Feb 17, 2017 Comments to the U.S. Department of Transportation on the Pipelines and Hazardous Materials Safety Administration Interim Final Rule for Safety of Underground Natural Gas Storage Facilities
The Independent Petroleum Association of America (IPAA) submits the following comments in response to the Interim Final Rule (IFR) issued on December 19, 2016, by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) in Docket No. PHMSA-2016-0016. IPAA represents the companies that drill 90 percent of the nation’s oil and natural gas wells. These companies produce 85 percent of American natural gas and 54 percent of American oil. IPAA members represent the full range of producers, from small family-owned businesses, to the large independent companies that are some of the largest domestic natural gas producers. IPAA’s comments focus on the need for PHMSA to clarify that its underground gas storage regulations do not apply to storage associated with production.