The City of San Francisco is currently appealing the Northern District of California’s dismissal of its claims brought under the citizen suit provision of the Pipeline Safety Act (PSA), including a claim that the Pipeline and Hazardous Materials Safety Administration (PHMSA) is required to ensure that pipeline safety standards are enforced by certified States and should limit the disbursement of federal funds accordingly. Appeal, City and County of San Francisco v. U.S. Dep’t. of Transp., No. 13-15855 (9th Cir. Apr. 26, 2013). On October 11, 2013, the Pipeline Safety Trust filed an amicus brief in support of the City of San Francisco’s appeal before the Ninth Circuit, marking the first time that the Trust has ever participated in litigation. The Trust is participating in the appeal based on its belief that the case could determine whether the Trust or others will be able to avail themselves of the citizen suit provision of the PSA, 49 U.S.C. 60121(a). The outcome of the City of San Francisco’s Ninth Circuit appeal should clarify how courts will interpret the PSA citizen suit provision, and may influence judicial review of PHMSA’s actions in the coming years.