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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-95-044 ([Columbia Gas] [Donald K. Gartman, Ph.D.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Columbia Gas

Individual Name: Donald K. Gartman, Ph.D.

Location State: DE Country: US

View the Interpretation Document

Response text:

Dr. Donald K. Gartman, Ph.D.

Environmental Affairs

Columbia Gas

20 Montchanin Road

P.O. Box 4020

Wilmington, DE 19807-0020

Dear Dr. Gartman:

This is in response to your question to L.E. Herrick at the September 7-8, 1995, INGAA Foundation Stream and River Crossing Roundtable in Orlando, FL. Your question concerned allowing a trail system on a natural gas pipeline right-of-way.

Section 192.5(d)(2)(ii) of 49 CFR states "A Class 3 location is an area where the pipeline lies within 100 yards of either a building or a small, well-defined outside area (such as a playground, recreation area, outdoor theater, or other place of public assembly) that is occupied by 20 or more persons on at least five days a week for 10 weeks in any 12-month period. (The days and weeks need not be consecutive.)"

Although a trail system bears some resemblance to a "small, well-defined outside area that is occupied by 20 or more people," it differs in a number of significant aspects. In particular, it appears that a trail used by hikers, bicycles, horses, cross country skiers, etc., would not be occupied by 20 or more people in a small and well-defined area at the same time. Furthermore, such a trail system would not be basically similar to a playground, recreation area, outdoor theater, or other place of public assembly. Therefore, the trail system would not require a change in class location.

We trust that this has answered your particular question. If we can be of further assistance, please let us know.


Cesar De Leon

Deputy Associate Administrator

Office of Pipeline Safety

Regulation Sections

Section Subject
192.5 Class locations