# Pipeline Safety Interpretation PI-80-0102

- **operation:** document
- **citation:** PI-80-0102
- **title:** Pipeline Safety Interpretation PI-80-0102
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1980-06-16
- **effective on:** Not available
- **summary:** PI-80-0102 concerning 192.325.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0102
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/g80-06-16_Hammons_192.325-wsx.pdf
**body:**

<<<PAGE 1>>>

PI-80-0102
Department of Transportation
Research and Special Programs Administration
Washington, D.C. 20590
June 16, 1980
Mr. Gary L. Hammons
556 Main Avenue
Durango, Colorado 81301
Dear Mr. Hammons:
Thank you for your letter of April 10, 1980, in which you requested answers to two questions regarding rights-of-way for
pipelines.
In answer to your first question regarding any laws or regulations that specify minimum distances between pipelines, 49
CFR 192.325 and 195.250 contain the Department of Transportation's requirements for clearance of underground gas
and liquid pipelines, respectively. Copies of sections 192.325 and 195.250 are enclosed for your information. These
clearance requirements would not, under most conceivable circumstances, restrict the use of a single right-of-way for
multiple pipelines.
To answer your second question, the Department's regulations do not prevent pipeline operators from using multiple
parallel rights-of-way. The selection of a pipeline's right-of-way is made by the owner of the pipeline, subject to any
State or local controls or approval by the Federal Energy Regulatory Commission in the case of an interstate gas
transmission pipeline. It would appear that a definitive answer to your second question would involve legal counseling
regarding individual rights of condemnation under State law. An attorney versed in these matters could best answer
your question.
I hope this information is a benefit to you. If I can be of further assistance, please let me know.
Sincerely,
SIGNED
Melvin A. Judah
Acting Associate Director
for Pipeline Safety Regulation
Materials Transportation Bureau

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Southwest Exchange, Inc.
Real Estate Business Opportunities
556 Main Ave.
Durango, Colorado 81301
April 10, 1980
Mr. Ceasar DeLeon, Associate Director
Pipeline Safety Regulations
M.T.B.
Department of Transportation
400 7th St. S. W.
Washington, D. C. 20590
Dear Mr. DeLeon:
After having been referred to several offices, I have been given your name as the person who can answer my questions.
I live on 36.5 acres seven miles west of Durango, Colorado. There is a 75 foot Northwest Pipeline right-of-way across my
property that contains a 26 inch, high pressure natural gas line.
I am now being approached by agents of Mapco who wish to purchase an additional 50 foot right-of-way paralleling the
Northwest right-of-way. There is also probably going to be a carbon dioxide pipe line in the near future following this
same general route. Obviously, if pipeline companies are allowed to take 50 - 75 foot parallel easements it could cause
severe hardship and loss of real estate value to me and all of the other private landowners along the way. These lines
will also be traversing the Ute Indian Reservation and the San Juan National Forest.
With this background, I would appreciate the answers to the following questions:
1. Are there any laws or regulations specifying minimum distances between the actual pipelines that could
make it impossible for all of these pipelines to be constructed within the 75 foot Northwest Pipeline
right-of-way?
2. Under these circumstances, could Mapco and then future contractors be permitted to condemn
additional parallel right-of-ways ad infinitum?
My neighbors and I have no desire to obstruct any pipeline, particularly now with our current energy situation. However,
we would hope that they could all be constructed within the existing right-of-way in order to limit financial losses to the
landowners involved and to limit environmental damage to this beautiful mountain and forest country in southwest
Colorado.
Yours truly,
Gary L. Hammons
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