# State Corporation Commission — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-73-024
- **title:** State Corporation Commission — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1973-09-05
- **effective on:** Not available
- **summary:** PI-73-024 response to State Corporation Commission concerning 192.5.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-024.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-024.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-024
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73024.pdf
**body:**

<<<PAGE 1>>>

Mr. 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
- **truncated:** false
- **body characters:** 1797