Interpretation Response #PI-18-0019
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: PSC
Individual Name: Mr. Michael J. Schmitt
Location State: KY Country: US
View the Interpretation Document
Response text:
Mr. Michael J. Schmitt
Chairman, Kentucky Public Service Commission
211 Sower Boulevard
P.O. Box 615
Frankfort, KY 40602
Dear Mr. Schmitt:
Thank you for your letter of September 6, 2018, requesting an interpretation on whether 49 CFR 192.740 applies to certain "farm taps" required by Kentucky statute, and if so, whether responsibility for maintaining regulators in accordance with that section lies with the production or gathering line operator, or with the customer.
Part 192 defines a service line as a "distribution line that transports gas from a common source of supply to an individual customer." (49 CFR 192.3). A "farm tap" is not defined in Part 192, but commonly refers to a pipeline directly connected to a source pipeline that transports natural gas to a customer along the source pipeline right-of-way, and thus, meets the definition of a service line in the pipeline safety regulations. A non-regulated production or gathering pipeline may be the common source of supply for a regulated service line. The pipeline upstream of the service line retains its original functional identity or classification.
Because "farm taps" meet the definition of service lines, piping and appurtenances that comprise a "farm tap" that are owned or maintained by an entity engaged in the transportation of gas, are subject to the requirements of Parts 191 and 192 as a distribution service line, including the requirements at § 192.740.
However, a service line ends at the connection to customer owned piping, or the outlet of the meter, whichever is further downstream. Such piping and appurtenances that are owned by a customer or person not engaged in the transportation of gas (e.g., a farmer or residential customer) are not service lines and are not subject to requirements in Part 191 or Part 192. Therefore, neither the customer nor the operator are required by federal regulation to maintain a customer owned regulator on a customer fuel line in accordance with § 192.740.
I hope this information is helpful. If you require additional information or assistance, please contact John Gale by phone at 202-366-0434 or by e-mail at John.Gale@dot.gov.
Sincerely,
Alan Mayberry
Associate Administrator for Pipeline Safety