# ROCKIES EXPRESS PIPELINE LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 32024040NOPV
- **title:** ROCKIES EXPRESS PIPELINE LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-09-06
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 191.22(c)(1)(i), 192.195(a), 192.491(c), 192.5(b)(1), 192.5(b)(2), 192.5(b)(3), 192.619(a)(1), 192.705(c).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32024040NOPV
**body:**

Notice of Probable Violation involving ROCKIES EXPRESS PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 191.22(c)(1)(i),  192.195(a),  192.491(c),  192.5(b)(1),  192.5(b)(2),  192.5(b)(3),  192.619(a)(1),  192.705(c). The case was opened on 2024-09-06 and is reported as closed as of 2025-10-14. Proposed civil penalty: $246,800. Assessed civil penalty: $188,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32024040NOPV_Consent Agreement and Order_10062025_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_Consent%20Agreement%20and%20Order_10062025_(23-264452).pdf

32024040NOPV_Consent Agreement and Order_10062025_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_Consent%20Agreement%20and%20Order_10062025_(23-264452)_text.pdf

32024040NOPV_Operator Response to Notice and Request for Hearing and Request for Informal Settlement Conference and Statement of Issues_10042024_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20and%20Request%20for%20Informal%20Settlement%20Conference%20and%20Statement%20of%20Issues_10042024_(23-264452).pdf

32024040NOPV_Operator Withdrawal of Hearing Request_10072025_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_Operator%20Withdrawal%20of%20Hearing%20Request_10072025_(23-264452).pdf

32024040NOPV_PCP PCO_09062024_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PCP%20PCO_09062024_(23-264452).pdf

32024040NOPV_PCP PCO_09062024_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PCP%20PCO_09062024_(23-264452)_text.pdf

32024040NOPV_PHC Hearing Rescheduled_05212025_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_05212025_(23-264452).pdf

32024040NOPV_PHC Hearing Rescheduled_05212025_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_05212025_(23-264452)_text.pdf

32024040NOPV_PHC Hearing Rescheduled_05222025_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_05222025_(23-264452).pdf

32024040NOPV_PHC Hearing Rescheduled_05222025_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_05222025_(23-264452)_text.pdf

32024040NOPV_PHC Hearing Rescheduled_06102025_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_06102025_(23-264452).pdf

32024040NOPV_PHC Hearing Rescheduled_06102025_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_06102025_(23-264452)_text.pdf

32024040NOPV_PHC Hearing Rescheduled_08282025_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_08282025_(23-264452).pdf

32024040NOPV_PHC Hearing Rescheduled_08282025_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Rescheduled_08282025_(23-264452)_text.pdf

32024040NOPV_PHC Hearing Scheduled_11212024_(23-264452).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Scheduled_11212024_(23-264452).pdf

32024040NOPV_PHC Hearing Scheduled_11212024_(23-264452)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024040NOPV/32024040NOPV_PHC%20Hearing%20Scheduled_11212024_(23-264452)_text.pdf

32024040NOPV_Consent Agreement and Order_10062025_(23-264452)_text.pdf

October 6, 2025
VIA ELECTRONIC MAIL TO: CEO@tallgrass.com
Matt Sheehy
President & Chief Executive Officer
Tallgrass Energy, LP
370 Van Gordon Street
Lakewood, Colorado 80228
CPF No. 3-2024-040-NOPV
Dear Mr. Sheehy:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Tallgrass Energy, LP,
which was executed on September 26, 2025. When the civil penalty has been paid, this
enforcement action will be closed. Service of the Consent Order and Consent Agreement by
electronic mail is deemed effective upon the date of transmission and acknowledgement of receipt,
or as otherwise provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: David Barrett, Acting Region Director, Central Region, Office of Pipeline Safety,
PHMSA
Danielle Stephens, DOT Compliance Primary, Tallgrass Energy, LP,
Danielle.Stephens@tallgrass.com
Crystal Heter, Chief Operating Officer, Tallgrass Energy, LP,
Crystal.Heter@tallgrass.com



Catherine Little, Counsel for Tallgrass, Bracewell, LLP, catherine.little@bracewell.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Tallgrass Energy, LP, ) CPF No. 3-2024-040-NOPV
)
)
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated September 6, 2024, pursuant to 49 CFR § 190.207, the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of
Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice) to
Tallgrass Energy, LP (Tallgrass or Respondent).
In response to the Notice, Respondent contested several of the alleged violations, the proposed
civil penalty, and the proposed compliance order, and requested a hearing (Response). Tallgrass
also requested to meet informally with PHMSA to discuss the matters raised in its Response.
Respondent and PHMSA (the Parties) subsequently met to discuss the case. As a result of those
discussions, the Parties have agreed to a Consent Agreement by which PHMSA makes findings
of violations for two of the Items alleged in the Notice (Items 1 and 2), modifies two of the Items
alleged in the Notice to warnings (Items 3 and 5), and withdraws two of the Items alleged in the
Notice (Items 4 and 6). Respondent will pay a civil penalty in the amount of $188,800, and there
are no outstanding compliance order obligations under the terms of the Consent Agreement.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order issued pursuant to § 190.219. Tallgrass is hereby ordered to comply with the
terms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et seq.,
failure to comply with this Consent Order may result in the assessment of civil penalties as set
forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney General for
appropriate relief in a district court of the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 CFR § 190.5.
______________________ ______________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Rockies Express Pipeline, LLC, ) CPF No. 3-2024-040-NOPV
a subsidiary of Tallgrass Energy, LP )
)
)
)
Respondent. )
____________________________________)
CONSENT AGREEMENT
From February 2, 2023, through January 25, 2024, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of Title 49, United States Code (U.S.C.), inspected Rockies Express Pipeline, LLC’s (REX
or Respondent) pipeline facilities from Mexico, Missouri, to Powhatan Point, Ohio. REX is a
subsidiary of Tallgrass Energy, LP (Tallgrass).1
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated September 6, 2024, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice
proposed finding that REX committed one violation of 49 CFR Part 191 (Item 1) and five
violations of 49 CFR Part 192 (Items 2 – 6), proposed ordering Respondent to take certain
measures to correct certain of the alleged violations, and proposed a civil penalty of $246,800.
REX responded to the Notice by letter dated October 4, 2024 (Response). Respondent contested
four of the alleged violations, the associated proposed civil penalty, and the associated proposed
compliance order, and requested a hearing. Respondent did not contest Items 1 and 2 of the
Notice. REX also requested to meet informally with PHMSA to discuss the matters raised in its
Response.
PHMSA and Respondent (the Parties) subsequently met to discuss the issues raised in the
Response. As a result of those discussions and as explained in more detail below, the Parties
have agreed to a Consent Agreement by which PHMSA makes findings of violations for Notice
Items 1 and 2 as alleged, reduces Items 3 and 5 to warnings, and withdraws Items 4 and 6.
Respondent will pay a reduced civil penalty in the amount of $188,800 specifically associated
with uncontested Items 1 and 2.
1 See Rockies Express Pipeline (REX), TALLGRASS ENERGY,
https://pipeline.tallgrassenergylp.com/Pages/Content.aspx?pipeline=501&type=SMRY (last accessed August 28,
2025).



Having agreed that settlement of this proceeding will avoid further administrative proceedings or
litigation and will serve the public interest by promoting safety and protection of the
environment, pursuant to 49 U.S.C. § 60101, et seq. and 49 CFR Part 190, and upon consent and
agreement, the Parties hereby agree as follows:
I. General Provisions
1. Respondent acknowledges that as the operator of the pipeline facilities subject to
the Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the
Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative
orders issued thereunder. For purposes of this Consent Agreement (Agreement), Respondent
acknowledges that it received proper notice of PHMSA’s action in this proceeding and that the
Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq.,
and the regulations and orders issued thereunder.
2. After Respondent returns this signed Agreement to PHMSA, the Agency’s
representative will present it to the Associate Administrator for Pipeline Safety, recommending
that the Associate Administrator adopt the terms of this Agreement by issuing an administrative
order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement
constitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the
Associate Administrator will issue a Consent Order incorporating the terms of this Agreement.
3. Respondent consents to the issuance of the Consent Order, and hereby waives any
further procedural requirements with respect to its issuance. Respondent waives all rights to
contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including
all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution
provisions set forth herein. Respondent agrees to withdraw its request for an administrative
hearing regarding the Notice.
4. This Agreement shall apply to and be binding upon PHMSA and Respondent, its
officers, directors, and employees, and its successors, assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
5. This Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this Agreement.
The Parties acknowledge that there are no representations, agreements or understandings relating
to settlement other than those expressly contained in this Agreement, except that the terms of this
Agreement may be construed by reference to the Notice.
6. Nothing in this Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,
et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters
PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to



bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.
7. For all transfers of ownership or operating responsibility of Respondent’s pipeline
system referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice of the
transfer to the Director no later than 60 days after the transfer occurs.
8. This Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a permit,
or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
9. This Agreement does not create rights in, or grant any cause of action to, any third
party not party to this Agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this Agreement. Respondent
agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents,
and representatives from any and all causes of action arising from any acts or omissions of
Respondent or its contractors in carrying out any work required by this Agreement.
10. Except as set forth herein, this Agreement does not constitute a finding of
violation of any other federal law or regulation and may not be used in any civil proceeding of
any kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any
law, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this
Agreement or in future PHMSA enforcement actions.
II. Findings of Violation:
11. Item 1 - 49 CFR § 191.22(c)(1)(i): The Notice alleged REX failed to notify
PHMSA of a planned modification to the Rockies Express Pipeline costing more than $10
million, no later than 60 days before it began. Respondent does not contest the allegation of
violation as alleged in the Notice. As such, PHMSA finds a violation of 49 CFR
§ 191.22(c)(1)(i).
12. Item 2 - 49 CFR § 192.5(b): The Notice alleged REX failed to identify the correct
class location related to two sites on the REX/Kinetrex Interconnect (RKI) lateral pipeline.
Respondent does not contest the allegation of violation as alleged in the Notice. As such,
PHMSA finds a violation of 49 CFR § 192.5(b).
13. Items 1 and 2 will be considered by PHMSA as prior offenses in any future PHMSA
enforcement action taken against Respondent.



III. Warning Items:
14. Item 3 - 49 CFR § 192.195(a): The Notice alleged that REX failed to install
adequate pressure relieving or limiting devices meeting the requirements of §§ 192.199 and
192.201 on its RKI lateral pipeline. The allegation arose from one of the class location
misidentifications referenced in Item 2. This Item was brought as an allegation of violation with
an associated proposed compliance order; however, PHMSA finds that a warning is more
appropriate for this Item. As such, this Item does not constitute a finding of violation, and the
proposed compliance order associated with this Item is withdrawn. In addition, following
discovery of the misidentification, REX carried out measures to protect the RKI lateral from an
overpressure event, including by installing permanent overpressure protection devices before the
initiation of this enforcement action and conducting inspections of those devices, removing the
need for further compliance actions. Respondent, without admission, accepts a warning.
15. Item 5 - 49 CFR § 192.619(a)(1): The Notice alleged that REX established the
Maximum Allowable Operating Pressure (MAOP) at a pressure that exceeded the design
pressure of its weakest element. The allegation arises from one of the class location
misidentifications referenced in Item 2. This Item was brought as an allegation of violation with
an associated proposed compliance order; however, PHMSA finds that a warning is more
appropriate for this Item. As such, this Item does not constitute a finding of violation, and the
proposed compliance order associated with this Item is withdrawn. In addition, following
discovery of the misidentification and prior to the initiation of this enforcement action, REX
properly established the MAOP for the RKI lateral, thus removing the need for further
compliance actions. Respondent also provided PHMSA with supporting documentation
regarding the highest operating pressure, design, and set points for the line. Respondent, without
admission, accepts a warning.
16. For Warning Items 3 and 5, if OPS finds a violation of these provisions in a
subsequent inspection, Respondent may be subject to future enforcement action.
IV. Items Withdrawn:
17. Item 4 - 49 CFR § 192.491(c): With respect to Item 4 of the Notice, the Parties
agree that this Item should be withdrawn following further review of Respondent’s management
of its corrosion control program, including its process for assessing the capacitance effect of AC
mitigation devices on its system. Because this Item is withdrawn, it will not constitute a finding
of violation for any purpose, and no further action by Respondent is necessary with respect to
this item. As such, the allegation of violation for Item 4 and the proposed compliance order
associated with this Item are withdrawn.
18. Item 6 - 49 CFR § 192.705(c): With respect to Item 6 of the Notice, the Parties
agree that this Item should be withdrawn following further review of REX’s aerial patrol
program. Because this Item is withdrawn, it will not constitute a finding of violation for any
purpose, and no further action by Respondent is necessary with respect to this item. As such, the
allegation of violation for Item 6, the proposed civil penalty, and the proposed compliance order
associated with this Item are withdrawn.



V. Civil Penalty:
19. Items 1 and 2: The Notice proposed assessing a civil penalty in the amount of
$39,100 for Item 1 and $149,700 for Item 2. Respondent did not contest the proposed civil
penalties for these Items. As such, Respondent shall pay a civil penalty in the amount of $39,100
for Item 1 and $149,700 for Item 2.
20. Respondent will pay a total reduced civil penalty in the amount of $188,800,
pursuant to the payment instructions at 49 CFR § 190.227(a), to be paid in full no later than 20
days from the Effective Date of this Agreement.
VI. Compliance Order:
21. All proposed compliance order requirements set forth in the Notice have been
withdrawn. Respondent has no outstanding compliance order obligations under the terms of this
Agreement.
VII. Enforcement:
22. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties
under 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues
and referral of the case to the Attorney General for judicial enforcement, if PHMSA determines
that Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil
penalty amounts are adjusted annually for inflation. See 49 CFR § 190.223.
VIII. Dispute Resolution:
23. The Director and Respondent will informally attempt to resolve any disputes
arising under this Agreement. If Respondent and the Director are unable to informally resolve
the dispute within 15 calendar days after the dispute is first raised, in writing, to the Director,
Respondent may submit a written request for a determination resolving the dispute from the
Associate Administrator. Such request must be made in writing and provided to the Director,
counsel for the Central Region, and to the Associate Administrator, no later than 10 calendar
days from the 15-day deadline for informal resolution referenced in this paragraph. Along with
its request, Respondent must provide the Associate Administrator with all information
Respondent believes is relevant to the dispute. Decisions of the Associate Administrator under
this paragraph will constitute final agency action. The existence of a dispute and PHMSA’s
consideration of matters placed in dispute will not excuse, toll, or suspend any term or timeframe
for completion of any work to be performed under this Agreement during the pendency of the
dispute resolution process.



IX. Effective Date:
24. The term “Effective Date,” as used herein, is the date on which the Consent Order
is issued by the Associate Administrator incorporating the terms of this Agreement.
X. Recordkeeping and Information Disclosure:
25. Unless otherwise required in this Agreement, Respondent agrees to maintain
records demonstrating compliance with all requirements of this Agreement for a period of at
least five (5) years following completion of all work to be performed, unless a longer period of
time is required pursuant to 49 CFR parts 190-199. For any reports, plans, or other deliverables
required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim
of business confidentiality or other protections applicable to the release of information by
PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to
this Agreement in accordance with 49 CFR Part 7. Respondent must mark the claim of
confidentiality in writing on each page, and include a statement specifying the grounds for each
claim of confidentially. PHMSA determines release of any information submitted pursuant to
this Agreement in accordance with 49 CFR Part 7, the Freedom of Information Act, 5 U.S.C. §
552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.
XI. Modification:
26. The terms of this Agreement may be modified by mutual agreement of the Parties.
Such modifications must be in writing and signed by both parties.
XII. Termination:
27. This Agreement will remain in effect until the Civil Penalty in Section V is paid
in full. This enforcement action will be closed upon payment. Nothing in this Agreement
prevents Respondent from completing any of the obligations earlier than the deadlines provided
for in this Agreement.
XIII. Ratification:
28. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Agreement and to execute and legally bind such party
to this document.
29. The Parties hereby agree to all findings, conditions, and terms of this Agreement.
[Signature Lines on Following Page]



For Rockies Express Pipeline, LLC:
___________________________________
________________________
Date
For PHMSA:
________________________________________
Acting Director, Central Region, Office of Pipeline Safety

32024040NOPV_PHC Hearing Rescheduled_08282025_(23-264452)_text.pdf

August 28, 2025
VIA EMAIL TO: Catherine.Little@bracewell.com, Ryan.McClure@dot.gov et al.
Ms. Catherine Little, Esq.
Counsel for Rockies Express Pipeline LLC, Tallgrass Energy, LP
Bracewell LLP
2001 M Street, NW, Ste. 900
Washington, DC 20036
Mr. Ryan McClure, Esq.
Counsel for the Agency
Pipeline and Hazardous Materials Safety Administration (PHMSA)
1200 New Jersey Ave., S.E.
Washington, DC 20590
Re: PHMSA CPF No.: 3-2024-040-NOPV, Rockies Express Pipeline, LLC Tallgrass
Energy, LP, Hearing Rescheduled
Dear Ms. Little and Mr. McClure,
On August 27, 2025, the parties jointly requested a continuance with respect to the
September 16th hearing and pre-hearing filings in this matter because they have reached
an agreement in principle and are awaiting final signatures and the issuance of a Consent
Agreement and Order. Accordingly, the hearing is rescheduled for October 10, 2025,
beginning at 9:30 a.m. Eastern Time at DOT Headquarters. Prehearing filings are due
October 9, 2025. The September 5th prehearing conference is canceled. Instructions
communicated in the prior scheduling order remain in effect.
Regards,
Dolores Francis
Presiding Official

32024040NOPV_PHC Hearing Rescheduled_06102025_(23-264452)_text.pdf

June 10, 2025
VIA EMAIL TO: Catherine.Little@bracewell.com, Ryan.McClure@dot.gov et al.
Ms. Catherine Little, Esq.
Counsel for Rockies Express Pipeline LLC, Tallgrass Energy, LP
Bracewell LLP
2001 M Street, NW, Ste. 900
Washington, DC 20036
Mr. Ryan McClure, Esq.
Counsel for the Agency
Pipeline and Hazardous Materials Safety Administration (PHMSA)
1200 New Jersey Ave., S.E.
Washington, DC 20590
Re: PHMSA CPF No.: 3-2024-040-NOPV, Rockies Express Pipeline, LLC Tallgrass
Energy, LP, Notice of Hearing and Order Regarding Prehearing Statement
Dear Ms. Little and Mr. McClure,
In accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty and Proposed Compliance Order issued by
PHMSA in the above referenced case. The hearing will take place on September 16,
2025, beginning at 9:30 a.m. Eastern Time. The hearing will be held at PHMSA
Headquarters:
DOT Headquarters
1200 New Jersey Ave, S.E.
Washington, DC
20590
Additional instructions for accessing the DOT Headquarters building will be provided
later.
Each party is directed to submit to the presiding official and the other party by email a
pre-hearing statement, due no later than September 3, 2025, including the following
information:



1. A statement of facts
2. A list of all agreed upon facts
3. Defenses (by Respondent)
4. A witness list including a description and anticipated length of each witness’
anticipated testimony. The description must be sufficient to show how the
anticipated testimony may prove or disprove a fact significant to the case.
5. A copy of all exhibits with an index identifying the documents. All exhibits must
be marked for identification in the lower right corner of each page. Documents
already in the case file should not be included.
The parties must confer regarding item 2 above. Failure to submit items 4 and 5 above
may result in disallowance of that evidence at the hearing. The parties may supplement
their hearing exhibits or witness list with fair notice to the other party and the presiding
official.
A brief pre-hearing conference may be held 7-10 days prior to the hearing if the
presiding official deems it appropriate.
The presiding official strongly recommends that a court reporter transcribe the hearing.
If Respondent elects to transcribe the hearing, Respondent should notify the presiding
official (with copy to the other party) as soon as practicable.
The Agency is required to be represented by counsel for these proceedings.
Regards,
Dolores Francis
Presiding Official

32024040NOPV_PHC Hearing Rescheduled_05222025_(23-264452)_text.pdf

May 22, 2025
VIA EMAIL TO: Catherine.Little@bracewell.com, Ryan.McClure@dot.gov et al.
Ms. Catherine Little, Esq.
Counsel for Rockies Express Pipeline LLC, Tallgrass Energy, LP
Bracewell LLP
2001 M Street, NW, Ste. 900
Washington, DC 20036
Mr. Ryan McClure, Esq.
Counsel for the Agency
Pipeline and Hazardous Materials Safety Administration (PHMSA)
1200 New Jersey Ave., S.E.
Washington, DC 20590
Re: PHMSA CPF No.: 3-2024-040-NOPV, Rockies Express Pipeline, LLC Tallgrass
Energy, LP, Notice of Hearing and Order Regarding Prehearing Statement
Dear Ms. Little and Mr. McClure,
In accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty and Proposed Compliance Order issued by
PHMSA in the above referenced case. The hearing will take place on September 3,
2025, beginning at 9:30 a.m. Eastern Time. The hearing will be held virtually via
Microsoft Teams. Hearing login information will be provided later.
Each party is directed to submit to the presiding official and the other party by email a
pre-hearing statement, due no later than August 21, 2025, including the following
information:
1. A statement of facts
2. A list of all agreed upon facts
3. Defenses (by Respondent)
4. A witness list including a description and anticipated length of each witness’
anticipated testimony. The description must be sufficient to show how the
anticipated testimony may prove or disprove a fact significant to the case.



5. A copy of all exhibits with an index identifying the documents. All exhibits must
be marked for identification in the lower right corner of each page. Documents
already in the case file should not be included.
The parties must confer regarding item 2 above. Failure to submit items 4 and 5 above
may result in disallowance of that evidence at the hearing. The parties may supplement
their hearing exhibits or witness list with fair notice to the other party and the presiding
official.
A brief pre-hearing conference may be held 7-10 days prior to the hearing if the
presiding official deems it appropriate.
The presiding official strongly recommends that a court reporter transcribe the hearing.
If Respondent elects to transcribe the hearing, Respondent should notify the presiding
official (with copy to the other party) as soon as practicable.
The Agency is required to be represented by counsel for these proceedings.
Regards,
Dolores Francis
Presiding Official

32024040NOPV_PHC Hearing Rescheduled_05212025_(23-264452)_text.pdf

May 21, 2025
VIA EMAIL TO: Catherine.Little@bracewell.com, Ryan.McClure@dot.gov et al.
Ms. Catherine Little, Esq.
Counsel for Rockies Express Pipeline LLC, Tallgrass Energy, LP
Bracewell LLP
2001 M Street, NW, Ste. 900
Washington, DC 20036
Mr. Ryan McClure, Esq.
Counsel for the Agency
Pipeline and Hazardous Materials Safety Administration (PHMSA)
1200 New Jersey Ave., S.E.
Washington, DC 20590
Re: PHMSA CPF No.: 3-2024-040-NOPV, Rockies Express Pipeline, LLC Tallgrass
Energy, LP, Notice of Hearing and Order Regarding Prehearing Statement
Dear Ms. Little and Mr. McClure,
In accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty and Proposed Compliance Order issued by
PHMSA in the above referenced case. The hearing will take place on August 28,
2025, beginning at 9:30 a.m. Eastern Time. The hearing will be held virtually via
Microsoft Teams. Hearing login information will be provided later.
Each party is directed to submit to the presiding official and the other party by email a
pre-hearing statement, due no later than August 14, 2025, including the following
information:
1. A statement of facts
2. A list of all agreed upon facts
3. Defenses (by Respondent)
4. A witness list including a description and anticipated length of each witness’
anticipated testimony. The description must be sufficient to show how the
anticipated testimony may prove or disprove a fact significant to the case.



5. A copy of all exhibits with an index identifying the documents. All exhibits must
be marked for identification in the lower right corner of each page. Documents
already in the case file should not be included.
The parties must confer regarding item 2 above. Failure to submit items 4 and 5 above
may result in disallowance of that evidence at the hearing. The parties may supplement
their hearing exhibits or witness list with fair notice to the other party and the presiding
official.
A brief pre-hearing conference may be held 7-10 days prior to the hearing if the
presiding official deems it appropriate.
The presiding official strongly recommends that a court reporter transcribe the hearing.
If Respondent elects to transcribe the hearing, Respondent should notify the presiding
official (with copy to the other party) as soon as practicable.
The Agency is required to be represented by counsel for these proceedings.
Regards,
Dolores Francis
Presiding Official

32024040NOPV_PHC Hearing Scheduled_11212024_(23-264452)_text.pdf

November 21, 2024
VIA ELECTRONIC MAIL TO: kale.stanton@tallgrass.com and gregory.ochs@dot.gov
Mr. Kale Stanton
Vice President, Asset Integrity
Tallgrass Energy, LP
370 Van Gordon Street
Lakewood, CO 80228
Mr. Gregory Ochs
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
901 Locust Street, Suite 480
Kansas City, MO 64106-2641
Re: Notice of Hearing, Tallgrass Energy, LP
CPF No. 3-2024-040-NOPV
Dear Mr. Stanton and Mr. Ochs:
In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the
Pipeline and Hazardous Materials Safety Administration in the above-referenced case. The
hearing will take place on April 24, 2025, beginning at 8:30 a.m. Central Time.
The hearing will be held at the PHMSA Central Region office, 901 Locust Street, Suite 480,
Kansas City, Missouri 64106. Upon arrival at the building, attendees will be required to present
photo identification to security personnel. A contact phone number for the day of the hearing is
(816) 329-3800.
At least 10 calendar days prior to the hearing (or by April 14, 2025), both parties must submit
and exchange any additional written materials they intend to present at the hearing and the name
and email address of each attendee. This information should be provided electronically.
Materials not submitted by this date may be excluded. If you have any questions, please do not
hesitate to contact me.



Sincerely,
Larry White
Presiding Official
cc: Ms. Danielle Stephens, Director, PHMSA Compliance, Tallgrass Energy, LP
danielle.stephens@tallgrass.com
Ms. Catherine Little, Esq., Counsel for Tallgrass Energy, Bracewell, LLP,
catherine.little@bracewell.com
Mr. Ryan McClure, Counsel, Central Region, Office of Pipeline Safety,
ryan.mcclure@dot.gov
Ms. Mia Petrucci, Law Clerk, Central Region, Office of Pipeline Safety,
mia.petrucci@dot.gov
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