Update by Todd Pappasergi – PIOGA’s General Counsel & Vice President of Government Affairs

In early June, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced a broad initiative to review and potentially revise its policies, procedures, and pipeline safety regulations (PSRs). In advance of the potential new rulemaking, PHMSA is seeking public comment on whether current rules, regulations, procedures, or guidance documents impose unnecessary burdens on domestic energy.

The invitation for public comment identifies that many safety regulations have not undergone recent cost-benefit analyses and may be outdated due to new technology. The agency is also considering mandatory periodic review of its regulations so that PHMSA can stay up-to-date with evolving technology and industry practices, so that regulation can hit the sweet spot between safety and energy development.

PIOGA invites all of its members to read the new notice here and to submit comments before the deadline of August 4, 2025.

This is truly an open invitation from the agency, and it appears that everything is on the table. Some of the specific areas in which PHMSA is inviting industry comments include:
• Which PSRs impose compliance burdens disproportionate to their safety benefits?
• Which PSRs promote inefficient energy production or hinder innovation?
• Which PSRs negatively impact or unduly burden small businesses, rural markets, or operators of gathering lines? If so, can those PSRs be improved?
• What categorical exemptions should be (or continue to be) included in PSRs?
• Are there any consensus industry practices or specifications that PHMSA should incorporate into its PSRs and policy documents?

These are just a small sample of the topics that PHMSA hopes to address. To help the agency, PHMSA also requests that with your comment, you cite to specific regulatory provisions or documents; include technical, safety, and economic details relevant to your comment; and identify and provide any existing cost-benefit analyses that may exist.

PIOGA will be reviewing this development and likely making its own submission. So that we can provide industry-wide comments, please let the PIOGA staff know if you are planning on submitting a topic for PHMSA’s consideration and/or what you think PIOGA should include in its potential comment. You can email our General Counsel, Todd Pappasergi at todd@pioga.org with your thoughts! Please put PHMSA ANPRM in your subject header of your email.

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