IPAA submitted supplemental comments to the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) on November 16 in response to PHMSA’s Gas Pipeline Advisory Committee (GPAC) discussion of proposed regulatory reform, which included regulation of farm taps. Submitting as “Indicated Producers,” IPAA was joined by the Kentucky Oil & Gas Association, the Ohio Oil & Gas Association, Pennsylvania Independent Oil & Gas Association, the Texas Alliance of Energy Producers, the Virginia Oil and Gas Association, and the Independent Oil and Gas Association of West Virginia.
In the comments, the Indicated Producers noted “support [for] PHMSA in its efforts to align regulatory responsibilities with the safe operation of pipeline facilities. However, Indicated Producers urge PHMSA to recognize the significant differences between privately-owned farm taps, governed by contract or statute, and true distribution systems.” The comments urged PHMSA to make that distinction in pending Frequently Asked Questions, in future proceedings, or in the pending Regulatory Reform rule. Recognizing this significant distinction “will help achieve regulatory reform without interfering with existing contracts and/or state statutes and will better align regulatory responsibility without sacrificing public safety.”