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In June 2021, PHMSA issued Advisory Bulletin ABD-2021-01 in response to Section 114 of the PIPES Act of 2020. That Advisory Bulletin required pipeline operators to update their Operations & Maintenance (O&M) procedures to address both unintentional (fugitive) and intentional (vented) methane emissions. This directive was treated as a self-executing mandate and led many state regulators to request documentation from operators (APGA member login required to view) explaining how their systems addressed methane emissions. PHMSA has now rescinded that 2021 Advisory Bulletin. The agency determined that the bulletin overstepped the statutory language of Section 114, particularly by:

• Applying to facilities not transporting natural gas.

• Introducing new, undefined terms not found in law or regulation (i.e., Fugitive and vented emissions)

As a result, PHMSA and state regulators no longer have ABD-2021 as a reference point when reviewing O&M procedures. That said, many APGA members may find that the practices adopted since 2021, such as enhanced leak detection and changes to venting and blowdown procedures, have become routine. Operators are not required to rollback those changes but may choose to adjust procedures now that the ABD has been formally withdrawn.

For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at ekurilla@apga.org.