![](media/image1.wmf){width="0.8013888888888889in"
height="0.7909722222222222in"}**\
U.S. Department of Transportation\
Pipeline and Hazardous Materials Safety Administration**

**Pipeline Safety: Standards for Increasing the Maximum Allowable
Operating Pressure for Gas Transmission Pipelines**

**Draft Environmental Assessment**

**\[Docket No. PHMSA-05-23447\]**

**February 2008**

**Prepared by:**

**Environmental Engineering Division**

**Volpe National Transportation Systems Center**

**Research and Innovative Technology Administration**

**and**

**Pipeline and Hazardous Materials Safety Administration**

*This EA was prepared pursuant to section 102(2)(c) of the National
Environmental Policy Act (42 U.S.C. § 4332) and the Council on
Environmental Quality regulations (40 C.F.R. §§ 1500-1508).*

Table of Contents

[1.0 Purpose and Need for Action 3](#purpose-and-need-for-action)

[1.1 Introduction 3](#introduction)

[1.2 Background 3](#background)

[1.3 Purpose and Need 3](#purpose-and-need)

[1.4 Public Involvement 3](#public-involvement)

[2.0 Alternatives 3](#alternatives)

[2.1 No Action Alternative 3](#no-action-alternative)

[2.2 Alternative 1: Delay Rulemaking concerning a revised MAOP
3](#alternative-1-delay-rulemaking-concerning-a-revised-maop)

[2.3 Alternative 2 (Proposed Action): Undertake a Rulemaking Action to
Revise the MAOP regulations
3](#alternative-2-proposed-action-undertake-a-rulemaking-action-to-revise-the-maop-regulations)

[2.4 Comparison of the Alternatives 3](#comparison-of-the-alternatives)

[3.0 Affected Environment and Environmental Consequences
3](#affected-environment-and-environmental-consequences)

[3.1 Affected Environment 3](#affected-environment)

[3.2 Environmental Consequences 3](#environmental-consequences)

[3.2.1 Public Health and Safety 3](#public-health-and-safety)

[3.2.2 Hazardous Materials Transportation
3](#hazardous-materials-transportation)

[3.2.3 Socioeconomics 3](#socioeconomics)

[3.2.4 Natural Resources 3](#natural-resources)

[3.2.5 Special Areas of Consideration
3](#special-areas-of-consideration)

[4.0 List of Persons and Agencies Consulted
3](#list-of-persons-and-agencies-consulted)

[5.0 List of Preparers and Reviewers
3](#list-of-preparers-and-reviewers)

[6.0 References 3](#references)

**List of Acronyms and Abbreviations**

ASME American Society of Mechanical Engineers

CEQ U.S. Council on Environmental Quality

CFR Code of Federal Regulations

DMS Docket Management System

DOT U.S. Department of Transportation

EA Environmental Assessment

ESA Endangered Species Act

HCA High consequence area

IPS Nominal pipe size

MAOP Maximum allowable operating pressure

NEPA National Environmental Policy Act

NGL Natural gas liquids

NHPA National Historic Preservation Act

NPRM Notice of Proposed Rulemaking

O&M Operation and maintenance

PHMSA Pipeline and Hazardous Materials Safety Administration

psig Pounds per square inch gauge

RCP Rapid crack propagation

ROW Right of way

SDR Standard Dimension Ratio

SMYS Specified minimum yield strength

U.S.C. United States Code

# Purpose and Need for Action

## Introduction

The nation\'s pipelines are a transportation system that enables the
safe movement of energy products to industry and consumers. The Pipeline
and Hazardous Materials Safety Administration (PHMSA) is the federal
safety authority for the nation\'s natural gas and hazardous liquid
pipelines. PHMSA is the federal agency charged with the safe and secure
movement of almost one-million daily shipments of hazardous materials by
all modes of transportation. The agency also oversees the nation\'s
pipeline infrastructure which accounts for 64 percent of the energy
commodities consumed in the United States (PHMSA 2007a).

The Federal Pipeline Safety Law (49 United States Code (U.S.C.) 60101 et
seq.), Section 60102 authorizes the Secretary of Transportation to issue
regulations applying to design, installation, inspection, emergency
plans and procedures, testing, construction, extension, operation,
replacement, and maintenance of pipeline facilities.

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is
proposing changes to the Federal pipeline safety regulations in 49 CFR
Part 192, which cover the transportation of natural gas by pipeline.
Specifically, PHMSA proposes allowing natural gas transmission pipeline
operators to raise the maximum allowable operating pressure (MAOP) for
certain pipelines (1) constructed of steel pipe manufactured using
modern steel chemistry and rolling practices and standards, and (2)
inspected and tested to more rigorous standards. The proposed rule would
require a new pipeline to meet more rigorous design and construction
standards as a condition for an operator to calculate the MAOP based on
higher stress levels. An existing pipeline that meets the more rigorous
design and construction standards could also qualify for an increase of
its MAOP based on higher stress levels. The proposed rule would also
require the operator of a new or existing pipeline operating at the
increased MAOP to comply with added operation and maintenance
requirements.

Federal agencies are required to evaluate the environmental impacts of
their actions under the National Environmental Policy Act of 1969
(NEPA).[^1] NEPA and the Council on Environmental Quality's (CEQ)
implementing regulations[^2] establish policies and procedures that
ensure environmental information is available to decision makers,
regulatory agencies, and the public before Federal actions are
implemented. PHMSA, with the cooperation of the John A. Volpe National
Transportation Systems Center (Volpe Center) prepared this Draft
Environmental Assessment (EA) for the purpose of analyzing the potential
environmental impacts associated with the rulemaking proposed by PHMSA.
This EA follows the procedures established by the United States
Department of Transportation (DOT)[^3] to implement NEPA, pursuant to
the CEQ regulations.

## Background

Gas transmission pipelines in the U.S. use steel pipe almost
exclusively.[^4] Under Federal pipeline safety regulations, steel
transmission pipelines must use a MAOP that is below the specified
minimum yield strength (SMYS) of the steel pipe. In the 1950's, there
was limited information available about the material properties of pipe
and limited ability to evaluate its integrity during its operating
lifetime. Thus, pipeline engineers looked for ways to impede the
potential defects initiated during manufacture, construction, or
operation. The solution was a standard conservative margin of safety
added to the hydrostatic test pressure used to evaluate the pipe at the
mill. In the industry design standards, a 25 percent margin of safety
translated into a design factor limiting stress level to 72 percent of
SMYS in rural areas. The Federal pipeline safety regulations
incorporated this design factor into the requirements for determining
MAOP when the regulations were first issued in the early 1970's. Each
pipeline class location has a different MAOP, which are currently as
follows:

-   Class 1: 72% of SMYS

-   Class 2: 60% of SMYS

-   Class 3: 50% of SMYS

-   Class 4: 40% of SMYS

The estimated percentages of transmission mileage in these four class
locations are

-   Class 1: 80%[^5] to 90%[^6] of mileage

-   Class 2: 5%[^7] to 10%[^8] of mileage

-   Class 3: Less than 5%[^9] to 10%[^10] of mileage

-   Class 4: Approximately 0.5% of mileage[^11]

Originally, 72% of SMYS was selected as the upper limit for MAOP to
ensure conservative safety margins. Manufacturers have dramatically
improved the quality of steel pipe over the past 50 years. Additionally,
pipeline construction practices and operation and maintenance (O&M)
procedures of pipeline operators have improved. In response to the
material, construction, and O&M advances, several nations, including
Canada and the United Kingdom, have increased MAOP to around 80% of
SMYS.[^12] A few nations, including Japan and Germany, continue to
mandate a MAOP lower than 72% of SMYS.[^13]

Currently, approximately five thousand miles of gas transmission
pipelines in the U.S. are operating at a MAOP that is greater than 72%
of SMYS because of grandfathering.[^14] Operators desiring a MAOP
greater than 72% of SMYS may apply to PHMSA for waivers (i.e., special
permits). When evaluating waiver applications, the key consideration for
PHMSA is whether the pipelines can operate at higher MAOP without
compromising safety.

Given the technological advances in pipe production and management over
the years, researchers, including the American Society of Mechanical
Engineers (ASME), further examined pipeline design factors and
determined pipelines could operate safely at stress levels up to 80
percent SMYS. ASME published the adjusted design factors in the 2003
industry design standards. Beginning in 2006, PHMSA evaluated requests
for special permits from three companies seeking to operate natural gas
transmission pipelines at higher pressures than currently allowed by
federal regulations. Those requests were made by

-   Alliance Pipeline L.P.[^15]

-   Maritimes & Northeast Pipeline, L.L.C.[^16]

-   Rockies Express Pipeline LLC[^17]

The majority of the requests were for proposed pipelines, and all
requested permission to operate at 80% of SMYS in the class 1 locations.
Some requests also included increases in the MAOP for other class
locations.

PHMSA afforded the public an opportunity to provide comments on each
special permit request, and received favorable comments from both
industry and the public. Additionally, PHMSA briefed its technical
advisory committees, held a public meeting, and brought stakeholders
into the development of permitting criteria. PHMSA received supportive
comments at these meetings.

PHMSA granted all three requested special permits. In granting them,
PHMSA required the operators to demonstrate compliance with certain
design specifications and imposed additional safety standards.

## Purpose and Need

Due to technological advances and revised industry standards, PHMSA has
received requests for waivers from operators wishing to be allowed
operation at the MAOP levels that ASME B31.8 would allow. PHMSA has
granted permits of waivers on individual basis to specific operators
demonstrating compliance with the stricter construction, operation, and
maintenance guidelines, and has sought to address the inconsistency
between the existing regulations and the new ASME design standards.
PHMSA is now proposing to modify the existing regulation concerning MAOP
after thorough examination of the safety issues associated with allowing
existing or proposed pipeline to operate at higher pressure.

The purpose of this action stems from the advances in technology that
allow for increased operating pressure. The proposed rule would ease
regulatory burdens, encourage the development of new infrastructure,
improve regulatory certainty, and reduce the agency workload associated
with granting individual applications. The need for the action results
from operators' desire to procure waivers in order to operate at the
higher ASME design standards. This action seeks to make the regulations
consistent with technological advances as well as published research and
industry standards, and eliminate the special permitting process.

## Public Involvement

Public involvement is a critical aspect of the NEPA process. As such,
PHMSA must consider any comments received from the public and any
comments and recommendations of the Technical Pipeline Safety Standards
Committee and other relevant stakeholders. PHMSA has already solicited
public comments on the proposed action; responses, which generally have
been favorable toward amending the regulations, can be found on the
DOT's Document Management System (DMS). A notice of proposed rulemaking
(NPRM) for the revised MAOP will be published after the completion of
the EA, in which PHMSA will again request public comments on the
proposed rulemaking. The public will also have the opportunity to
comment on this Draft EA before the Final EA is published (PHMSA 2000b).

# Alternatives

PHMSA considered the following three alternatives with respect to MAOP:

-   Take no action

-   Delay an increased MAOP rulemaking

-   Undertake the proposed revised MAOP rulemaking

## No Action Alternative

Under the no action alternative, PHMSA would not undertake a rulemaking
action in order to address the technological advances in pipe production
and management. Therefore, the current regulations would continue to be
inconsistent with industry standards set by ASME. PHMSA could continue
to address individual special permit applications on a case-by-case
basis. Although this approach would give PHMSA additional oversight
control, it would be less efficient for industry and for the agency than
promulgating a regulatory standard.

## Alternative 1: Delay Rulemaking concerning a revised MAOP

Instead of embarking on the immediate development and implementation of
a regulatory standard, PHMSA could delay rulemaking and continue to work
with consensus standard-setting organizations. Current consensus
standards already allow increased operating pressures, but without the
additional safety requirements PHMSA has imposed in special permits. The
standard-setting organization responsible for these standards is
currently establishing a subcommittee to address operation of pipelines
at higher pressures.

If PHMSA delayed an MAOP rulemaking, they could gain more experience
with evaluating applications, and monitoring compliance and outcomes.
Delaying the rulemaking would only provide narrow opportunities to take
advantage of current technological advances, and only through the
permitting process. Delaying the rulemaking would also delay resolving
the inconsistencies between the government regulations and industry
standards. Hence, this alternative does not meet the purpose and need,
and has been dismissed from detailed analysis.

## Alternative 2 (Proposed Action): Undertake a Rulemaking Action to Revise the MAOP regulations

The third alternative considered by PHMSA was to undertake a new
rulemaking to revise the MAOP regulations. This would minimize the
inefficiencies associated with the special permit process and address
inconsistencies between the government and industry standards.

PHMSA proposes to revise the Federal pipeline safety regulations in 49
CFR Part 192 to allow use of an "alternative" MAOP when certain
conditions are met. Under the proposed rule, the alternative MAOP for
each class location would be as follows:

-   Class 1: Greater than 72% of SMYS but less than or equal to 80% of
    SMYS

-   Class 2: Greater than 60% of SMYS but less than or equal to 67% of
    SMYS

-   Class 3: Greater than 50% of SMYS but less than or equal to 56% of
    SMYS

-   Class 4: No alternative MAOP is proposed for class 4 locations

> Specific design, construction, O&M, and notification conditions must
> be met in order for a segment to be eligible for operation at the
> alternative (higher) MAOP. With respect to design, operators must
> comply with requirements for the following:

-   The properties of the steel used for the pipe

-   The manufacturing standards for the pipe

-   Fracture control

-   Plate quality control

-   Seam quality control

-   Mill hydrostatic testing

-   Coating

-   Fittings and flanges

With respect to construction, operators must comply with requirements
for the following:

-   Quality assurance

-   Girth welds

-   Depth of cover

-   Initial strength testing

-   Cathodic protection

-   Interference currents

With respect to O&M, operators must comply with requirements including
as follows:

-   Responding to emergencies in high consequence areas (HCAs)

-   Monitoring gas quality for internal corrosion control

-   Controlling interference that can impact external corrosion

-   Implementing external corrosion control -- cathodic protection

-   Implementing external corrosion control -- close interval survey

-   Implementing external corrosion control -- annual readings

-   Patrolling the right of way

-   Maintaining the depth of cover

-   Reevaluating the potential impact radius as necessary

-   Notifying the public proximate to the pipeline

-   Performing threat assessments

-   Performing indirect assessments

-   Performing baseline internal inspections

-   Performing additional inspections

-   Performing direct assessments when internal inspection is not
    possible

-   Evaluating anomalies conservatively and repairing defects
    expeditiously

Additionally, notification requirements specify that operators must
notify PHMSA when they choose to use an alternative MAOP.

## Comparison of the Alternatives

Table 2‑1. Comparison of the alternatives by impact category.

  ---------------- ------------------------------ ----------------------------
  Impact Category  No Action Alternative          Proposed Action Alternative

  Public Health    No significant adverse impacts Potential minor beneficial
  and Safety                                      impacts

  Hazardous        No significant adverse impacts Potential minor beneficial
  Materials                                       impacts
  Transportation                                  

  Socioeconomics   No significant adverse impacts Potential beneficial impacts

  Natural          No significant adverse impacts No significant adverse
  Resources                                       impacts

                                                  

  Endangered       No significant adverse impacts No significant adverse
  Species                                         impacts

  Resources        No significant adverse impacts No significant adverse
  protected by the                                impacts
  NHPA                                            

  Section 4(f)     No significant adverse impacts No adverse impacts
  resources                                       
  ---------------- ------------------------------ ----------------------------

# Affected Environment and Environmental Consequences

## Affected Environment

PHMSA is responsible for regulating the safety of over two million miles
of gas and hazardous liquid pipelines. The nation's pipelines are
located throughout the United States, onshore and offshore, and traverse
of variety of environments -- from highly populated urban sites to
remote, unpopulated rural areas (PHMSA 2007c). The proposed rule would
cover all existing gas transmission pipelines, of which there are
approximately 320 thousand miles currently,[^18] as well as any future
gas transmission pipelines.

PHMSA expects the MAOP for approximately 3,500 miles of existing
pipeline to be updated as a consequence of the proposed rule. Only a
portion of the existing gas transmission pipeline mileage would be a
candidate for a higher alternative MAOP due to the requirements
associated with increasing the MAOP. Many pipeline operators are
expected to find the cost of the additional requirements associated with
increasing the MAOP to be too high. For instance, fitting and pressure
vessel replacement costs may prevent some pipelines from converting to a
higher MAOP. Additionally, the costs associated with converting
non-piggable lines are expected to be prohibitive. Also, PHMSA expects
that only post-1980 pipelines will be appropriate for converting to a
higher MAOP.

PHMSA also expects approximately 700 miles of new gas transmission
pipeline certificated each year to take advantage of the proposed
regulation and be operated at an alternative MAOP. This includes
pipeline mileage in class 1, class 2, and class 3 locations. PHMSA
expects that many operators will only select an alternative MAOP for
their new pipelines in class 1 locations.

Therefore, PHSMA expects that in the first year after implementation of
the proposed rule 4,200 miles of pipeline would begin to be operated at
an alternative MAOP. This consists of 3,500 miles of existing pipeline
and 700 miles of new pipeline. In each subsequent year, PHMSA expects
that an additional 700 miles of new pipeline would begin to be operated
at an alternative MAOP.

The physical environment potentially affected by the proposed action
includes the airspace, water resources (e.g., oceans, streams, lakes),
cultural and historical resources (e.g., properties listed on the
National Register of Historic Places), biological and ecological
resources (e.g., coastal zones, wetlands, plant and animal species and
their habitat, forests, grasslands, offshore marine ecosystems), and
special ecological resources (e.g., threatened and endangered plant and
animal species and their habitat, national and state parklands,
biological reserves, Wild and Scenic Rivers) that exist directly
adjacent to and within the vicinity of pipelines.

Because the pipelines subject to the proposed rulemaking contain
hazardous materials, these resources within the physical affected
environment, as well as public health and safety, may be affected by gas
pipeline incidents such as spills and leaks. Incidents on pipelines can
result in fires and explosions, with resulting damage to the local
environment. In addition, since pipelines often contain gas streams
laden with condensates and natural gas liquids (NGL\'s), failures also
result in spills of these liquids, which can cause environmental harm.
Depending on the size of a spill or gas leak, and the nature of the
impact zone, the environmental impacts could vary from property damage
and environmental damage to injuries or on rare occasions, fatalities.

This EA will focus only on those resource categories that are
potentially impacted by the alternatives, those that are of interest to
the public, and/or important to the decision. The resource categories to
be analyzed in this EA are: public health and safety, hazardous
materials transportation, socioeconomics, natural resources, and other
special areas of consideration. No construction is planned for this
action, as it is a regulatory modification concerning operation
standards. Therefore, no significant increase in adverse construction
impacts is expected with this action. Similarly, no increase in adverse
impacts to solid waste is expected as a result of this action. These
areas have therefore been dismissed from detailed analysis.

## Environmental Consequences

### Public Health and Safety

##### No Action Alternative

Under the No Action Alternative, PHMSA would not modify 49 CFR Part 192
regarding the use of alternative MAOPs. Therefore, the regulations would
continue to require the MAOPs to be 72, 60, and 50 percent at Class 1,
2, and 3 locations respectively. Rates of incidents and accidents would
be expected to remain the same and therefore no change in impacts to
public health and safety would be expected.

Since operating pressures would remain the same, operators would not be
required to adhere to the increased operation and management
requirements being proposed in conjunction with the use of alternative
MAOPs. The potential benefits of these requirements would not be
realized, but the lack of these benefits should have no change in
impacts on public health and safety. PHMSA currently maintains high
safety standards through regular maintenance and inspections of lines.

Additionally, PHMSA would need to continue with the special permitting
process as operators would continue to seek permits of waiver to operate
according to the industry standards set forth by ASME. The permitting
process adds regulatory burdens onto operators and reviewing and
granting individual applications adds to PHMSA's agency workload. The
impacts associated with the permitting process, however, should have no
impacts on public health and safety.

Table 3‑2. Gas transmission line incidents and associated damages in
2006.

  ---------------------- ----------- ------------ ----------- -----------------
  Type of Line           Incidents   Fatalities   Injuries    Property Damage

  Gas Transmission Lines 141         3            4           \$48.6M
  ---------------------- ----------- ------------ ----------- -----------------

(PHMSA 2005)

##### Proposed Action Alternative

Under the proposed action alternative, PHMSA would implement regulatory
changes to 49 CFR Part 192 associated with MAOP. Associated with the
alternative MAOPs, PHMSA would also implement additional operation and
maintenance regulatory requirements, detailed in Section 2.3, which
would provide an increased safety factor. The operation of natural gas
transmission pipelines that meet specific safety requirements at higher
MAOP is not expected to increase the number or severity of pipeline
incidents.[^19] Moreover, the proposed rule's requirements, such as
monthly right of way patrolling, additional internal inspections, and
anomaly repair, are expected to prevent incidents that would have
occurred in the absence of the proposed rule, and to help mitigate the
consequences of the incidents that do occur. This is expected to result
in a positive measurable impact to public health and safety.

### Hazardous Materials Transportation

##### No Action Alternative

No changes to the pipeline regulations or the pipelines themselves would
occur under the no action. Therefore, no changes in impacts to hazardous
materials transportation should result. Leak and incident rates would be
assumed to remain the same.

##### Proposed Action Alternative

Implementing the modifications to the regulations would have no other
direct effects on hazardous materials transportation. However, this
action would allow operators the choice to operate at alternative MAOPs
by meeting increased safety, operation, and management requirements. For
operators that were eligible and chose to adhere to the increased
requirements, they would be given the provision to operate at the higher
regulated MAOP according to their class location. It is expected that
the majority of current operators would not commit to incurring the
increased costs associated with higher MAOP operation. These operations
would have no change in impact on hazardous materials transportation.
However, it is estimated that 3,500 of exiting pipeline would be
converted for increased MAOP use, and 700 miles of new pipeline each
year would also use an alternative MAOP. As mentioned above, due to
superior metallurgy and increased safety and maintenance activities,
these increased MAOP operations are not expected to increase the number
or severity of pipeline incidents. Rather, pipelines operating at
alternative MAOPs will be subject to more stringent construction,
operation, and maintenance requirements, which in turn are expected to
produce beneficial impacts by reducing the number and severity of
incidents. In addition to a potential reduction in incidents, the
proposed action is expected to also result in fuel cost savings,
reductions in pipeline capital expenditures, and increases in pipeline
capacity and line-pack. Together, these consequences are expected to
result in minor beneficial impacts to hazardous materials
transportation.

### Socioeconomics

A detailed cost-benefit analysis has been prepared for this federal
action, and is posted on the DOT's Document Management System (DMS)
docket (No. PHMSA-05-23447) (PHMSA 2007d). The results of the analysis
are presented briefly below.

##### No Action Alternative

PHMSA would continue to address individual special permit applications
on a case-by-case basis. The permitting process adds regulatory burdens
onto operators and reviewing and granting individual applications adds
to PHMSA's agency workload. Although this approach would give PHMSA
additional oversight control, it would be less efficient for industry
and for the agency than promulgating a regulatory standard. As the
status quo alternative, no changes in impacts to socioeconomics are
expected.

##### Proposed Action Alternative

The proposed rule does not require operators of natural gas transmission
systems to use an alternative MAOP on their pipeline. Rather, it
provides operators with pipeline in Class 1, Class 2, or Class 3
locations with the option of using an alternative MAOP under certain
circumstances. The proposed rule will cost operators only if they choose
to use an alternative MAOP on their pipeline. PHMSA expects costs
attributable to the proposed rule are most likely to be incurred by
operators for

-   Performing baseline internal inspections

-   Performing additional internal inspections

-   Performing anomaly repairs

-   Installing remotely controlled valves on either side of high
    consequence areas (HCAs)

-   Preparing threat assessments

-   Patrolling pipeline rights-of-way

-   Notifying PHMSA

In total, the costs of the proposed rule are expected to be \$34.7
million in the first year, go from \$6.8 million in the second year to
\$14.7 million in the tenth year, be \$48.1 million in the eleventh
year, and then go from \$23.3 million in the twelfth year to \$31.2
million in the twentieth year.

However, if operators choose to utilize an alternative MAOP, several
benefits are expected to potentially result associated with the proposed
action:

-   A reduction in deaths, injuries, and property damage resulting from
    reportable pipeline incidents

-   A reduction in the consequences of non-reportable pipeline incidents

-   Fuel cost savings

-   A reduction in pipeline capital expenditures

-   An increase in pipeline capacity

-   An increase in line-pack

The estimated benefits of the proposed rule over 20 years are expected
to be \$70.8 million in the first year with \$14.5 million added to
benefits in each subsequent year. These figures do not include estimates
for the benefits associated with (1) reduced non-reportable incidents,
(2) reduced capital expenditures, (3) increased pipeline capacity, or
(4) increased line pack. The benefits from these could add hundreds of
millions to the total beneficial impacts from the proposed rule.

### Natural Resources

##### No Action Alternative

As no changes to the pipeline regulations would occur, no change to the
management of pipeline transmission systems would occur. Rates for leaks
and incidents would be assumed to stay the same. Currently, most systems
have effective safety measures and leak management programs. Therefore,
since the incidence of accidents is low, significant adverse impacts to
natural resources, including air quality, water quality, and wildlife
would not be expected.

##### Proposed Action Alternative

As discussed previously, amending the regulations concerning the MAOP
would increase the amount of operators utilizing higher operating
pressures and also mandate additional safety, operation, and maintenance
requirements. According to industry research, no increase in leaks or
incidents is expected. Consequently, no adverse impacts to air quality,
water quality, or wildlife are expected. Rather, given the additional
safety, operation, and management requirements, there may be beneficial
impacts to natural resources due to the potential decrease in risk of
leaks.

No additional construction or land conversions would be expected from
the proposed action. Therefore, no significant adverse impacts are
expected. If operators chose to install new pipes, they would be
responsible for complying with applicable Federal, State and local
wetland, wildlife protection, and other relevant environmental laws.
Therefore, this action should have no significant adverse impacts to
wetlands, nor to flood plains, coastal zones, coastal barriers, or wild
and scenic rivers.

### Special Areas of Consideration

Special areas of consideration evaluated in this EA include endangered
species protected under the Endangered Species Act (ESA), historic
properties protected by Section 106 of the National Historic
Preservation Act (NHPA) and DOT Section 4(f) properties.

##### No Action Alternative

Making no changes to the pipeline regulations should have no adverse
effects on any special areas of consideration. Current pipelines would
continue to need regular maintenance and replacement at the same rates
as previously recorded. Incidental leaks and accidents, which have the
potential to impact special areas, would be expected to continue at
current rates.

##### Proposed Action Alternative

In general, revising the pipeline safety regulations in 49 CFR Part 192
concerning MAOP is expected to have no significant adverse impacts on
the special areas of consideration mentioned above. As discussed
previously, the change in regulations would allow operators, by meeting
several additional requirements, to utilize higher operating pressures.
Industry research on MAOPs indicates no increases in incidents, leaks,
or other disturbances are expected from this action. Therefore, no
significant adverse impacts are expected to wildlife, including
threatened and endangered species, in association with the increased
MAOPs. However, if operators chose to install new pipe, the would be
responsible for complying with applicable Federal/State endangered
species laws depending on the presence of species or habitat in the area
of excavation.

Based on the information found at 36 CFR 800.16(y)[^20], the rulemaking
proposed under the Proposed Action Alternative constitutes an
undertaking, as it is an activity funded under the direct jurisdiction
of PHMSA. Based on the lack of national data on pipelines in the
vicinity of Sec. 106 protected resources, it is impossible to estimate
the extent of potential impacts on historical and cultural resources
protected under the NHPA. However, because the rulemaking should not
increase the incidence of accidents or leaks, no adverse impacts to
historical and cultural resources is expected.

Additionally, no construction or land use conversions are expected in
association with this action. Therefore, secondary impacts to historic
and cultural resources as a result of construction are not expected.
Most activities for routine pipeline repair and maintenance involve
excavating and backfilling around existing pipelines, and initial
pipeline construction would have revealed most archeological artifacts.
Moreover, ground excavation would typically not impact historic
structures such as buildings. Thus, the proposed action does not have
the potential to cause adverse effects on historic properties or
cultural resources.

Section 4(f) of the DOT Act requires agencies within the DOT to make
special effort to preserve the natural beauty of historic sites and
public parks and recreation lands; if a transportation program requires
the use of public land in a public park, the program must include all
possible planning to minimize harm to the park or historic area. The
proposed action does not include the use of any land from, or in close
proximity to, a public park, recreation area, wildlife and waterfowl
refuge, or historic site, because of an activity such as construction,
of a new building. As such, there will not be a 4(f) statement prepared
for this proposed rulemaking.

# List of Persons and Agencies Consulted

Multiple stakeholder groups, along with the public, were consulted
during the alternatives development process for the modification of the
regulations as detailed in the NPRM. In summary, the stakeholder groups
included the following:

-   Advanced Technology Corporation

-   Advantica

-   Alliance Pipeline, L.P.

-   BP Canada

-   ConocoPhillips

-   Duke Energy

-   Dynamic Risk Assessment Systems, Inc.

-   Energy Experts International

-   Interstate Natural Gas Association of America

-   Kern River Gas Transmission Company

-   Kiefner and Associates

-   Pipeline Safety Trust

-   TransCanada Pipelines

# List of Preparers and Reviewers

This EA was prepared and reviewed by staff and specialists within PHMSA
and the Environmental Engineering Division within the Volpe National
Transportation Systems Center (Research and Innovative Technology
Administration).

# References

Pipeline and Hazardous Materials Safety Administration (PHMSA) 2005.
Pipeline Statistics. <http://ops.dot.gov/stats/stats.htm> (accessed June
7, 2007).

Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007a.
About PHMSA. <http://www.phmsa.dot.gov/about/index.html> (accessed June
11, 2007).

Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007b.
Notice of Proposed Rulemaking (Draft). Pipeline Safety: Standards for
Increasing the Maximum Allowable Operating Pressure for Natural Gas
Transmission Pipelines. Docket No. PHMSA-05-23447. Washington, D.C.:
PHMSA.

Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007c.
Pipeline Basics. <http://primis.phmsa.dot.gov/comm/PipelineBasics.htm>
(accessed June 8, 2007).

Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007d.
Regulatory Assessment with Regulatory Flexibility Analysis (Draft).
Notice of Proposed Rulemaking -- Pipeline Safety: Safety Standards for
Increasing the Maximum Allowable Operating Pressure for Natural Gas
Transmission Pipelines. Docket No. PHMSA-05-23447. Washington, D.C.:
PHMSA.

[^1]: 42 U.S.C. § 4321 et seq.

[^2]: 40 C.F.R. § 1500 et seq.

[^3]: DOT Order 5610.1C, Procedures for Considering Environmental
    Impacts, 9/18/79, as amended 7/13/82, 7/30/85.

[^4]: Howard J. Murphy, Jr., Energy Experts International,
    "Reconsideration of Maximum Allowable Operating Pressure: Costs and
    Benefits -- A Macroeconomic View," PHMSA-2006-23447-35.

[^5]: Howard J. Murphy, Jr., Energy Experts International,
    "Reconsideration of Maximum Allowable Operating Pressure: Costs and
    Benefits -- A Macroeconomic View," PHMSA-2006-23447-35.

[^6]: Richard B. Kuprewicz, Accufacts Inc., "Increasing MAOP on U.S. Gas
    Transmission Pipelines," a paper prepared for the Pipeline Safety
    Trust, PHMSA-2006-23447-50.

[^7]: Richard B. Kuprewicz, Accufacts Inc., "Increasing MAOP on U.S. Gas
    Transmission Pipelines," a paper prepared for the Pipeline Safety
    Trust, PHMSA-2006-23447-50.

[^8]: Howard J. Murphy, Jr., Energy Experts International,
    "Reconsideration of Maximum Allowable Operating Pressure: Costs and
    Benefits -- A Macroeconomic View," PHMSA-2006-23447-35.

[^9]: Richard B. Kuprewicz, Accufacts Inc., "Increasing MAOP on U.S. Gas
    Transmission Pipelines," a paper prepared for the Pipeline Safety
    Trust, PHMSA-2006-23447-50.

[^10]: Howard J. Murphy, Jr., Energy Experts International,
    "Reconsideration of Maximum Allowable Operating Pressure: Costs and
    Benefits -- A Macroeconomic View," PHMSA-2006-23447-35.

[^11]: Richard B. Kuprewicz, Accufacts Inc., "Increasing MAOP on U.S.
    Gas Transmission Pipelines," a paper prepared for the Pipeline
    Safety Trust, PHMSA-2006-23447-50.

[^12]: Joy O. Kadner, PHMSA, "Reconsideration of Maximum Allowable
    Operating Pressures for Natural Gas Pipelines, PHMSA-2006-23447-46.

[^13]: Howard J. Murphy, Jr., Energy Experts International,
    "Reconsideration of Maximum Allowable Operating Pressure: Costs and
    Benefits -- A Macroeconomic View," PHMSA-2006-23447-35.

[^14]: Richard B. Kuprewicz, Accufacts Inc., "Increasing MAOP on U.S.
    Gas Transmission Pipelines," a paper prepared for the Pipeline
    Safety Trust, PHMSA-2006-23447-50.

[^15]: See DOT Docket PHMSA-2006-23387.

[^16]: See DOT Docket PHMSA-2006-23448.

[^17]: See DOT Docket PHMSA-2006-23998.

[^18]: See PHMSA, Distribution & Transmission Annual Mileage Totals
    (1984-2005), <http://ops.dot.gov/stats/stats.htm>.

[^19]: See Joy O. Kadner, PHMSA, "Reconsideration of Maximum Allowable
    Operating Pressures for Natural Gas Pipelines," PHMSA-2006-23447-46;
    Alan Eastman, Mears Group, Inc., "Impact of 80% SMYS Operation on
    Time Dependent Threats," PHMSA-2006-23447-28.

[^20]: 36 CFR 800.16(y): "*Undertaking* means a project, activity, or
    program funded in whole or in part under the direct or indirect
    jurisdiction of a Federal agency, including those carried out by or
    on behalf of a Federal agency; those carried out with Federal
    financial assistance; and those requiring a Federal permit, license,
    or approval."