The Interstate Natural Gas Association of America criticizedproposed transmission pipelinesafety rules as "overlycomplicated and rigid," echoing the objections of other industryrepresentatives.
In comments submitted July 7 to the U.S. Pipeline andHazardous Materials Safety Administration, INGAA said the sweeping set of ruleswould force operators to redirect their resources to focus on activities that "dolittle, if anything, to increase the margin of safety."
The regulatory proposal overemphasizes using hydrostaticpressure tests to assess the maximum allowable operating pressure of pipelines,INGAA wrote. Instead, PHMSA should allow operators to focus more on advancingemerging technologies that have the ability to provide more information aboutthe infrastructure, the association said.
INGAA took issue with other testing requirements for legacypipe and material verification, arguing that what PHMSA has proposed wouldresult in more methane being released into the atmosphere from pipelinesundergoing testing and more gas service disruptions than would be necessarywith other testing strategies.
The association also said PHMSA's notice of proposedrulemaking did not effectively weigh the cumulative impact of the regulations.
"Provisions that would appear to be limited to specificsituations and types of pipelines in fact apply far more broadly due tonumerous cross references," INGAA wrote in its comments. "The[notice] does not acknowledge the actual reach of the proposed regulations, thecost associated with this, or the cumulative impact."
Seconding concernsexpressed July 7 by the American Petroleum Institute, INGAA said PHMSA'sregulatory impact analysis was "grossly inaccurate" in its estimatesof the rule's costs and the benefits.
"INGAA is committed to pipeline safety and accepts thechallenge of continuously improving pipeline integrity and safe operations,"the association wrote. "INGAA requests that PHMSA promote this effort bypromulgating regulations that enable, rather than , operators' to implement the most effectivetechnologies and approaches for promoting the safe and reliable operation ofthe nation's gas pipeline infrastructure."
The American Gas Association has expressed similarconcerns, contendingthat PHMSA's rulemaking may have unintended consequences and is rife with inconsistencies.
In separate comments filed late July 7, the IndependentPetroleum Association of America, along with 11 other oil and gas producerassociations, said PHMSA overstepped its bounds in its approach to regulatingnatural gas-gathering lines. The administration's decision to regulategathering lines based more on location than function is baseless and wouldnegatively affect the upstream sector, the groups argued.
"The independent producers are concerned that an overlyexpansive view of gathering that is based on something other than a pipeline'sfunction … threatens to regulate congressionally-exempted production facilitiesat the expense of sorely needed domestic energy resources and without anycommensurate improvement in actual pipeline safety," the comments said. "[T]hedesire to regulate more gathering lines and the challenges faced by PHMSA inenforcing its regulatory program do not justify disregarding the jurisdictionalboundaries set by Congress."
PHMSA issued the roughly 550-page in response tocongressional mandates and National Transportation Safety Boardrecommendations. The regulations would expand data collection requirements,compel companies to better understand pressure limitations, increaseconstruction oversight and broaden certain rules' reach beyond high-consequenceareas, among a host of other requirements.