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Inflation Reduction Act
PHMSA to Reassess Underground Natural Gas Storage Rule
On December 19, 2016, PHMSA issued an interim final rule (IFR) to establish for the first time minimum federal safety standards for underground natural gas storage facilities. The rule was issued in response to the 2015 Aliso Canyon storage leak...
DOT Requests Input Regarding Burdensome Regulatory Requirements
As part of his regulatory reform agenda , President Donald Trump instructed federal agencies to review their regulations to identify requirements that burden businesses and industry. See EO 13771 and EO 13777 . In order to comply with these directives...
Technical Advisory Committee Meeting Scheduled on Gas Mega Rule
The Gas Pipeline Advisory Committee (GPAC) will meet [Notice of advisory committee meeting ] in Washington, D.C. early next month to convene the second public meeting regarding PHMSA’s proposed gas rules, often referred to as the gas mega rule. The...
Pipeline Safety Management Systems: Reflections on Implementation of API 1173
The Pipeline Safety Management System (SMS) industry standard API RP 1173 was published in July 2015 and developed by API with input from NTSB, PHMSA, states, and industry representatives, following the 2010 oil pipeline accident in Marshall, Michigan. The standard’s...
The First 100 Days: Executive Directives Impacting the Oil & Gas Pipeline Industry
President Trump has issued 30 Executive Orders and 28 Executive Memoranda since taking office on January 20, 2017, despite his failure to pass any major laws. That is more Executive Orders than any President has issued in the first 100...
Insights to PHMSA Enforcement and Rulemaking under the Trump Administration
Since the Trump Administration took office, oil and gas industry stakeholders have questioned whether pending PHMSA rulemakings will move forward, whether the rate of PHMSA enforcement will continue, and whether agency priorities will change. The API conference held in San...
Industry Responds to U.S. Made Pipe Directive
Industry trade groups anticipate construction delays and cancelations, higher costs, and consumer impacts if the Trump administration’s January 24, 2017 Executive Memorandum , requiring that all new and repaired pipe be made in the U.S., is implemented. In comments filed...
Protecting Critical Energy Infrastructure from Pipeline Sabotage
Oil and gas provides nearly two thirds of all energy used in the United States, which is primarily transported by pipelines. The United States currently has roughly 2.8 million miles of pipelines. Most of this infrastructure is buried, but aboveground...
Expansive Integrity Management Training and Qualification Advisory
PHMSA issued a brief advisory reminding gas transmission operators of training and qualification requirements under the integrity management regulations. The advisory responds to inconsistencies in operator implementation of these rules (at 49 C.F.R. Part 192.915) and outlines PHMSA’s “expectations.” Further...
Underground Natural Gas Storage: Regulations and Fees Move Forward Despite Appeal and Criticism
Last December, PHMSA issued an interim final rule (IFR) to establish—for the first time ever—minimum federal standards for underground natural gas storage facilities. The IFR imposes significant new requirements in a short timeframe for “downhole facilities,” including wells, wellbore tubing...
Fate of Environmental Justice Considerations
Just last summer, EPA released its final version of the Technical Guidance for Assessing Environmental Justice in Regulatory Analysis (EJ Technical Guidance), defining “environmental justice” as “the fair treatment and meaningful involvement of all people regardless of race, color, national...
Recent Developments in Water
Sara Burgin covers a range of water issues, including: Nationwide Permits: What you need to know about the nationwide permits reissued by the Army Corps of Engineers Water Jurisdiction: What waters will be jurisdictional under the Trump administration NPDES Permit...
Risk Management Program (RMP) Update: EPA Adopts Final Amendments to the RMP Rule
Partners Whit Swift and Matt Paulson will discuss the amendments to the RMP rule at 40 CFR Part 68 that EPA finalized on December 21, 2016. The talk will cover the changes to the RMP program that EPA adopted and...