# Memo: Internal — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-89-012
- **title:** Memo: Internal — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1989-07-06
- **effective on:** Not available
- **summary:** PI-89-012 response to Memo: Internal concerning 192.5.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1989/PI89012.pdf
**body:**

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Class 3 Determination based on Motel within 220 yards of a transmission line.
The situation in Forgus Falls where Great Plains Gas Company has a transmission line near a
Holiday Inn was discussed with Furrow. The motel is not within 100 yards of the motel, but it
may be within 220 yards.
The question is: Should the motel rooms be counted as dwellings units, similar to apartments, or
as a single building?
In Furrow's opinion (emphasis) there is probably a distinction between a dwelling unit, which
serves as a more permanent place of residence, and a motel room, which is generally occupied for
a short term. He does not feel that the motel room would be classified as a dwelling unit for the
purposes of the regulations.
A motel alone would have to be within 100 yards of a pipeline and meet the occupancy
requirements of 192.5(d)(2) to establish a class 3 location.
NOTE: THIS IS AN OPINION, NOT AN INTERPRETATION. IT COULD BE REVERSED.
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