing here including Rick’s testimony (starting at 1:39:48).
Trust Testimony from 1/28/2013 U.S. Senate field hearing in West Virginia
“So here we are again after the very recent failure of a pipeline in Sissonville which completely destroyed three homes, damaged other homes, caused extensive damage to an interstate highway, and once again terrorized a community. This recent failure falls too soon after a spate of significant failures over the past few years in Michigan, California, Pennsylvania, Montana, and Utah. Many of these failures had common themes and common solutions that could have prevented or at least minimized their impacts. We have been asking for action on these issues in previous hearings following previous tragedies for years now. Last Congress passed the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, which began to move the regulators and the pipeline industry in the right direction on some of these issues, but the speed of review, rule making, implementation and enforcement of the needed changes was not sufficient to prevent the tragedy in Sissonville. It is our sincere desire not to be back in front of this committee again in the future saying the same things after yet another tragedy.”
Federal Agency comments
PST class location comments regarding docket number PHMSA 2013-0161; Nov 1, 2013. A class location public workshop on this docket was held Ap 16, 2014, which included a presentation by Carl Weimer.
PST comments on changes to incident and annual reports for gas pipeline operators regarding docket number PHMSA 2013-0084; submitted Aug 26 and Dec 20, 2013
PST mapping information comments regarding docket number PHMSA 2013-0137
PST comments on revisions to annual reports for hazardous liquid pipeline operators regarding docket number PHMSA 2013-0003; submitted Aug 12, 2013
Trust comments submitted to the US Department of Transportation regarding their draft Strategic Plan; Sept 10, 2013
State Agency comments
Trust comments submitted to WA State Department of Ecology on 9/9/2013 regarding the Kinder-Morgan Transmountain Pipeline Oil Spill Contingency Plan.
2012
Federal Agency comments
Comments on the Advanced Notice of Proposed Rulemaking Relating to the Safety of Gas Transmission Lines (docket PHMSA-2011-0023) – January 19, 2012
State Agency comments
Comments on the Draft Report of the Montana Oil Pipeline Safety Review Council – June 2012
2011
Federal Legislation and Testimony
Testimony to Congress 2011
PST testimony on July 15, 2011 before the House Committee on Energy and Commerce, Subcommittee on Energy and Power
PST testimony on July 14, 2011 before the House Committee on Transportation and Infrastructure, Subcommittee on Railroads, Pipelines and Hazardous Materials
PST testimony June 16, 2011 before the House Committee on Energy and Commerce, Subcommittee on Energy and Power
Pipeline Safety Legislation In Congress 2011
Bill from Senator Frank Lautenberg (NJ)
Pipeline Transportation Safety Improvement Act of 2011
Bill from Senators Feinstein and Boxer (CA)
Strengthening Pipeline Safety and Enforcement Act of 2011
Bill from Rep. Jackie Speier (CA)
Pipeline Safety and Community Empowerment Act of 2011
Bill from the Obama Administration
Federal Agency Comments
Presentation of Carl Weimer to Pipeline Safety Forum: “What are the highest Pipeline risks?” – April 18, 2011
Comments on Pipeline Safety; Safety of On‐Shore Hazardous Liquid Pipelines – (docket PHMSA-2010-0229) February, 2011
2010
Federal Legislation and Testimony
Congressional Hearings on Pipeline Safety –
These links lead to copies of the testimony given and videos of the hearings.
Subcommittee on Railroads, Pipelines, and Hazardous Materials
Implementation of the Pipeline Inspection, Protection, Enforcement and Safety Act of 2006 and Reauthorization of the Pipeline Safety Program
Senate Committee on Commerce, Science, and Transportation
Subcommittee on Surface Transportation and Merchant Marine Infrastructure, Safety, and Security
Ensuring the Safety of Our Nation’s Pipelines
Subcommittee on Railroads, Pipelines, and Hazardous Materials
The Safety of Hazardous Liquid Pipelines: Regulated vs. Unregulated Pipelines
Subcommittee on Railroads, Pipelines, and Hazardous Materials
The Safety of Hazardous Liquid Pipelines (Part 2): Integrity Management
Subcommittee on Railroads, Pipelines, and Hazardous Materials
Pipeline Safety Public Awareness and Education
Hearing on “Pipeline Safety Oversight and Legislation”
Hearings – Subcommittee on Energy and Environment
Senate Committee on Commerce, Science, and Transportation
Subcommittee on Surface Transportation and Merchant Marine Infrastructure, Safety, and Security
Pipeline Safety: Assessing the San Bruno, California Explosion and Other Recent Accidents
Pipeline Safety Trust’s 2010 Congressional Testimony
Rick Kessler – September 23, 2010
Background Information
Pipeline Safety and Security: Federal Programs
Congressional Research Services, February 18, 2010
2009
Federal Agency Comments
Docket number PHMSA-2008-0291 regarding reporting requirements for operators of liquid, gas, and LNG lines; PST comments, August 27, 2009
2007
Federal Legislation and Testimony
PST testimony on March 12, 2007 before the House Committee on Energy and Commerce, Subcommittee on Energy and Air Quality
2006
Federal Legislation and Testimony
PST testimony on Nov 16, 2006 before the Senate Committee on Commerce, Science & Transportation, Hearing on Reauthorization of the Pipeline Safety Program – testimonies and information available through this link
PST testimony on July 27, 2006 before the House Committee on Energy and Commerce, Subcommittee on Energy and Air Quality; all testimonies available through this link
PST testimony on March 16, 2006 Testimonies before the House Committee on Transportation and Infrastructure, Subcommittee on Highways, Transit, and Pipelines – all testimonies available here
2004
Federal Legislation and Testimony
Testimony Before the Subcommittee on Energy and Air Quality, Committee on Energy and Commerce, House of Representatives; July 20, 2004
U.S. Government Accountability Office’s Preliminary Information on the Office of Pipeline Safety’s Actions to Strengthen Its Enforcement Program
The Testimony of Mr. Breean Beggs Board of Directors, Pipeline Safety Trust
2000 and earlier
Federal Legislation and Testimony
March 13, 2000 – US Senate Committee on Commerce, Science and Transportation
Testimony of Katherine Dalen
Testimony of SAFE Bellingham
Testimonies of Marlene Robinson and Bruce Brabec
October 27, 1999 – Subcommittee on the Economic Development, Publice Buildings, Hazardous Materials, and Transportation and Infrastructure, Hearing on Bellingham Washington Hazardous Liquid Pipeline Explosion
Testimony of SAFE Bellingham
July 27, 1999 – House of Representatives Committee on Transportation and Infrastructure Subcommittee on Economic Development, Public Buildings, Hazardous Materials, and Pipeline Transportation
Testimony of Jim Hall, Chairman- National Transportation Safety Board