On January 27, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced a public informational meeting on February 17, 2022 regarding PHMSA’s plan for forthcoming audits of updated inspection and maintenance plans to eliminate and minimize leaks pursuant to Section 114 of the Protecting Our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020. According to the notice, the purpose of the meeting is to review the requirements of Section 114, which required pipeline operators to update their inspection and maintenance plans by December 27, 2021, to (1) eliminate hazardous leaks, (2) minimize releases of natural gas, and (3) address the replacement or remediation of pipelines that are known to leak due to their material, design, or past operating and maintenance history.

To ensure compliance with Section 114, the PIPES Act of 2020 requires PHMSA and certified states to conduct inspections in 2022, and PHMSA plans to discuss its approach to these inspections during the informational meeting. The PIPES Act further requires the Comptroller General to perform a study to evaluate PHMSA and state partners’ review of those plans and provide recommendations for how to further minimize methane releases. PHMSA will then report to Congress on the study and recommendations in the report.

Although the deadline for updating inspection and maintenance plans passed at the end of last year, this informational meeting will provide more insight into PHMSA’s interpretation of the self-executing provision of Section 114 and what operators can expect during upcoming inspections. The webinar will address the following topics:

  • Key elements of Section 114;
  • Significant sources of natural gas (primarily methane) emissions from pipelines;
  • Discussion on which types of pipeline facilities must comply with each portion of Section 114;
  • PHMSA and state inspections, including reviews of a pipeline operator’s programs and procedures to reduce methane emissions;
  • Inspection topics related to methane reduction and leak-prone pipes;
  • General review of how operators’ programs and procedures will be inspected; and
  • Timelines for actions required by Section 114.

Members of the public can register to attend the virtual meeting here. For additional information about the PIPES Act of 2020, leak detection, or PHMSA’s recent efforts to address methane emissions, please contact Catherine Little or Annie Cook.

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Photo of Catherine D. Little Catherine D. Little

Catherine Little has been advising oil and gas pipelines, terminals and LNG facilities on energy and environmental administrative law for over 25 years at all levels of federal, state and local government, with particular emphasis on regulatory compliance, litigation and enforcement defense and…

Catherine Little has been advising oil and gas pipelines, terminals and LNG facilities on energy and environmental administrative law for over 25 years at all levels of federal, state and local government, with particular emphasis on regulatory compliance, litigation and enforcement defense and administrative adjudication under the Pipeline Safety Act, Natural Gas Act, Clean Water Act (including wetlands), Oil Pollution Act and National Environmental Policy Act. Her team has sought appellate review for enforcement matters with favorable results and works closely with industry and regulators alike to obtain favorable results for their clients. Catherine also regularly counsels clients with respect to pipeline construction and design issues, permitting, confidential investigations, spill and release reporting and response.

Photo of Annie M. Cook Annie M. Cook

Annie Cook’s practice focuses on administrative, environmental, and oil and gas transportation laws. Annie counsels clients on regulatory issues, compliance and litigation strategy, construction and siting, and permitting and enforcement defense relating to the Pipeline Safety Act, the Natural Gas Act, the Clean…

Annie Cook’s practice focuses on administrative, environmental, and oil and gas transportation laws. Annie counsels clients on regulatory issues, compliance and litigation strategy, construction and siting, and permitting and enforcement defense relating to the Pipeline Safety Act, the Natural Gas Act, the Clean Water Act, the Oil Pollution Act, National Environment Policy Act, TCSA, and related state and local laws.  Her team also represents clients regarding related transportation security issues and in responding to inquiries and investigations from the Department of Transportation’s Office of Inspector General. Annie’s clients include owners and operators of oil and natural gas pipeline and related storage, terminal, and LNG facilities as well as other energy industry stakeholders.