Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators regarding interpretations and pending regulatory deadlines.
Q: To clarify, has there been a final approved and implemented requirement for Management of Change processes for DISTRIBUTION companies?
A: No, this was published in the Notice of Proposed Rulemaking, but has not yet been discussed within the Gas Pipeline Advisory Committees (GPAC). That must occur prior to publication of any final rule.
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Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will be 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.