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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-94-005 ([California Public Utilities Commission] [Russell W. Copeland])

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

Interpretation Response Details

Response Publish Date:

Company Name: California Public Utilities Commission

Individual Name: Russell W. Copeland

Location State: CA Country: US

View the Interpretation Document

Response text:

February 4, 1994

Mr. Russell W. Copeland

Chief, Utilities Safety Branch

California Public Utilities Commission

505 Van Ness Avenue

San Francisco, CA 94102-3298

Dear Mr. Copeland:

This is in reply to your letter of January 13, 1994, concerning the applicability of Federal pipeline safety standards to the pipeline owned and operated by the San Luis Ray [sic] Homes (SLRH) mobilehome park. The SLRH is a senior citizen mobile home park cooperative sub-divided such that each resident owns 1/328th of the cooperative. Gas is master metered at the property line with the cooperative owning the distribution system in the park.

The Federal pipeline safety requirements in 49 CFR parts 191 and 192 apply to pipelines used in the transportation of gas. In accordance with the definition of a service line under §192.3, the pipeline transportation subject to federal regulation ends when the gas has been sold and delivered to the consumer. It is important to note that the definition of "person" under §192.3 includes the term "cooperative association" and the word "person" is used to define an "operator" that is engaged in the transportation of gas.

Under the facts given in your letter and its attached documents, the transportation of gas does not end until the gas is delivered to each resident in the cooperative. Therefore, it appears that the cooperative is engaged in the transportation of gas to the individual lots within the SLRH. The fact that the lots are individually owned and are not rented does not affect compliance with the Federal regulations. Accordingly, as the operator, the cooperative is responsible for compliance with the Federal pipeline safety standards in 49 CFR parts 191 and 192.

We trust that this adequately responds to your request. Please feel free to contact me if you have further questions.


Cesar DeLeon

Director, Technology and

Standards Division

Regulation Sections

Section Subject
192.3 Definitions