2137-0594 Supporting Statement2008

Department of Transportation

Office of the Chief Information Officer

Supporting Statement

Customer-Owned Service Lines

OMB Control No. 2137-0594

INTRODUCTION

This is to request the Office of Management and Budget’s (OMB) renewed three-year approved clearance for the information collection entitled, “Customer-Owned Service Lines” (OMB Control No. 2137-0594, which is currently due to expire on November 30, 2008.

Part A. Justification.

1. Circumstances that make collection of information necessary.

The mandate in 49 U.S.C. 60113 requires the Secretary of Transportation to issue regulations requiring operators of natural gas distribution pipelines that do not maintain customer-owned service lines up to building walls to advise their customers of the requirements for maintenance of those lines, any resources known to the operator that could assist customers in maintaining the lines, information the operator has concerning the operation and maintenance of its lines that could aid customers, and the potential hazards of not maintaining the lines.

This information collection request supports DOT’s safety performance goal of reducing total incidents for gas and hazardous liquid pipelines which directly supports the DOT’s safety strategic objective of enhancing public health and safety by working toward the elimination of transportation-related deaths and injuries.

Current Federal gas pipeline safety standards do not require operators to maintain customer piping that lies downstream from regulated service lines. In many cases, the customer is not aware the operator is not responsible for the maintenance of piping or what those maintenance responsibilities are. To address these concerns and a statutory mandate, the Office of Pipeline Safety (OPS) established notification requirements in 49 CFR 192.16.

This information collection request requires that operators of gas service lines who do not maintain their customers’ buried piping between service lines and building walls or gas utilization equipment to send written notices to their customers of the proper maintenance of these gas lines and of the potential hazards of not properly maintaining these gas lines. Operators also have to maintain records that include a copy of the notice currently in use and evidence that notices were sent to customers within the previous 3 years.

2. How, by whom, and for what purpose is the information used.

The written notice referenced under Item 1 of this Supporting Statement, goes to each customer receiving gas at a particular location. It is used to make them aware of the need to maintain buried customer piping to avoid accidents. OPS and State authorities review operators’ records to investigate compliance with the notification requirement.

3. Extent of automated information collection.

Operators are permitted to use any method to send written notices and maintain records. They may use the latest information technology to reduce the additional burden. The operators do not submit any information to OPS but maintain records that include a copy of the notice currently in use and evidence that notices were sent to customers within the previous 3 years. There are no legal obstacles to reducing the burden if the operators choose to keep record electronically.

4. Efforts to identify duplication.

These requirements do not duplicate any other information collection burden for gas pipeline operators. There are no Federal pipeline safety standards which could be modified for the intended purpose. However, if a gas pipeline operator has a similar voluntary program in place, the operator may modify that program to meet the Federal regulations.

5. Efforts to minimize the burden on small businesses.

The small entities predominately affected are operators of gas distribution systems serving fewer than 10,000 customers. Most of these small entities operate master meter systems. Master meter systems, as defined in 49 CFR 191.3, are pipeline systems for distributing gas within, but not limited to, a definable area, such as a mobile park, housing project, or apartment complex, where the operator purchases metered gas from an outside source for resale through a gas distribution system. The gas distribution pipeline system supplies the ultimate consumer who either purchases the gas directly through a meter or by other means, such as by the rents.

To reduce the burden on small entities, the rule allows master meter operators to post a general notice in a predominant location frequented by customers.

6. Impact of less frequent collection of information.

The frequency for sending the notices is one time for each customer at a particular location. This information could not be sent less frequently.

7. Special circumstances.

No special circumstances exist in this collection.

8. Compliance with 5 CFR 1320.8.

A 60-day Federal Register Notice was published on May 22, 2008 (73 FR 29846). No comments were received regarding this information collection. A 30-day Federal Register Notice was published on September 10, 2008 (73 FR 52722).

9. Payments or gifts to respondents.

There is no remuneration provided.

10. Assurance of confidentiality.

The information collection requirements do not include anything of a sensitive nature or any matters considered private.

11. Justification for collection of sensitive information.

The information requested is not sensitive in nature.

12. Estimate of burden hours for information requested.

In order to comply with this rule, operators had to notify all their affected customers before August 14, 1996. Thereafter they have to notify each new customer at a particular location. Operators who maintain customers’ buried piping up to building walls or gas utilization equipment, either voluntarily or under a state or local mandate, are exempt.

Several states currently require operators to maintain customer-owned lines downstream from regulated service lines. For example, Kansas, as a result of 5 incidents on customer-owned service lines during 1988-89 and a subsequent National Transportation Safety Board recommendation, requires such maintenance. Other states, such as New York, Missouri and Michigan, have similar requirements. As a consequence, these operators, as well as any operators that voluntarily maintain customer-owned lines downstream from regulated service lines, will incur no additional cost for this regulation.

As a result of 2 surveys done in 1991, OPS estimated there are approximately 5.5 million buried customer-owned lines downstream from regulated service lines (excluding the states mentioned above) in the United States.

The 5.5 million estimate does not include farm taps. Farm taps are customer-owned lines that supply gas to farms from gathering or transmission lines. While OPS does not have specific numbers of farm taps, OPS believes they represent only a small percentage of the total number of customers’ buried lines. Therefore, regulating farm taps adds only minimal costs to the requirement.

OPS has examined customer notifications used under 49 CFR 192.16. Typically a standard 2-sided typed information sheet provides adequate notification to customers.

According to OPS data, there are approximately 1,540 natural gas distribution operators. These operators can be broken down into three categories: 1,280 small operators with less than 10,000 customers; 234 moderate operators with 10,000 customers; and 26 large operators that account for over 46 million of the 53.5 million gas services in the United States.

OPS estimates that approximately 10 percent of customers with buried piping downstream from regulated service lines will move annually, requiring 550,000 notifications yearly. It is assumed that the cost of copying a notification letter is estimated to be 10 cents per notice (the cost of developing the notice will be minimal as generic notifications will be available), the annual recurring cost due to customers moving is $55,000 annually (5,500,000 X .1 = 550,000 X $.1 = $55,000).

It is assumed that the time to add this insert for each customer is approximately 1 minute the total hour burden is (550,000 * 1 minute) or 9,167 each year.

Given the recordkeeping requirements in §§ 192.16(d) and 192.383(e):

§ 192.16(d) Each operator must make the following records available for inspection by the Administrator or a State agency participating under 49 U.S.C. 60105 or 60106:

(1) A copy of the notice currently in use; and

(2) Evidence that notices have been sent to customers within the previous 3 years.

§ 192.383(e) What records are required. (1) An operator must make the following records available for inspection by the Administrator or a State agency participating under 49 U.S.C. 60105 or 60106:

(i) A copy of the notice currently in use; and

(ii) Evidence that notice has been sent to the service line customers set forth in paragraph (b) of this section, within the previous three years.

Therefore, the time to add this insert for each customer is estimated to be approximately 1 minute the total hour burden is (550,000 * 1 minute) or 9,167 hour each year.

The annual total burden hour is estimated to be 9,167.

13. Estimate of total annual costs to respondents.

There are no additional costs beyond the paperwork expenses stated under item 12.

14. Estimate of cost to the Federal government.

Costs to the Federal Government are minimal. Reviewing operators’ records to ensure that the notice contains the appropriate material and is being sent out as required is done during routine operator inspections and takes very little time.

15. Explanation of program changes or adjustments.

There is no change in burden due to the renewal of this information collection.

16. Publication of results of data collection.

The information will not be published for statistical purposes.

17. Approval for not explaining the expiration date for OMB approval.

OPS is not seeking such approval.

18. Exceptions to certification statement:

There is no exception.

Part B. Collections of Information Employing Statistical Methods.

This information collection does not employ statistical methods.

1. Describe potential respondent universe and any sampling selection method to be used.

There is no potential respondent universe or any sampling selection method being used.

2. Describe procedures for collecting information, including statistical methodology for stratification and sample selection, estimation procedures, degree of accuracy needed, and less than annual periodic data cycles.

There are no procedures for collecting information, including statistical methodology for stratification and sample selection, estimation procedures, degree of accuracy needed, and less than annual periodic data cycles.

3. Describe methods to maximize response rate.

There are no methods to maximize the response rate.

4. Describe tests of procedures or methods.

There are no tests of procedures or methods.

5. Provide name and telephone number of individuals who were consulted on statistical aspects of the information collection and who will actually collect and/or analyze the information.

There were no individuals consulted on statistical aspects of this information collection.

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