{"operation":"document","citation":"PI-77-028","title":"Public Service Commission of the District of Columbia — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-12-09","effective_on":null,"summary":"PI-77-028 response to Public Service Commission of the District of Columbia concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-028.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-028.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-028","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77028.pdf","body":"<<<PAGE 1>>>\n\nMs Mary E. Brazelton\nExecutive Secretary\nPublic Service Commission\nof the District of Columbia\n1625 I Street, N.W.\nWashington, D.C. 20006\nDear Ms. Brazelton:\nThis responds to your letter of November 18, 1977, asking us to clarify an apparent difference of\nopinion on whether the Washington Gas Light Company (WGL) operates transmission lines in the\nDistrict of Columbia.\nAfter reviewing the matter, it appears that the issue may involve a misunderstanding of the\ndefinition of the term \"transmission line\" as set forth in 49 CFR 192.3. This definition provides, in\nrelevant part, that a pipeline is a \"transmission line\" if it \"transports gas from a gathering line or\nstorage facility to a distribution center of storage facility.\" Referring to this definition, the WGL\nconcludes in its letter to you dated October 31, 1977, that it does not have any transmission lines\nin the District of Columbia in part because it \"has no gathering lines or gas storage fields within\nthe District.\" This conclusion does not follow, however, because neither ownership of, nor the\npresence of, gas storage fields or gathering lines in the District is determinative of whether lines\noperated by the WGL in the District are properly classified as transmission lines.\nIn the October 7, 1977, colloquy, Mr. Heverly referred to WGL-operated pipelines running\nbetween interstate transmission lines outside the District and distribution centers inside the\nDistrict as \"transmission lines.\" In our view, his interpretation is correct. With the classification\nscheme of Part 192, the true beginnings of these lines are not the interstate lines, themselves, but\nthe sources of the interstate lines. These WGL-owned lines are merely extensions of transmission\nlines which begin at junctures with gathering lines or storage fields located outside the District.\nWe trust that this analysis will be useful to the Commission in carrying out its enforcement\nresponsibilities.\nSincerely,\nCesar DeLeon\nActing Director\nDB\nC:\\WP51\\INTERPRT\\192\\3\\77-12-09\n1\n\n<<<PAGE 2>>>\n\nOffice of Pipeline\nSafety Operations\nDB\nC:\\WP51\\INTERPRT\\192\\3\\77-12-09\n2","truncated":false,"body_characters":2123}