PHMSA Publishes 60-Day ICR for OPID and Operator Registry Forms

The DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) published a 60-day ICR revision notice in Monday’s Federal Register (79 FR 18118-18119, available on-line today) concerning proposals to revise two forms used by gas transmission and gas distribution pipeline operators to provide information to the National Registry of Pipeline and LNG Operators under authority of 49 CFR §191.22 and  §195.64.

Those two forms are:

• PHMSA F 1000.1, OPID Assignment Request; and

• PHMSA F 1000.2, Operator Registry Notification

OPID Assignment Request Changes

PHMSA is proposing to make the following changes to the OPID Assignment Request form:

• Align the gas distribution and gas transmission commodity choices with those found on the annual and incident reports;

• Modify the list for types of gas distribution operators to reflect the ownership structure of the operator;

• Collect the miles of pipe and facility descriptions for each state;

• Eliminate liquefied natural gas (LNG) plans and procedures as a separate safety program type; and

• Collect business cell phone numbers for contacts in addition to office phone numbers.

Operator Registry Notification Changes

PHMSA is proposing to make the following changes to the Operator Registry Notification form:

• Remove and revise instructions regarding pipeline safety program information submissions at several locations in the form and instructions;

• Reduce the number of notification types and the text describing each type to enhance clarity;

• Require Type B notifications to indicate whether the operator is assuming or ceasing operatorship of pipeline facilities;

• Require separate notifications for an acquisition and a divestiture;

• Allow an operator submitting a divestiture to request the deactivation of their OPID

• Align the gas distribution and gas transmission commodity choices with those found on the annual and incident reports;

• Collect data about miles of pipeline separate from facilities, such as breakout tanks, storage fields, and compressor stations, in Step 3;

• Require operators to provide data about pipeline facilities (Step 3) when they submit a change in entity operating (Type B) notification;

• Collect the miles of pipe and facility descriptions for each state; and

• Add a “Guidance for Selecting the Appropriate Notification Type” section to the instructions.

Burden Estimate

This ICR Notice provides a revised estimate of the burden that these collections will impose on the 2,328 Natural gas, 82 LNG facility and 335 Hazardous Liquid operators on an annual basis. Table 1 below shows a comparison of proposed revised ICR with the currently approved ICR for these forms. The current data comes from information submitted  to the OMB’s Office of Information and Regulatory Affairs (OIRA).

	Current OPID	Current Notification	Proposed
Responses	2753	11012	630
Time Burden	2753	2753	630
Cost Burden	NR	NR	NR

Table 1: Burden Estimates

The currently approved OPID numbers are high because this was for the initial implementation of the program and all 2753 operators had to register. Only new operators and certain changes would be reported with this form now so the current annual collection requirement would be much less than 2753 submissions. PHMSA estimated that it would take one hour to complete the OPID Assignment Request form.

PHMSA originally estimated that there would be four notifications per year from each operator using the Operator Registry Notification form. They estimated that it would take 15 minutes for each of those notifications.

PHMSA does not routinely report the cost burden in its ICRs. They do, however, provide a cost estimate to OIRA. They most recently estimated that hourly cost for this ICR was $64.75 providing a total annual burden cost for both forms at $356,513.50.

The ICR notice does not make it clear what form the 630 responses would involve. It would seem that the one hour per submission would mean that it was the OPID Assignment Request. Either that or the proposed changes to the Operator Registry Notification form would take four times as long to complete. In either case, PHSMA should explain the basis for the change in the burden estimate.

Public Comments

PHMSA is soliciting public comments on these proposed form changes and the associated change in the ICR burden. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # PHMSA-2014-0018). Comments need to be submitted by May 30^th, 2014.