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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-17-0001

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

Interpretation Response Details

Response Publish Date:

Company Name: G2 Partners

Individual Name: Mr. John A. Jacobi

Location State: TX Country: US

View the Interpretation Document

Response text:

October 23, 2017

Mr. John A. Jacobi
Vice President and Principal
G2 Partners
10850 Richmond Avenue, #200
Houston, TX 77042

Dear Mr. Jacobi:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated December 16, 2016, you requested an interpretation of the reporting requirements for 49 CFR Parts 192 and 195. You specifically requested clarification on the reporting requirements in DOT Form PHMSA F 7000-1.1 for hazardous liquid pipeline facilities and DOT Form PHMSA 7100.2-1 for gas pipeline facilities.

You stated your understanding is that "if a line has never been placed in service, it should not be placed on an annual report or reported to the National Pipeline Mapping System (NPMS)." You provided reasons why some pipelines may be properly designed to meet PHMSA regulations but have never had product introduced, such as where the construction of planned connections has not been completed. You asked if an operator needs to report information to PHMSA using DOT Forms PHMSA F 7000-1.1 and PHMSA 7100.2-1 and the NPMS for a pipeline that has never been placed in service and has never transported a PHMSA regulated product.

The Federal pipeline safety regulations do not require operators to submit DOT Form PHMSA F 7000–1.1 for hazardous liquid pipeline facilities and DOT Form PHMSA 7100.2-1 for gas pipeline facilities or report information using NPMS until a regulated pipeline is placed in service. Once the pipeline is in service, the operator must report using DOT Form PHMSA F 7000-1.1 for hazardous liquid pipeline facilities and DOT Form PHMSA 7100.2-1 for gas pipeline facilities, as well as NPMS, for the life of the pipeline until it is formally abandoned.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.

 

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192 TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE: MINIMUM FEDERAL SAFETY STANDARDS
195 TRANSPORTATION OF HAZARDOUS LIQUIDS BY PIPELINE