Re: Docket PHMSA-2019-0131; Pipeline Safety: Farm Taps Frequently Asked Questions

While production does not fall under the jurisdiction of the Pipeline and Hazardous Materials Safety Administration (“PHMSA”), many of PHMSA’s actions affect producers through regulation of gathering and efforts to move the point of regulation upstream toward the wellhead. These FAQs, as proposed, would regulate thousands of natural gas wells. In these comments, IPAA urges PHMSA, first, to reconsider these FAQs as they pertain to gas connections originating from non-jurisdictional production and rural gathering facilities. Second, at the very least, PHMSA should hold off on finalizing these FAQs following completion of the Pipeline Safety: Gas Pipeline Regulatory Reform notice of proposed rulemaking (“NOPR”), published in the June 9, 2020, Federal Register.

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