In This Issue

MOU on Pipeline Repair Permitting Streamlining

A copy of the “Memorandum of understanding on coordination of environmental reviews for pipeline repair projects” is now available on the web at: This document explains in general terms how various federal agencies have agreed to work together to expedite permits and authorizations as necessary for pipeline repairs. It envisions the use of the National Pipeline Mapping System for the consolidation and exchange of information relevant to specific geographic areas (i.e. what endengered species are near a pipeline?), commits to agencies to participate in pre-inspection planning and coordination meetings (i.e. before a pipeline assessment is conducted for Integrity Management purposes), and mentions that the agencies will give priority to processing of time sensitive pipeline permit requests. The MOU also states that the agencies will work together to develop a set of Best Management Practices that “when used in making pipeline repairs, will aid the expedited consideration of permitting requests, minimize adverse impacts on the environment and reduce the need for post-repair remediation”. The agencies also plan to establish a working group to develop guidance documents for the agencies to use to coordinate and expedite permitting of time sensitive repairs. The agencies also agreed to participate in the processes established by the Ombudsman designated pursuant to 49 U.S.C. 60133(e) to assist in resolving disagreements.

As a side benefit, section III of the MOU describes the legal authority, jurisdiction, and major activities that impact pipeline permitting for 15 federal agencies / organizations, in only 15 paragraphs. It is one of the best high-level summaries of “which federal agencies regulate what pipeline activities, and under what authority” that we have seen. The authors of Cliffs Notes would be proud!