In This Issue

PHMSA Released RIN 3 FAQ

On May 9, 2023, PHMSA published the long-awaited Frequently Asked Questions (FAQ) related to the rulemaking known as RIN #3 regarding onshore gas gathering lines now classified as Types C and R.  There are 24 FAQ included in the “packet” and they can be found here.

The publication is timely given the original effective date for the remainder of compliance activities is just around the corner, May 24th.  RCP notes that the enforcement discretionary policy remains in effect, as noticed by PHMSA: Note that an Enforcement Discretion has been issued related to the 2021 Rulemaking RIN 2137–AF38, titled “Pipeline Safety: Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments,” issued November 15, 2021. PHMSA’s Notice can be found here.