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Interpretation Response #PI-76-073 ([E. A. Hamilton])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: E. A. Hamilton

Location State: CA Country: US

View the Interpretation Document

Response text:

December 1, 1976

Ms. E. A. Hamilton
1724 Minnewawa Springs
Clovis, California 93612

Dear Ms. Hamilton:

Thank you for your letter dated October 25, 1976, concerning the application of the Federal gas pipeline safety standards (copy enclosed) to gas pipeline distribution systems in mobile home parks.

The standards are established under the Natural Gas Pipeline Safety Act of 1968 (the Act), and apply to the gathering, transmission, and distribution of gas by pipeline. Gas pipelines in a mobile home park are covered by the standards if they are used to deliver gas to the persons who consume it, normally the tenants in the park.

This Office is responsible for enforcing compliance with the standards in California against systems in mobile home parks which are not operated by public utilities. In order to maximize the public benefit from our limited resources, however, our enforcement activities are primarily directed toward the major systems under our jurisdiction and to a far lesser degree systems in
mobile home parks.

At present we have under consideration a petition for rulemaking to exclude systems in mobile home parks from the jurisdiction of the Federal standards because of alleged difficulties in
compliance. Our main concern is whether this proposal would have an adverse effect on the public's interest in pipeline safety. We do not yet have enough information to reach a conclusion
and have requested the advice of the Technical Pipeline Safety Standards committee, a Federal Advisory Committee established under the Act. The Committee will address the subject at its next meeting on December 16 and 17, 1976.

This Office does not have statutory authority over the charges made by operators of gas systems to recover the costs of operating and maintaining the systems.

We appreciate your concern over this matter.

Sincerely,

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Enclosure

Regulation Sections