On November 5, 2018, PHMSA issued a letter of interpretation (LOI) to the Kentucky Public Service Commission concerning the application of 49 CFR 192.740 to Farm Taps, including Farm Taps which come directly from otherwise un-regulated gas pipelines.
The LOI says in part:
Part 192 defines a service line as a “distribution line that transports gas from a common source of supply to an individual customer” (49 CFR 192.3). A “farm tap” is not defined in Part 192, but commonly refers to a pipeline directly connected to a source pipeline that transports natural gas to a customer along the source pipeline right-of-way, and thus, meets the definition of a service line in the pipeline safety regulations. A non-regulated production or gathering pipeline may be the common source of supply for a regulated service line. The pipeline upstream of the service line retains its original functional identity or classification.
Because “farm taps” meet the definition of service lines, piping and appurtenances that comprise a “farm tap” that are owned or maintained by an entity engaged in the transportation of gas, are subject to the requirements of Parts 191 and 192 as a distribution service line, including the requirements at §192.740.
However, a service line ends at the connection to customer owned piping, or the outlet of the meter, whichever is further downstream. Such piping and appurtenances that are owned by a customer or person not engaged in the transportation of gas ( e.g., a farmer or residential customer) are not service lines and are not subject to requirements in Part 191 or Part 192. Therefore, neither the customer nor the operator are required by federal regulation to maintain a customer owned regulator on a customer fuel line in accordance with §192.740.
In other words:
- a Farm Tap is a regulated service line, even when it starts from an un-regulated line
- an un-regulated line can directly feed a regulated service line and still be un-regulated, and
- downstream of the meter, any customer owned pipe and equipment, including pressure regulators, is un-regulated.
Note that this LOI is for the federal regulations published by PHMSA. State regulatory agencies might have different regulatory boundaries and additional requirements applicable to Farm Taps and their associated equipment.