{"operation":"document","citation":"PI-76-073","title":"E. A. Hamilton — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-12-01","effective_on":null,"summary":"PI-76-073 concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-073.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-073.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-073","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76073.pdf","body":"<<<PAGE 1>>>\n\nDecember 1, 1976\nMs. E. A. Hamilton\n1724 Minnewawa Springs\nClovis, California 93612\nDear Ms. Hamilton:\nThank you for your letter dated October 25, 1976, concerning the application of the Federal gas\npipeline safety standards (copy enclosed) to gas pipeline distribution systems in mobile home\nparks.\nThe standards are established under the Natural Gas Pipeline Safety Act of 1968 (the Act), and\napply to the gathering, transmission, and distribution of gas by pipeline. Gas pipelines in a mobile\nhome park are covered by the standards if they are used to deliver gas to the persons who\nconsume it, normally the tenants in the park.\nThis Office is responsible for enforcing compliance with the standards in California against\nsystems in mobile home parks which are not operated by public utilities. In order to maximize the\npublic benefit from our limited resources, however, our enforcement activities are primarily\ndirected toward the major systems under our jurisdiction and to a far lesser degree systems in\nmobile home parks.\nAt present we have under consideration a petition for rulemaking to exclude systems in mobile\nhome parks from the jurisdiction of the Federal standards because of alleged difficulties in\ncompliance. Our main concern is whether this proposal would have an adverse effect on the\npublic's interest in pipeline safety. We do not yet have enough information to reach a conclusion\nand have requested the advice of the Technical Pipeline Safety Standards committee, a Federal\nAdvisory Committee established under the Act. The Committee will address the subject at its\nnext meeting on December 16 and 17, 1976.\nThis Office does not have statutory authority over the charges made by operators of gas systems\nto recover the costs of operating and maintaining the systems.\nWe appreciate your concern over this matter.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nEnclosure\ndal\\192\\457\\76-12-01\n1\n\n<<<PAGE 2>>>\n\nOctober 25, 1976\nDepartment of Transportation\nMaterial Transportation Bureau\nOffice of Pipeline Safety Operation\nWashington, D.C. 20590\nGentlemen:\nThis is with reference to enforcing your regulation \"Federal Gas Pipeline Regulation\", that\ncompels Mobile Home Park Owners to spend, thru [sic] out the United States, millions of dollars,\nfor which most people can see no earthly reason.\nIn the case of the park in which we live the owners, \"Travelodge\", were compelled to increase our\nrent by $12.50 per month to recover this added expense. Our Park, as no doubt most Mobile\nHome Parks, are occupied by a large percentage of Senior Citizens living on a fixed income, many\non just their Social Security. This added monthly cost will make it just that much more difficult\nfor them to get by.\nMay I suggest you give serious consideration to recinding [sic] the enforcing this regulation which\nwill increase inflation, and will add an extra burden to those living on fixed incomes. No doubt\nour Park owners, as well as other Park owners would reduce this rental increase if you cancel the\nenforcement of this regulation.\nSincerely yours,\nE A Hamilton\n1724 Minnewawa Springs\nClovis CA 93612\nP.S. I will appreciate your reaction to this letter.\ndal\\192\\457\\76-12-01\n2","truncated":false,"body_characters":3235}