News & Analysis as of

PHMSA

Troutman Pepper Locke

FERC Denies NGO Transmission, Inc.’s Application to Abandon Jurisdictional Facilities

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On April 24, 2025, FERC denied NGO Transmission, Inc.’s (“NGO Transmission”) application under 7(b) of the Natural Gas Act (“NGA”) to abandon its jurisdictional facilities and reclassify them from jurisdictional transmission...more

Akin Gump Strauss Hauer & Feld LLP

PHMSA Issues Advance Notice of Proposed Rulemaking to Modernize LNG Facility Regulations

On May 5, 2025, the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published in the Federal Register an Advance Notice of Proposed Rulemaking (ANPRM) titled “Pipeline...more

Steptoe & Johnson PLLC

PHMSA Issues Advance Notice of Proposed Rulemaking Seeking Stakeholder Comments Related to LNG Regulation Amendments

On April 29, U.S. Secretary of Transportation Sean P. Duffy announced that the Pipeline and Hazardous Materials Safety Administration (PHMSA) has submitted an Advance Notice of Proposed Rulemaking (ANPRM) to the Office of the...more

McGuireWoods LLP

Environmental Vanguard: May 2025 Edition

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“Environmental Vanguard” is a quarterly newsletter from McGuireWoods, sharing key insights from our leading environmental attorneys and consultants at the forefront of regulatory, litigation, and policy developments. This...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Shipping...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an April 8th Interpretive Letter a question regarding the Hazardous Materials Regulations (“HMR”) applicable to the use of United...more

Jones Day

PHMSA Issues Proposed Rule Seeking to Impose Enhanced Safety and Operational Requirements on Carbon Dioxide Pipelines

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On January 10, 2025, the Pipeline and Hazardous Materials Safety Administration ("PHMSA") issued a proposed rule setting forth revisions to the federal Pipeline Safety Regulations ("PSR") (49 C.F.R. Parts 190-99) to include...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Carbon...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 3rd Interpretive Letter the applicability of the federal Hazardous Materials Regulations (“HMR”) to a device designed...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Cargo...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a December 20, 2024, Interpretive Letter addressing the application of the Hazardous Materials Regulations (“HMR”) applicable to...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials; Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a January 10th interpretive Letter addressing the application of the Federal Hazardous Materials Regulations (“HMR”) to the combustible liquid...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Letter Addressing Packaging Residue

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 7th Interpretive Letter a question regarding the Hazardous Materials Regulation’s (“HMR”) applicability to residue on...more

K&L Gates LLP

D.C. Circuit Vacates PHMSA's LNG-by-Rail Rule

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On 17 January 2025, the D.C. Circuit Court of Appeals vacated a 2020 Pipeline and Hazardous Materials Safety Administration (PHMSA) rule—the “Hazardous Materials: Liquefied Natural Gas by Rail Rule” (the LNG-by-Rail...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Considerations for Municipalities/Permitting Operations of Lithium-Ion Battery Powered Micromobility Devices: U.S. Pipeline and...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a document titled: Considerations for Municipalities for Permitting Operations of Lithium-Ion Battery Powered Micromobility Devices...more

Blank Rome LLP

LNG by Rail: The D.C. Circuit Vacates a DOT Rulemaking and Outlines a Path for Challenges Yet to Come

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In Sierra Club v. United States Dep’t of Transportation, a panel of the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) vacated and remanded a final rule issued by the Department of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Lithium Battery Guide for Shippers: Pipeline and Hazardous Materials Safety Administration Compliance Tool for All Modes of...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued an October 2024 document titled: LITHIUM BATTERY GUIDE FOR SHIPPERS: A Compliance Tool for All Modes of Transportation (“Guide”)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Lithium...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an October 1st Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”): …to determine...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a September 25th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the definition of...more

Jackson Lewis P.C.

DOT Random Drug and Alcohol Testing Rates for 2025

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The Department of Transportation’s operating agencies have announced their random drug and alcohol testing rates for 2025. The rates are the same as 2024, except that PHMSA has increased its random drug testing rate to 50%....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Aerosols

The Pipeline and Hazardous Materials Administration (“PHMSA”) addressed in an October 9th interpretive letter the application of federal Hazardous Materials Regulations (“HMR”) to limited quantities of compressed gas and how...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Lithium...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an October 16th interpretive letter the application of the Federal Hazardous Materials Regulations (“HMR”) to lithium batteries. See reference...more

Benesch

Motor Carrier Regulatory Agencies: Determining Which are Applicable and How to Comply

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The regulatory environment is top of mind these days coupled with speculation over potential change. Any attention paid to our obligations for safe and lawful operation is positive as we strive for compliance by our companies...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: U.S. Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a September 24th Interpretive Response Letter (“IRL”) a question regarding the Hazardous Materials Regulations (“HMR”) applicable...more

McGuireWoods LLP

PHMSA Proposes Significant Revisions to Rail Hazardous Materials Regulations

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The Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published on Oct. 28, 2024, a notice of proposed rulemaking (NPRM) that recommends modernizing and simplifying the...more

Benesch

Supply Chain Security Is National Security: Cyber, Physical, and Personnel Protections

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U.S. supply chain security is increasingly under threat. The White House’s National Security Strategy describes this moment as an inflection point. Many federal agencies have taken charge in elevating the very concept of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a July 16th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) applicable to: …the size of a...more

Vinson & Elkins LLP

Appeals Court Invalidates Key Parts of PHMSA’s 2022 Rulemaking on Natural Gas Safety

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In a unanimous opinion, a panel of judges from the United States Court of Appeals for the District of Columbia Circuit (the “D.C. Circuit”) vacated four key aspects from a 2022 rulemaking by the Pipeline and Hazardous...more

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