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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-77-010 ([James A. Long])

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: James A. Long

Location State: CA Country: US

View the Interpretation Document

Response text:

March 28, 1977

Mr. James A. Long
12596 Lomica Drive
San Diego, California 92128

Dear Mr. Long:

Thank you for your letter of February 1, 1977, concerning the applicability of the Federal gas
pipeline safety standards (copy enclosed) to gas pipeline distribution systems in mobile home
parks.

The standards are established under the Natural Gas Pipeline Safety Act of 1968 (the Act), and
apply to the gathering, transmission, and distribution of gas by pipeline. The Federal gas pipeline
safety standards have been available through the Office of Pipeline Safety Operations and various
public and industry organizations since they were enacted.

Gas pipelines in a mobile home park are covered by the Federal standards if they are used to
deliver gas to the persons who consume it, normally the tenants in the park.

This Office is responsible for enforcing compliance with the standards in California against
systems in mobile home parks which are not operated by public utilities. In order to maximize the
public benefit from our limited resources, however, our enforcement activities are primarily
directed toward the major systems under our jurisdiction and to a far lesser degree systems in
mobile home parks.

At present we have under consideration a petition for rulemaking to exclude systems in mobile
home parks from the jurisdiction of the Federal standards because of alleged difficulties in
compliance. Our main concern is whether this proposal would have an adverse effect on public
safety. We do not yet have enough information to reach a conclusion and have requested the
advice of the Technical Pipeline Safety Standards Committee, a Federal Advisory Committee
established under the Act.

We appreciate your concern in this matter.

Sincerely,

James T. Curtis, Jr.

Enclosure

Regulation Sections

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