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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-07-0104 ([Sutherland Asbill & Brennan LLP] [Mr. Andrew K. Soto])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sutherland Asbill & Brennan LLP

Individual Name: Mr. Andrew K. Soto

Location State: DC Country: US

View the Interpretation Document

Response text:


U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590

June 4, 2001

Mr. Andrew K. Soto
Sutherland Asbill & Brennan LLP
1275 Pennsylvania Avenue, NW
Washington, DC 20004

Dear Mr. Soto:

On December 27, 2006 you wrote to the Pipeline and Hazardous Materials Safety Administration (PHMSA) requesting a determination as to the jurisdiction of the Federal pipeline safety regulations to a Questar Gas Management Company (QGM) pipeline in Wyoming.

In your letter you state that QGM owns and operates a system of flow lines that separately carry condensates, natural gas, and water from well pads to the Gobbler's Knob Station in Sublette County, Wyoming. At Cobbler's Knob, QGM operates stabilization facilities that, in part, stabilize the condensate to a 10.5 pounds per square inch absolute (psia) true vapor pressure product. This stabilized condensate product then moves directly into QGM's No. 611 pipeline or a temporary holding tank, which is an integral part of the stabilization facilities used to ensure a consistent flow of condensate into the No. 611 pipeline.

In your letter you describe the No. 611 pipeline as a nominal 6-inch, 61-mile pipeline that transports the stabilized condensate from Gobbler's Knob Station to an interconnection with Rocky Mountain Pipeline Company at Labarge Station near Labarge, Wyoming. You add that the pipeline lies entirely within rural areas and does not pass through any cities, towns, villages or other designated residential or commercial areas.

The PHMSA's Federal pipeline safety regulations in 49 CFR Part 195 prescribe the minimum safety standards and reporting requirements for pipeline facilities used to transport hazardous liquids and carbon dioxide. According to § 195.1(b)(4), the regulations do not apply to the "Transportation of petroleum in onshore gathering lines in rural areas except for gathering lines in the inlets of the Gulf of Mexico subject to § 195.413." (See § 195.1(b)(4)). The Federal pipeline safety regulations in § 195.2 contain the following definitions:

"Gathering line means a pipeline 219.1 mm (8 5/8 in) or less nominal outside diameter that transports petroleum from a production facility.

"Petroleum means crude oil, condensate, natural gasoline, natural gas liquids, and liquefied petroleum gas.

"Production facility means piping or equipment used in the production, extraction, recovery, lifting, stabilization, separation or treating of petroleum or carbon dioxide, or associated storage or measurement.

"Rural area means outside the limits of any incorporated or unincorporated city, town, village, or any other designated residential or commercial area such as a subdivision, a business or shopping center, or community development."

QGM's No. 611 pipeline as described in your letter of December 27, 2006 is less than 8 5/8-inches in nominal outside diameter, lies entirely within rural areas, and transports condensate (petroleum) from Gobbler's Knob Station (production facility). Accordingly, it is not regulated by PHMSA under 49 CFR Part 195. This determination is based upon the facts given to PHMSA in your letter. Should those facts be in error or change with time, such as residential or commercial encroachment along the pipeline, this decision could be rescinded.

If I can further assist you with this, or any other regulatory matter, please contact me at (202) 366-4595.


Florence L. Hamn
Director, Office of Regulations

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?