The American Gas Association (AGA) filed joint comments together with the American Public Gas Association (APGA), Interstate Natural Gas Association of America (INGAA), American Petroleum Institute (API), GPA Midstream, American Fuel & Petrochemical Manufacturers (AFPM), and Northeast Gas Association (NGA) with the Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding PHMSA’s Notice of Proposed Rulemaking, ‘Pipeline Safety: Gas Pipeline Leak Detection and Repair.’
These comments make substantive suggestions for improving the implementation of the proposed rule. As stated in the comments, “The Associations support the intent of the proposed rule and share PHMSA’s goal of addressing methane emissions. However, the Associations have significant concerns with PHMSA’s proposed rule, its proposed implementation of the Congressional mandates… and its expanded interpretation of its regulatory reach in the NPRM which is far beyond Congress’ mandate.”
Among the issues identified in the proposed rule is flawed accounting of the costs and benefits by PHMSA, unrealistic timeframes for implementation, mandates for leak detection methodologies that do not necessarily yield tangible improvements in public or environmental safety, and the presumption that all leaks must be managed as hazardous leaks. One major goal of these comments is to help align the proposed rule with the Environmental Protection Agency’s (EPA) anticipated final rule, “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review”, and other regulations aimed at reducing methane emissions.
This objective is reflected in the comments. “Based on the proposed rule, it is the perception of the Associations that PHMSA has shifted its primary focus from pipeline safety to pursue environmental goals. Both goals – improving pipeline safety and reducing emissions – can be accomplished. However, extensive changes must be made to PHMSA’s proposed rule in order for it to be consistent with Congress’ intent in the PIPES Act of 2020 and for it to be technically and economically feasible.”
“Our industry has made and continues to make a sincere commitment to leak detection and repair” said Karen Harbert, AGA President and CEO. “We support improving pipeline safety and reducing emissions and are confident these goals can be met. However, extensive changes to this proposed rule are necessary to ensure that the final rule is viable and not contradictory to other federal guidance. Our comments provide a roadmap for these essential changes.”
Additionally, nine state associations and three regional associations sent a letter to PHMSA endorsing the joint comments. These groups, representing 29 states in total, include the Energy Association of Pennsylvania, the Florida Natural Gas Association, Gas & Oil Association of West Virgina (GO-WEST), the Indiana Energy Association, the Iowa Utility Association, the MEA Energy Association, the Michigan Electric and Gas Association, the New Jersey Utilities Association, the Northeast Gas Association, the NW Gas Association, the Tennessee Gas Association and the Wisconsin Utilities Association.
The full joint comments are available here.
Read the article online at: https://www.worldpipelines.com/regulations-and-standards/29082023/aga-and-others-recommend-improvements-to-phmsa-proposed-rule/
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