PHMSA has been called on to clarify a familiar pipeline jurisdiction question: When does a pipeline stop being regulated in transportation and become customer-owned piping?
Martin Operating Partnership has requested a formal interpretation involving a 1.8-mile natural gas line in Odessa, Texas. The Railroad Commission of Texas currently treats the line as transmission, but Martin argues that it falls outside 49 CFR Part 192 because it is downstream of the customer sales meter and carries gas solely for Martin’s own consumption.
The facts make the question particularly interesting. The line serves a single industrial facility, operates at 20 psig or less, has no downstream customers or delivery points, and does not resell or redistribute gas.
Martin has asked PHMSA to determine that the segment is customer-owned consumption piping and therefore not subject to Part 192. If PHMSA disagrees, Martin is asking for an alternative determination that the line is a distribution service line rather than a transmission line.
PHMSA’s response could offer useful clarification for operators facing similar questions about customer meters, industrial laterals, large-volume customers, and the boundaries of Part 192 jurisdiction.