McAfee & Taft RegLINC - April 2012: Industry comments on high consequence area (HCA) expansion By Heidi Slinkard Brasher


By Heidi Slinkard Brasher

PHMSA’s Advance Notice of Proposed Rule Making (ANPRM) in August 2011 (76 Fed. Reg. 53086, August 25, 2011), posed several questions on numerous pipeline safety issues, including possible expansion of HCAs. However, the January pipeline safety legislation addressed some of the issues raised by the agency’s ANPRM.

As a result many, including the Interstate Natural Gas Association of America (INGAA) which commented on January 20, 2012, argue the HCA definition adequately protects people and property based on prioritized risks and does not warrant further expansion. Expansion, INGAA argued, would increase industry costs and not increase public safety because many already voluntarily extend additional integrity management measures to areas outside of the HCAs, and it estimates that by 2030 all areas within the potential impact radius of all pipelines will have integrity management principles applied, thereby making expansion of HCAs unnecessary at this time.

It remains to be seen how PHMSA will respond to stakeholder comment.



DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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