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Thank you for the opportunity to submit comments on PHMSA’s Notice of Proposed Rulemaking (NPRM) amending your hazardous liquid pipeline regulations (49 CFR Part 195).

Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the impacts of mineral and energy development while seeking sustainable solutions. For more than 25 years, we’ve worked to advance policy reforms, safeguard land and public health, and improve corporate practices. Our Oil & Gas Accountability Project works with local communities, partner organizations, public agencies, and elected officials to advance these goals nationwide.

Several years into the national shale boom, our work increasingly focuses on the expansion of infrastructure, including pipelines, to process, transport, and deliver oil and gas and related products. In this context, we believe that oil and gas operators that profit from the movement of their products must be held accountable for any accidents, pollution, and harm that occur as a result.

We express our support for the detailed comments submitted on this docket by Carl Weimer on behalf of the Pipeline Safety Trust (PST). We agree with PST that PHMSA has taken a step forward with the proposed rule. However, we also believe that as currently written, the proposed rule leaves far too many pipelines uninspected and gives the regulated industry far too much discretion to address problems they cause.

In light of the expansion of pipelines and increasing frequency of pipeline incidents, PHMSA should go much further in adopting binding regulations and ensuring enforcement. Given that the NPRM has been under development since 2010, it is high time that PHMSA adopt meaningful safety regulations to address the impacts of this burgeoning industry.