State Corporation Commission — Pipeline Safety Interpretation

Page 1Mr. John A. Elliott, Director Pipeline Division State Corporation Commission Santa Fe, New Mexico 87501 Dear Mr. Elliott: This is in response to your letter dated August 10, 1973 regarding §192.5, 49 CFR. Your particular question is: "Would a trail system such as proposed by the Bureau of Outdoor Recreation cause a change in class location when all or a portion of a trail paralleled a natural gas pipeline right-of-way? It is my understanding that the trails could be used by motorcycles, bicycles, horses, dune buggies, snowmobiles, etc. I am specifically referring to Section 192.5(d)(2)(ii) 'A Class 3 location is ...a small, well-defined outside area that is occupied by 20 or more persons during normal use, such as a playground, recreation area, outdoor theater, or other place of public assembly.'" Although a trail system as you have described bears some resemblance to a "small, well-defined outside area that is occupied by 20 or more people." it differs in a number of significant aspects. In particular, it appears that a trail used by motorcycles, bicycles, horses, ect. would not be occupied by 20 or more people in a small and well-defined area at the same time. Furthermore, such a trail system would not be basically similar to a playground, recreation area, outdoor theater, or other place of public assembly. Therefore, the trail system as you have described would not require a change in class location when all or a portion of a trail paralleled a natural gas pipeline right-of-way. We trust that this has answered your particular question. If we can be of further assistance, please let us know. Sincerely, DB C:\WP51\INTERPRT\192\5\73-09-05 1#

Page 2/signed/ Joseph C. Caldwell Director Office of Pipeline Safety DB C:\WP51\INTERPRT\192\5\73-09-05 2#