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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-00-0100 ([Air Transport Association of America] [Mr. Scott Belcher])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Transport Association of America

Individual Name: Mr. Scott Belcher

Location State: DC Country: US

View the Interpretation Document

Response text:


Mr. Scott Belcher
Managing Director Environmental Affairs
Air Transport Association
1301 Pennsylvania Avenue, NW Suite 1100
Washington, DC 20004-1707

Dear Mr. Belcher:

Your letter of July 7, 1999, requested an interpretation as to the applicability of the Federal pipeline safety regulations to Sky Harbor Airport's on-airport jet fuel hydrant system. The on- airport system consists of the jet fuel storage facility and "extend[s] to the pipes, valves, filters, pumps, equipment and materials that comprise the system up to and including the individual hydrant pits at each gate at each terminal." In addition, you noted that ATA would prefer to have an OPS opinion "applicable to all jet fuel hydrant systems at major airports in the United States."

The fuel distribution facilities at Sky Harbor Airport are typical of arrangements at most major airports. Jet fuel arrives via one or more transportation pipelines for storage and distribution to aircraft via a jet fuel hydrant system or by tank truck. The on-airport jet fuel storage tanks are part of the terminal function, and are not usually part of the transportation pipeline system. An exception to this would be any tanks or valves on airport grounds that are required to safely operate the transportation pipeline system or that are used as pipeline "breakout tanks."

Fuel distribution systems on airport grounds are akin to in-plant piping systems that are excluded from Part 195 under § 195.1(b)(7) or terminal facilities that are excluded under § 195.1(b)(8). Because of the similarity, these systems are not generally subject to the Federal pipeline safety standards in 49 CFR Part 195. Of course, on-airport jet fuel hydrant systems may be subject to local and state safety and environmental regulations.

If you require any further information, please contact me at (202) 366-4565.


Richard D. Huriaux, P.E.
Manager, Regulations
Office of Pipeline Safety

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?