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Interpretation Response #PI-76-063 ([Marshall, Hawks, McKinney & Hendrix] [William T. Nichols])

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

Interpretation Response Details

Response Publish Date:

Company Name: Marshall, Hawks, McKinney & Hendrix

Individual Name: William T. Nichols

Location State: KS Country: US

View the Interpretation Document

Response text:

September 17, 1976

Mr. William T. Nichols
Marshall, Hawks, McKinney & Hendrix
810 Merchants National Bank Building
Topeka, Kansas 66612

Dear Mr. Williams:[sic]

This responds to your letter of August 13, 1976, concerning gas pipeline distribution systems in mobile home parks.

With respect to a system serving individual mobile home sites, you ask whether "the ultimate user of the gas is the occupant of the individual mobile home and consequently, the service line is the line running to a meter measuring the usage at the individual mobile home or to the piping of the individual mobile home." In such a system, the "ultimate user" or consumer of the gas would be the mobile home owner or tenant as long as that owner or tenant is consuming all the gas purchased himself and not reselling and distributing any part of the gas to others. The service line would be that pipeline running between a main and the consumer's piping or a meter which measures the transfer of gas to the consumer, whichever is farther downstream. The consumer's piping is that piping which is within the possession of the consumer.

Secondly, you ask whether the service lines downstream from a master meter are "considered as service lines of the gas distribution company which had also transported the natural gas up to the point of the master meter, even though the lines downstream of the master meter were not initially installed by the gas distribution company." The service lines downstream of a master meter would only be those of the gas distribution company if that company owns the line. If it does not own the lines, the company may nonetheless be responsible for the compliance of those lines with Part 192 if it operates the lines. These statements are consistent with Sec. 8 of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1677) which designates persons engaged in the transportation of gas or who own or operate pipeline facilities as persons responsible for compliance with the Federal standards. We do not consider a person to be "engaged in the transportation of gas" unless that person owns or operates the pipeline involved in the transportation.

Generally speaking, where the owner of a mobile home park buys gas from a public utility via a master meter and then sells and distributes the gas by pipeline to others who consume the gas, the pipeline and the park owner are subject to the jurisdiction of Part 192.

We trust that our response is helpful to you.


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