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What Does the 2021 PHMSA Gas Gathering Rule Require of Operators?

The 2021 Gas Gathering final rule requires operators of all onshore gas gathering lines to report incidents and file annual reports under 49 CFR part 191, and this final rule provides for a new Type C regulated gathering line with certain regulatory compliance requirements defined in § 192.8. Type C gathering lines are defined as gas gathering lines in Class 1 locations that have an outer diameter of 8.625 inches or greater and operate at an MAOP producing a hoop stress of 20% or more of SMYS, or if the pipeline is non-metallic or the stress level is unknown, operates above 125 pounds per square inch gauge. A description of the rulemaking is provided at New Federal Regulations Add More Than 400,000 Miles of “Gas Gathering” Pipelines Under Federal Oversight .

Gas gathering pipeline operators who were previously not regulated are required to acquire a PHMSA Operator Identification Number (OpID) in accordance with § 191.22 in order to submit required reports. (Gas Gathering Fact Sheet | PHMSA (dot.gov))

Compliance Timelines:

2021 Gas Gathering Final Rule Publication Date: 11/15/2021; Effective Date: May 16, 2022 Reporting Requirements for all gas gathering pipeline operators:

  • Incident Reports: Report events occurring after May 16, 2022

  • Annual Reports: 2022 reports due March 2023

Type C Gas Gathering Pipeline Operators:

  • Identify Type C lines: November 16, 2022

  • Compliance with safety standards: May 16, 2023

  • MAOP lookback: 5-year period ending May 16, 2023


The final rule requires operators of all onshore gas gathering lines to report incidents and file annual reports under part 191. Type R gathering lines are exempt from safety-related condition reporting requirements in §§ 191.23 and 191.25. The final rule clarifies that all gathering lines are exempt from National Pipeline Mapping System submittals.


PHMSA is adding definitions under § 191.3 for “regulated onshore gathering” and “Reporting-regulated gathering.” The term “regulated onshore gathering” is defined as a Type A, Type B, or Type C gas gathering line as determined in accordance with § 192.8. The term “reporting-regulated gathering” is defined as an onshore gathering pipeline other than a regulated onshore gathering pipeline. These pipelines have been designated as “Type R” gathering lines in § 192.8 but are not regulated under that part. (Gas Gathering Final Rule – RCP Inc.)


Here is a summary of regulatory requirements by pipeline type:

Gathering Line Notes
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If you have questions about how this new gas gathering rule impacts your pipelines, please reach out to Oak Tree Group. Find out how Oak Tree Group can help your company fully comply with this rule change.

Summary of Type C Requirements in Table format (see regulatory text for specific requirements):

Summary of Type C Requirements in Table format (see regulatory text for specific requirements)

Provision Scope Estimated Mileage

Reporting (incident, annual)

Part 191 All gathering >400,000 miles

Design, Construction, Initial

Inspection, and Testing* All new and replaced Type C (diameter>8.625") New and replaced only

Damage Prevention

§ 192.614 All Type C (diameter>8.625") 90,863 miles

Emergency Plans

§ 192.615 All Type C (diameter>8.625") 90,863 miles

Public Awareness

§ 192.616 Diameter 8.625" through 16" with a PIR exception

All Type C with a diameter>16" 20, 336 miles

Line Markers

§ 192.707 Diameter 8.625" through 16" with a PIR exception

All Type C with a diameter>16" 20, 336 miles

Corrosion Control

Subpart I to part 192 Diameter 8.625" through 16" with a PIR exception

All Type C with a diameter>16" 20, 336 miles

Leakage Surveys and Repairs

§ § 192.703, 192.706 Diameter 8.625" through 16" with a PIR exception

All Type C with a diameter>16" 20, 336 miles

Maximum Allowable Operating

Pressure

§192.619 Diameter >12.75" through 16" with a PIR exception

All Type C with a diameter>16" 13,760 miles

Plastic Pipe Requirements Diameter >12.75" through 16" with a PIR exception

All Type C with a diameter>16" 13,760 miles



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