PHMSA recently proposed revisions to its Operator Identification (OPID) forms in an effort to streamline reporting, reduce unnecessary notifications, and collect additional information.  In order to assist the Agency in identifying new operators and monitoring changes to existing pipeline systems, PHMSA requires that operators obtain an operator identification number for their pipeline system(s) and provide the Agency with notice of certain changes, including various construction projects and changes in ownership.  49 C.F.R. Parts 191.22; 195.64.  PHMSA proposes to revise the Agency’s OPID Assignment Request and Registry Notification forms to align with categories on PHMSA incident and accident report forms, enhance clarity, reduce the number of notification types, and collect additional information on miles of pipe and facility description by State.  In conjunction with this proposal, the Agency has identified detailed redline changes to the Assignment Request and Registry Notification, including four flow charts providing guidance on the correct type of registry notification.

When requesting an OPID through the Agency’s Assignment Request form, operators have considerable flexibility in electing how many OPIDS to claim for larger systems.  In addition, operators must report certain construction projects on the Registry Notification form 60 days before construction commences, including projects that cost $10 million or more or construction of 10 or more miles of new pipeline.  Other changes, such as a change in ownership and entity responsible for pipeline safety, must be reported within 60 days after the occurrence of the event.  PHMSA’s Assignment and Registry Notification forms are intended to provide additional guidance to operators in complying with these regulatory obligations.  The Agency has requested comments on its proposed changes on or before May 30th, 2014.