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Interpretation Response #PI-77-014 ([G&K Management Co., Inc.] [Sherman Gardner])

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

Interpretation Response Details

Response Publish Date:

Company Name: G&K Management Co., Inc.

Individual Name: Sherman Gardner

Location State: CA Country: US

View the Interpretation Document

Response text:

May 1, 1977

Mr. Sherman Gardner
Association of HUD
Management Agents
G&K Management Co., Inc.
1309 Wilshire Boulevard
Suite 250
Los Angeles, California 90010

Dear Mr. Gardner:

This refers to your letter of March 4, 1977, in which you suggest that since the enforcement activities of this Office are directed to a lesser degree to master meter operators, the deadline for compliance with 49 CFR 192.457 should be extended to allow HUD-insured developments time to obtain appropriate funding for compliance activities.

After consideration of the argument presented in your letter, this Office does not feel that you have presented any additional information that would justify amending the cathodic protection
deadline under Section 192.457 for HUD-insured developments. Our policy with respect to enforcement is not founded on the appropriateness of the legal requirement, and should not be
construed as such. We have discussed the issue of notice in previous correspondence and in the absence of any showing that HUD developments in general were unable to secure funding during the 5-year lead time provided for compliance, we do not feel that the requirement is unreasonably applied to those developments. We would of course consider individual applications for waiver of the requirement, based on evidence of a good faith effort to comply within the 5-year period and an inability to secure funding in that period.

With regard to any development which is now operating in violation of the requirement, our enforcement policy takes into account all timely efforts made to achieve compliance and any
extenuating circumstances involved.


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