2137- 0622 Supporting_Statement 2021

Department of Transportation

Office of the Chief Information Officer

Supporting Statement

Pipeline Safety: Public Awareness Program

OMB Control No. 2137-0622

Introduction

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requests a renewal, without change, from the Office of Management and Budget (OMB) of an information collection entitled, “Pipeline Safety: Public Awareness Program,” OMB Control No. 2137-0622, which is currently due to expire on September 30, 2021.

Part A. Justification.

1. Circumstances that make collection of information necessary.

Current regulations require pipeline operators to develop and implement public awareness programs based on the provisions of the American Petroleum Institute’s (API’s) Recommended Practice RP-1162, Public Awareness Programs for Pipeline Operators.

Public awareness and understanding of pipeline operations is vital to the continued safe operation of pipelines. Pipeline operator public awareness programs are an important factor in establishing communications and providing information necessary to enhance public understanding of how pipelines function and the public’s role in promoting pipeline safety.

Upon request, operators must submit their completed programs to the Pipeline and Hazardous Materials Safety Administration (PHMSA) or, in the case of an intrastate pipeline facility operator, the appropriate State agency. The operator's program documentation and evaluation results must also be available for periodic review by appropriate regulatory agencies.

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

Natural gas and hazardous liquid pipeline operators must develop and implement a written continuing public education program that follows the guidance provided in the American Petroleum Institute's Recommended Practice (RP) 1162. Upon request, operators must submit their completed programs to PHMSA or, in the case of an intrastate pipeline facility operator, the appropriate State agency. The operator's program documentation and evaluation results must also be available for periodic review by appropriate regulatory agencies according to 49 CFR Parts 192.616 and 195.440.

This information will be used by PHMSA to evaluate compliance with the standards. Effective public awareness programs can increase awareness of the risks caused by unintentional pipeline releases and their impact on the public and the environment. Public awareness programs help outline the steps that can be taken to prevent or mitigate those risks. These programs can also improve excavation damage prevention, reduce encroachment on pipeline rights-of-way, improve pipeline safety, and enhance emergency response.

3. Extent of automated information collection.

The Government Paperwork Elimination Act directs agencies to allow the option of electronic filing and recordkeeping by October 2003, when practicable. PHMSA does not prohibit electronic maintenance of written procedures and filing when requested.

4. Efforts to identify duplication.

There is no duplication, as this recordkeeping activity is not required by any other source. Each operator system is unique. This information may not be derived from by any other source.

5. Efforts to minimize the burden on small businesses.

The American Public Gas Association has agreed to assist small gas distribution operators (who make up the bulk of small pipeline operators) in developing public education plans. PHMSA issued a final rule entitled “Pipeline Safety: Applicability of Public Awareness Regulations to Certain Gas Distribution Operators” (72 FR 70808; December 13, 2007). This final rule relaxed regulatory requirements governing public awareness programs conducted by operators of master meter systems and certain operators of petroleum gas systems. These operators typically manage property and incidentally provide gas service to customers located on the property. The change provided a less burdensome means for these operators to satisfy public awareness needs.

6. Impact of less frequent collection of information.

If this information were collected less frequently, PHMSA would unable to evaluate compliance with the pipeline safety standards.

7. Special circumstances.

There are no special circumstances that apply to this information collection. This collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

8. Compliance with 5 CFR 1320.8.

PHMSA published a 60-Day Notice in the Federal Register [86 FR 9568] on February 16, 2021. PHMSA received no comments pertaining to this information collection.

Additionally, PHMSA maintains an “open-door” policy with its stakeholders where continual engagement on ways to improve pipeline safety are routine. In this vein, PHMSA has participated in various discussions where updates on this information collection were provided. PHMSA included updates on this information collection in its regulatory updates presentation that is used to update stakeholders on the status of pending actions. PHMSA has taken all feedback received into consideration in the proposed adjustments.

9. Payments or gifts to respondents.

There is no payment or gift provided to respondents associated with this collection of information.

10. Assurance of confidentiality.

PHMSA does not have the authority to grant confidentiality.

11. Justification for collection of sensitive information.

Not applicable. No sensitive information is required.

12. Estimate of burden hours for information requested.

PHMSA estimates that there may be as many as 22,500 operators who are required to maintain the records for the program. Each operator requires as much as 23 hours per operator per year to comply with the requirement for an overall hourly burden of (22,500 x approximately 23 = 517,500). Assuming that each operator will review and update their public awareness program, annually, PHMSA estimates a total of 45,000 responses (2 responses for each of the 22,500 operators).

PHMSA estimates a cost of $62.75 per hour (average hourly wage) bringing the cost to each operator at $1,443.25 for 23 hours at $62.75 per hour (23 x 62.75= $1,443.25), and a total industry cost of $32,473,125.00 ($1443.25 X 22,500 = $32,473,125.00).

13. Estimate of total annual costs to respondents.

There is no additional cost to the respondents.

14. Estimate of cost to the Federal Government.

Currently, 100 Federal inspectors spend an estimated 10 percent of their time reviewing records retained by pipeline operators. The average salary of a Federal transportation inspector is $107,630. This calculates to an estimated annual cost to the Federal Government of:

100 (Federal inspectors) x $107,630 (mean salary) x 0.10 (time) = $1,076,300.

15. Explanation of program changes or adjustments.

There are no new information collection requirements.

16. Publication of results of data collection.

There are no plans for publication of this data.

17. Approval for not displaying the expiration date of OMB approval.

PHMSA intends to display the OMB Control Number and the approved expiration date.

18. Exceptions to certification statement.

There are no exceptions to PHMSA's certification of this request for information collection approval.