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In an effort to improve its incident, infrastructure and performance database, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed revisions to the National Pipeline Mapping System (NPMS) Program and is collecting comments on ways to improve this system. Add your name to our comment addressing this important issue that will be sent to the PHMSA before the comment period ends on May 13.

Pipeliners Local 798 supports PHMSA's desire to improve its National Pipeline Mapping System (NPMS) and make certain information more accessible to first responders and members of the public. However, Local 798 has significant concerns with the scope and content of PHMSA's Information Collection Request (ICR).

A particular concern is the proposed additional 31 data requests from pipeline operators during the review process. Above all, these requests will lead to more regulation on an already heavily-regulated industry, adding even more roadblocks to the approval of critical pipeline projects.

Local 798's specific concerns with these revisions are as follows:

- Not all of the 31 attributes are helpful for emergency responders or are relevant for a risk-ranking methodology;

- Requesting pipeline operators to consolidate existing data into a different format and resubmit it to PHMSA in NPMS or submit data that the agency itself generates is not "the least burdensome approach" for the agency to achieve its goals;

- Even more security protections would now be needed in order to protect the highly sensitive portions of the requested data. This would result in another cost and unnecessary step in the review process, stalling approvals;

- PHMSA has grossly underestimated the costs of producing the data in the format and at the level of accuracy requested.

Because of these specific concerns, Local 798 urges PHMSA to reconsider its ICR with the severe implications the proposed revisions will have on the timely approval of important pipeline infrastructure, threatening tens of thousands of jobs and millions of dollars in tax revenue that many communities depend on from these projects. 

Thank you for your consideration.

Signed,

Supporter of American Energy