In response to comments and concerns from industry stakeholders, PHMSA recently revised its National Pipeline Mapping System (NPMS) information collection proposal that was issued over a year ago.  Operators and industry members expressed concern in particular about the cost and time necessary to submit additional pipeline attributes as well as the sensitive nature of certain data.  In response, the Agency reduced the number attributes it proposes to collect by a quarter, proposed to restrict access to certain sensitive security information, and outlined a three year phase-in period for the new attributes.  While this represents an improvement from PHMSA’s initial proposal, many in the industry argued at a recent workshop that it is still unduly burdensome.

In the Notice, PHMSA withdrew its proposal to collect eight attributes (i.e., installation method where pipe crosses water body of 100 feet or greater, last direct assessment, type of leak detection, special permit segment, offshore gas gathering designations, average daily throughput, refineries, and gas processing and treatment plants).  In addition, the Agency modified certain attributes, most notably the positional accuracy requirement from a proposed 5 feet to 50 feet for most pipelines.  In response to security concerns, the Agency proposed to classify the following attributes as “Sensitive Security Information”:  highest percent operating SMYS; MAOP/MOP; segment “could affect” an HCA, pump and compressor stations; and mainline block valves.  Under the proposal, public access would be limited to five attributes (i.e., pipe grade, pipe join method, onshore/offshore, abandoned lines, breakout tanks (but excluding capacity)), and the remainder of the new attributes would be restricted to the Pipeline Information Management Mapping Application (PIMMA) where access is limited to operators and government officials (e.g., diameter, commodity detail, pipe grade, seam type, decade of installation, wall thickness, inline inspection, class location, original and last pressure test, etc.).

The Agency’s proposed phase-in period would allow operators 3 years (from the effective date of the proposal) for submission of positional accuracy data and date of original pressure test.  Operators would have only 2 years to collect decade of installation, hazardous liquid HCAs, last ILI, coated/uncoated and cathodic protection, type of coating, year and pressure of last pressure test, mainline block valves, and gas storage field location and type of storage.  The remaining 18 attributes would be required within one year of the effective date.

At a recent public workshop on this revised proposal, industry groups expressed continued concern that the proposal remains a significant expansion of information collected under NPMS at a high expense and burden to industry.  In particular, AGA and INGAA argued for a 7 year phase in period.  API and AOPL also renewed their security concerns with the collection of pump and compressor station information, block valve, gas storage field and MAOP/MOP.

In light of the burden required to collect and covert this information into geospatial format, issues for operators who simply do not have some of this data, and security concerns with the potential disclosure of sensitive security, we encourage operators to consider drafting individual comments and consult with industry trade groups regarding their concerns.  Comments are due by October 26, 2015.  With this proposal, PHMSA appears to focus its NPMS information collection activities on enforcement priorities (as opposed to public awareness and emergency response) and may effectively be codifying the traceable, verifiable and complete records standard without issuing any rulemaking.