Although the public comment request period ended on September 29, 2014, it is still an important requirement to know and understand, as the final decision will significantly impact operators.
Here’s the proposed requirement, as stated in the Federal Registry document:
Positional Accuracy: PHMSA proposes that for pipeline segments located within Class 3, Class 4, High Consequence Areas (HCA), or “could-affect” HCAs, operators submit data to the NPMS with a positional accuracy of five feet. The degree of positional accuracy needed is more stringent and important in these areas because of the potential for greater consequence in the event of a pipeline incident…PHMSA believes that a large number of operators already have access to data with this degree of accuracy within their GIS systems.
The current rule requires positional accuracy of 500 feet. To get some perspective, 500 feet is almost twice the size of a football field, which comes in at 360 feet. That’s a lot of feet!
At first read, the 500 feet to 5 feet requirement seems drastic, but further investigation reveals PHMSA’s logic:
The current accuracy requirement of 500 feet does not allow PHMSA to effectively locate a pipeline to the degree needed to respond to environmental and integrity threats. It also hinders PHMSA in identifying special features on the pipeline that may be relevant for emergency response considerations. The new degree of accuracy will help emergency responders more effectively locate a pipeline to the degree needed to respond to environmental and integrity threats and help in emergency planning.
So, why was it set at 500 feet to begin with? The original standards for data collection for NPMS were set back in 1998, then revised again in 2002 after the Pipeline Safety Improvement Act became law. As technology has improved, so has PHMSA’s accuracy requirements. Technology changes and improves at the speed of light, and the new technology will provide a more accurate location of a pipeline.
The Federal Registry document further states that:
While the standards [when the document was first written in 1998] reflected the state of geospatial data and positional accuracy at that time, they do not reflect the current state of geospatial data and positional accuracy. PHMSA requires more accurate and complete information about each pipeline, liquefied natural gas plant or breakout tank than the minimal set of attributes it receives with NPMS submissions. Collecting enhanced data will strengthen PHMSA’s ability to fulfill its strategic goals to improve public safety, protect the environment and ensure infrastructure is well-maintained. More accurate and complete NPMS data will also help emergency responders and government officials create better, more appropriate emergency response plans.
Our compliance experts and data management gurus are keeping their ears to the ground to be the first to know when a final decision has been made. In the meantime, we’re curious to know what you think. Leave us a comment on LinkedIn or send a Tweet to @NewCenturySW.