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On behalf of the States First Initiative, the Interstate Oil and Gas Compact Commission (IOGCC) and the Ground Water Protection Council (GWPC), submitted comments this week on PHMSA's planned Interim Final Rule (IFR) on natural gas storage.
The comments recommended the adoption in the IFR of American Petroleum Institute's Recommended Practices 1170 and 1171, and encouraged PHMSA to consider recommendations in the recently completed guidance States First document "Underground Gas Storage Regulatory Considerations."
In a letter submitted with the comments, the States First Initiative stated the purpose of the comments was to highlight the gaps in the coverages of the recommended practices with respect to key issues for regulating the life cycle and full scope of gas storage projects, and to point out areas where a provision from the Recommended Practices would be difficult for PHMSA to implement as a regulation – for example, because of vagueness, ambiguity, or insufficient detail.
The States First Initiative, led by states from across the country, has been a leader in proactively progressing state natural gas storage programs and addressing regulatory challenges. A national Gas Storage Work Group was developed in March 2016 to collect information from participating states. The work group released the report "Underground Gas Storage Regulatory Considerations: A Guide for State Regulatory Agencies" in May of 2017.
The report is available here: Download Gas Storage Regulatory Considerations Report