Regulatory Comments

  • AOPL & API Comment to Corps of Engineers on Regulatory Reform


    AOPL and API support the Corps’ regulatory reform efforts, and recommend that the Corps focus on efforts to streamline its regulatory requirements in ways that protect the environment and promote transparency while increasing the clarity, certainty, and timely decision-making needed for effective investment decisions…[Read Full Comments Here]


  • Joint Pipeline Industry Comments on American Pipeline Steel & Pipe


    The Association of Oil Pipe Lines (AOPL) joined a group of natural gas and liquids pipeline trade associations submitting joint comments to the Department of Commerce (Commerce) as it seeks ways to promote use of domestic steel and pipe in pipeline construction. Commerce sought comment as it prepares a plan as directed by the January 24, 2017, Presidential Memorandum on Construction of American Pipelines…[Read More on Comments Here]


  • API & AOPL Comments on PHMSA’s NPMS ICR


    API and AOPL joint comments on PHMSA’s Information Collection Request for the National Pipeline Mapping System program. [Read the full comments]


  • AOPL & API Comments on PHMSA Draft Integrity Verification Process


    AOPL and API comments on PHMSA’s Draft Hazardous Liquid Integrity Verification Process (HL IVP). AOPL and API offer input on the existing risk-based alternative regulatory process, high risk criteria, use of spike hydrostatic pressure tests, engineering critical assessments, limited HL IVP options and the material documentation process. [Read the full comments]


  • AOPL Comments on FWS & NMFS Critical Habitat Proposal


    AOPL, along with the American Petroleum Institute, Interstate Natural Gas Association of America, Utility Air Regulatory Group, Utility Water Group and International Association of Geophysical Contractors collectively commented on three Endangered Species Act critical habitat proposals – two proposed rules and a draft policy – published by the US Fish and Wildlife Service and the National Marine Fisheries Service on May 12, 2014. The proposals, if adopted as final rules and policy, significantly reshape and further complicate the critical habitat process, and unjustifiably expand the Services’ authority to designate critical habitat. [Read the full comments]

  • API-AOPL Comments on Proposed Indian Land Rights-of-Way Rule


    API and AOPL support the BIA’s efforts to update the right-of-way rules and make them more consistent with recently promulgated rules for residential, business, wind, and solar leasing on Indian lands. API and AOPL especially applaud the BIA’s desire to “update and streamline the process for obtaining BIA grants of rights-of-way on Indian lands.” 79 Fed. Reg. 34455. Indeed, each provision of the proposed rule should be judged against whether it will help streamline the right-of-way review and approval process. While the proposed rule includes many positive changes to the BIA’s current right-of-way regulations, a number of changes are necessary to clarify several key provisions of the proposed rule… [Read the full comments]

  • API/AOPL Member Testifies before DOE QER Hearing on Permitting


    Tad True, representing API and AOPL member True Companies and Belle Fourche, Bridger and Butte Pipelines testified in Cheyenne, WY at the U.S. Department of Energy hearing on federal permitting and siting for the Quadrennial Energy Review. Tad provide the perspective of his company building new pipeline infrastructure connecting the Bakken crude oil production region to American consumers and workers across the nation. Tad described the frustrations encountered when seeking federal permits for infrastructure construction and provided recommendations for improving the federal permitting process.

  • API/AOPL Member Shares Liquid Pipeline Operator R&D Priorities at PHMSA Forum


    On August 6, 2014, Craig Pierson, President of Marathon Pipeline, represented API and AOPL members at a research and development forum hosted by the U.S. Pipeline and Hazardous Materials Safety Administration in Chicago, IL. Craig provided the perspective of liquid pipeline operators on key R&D challenge facing government and industry. His presentation at the forum can be found here.

  • Pipeline Operators Partner with PHMSA to Host Safety Management System Workshop


    Liquid pipeline operators are working with natural gas transmission and distribution pipeline operators, federal and state regulators, and members of the public to develop an industry-wide recommended practice for using safety management systems (SMS) to improve and maintain pipeline safety. A pipeline SMS, recommended to industry by the U.S. National Transportation Safety Board, will help pipeline operators continuously and comprehensively track and improve their safety performance. This Spring, pipeline operators together with the U.S. Pipeline and Hazardous Materials Safety Administration hosted a one-day conference on the benefits and successes of SMS in other industries such as healthcare, nuclear energy and chemical manufacturing. Replay videos of the session at the link below: 

    VIDEO LINK: Pipeline Operators Partner with PHMSA to Host Safety Management System Workshop

  • Associations Coalition Comments to State Dept Supporting Keystone XL-National Interest Determination


    AOPL joined the American Petroleum Institute (API), American Fuels and Petrochemical Manufacturers and other organizations in comments to the U.S. Department of State (State) in its review of the Keystone XL pipeline and determination of whether the project is in the national interest. The comments demonstrated how construction of Keystone XL will make a significant contrition to the U.S.’s continuing economic recovery and will have no impact on greenhouse gas emissions associated with energy production.

  • AOPL Comments to State Dept Supporting Keystone XL-National Interest Determination


    As part of the U.S. Department of State’s (State) review of the Keystone XL pipeline, AOPL submitted comments to State on its determination of whether the project is in the “national interest.” AOPL’s comments demonstrated how the pipeline, as confirmed by the State’s own environmental, safety and economic impact analysis, is clearly in the national interest of the United States.

  • Statement against Oklahoma one-call exemptions to the state Pipeline Safety Task Force


    Andy Black provided testimony to the State of Oklahoma Pipeline Safety Task Force Exemptions Working Group on the need to limit state exemptions to one-call programs. Andy discussed how one-call programs prevent death and injury, damage to pipelines, and are undercut by exemptions to state and local agencies.

  • AOPL Brief In Response to FERC ALJ Initial Decision Concerning Seaway Committed Rates


    AOPL submitted an amicus curiae brief requesting that the Commission reaffirm its overarching policy of assuring the  sanctity and enforceability of contracts agreed upon by pipelines and their shippers in order to provide regulatory certainty for oil pipelines and other industry participants.

  • AOPL-API comments on PHMSA Natural Gas Pipeline Integrity Verification Process


    AOPL and API provided comments to PHMSA as it considered for a second time how to meet the mandate of the 2011 pipeline safety reauthorization law requirement that pipeline operators verify documentation of their pipeline system integrity. The comments discussed how PHMSA’s proposal exceeded the intended scope of the law, created needless redundancy and focused inappropriately on low-stress pipelines.

  • AOPL-API comments on PHMSA Natural Gas Pipeline Integrity Verification Process


    AOPL and API provided comments on PHMSA’s initial proposal to meet the mandate of the 2011 pipeline safety reauthorization law requirement that pipeline operators verify documentation of their pipeline system integrity. The comments discussed AOPL and API’s shared commitment to pipeline safety, recognition of the Congressional mandate on natural gas pipelines, and concern PHMSA proposed exceeding the scope of the mandate given to them by Congress.

  • AOPL Comments to State Department Environmental Review of Keystone XL


    AOPL provided comments to State on its Draft Supplemental Environmental Impact Statement (DSEIS) for the Keystone XL pipeline cross-border permit application. AOPL commented that the DSEIS appropriately found Keystone XL will not significantly impact the environment while at the same time creating thousands of U.S.. construction and manufacturing jobs.

  • API-AOPL Letter to PHMSA on Leak and Value Study


    AOPL and API wrote PHMSA to express concern over PHMSA’s flawed studies on leak detection and automatic and remotely controlled valves. AOPL and API feared new government requirements following the flawed studies could divert limited safety funds away from efforts that address the highest risks to public safety and the environment.

  • AOPL Comments On Seaway Petition For Declaratory Order


    AOPL intervened in the proceeding and sought Commission reassurance through its comments that the Commission will honor pipeline-specific contracts for “committed rates” that were entered into in accordance with the Commission’s current standards and policies and that it will enforce the rates agreed upon through such contracts.