Regulatory Submissions

On October 30, APGA joined the American Gas Association and the Interstate Natural Gas Association of America on joint industry comments in response to the National Transportation Safety Board’s Advance Notice of Proposed Rulemaking. The NTSB is an independent agency with the mission of making transportation safer in the United States. The NTSB performs incident investigations on all modes of transportation, including pipelines. Their investigation reports include Safety Recommendations, which are often catalysts for pipeline safety congressional mandates and Pipeline and Hazardous Materials Safety Administration (PHMSA) rulemakings. 

In the notice, the NTSB solicits public comment on the introduction of two terms “significant injury to the environment” and “substantial property damage.” These two terms are utilized when the NTSB is determining which pipeline incidents to investigate. The associations commented that it is our “opinion that defining these terms will unnecessarily limit the NTSB’s discretion to determine which pipeline incidents and accidents truly require a NTSB investigation. The adoption of bright-line definitions could be both over- and underinclusive, requiring the NTSB to invest time and resources in unnecessary investigations, while also excluding other incidents from investigation leaving their important lessons undiscovered.”