Effective Jan. 1, 2012, all liquid and gas pipeline operators must now obtain an Operator Identification (OPID) number. The forms for doing this are available on PHMSA’s website, and become part of the National Registry of Pipeline and LNG operators. An operator may use one number for its entire system, or obtain different numbers for each part of their system. Significantly, this new rule also requires an operator to update its National Registry OPID information upon the occurrence of certain events, most notably including the requirement to provide PHMSA 60 days prior notice before any new construction, replacement or modification of a pipeline facility commences that costs $10M or more. Many operators and agencies are not yet fully aware of this pre-construction notice requirement, and there is virtually no guidance available as of yet on how the rule will be applied. Operators should be aware of this new requirement and consider its applicability in all construction planning. See 49 C.F.R. Parts 191.22; 195.64.