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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-71-036 ([J. H. Lambdin])

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: J. H. Lambdin

Location State: MS Country: US

View the Interpretation Document

Response text:

March 16, 1971

Mr. J. H. Lambdin
Professional Engineer
349 Glenway
Jackson, Mississippi 39216

Dear Mr. Lambdin:

This is in reply to your letter of February 16, 1971, concerning the applicability of the Natural Gas
Pipeline Safety Act of 1968 to a line approximately 10 miles long operating at a pressure of 125
to 150 pounds, crossing various public and private rights-of-way and supplying only one
customer, a public utility owned generating station.

The Natural Gas Pipeline Safety Act of 1968 (hereinafter called the Act), and the regulations
contained in 49 CFR, Parts 191 and 192 would appear to be applicable to this facility. Section
2(3) of the Act defines "Transportation as gas" as "the gathering, transmission or distribution of
gas by pipeline or its storage in or affecting interstate or foreign commerce...." (underscoring
added). "Pipeline facility" as defined in Section 2(4) of the Act includes "any equipment, facility, or building used in the transportation of gas or the treatment of gas during the course of
transportation."

It is our view, based on the legislative history of the Act, that even though the operation may be
entirely within one State there is no question but that every element of a gas gathering,
transmission and distribution line is moving gas, which is either in or affects interstate commerce.

We hope this answers your question, and if we can be of any further assistance, please let us
know.

Sincerely,

Joseph C. Caldwell
Director, Acting
Office of Pipeline Safety

Regulation Sections

Section Subject
192.13 What general requirements apply to pipelines regulated under this part?