TULSA, Okla. (Dec. 2, 2014) - The Gas Processors Association (GPA) filed comments Monday in response to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) proposal to significantly expand the information collected from operators through the National Pipeline Mapping System. GPA says the proposed new, expanded requirements for detailed information place a significant burden on its member companies with minimal benefits.
PHMSA’s notice of proposed rulemaking published on July 30 said collecting additional data will help improve public safety, protect the environment and ensure infrastructure is well-maintained, while also helping emergency responders and government officials create improved emergency response plans.
GPA acknowledged that it shares PHMSA’s goals and that data, if collected consistently and accurately, can assist with risk management and improve safety.
“GPA stands willing to work with PHMSA and other stakeholders to provide feedback as to meaningful data collection that assists with better emergency response preparedness,” the comments said. But GPA followed that statement saying that, as proposed, few identified goals would be achieved through implementation.
GPA provided a chart illustrating each attribute requested in the proposal and whether providing the attribute information would accomplish PHMSA’s outlined goals. Of the 28 attributes requested, the chart showed that only three would assist with improved emergency response, with another five items relating to location being only potentially helpful. It also showed that information requested on 16 items is already being provided to PHMSA through other reporting requirements.
“It is extremely difficult to justify the cost and overall dedication of resources in order to provide the same information to PHMSA that is already being provided in a different format,” GPA said.
GPA comments also addressed security issues tied to compiling the requested information in a single location, saying it “raises exponentially the ability to obtain the information for purposes other than the intended use.”
GPA said there must be systems in place to guarantee the security of the sensitive information being provided to PHMSA, and such system must be “thoroughly vetted, tested, and actively reviewed by industry to ensure that such information is indeed secured and remains secure in the future.”
GPA also noted that the notice expands data collection requirements to facilities outside of PHMSA’s jurisdiction.
“Subjecting these types of facilities to regulatory requirements, while well intentioned, could lead to confusion about jurisdiction, and ultimately regulatory fines and penalties,” the comments said.
To address emergency preparedness, GPA said simply providing additional detail on maps or information related to pipeline operations won’t be effective.
“Emergency preparedness and corresponding response can only be meaningfully addressed through two-way communication between the operator and the appropriate emergency response agencies,” GPA said. “Operators have learned a tremendous amount in recent years about what emergency responders need and want in terms of information relating to pipelines in their communities … rather than including these issues in the expanded information request, they should instead be addressed via the existing regulations pertaining to emergency response liaison requirements.”
GPA President and CEO Mark Sutton said, “We are hopeful that PHMSA will reconsider its notice and instead establish a working group of representative operators to discuss what information is necessary and truly beneficial to stakeholders.”
The Gas Processors Association (GPA) has served the U.S. energy industry since 1921 as an incorporated non-profit trade association. GPA is composed of 130 corporate members that are engaged in the gathering and processing of natural gas into merchantable pipeline gas, commonly referred to in the industry as "midstream activities." Such processing includes the removal of impurities from the raw gas stream produced at the wellhead, as well as the extraction for sale of natural gas liquid products (NGLs) such as ethane, propane, butane and natural gasoline. GPA members account for more than 90 percent of the NGLs produced in the United States from natural gas processing.