[Docket No. PHMSA-2017-0151]
PHMSA has issued a technical correction to its January 14, 2026, final rule on Class Location Change requirements in 49 CFR §192.611.
The original rule allows operators to use an Integrity Management (IM) alternative to confirm or restore Maximum Allowable Operating Pressure (MAOP) on eligible gas transmission pipeline segments impacted by a class location change.
This latest action does not change the rule. It simply clarifies when the 24-month compliance timeline begins for MAOP restorations.
What Changed?
For operators restoring MAOP under the IM alternative, PHMSA confirms that the 24-month deadline runs from:
- The effective date of the final rule, or
- The date the operator decides to initiate the MAOP restoration,
whichever is later.
The correction makes clear that the decision date to restore MAOP is treated as the class location change date for purposes of starting the compliance clock.
Why This Matters for Pipeline Operators
This clarification removes ambiguity for both engineering and compliance teams.
If a Class 3 gas transmission segment was previously pressure-reduced due to a class location change, and you are now considering restoring MAOP using the IM alternative:
- Your 24-month window starts when you formally decide to move forward with restoration (if later than the rule’s effective date).
- There are no new technical requirements.
- PHMSA confirms there are no additional compliance costs.
Practical Takeaway
For operators managing gas transmission pipelines, MAOP restoration, and integrity management programs, documentation matters.
Make sure your internal records clearly establish the date the MAOP restoration decision is made. That date now drives your compliance timeline under §192.611.
This correction provides regulatory clarity—not new obligations—but it reinforces the importance of coordination between engineering, regulatory, and administrative teams when planning MAOP restoration activities.
Please message Jessica Foley for a copy of this rule change.