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Interpretation Response #PI-75-035 ([State of New York] [Robert L. Swartwout])

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

Interpretation Response Details

Response Publish Date:

Company Name: State of New York

Individual Name: Robert L. Swartwout

Location State: NY Country: US

View the Interpretation Document

Response text:

July 8, 1975

Mr. Robert L. Swartwout
Energy Division-Gas
State of New York
Public Service Commission
44 Holland Avenue
Albany, New York 12208

Dear Mr. Swartwout:

This refers to your letter of June 20, 1975, concerning the proper classification under 49 CFR
Part 192 of 6.16 miles of coated gas pipelines running from interstate transmission lines to
distribution centers.

You ask whether the connection of service lines to the pipelines causes them to be distribution
facilities under Part 192.

Under Section 192.3, the term "distribution line" is defined as "a pipeline other than a gathering or
transmission line." by this definition, a pipeline is classified as a "distribution line" only if it is not
a gathering line or a transmission line, irrespective of whether service lines are connected to the
pipeline. We are in agreement, I believe, that none of the 6.16 malls of pipelines is a "gathering
line" as that term is defined in Section 192.3. Therefore, unless it can be reasonably shown that
the pipelines are not transmission lines within the meaning of the term "transmission line" in
Section 192.3, they are not properly classified as "distribution lines."

As we stated in our letter of May 30, 1975, on this subject, the pipelines appear to us as lateral transmission lines. Assuming this is true, we expect that the Commission will revise its March 18 Order to make it apply to 49 CFR 192.457 in addition to the State requirements.

Please advise us what action the Commission plans to take.


Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

Section Subject
192.457 External corrosion control: Buried or submerged pipelines installed before August 1, 1971