# E. A. Hamilton — Pipeline Safety Interpretation

**Citation:** PI-76-073  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1976-12-01

PI-76-073 concerning 192.457.

## Document text

<<<PAGE 1>>>

December 1, 1976
Ms. E. A. Hamilton
1724 Minnewawa Springs
Clovis, California 93612
Dear Ms. Hamilton:
Thank you for your letter dated October 25, 1976, concerning the application of the Federal gas
pipeline safety standards (copy enclosed) to gas pipeline distribution systems in mobile home
parks.
The standards are established under the Natural Gas Pipeline Safety Act of 1968 (the Act), and
apply to the gathering, transmission, and distribution of gas by pipeline. Gas pipelines in a mobile
home park are covered by the standards if they are used to deliver gas to the persons who
consume it, normally the tenants in the park.
This Office is responsible for enforcing compliance with the standards in California against
systems in mobile home parks which are not operated by public utilities. In order to maximize the
public benefit from our limited resources, however, our enforcement activities are primarily
directed toward the major systems under our jurisdiction and to a far lesser degree systems in
mobile home parks.
At present we have under consideration a petition for rulemaking to exclude systems in mobile
home parks from the jurisdiction of the Federal standards because of alleged difficulties in
compliance. Our main concern is whether this proposal would have an adverse effect on the
public's interest in pipeline safety. We do not yet have enough information to reach a conclusion
and have requested the advice of the Technical Pipeline Safety Standards committee, a Federal
Advisory Committee established under the Act. The Committee will address the subject at its
next meeting on December 16 and 17, 1976.
This Office does not have statutory authority over the charges made by operators of gas systems
to recover the costs of operating and maintaining the systems.
We appreciate your concern over this matter.
Sincerely,
Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations
Enclosure
dal\192\457\76-12-01
1

<<<PAGE 2>>>

October 25, 1976
Department of Transportation
Material Transportation Bureau
Office of Pipeline Safety Operation
Washington, D.C. 20590
Gentlemen:
This is with reference to enforcing your regulation "Federal Gas Pipeline Regulation", that
compels Mobile Home Park Owners to spend, thru [sic] out the United States, millions of dollars,
for which most people can see no earthly reason.
In the case of the park in which we live the owners, "Travelodge", were compelled to increase our
rent by $12.50 per month to recover this added expense. Our Park, as no doubt most Mobile
Home Parks, are occupied by a large percentage of Senior Citizens living on a fixed income, many
on just their Social Security. This added monthly cost will make it just that much more difficult
for them to get by.
May I suggest you give serious consideration to recinding [sic] the enforcing this regulation which
will increase inflation, and will add an extra burden to those living on fixed incomes. No doubt
our Park owners, as well as other Park owners would reduce this rental increase if you cancel the
enforcement of this regulation.
Sincerely yours,
E A Hamilton
1724 Minnewawa Springs
Clovis CA 93612
P.S. I will appreciate your reaction to this letter.
dal\192\457\76-12-01
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76073.pdf>
- Source ID: `phmsa`
- SHA-256: `7b115c3e9eed301bb990c1fd7ab6248a34e20357ab5d40e36f5d48af97883078`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-24T16:46:49.492Z
- Document slug: `phmsa-interpretation-pi-76-073`

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