Snapshot: Pipeline Safety Rules

Size: px
Start display at page:

Download "Snapshot: Pipeline Safety Rules"

Transcription

1 Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY Phone: Fax: Snapshot: Pipeline Safety Rules Kenneth Simon Sara Orr Daniel Scripps Latham & Watkins LLP Latham & Watkins LLP Latham & Watkins LLP Law360, New York (October 06, 2011, 3:19 PM ET) The federal government is considering a number of potentially far reaching legislative and regulatory measures relating to pipeline safety. Heightened interest in strengthening pipeline safety laws and regulations results from a number of recent, highly publicized pipeline accidents, including a July 2011 spill of 42,000 gallons of oil into the Yellowstone River, a February 2011 natural gas explosion in Allentown, Pa., that led to five fatalities and extensive property damage, a September 2010 natural gas pipeline explosion in San Bruno, Calif., with eight fatalities and extensive property damage and a July 2010 spill of 843,000 gallons of oil in Michigan, among others. Proposed Legislation In April 2011, U.S. Department of Transportation Secretary Ray LaHood called on Congress to authorize the DOT to close what he termed as "regulatory loopholes" in the pipeline safety program and to strengthen the program by increasing the maximum civil penalties for pipeline violations, strengthening risk management requirements, adding more pipeline inspectors and improving data reporting to help with early identification of potential pipeline safety risks.[1] Congress has responded with a number of bills that address pipeline safety concerns[2] and would reauthorize the 2006 Pipeline Integrity, Protection, Enforcement and Safety (PIPES) Act,[3] which expired on Sept. 30, The legislation currently pending in the House of Representatives includes the Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011 (HR 2845), which was introduced by Congressman Bill Shuster, R Pa., and reported out of the House Committee on Transportation and Infrastructure on Sept. 8, In addition to reauthorizing federal pipeline safety programs, the legislation would provide tougher penalties for pipeline operators that violate pipeline safety laws; strengthen pipeline damage prevention measures; authorize the DOT to require automatic and remote controlled shut off valves on new pipelines; require the DOT to evaluate the effectiveness of expanding pipeline integrity management and leak detection requirements; and reform the process by which the DOT and pipeline operators

2 notify federal, state and local officials of pipeline accidents and provide information to the public and emergency responders. The other leading legislative proposal currently under consideration in the House is the Pipeline Infrastructure and Community Protection Act, sponsored by House Committee on Energy and Commerce Chairman Fred Upton, R Mich., and former Chairman John Dingell, D Mich., which won the support of the Energy and Commerce Committee on Sept. 21, While also reauthorizing the PIPES Act, this legislation goes further than the Transportation Committee s bill, and would expand the integrity management program, phase out class location requirements, and mandate the use of automatic and remote control shut off valves for new pipelines, as well as opening the door to require similar shut off valves on older pipelines. In addition, the legislation also grants the DOT s Pipeline and Hazardous Materials Safety Administration (PHMSA) authority to issue new leak detection requirements for pipelines located in high consequence areas. With the two House committees that share jurisdiction over pipelines having signed off on different legislative measures, the action now moves to the House floor, where legislative leadership is working to reconcile the proposals in anticipation of a vote later this year. In the Senate, the Pipeline Transportation Safety Improvement Act, cosponsored by Sen. Frank Lautenberg, D N.J., and Sen. Jay Rockefeller, D W. Va., mirrors many of the provisions of the Upton Dingell bill. The Lautenberg Rockefeller bill received unanimous support from the Senate Commerce, Science and Transportation Committee in May of this year and is currently pending on the Senate floor. Attempts by Senate leadership to move the legislation have been rebuffed, however, by "holds" placed by individual senators that impose additional procedural hurdles before the measure can be brought to a vote. With the hold preventing quick action on the legislation, it is unclear whether or when Senate leadership will move the measure to a floor vote.[4] Regulatory Developments While Congress is considering legislation, the PHMSA, the federal agency charged with monitoring the pipeline systems and enforcing safety measures, is proceeding with its own rulemaking processes to address safety issues for both oil and gas pipelines. On Oct. 18, 2010, the PHMSA issued an advance notice of proposed rulemaking on a range of topics relating to the safety of oil and other hazardous liquids pipelines.[5] Among other items, the advance notice of proposed rulemaking requested comment on whether to extend regulation to certain pipelines currently exempt from federal safety regulations; whether to extend integrity management regulations to additional pipeline segments or to include additional segments in high consequence areas; and whether to require emergency flow restricting devices and revise valve spacing requirements for new or existing pipelines. The deadline for comments was extended to Feb. 18, The PHMSA has not yet taken the next step of a issuing a proposed rule. More recently, the PHMSA issued an advance notice of proposed rulemaking on Aug. 25, 2011, to request comments on a number of similar proposed changes for natural gas transmission pipelines.[6] The PHMSA is requesting comments by Dec. 2, 2011, on various possible regulatory changes, including whether to modify integrity management requirements for pipeline segments in high consequence areas, whether to bring additional pipeline mileage under the integrity management program, and whether non integrity management requirements should be expanded to address other issues associated with pipeline system integration.

3 In addition to the legislative and regulatory efforts outlined above, the National Transportation Safety Board (NTSB), an independent federal investigative agency, issued a summary of an upcoming incident report that called for the strengthening of safety regulations and identified 13 recommended actions for the PHMSA, including a recommendation that the safety regulations cover pipelines that had been constructed before That recommendation, along with a number of others from the NTSB s report summary, overlap with the topics identified for consideration in the PHMSA s rulemaking process. The NTSB has no formal authority to regulate the transportation industry, and so its recommendations are not binding unless adopted by Congress, the PHMSA or others with such authority. This article summarizes the regulatory changes being considered by the PHMSA and the NTSB s recommendations. Members of the oil and natural gas pipeline and storage industry should consider responding to the PHMSA s request for comments and participate in any future rulemakings.[7] Existing Framework The federal government regulates oil and natural gas pipeline safety under a variety of laws and regulations.[8] Beginning with the Natural Gas Pipeline Safety Act of 1968,[9] in which Congress authorized the DOT to develop minimum safety standards for the transportation of natural gas, there have been a number of statutory and regulatory measures over the years designed to increase the safety of natural gas pipelines, as well as expanding the scope of those pipelines subject to federal safety requirements. Congress used the Natural Gas Pipeline Safety Act of 1968 as the model for the Hazardous Liquid Pipeline Safety Act of 1979, which authorized the DOT to develop minimum federal safety standards for the transportation of oil and other hazardous materials by pipeline. The Hazardous Liquid Pipeline Safety Act of 1979 has also been supplemented over time with legislation that, among other things, adds environmental considerations to the list of statutory factors that must be considered in developing safety regulations;[10] establishes safety standards for certain "regulated gathering lines";[11] adds special protection for pipelines in environmentally sensitive areas;[12] and extends regulation to low stress hazardous liquid pipelines.[13] Together, the Natural Gas Pipeline Safety Act of 1968, the Hazardous Liquid Pipeline Safety Act of 1979 and subsequent legislative developments are referred to as the pipeline safety laws,[14] and are administered by the PHMSA. The PHMSA and its predecessor agency, the Research and Special Projects Administration, have in turn promulgated regulations pursuant to the pipeline safety laws, which are known as the pipeline safety regulations.[15] These include recent rules such as the Distribution Integrity Management Final Rule, which was issued Dec. 4, 2009,[16] and extends the integrity management principles applicable to natural gas transmission pipelines to local distribution systems, which were previously not required to undertake integrity management programs, and a final rule issued May 5, 2011, which increases safety requirements for rural low stress hazardous liquid pipelines.[17] The PHMSA s Advance Notice of Proposed Rulemaking for Oil Pipelines In its October 2010 advance notice of proposed rulemaking involving on shore hazardous liquid pipelines, the PHMSA sought public input on six specific topics, including the scope of current pipeline safety requirements and whether exiting regulatory exemptions were appropriate; the criteria for designating areas as high consequence areas; repair criteria in areas falling outside of a high consequence area; leak detection and the use of emergency flow restricting devices; valve spacing; and ways to improve understanding and mitigation of threats stemming from stress corrosion cracking. Specifically, the PHMSA is considering changing the definition of a high consequence area to bring additional miles of pipeline under its requirements as well as potentially applying additional

4 requirements to pipeline segments lying outside of designated high consequence areas; requiring the use of emergency flow restricting devices, including remote controlled valves, in areas not currently subject to integrity management provisions; and adopting other measures relating to leak detection and prevention of stress control cracking. As mentioned above, the comment period for this advance notice of proposed rulemaking closed Feb. 18, 2011.[18] Should the PHMSA proceed to issue a formal proposed rule, the proposed regulatory changes would be subject to an additional comment period. The PHMSA s Advance Notice of Proposed Rulemaking for Gas Pipelines The PHMSA is also progressing with a proposed rulemaking to implement stricter safety measures for natural gas pipelines. In its Aug. 25, 2011, notice, the PHMSA solicits comments on a number of potential changes to the pipeline safety regulations, including changes that would extend the PHMSA s regulatory authority to pre 1970 pipelines, as well as requirements related to the integrity management program. 1) Non Integrity Management Requirements The PHMSA is currently seeking comment on a broad range of possible regulatory changes related to safety of natural gas pipelines. Among these, the most significant issues are whether the PHMSA should remove the current exemption for pipelines that were in operation prior to 1970; whether to establish safety requirements for underground natural gas storage; and whether to redefine "gathering lines" so as to increase the PHMSA s jurisdictional purview over these lines, as well as extending integrity management requirements to gathering lines. Pre 1970 Pipelines While gas transmission pipelines have been in use since the early 1920s, federal pipeline safety regulations did not take effect until Aug. 19, Because some of the pipelines in operation at that time were operating at higher maximum operating pressures than would have been allowed under the regulations, the DOT exempted those lines from the safety requirements and instead allowed pre 1970 lines to continue to operate at the highest actual operating pressure to which they were subjected in the five years prior to July 1, 1970.[19] These older pipelines are similarly exempt from subsequently adopted stress level regulations. Some of these same "grandfathered" pipelines are still in operation today.[20] The PHMSA is now considering eliminating these exemptions, repealing the regulatory provisions that allow for the use of older materials to repair these grandfathered pipelines, and considering additional IM and pressure testing requirements for pipeline segments that have not previously been tested. The PHMSA acknowledges that eliminating the exemptions for these older pipelines "would have the effect of requiring a reduction in the operating pressure for some older gas transmission pipelines."[21] Underground Natural Gas Storage The PHMSA is also seeking comment on whether to establish safety requirements applicable to underground natural gas storage facilities, which are not currently subject to PHMSA regulations. Specifically, the PHMSA is seeking comment on issues including whether the current lack of federal standards and preemption provisions in federal law preclude effective regulation of underground storage by individual states and whether it should develop federal standards to govern the safety of underground storage facilities and if so, whether the standards should be voluntary and what portions of facilities should be covered by any such standards.

5 Gathering Lines Similarly, the PHMSA is considering whether to expand its jurisdiction over gas gathering lines. PHMSA regulations currently require certain safety measures for certain defined gathering lines but not all gathering lines. In its notice, the PHMSA states that "[r]ecent developments in the field of gas exploration and production, such as shale gas, indicate that the existing framework for regulating gas gathering lines may no longer be appropriate."[22] As such, the PHMSA is now seeking comment on whether to adopt a new definition of the term "gathering line," as well as whether to impose new, risk based safety requirements on large diameter, high pressure gas gathering lines in rural locations and whether to impose IM requirements on gathering lines. Notably, PHMSA is also considering whether to adopt specific requirements for gathering lines associated with landfill gas systems, a development that has the potential to significantly alter the regulatory framework for these systems. Other topics under consideration include the adequacy of PHMSA regulations regarding the spacing and remote operational capabilities of block valves; the potential adoption of additional corrosion control requirements, including for stress corrosion cracking; and two "process" issues focused on how pipeline companies manage change and the adoption of quality management systems by industry participants. For each of these topics, the PHMSA is requesting information and supporting data on the potential costs of modifying existing regulatory requirements; the potential quantifiable safety and societal benefits; the potential impacts on small businesses; and the potential environmental impacts. 2) Integrity Management Requirements The PHMSA is also seeking comment on whether existing integrity management requirements should be strengthened to encompass additional natural gas pipeline mileage and to take steps to increase pipeline safety in high consequence areas, where the failure of a pipeline could have a significant impact on people or property, including areas of high population and areas where people regularly gather. The PHMSA seeks comment on whether to modify the definition of high consequence areas, including whether to expand the definition to subject additional pipeline segments to integrity management requirements. The PHMSA is also seeking comment on whether to add specificity to what is required of pipeline operators for areas within high consequence areas, as well as whether to expand these requirements to pipeline segments outside of high consequence areas. The current regulations require oil and gas transmission operators to take "additional measures" to prevent a pipeline failure in high consequence areas, as well as to take steps to mitigate the consequences of any potential failure in these areas, but do not currently specify what additional measures are required. Instead, operators are to base the additional measures on a comprehensive risk assessment for each pipeline segment (though the regulations do not contain any objective criteria to guide the determination of appropriate additional measures). In addition, following the issuance of an advisory bulletin on the requirements for collecting, validating and integrating pipeline data in January of this year,[23] the PHMSA is now considering "whether more prescriptive requirements for collecting, validating, integrating and reporting pipeline data [are] necessary,"[24] whether to mandate a particular risk assessment model, and whether to strengthen requirements on the functions risk models must perform. The PHMSA is also seeking comment on whether to extend existing repair requirements to pipelines outside of high consequence areas, as well as whether to revise its repair criteria to require an additional safety margin to failure and whether to update repair requirements to reflect technological advancements.

6 NTSB Recommendations The National Transportation Safety Board, which can only offer advice but not issue orders, has also recently weighed in on proposed changes to the pipeline safety regulatory regime, including issuing a number of recommendations that overlap with the issues contained in the PHMSA s notice. In a recent incident report, the NTSB outlines 13 specific recommendations for PHMSA. Specifically, the NTSB report summary includes recommendations that the PHMSA mandate the use of automatic shutoff and control valves; revoke the grandfathered status of older pipelines; require pressure tests for all pipelines and allow for other inspection and tests; and revise IM requirements. In addition, the NTSB also recommended that the PHMSA require pipeline operators to provide detailed information to the emergency response agencies of the communities in which those pipelines are located and to immediately notify emergency personnel in the event of possible pipeline ruptures; require pipeline operators to use tools to assist in recognizing and pinpointing the location of leaks; require drug and alcohol testing of all employees who were involved in accidents; and to work with state public utility commissions to assess the effectiveness of state oversight programs (and specifically, to assist the California Public Utilities Commission in conducting a comprehensive audit). The NTSB also made a number of recommendations for action to the U.S. transportation secretary, the governor of California, the California Public Utilities Commission, the Pacific Gas and Electric Company, the American Gas Association and the Interstate Natural Gas Association of America. Conclusion Taken together, the legislative and regulatory changes under consideration by the U.S. Congress and the PHMSA represent potentially sweeping changes to the scope of the federal government s regulatory authority over oil and natural gas pipelines, and, if adopted, could impose significant new regulatory requirements and associated costs on pipeline operators. Businesses engaged in the transportation of natural gas and oil and other hazardous liquids through pipelines, as well as the storage of natural gas in underground facilities, should carefully consider the potential impact these changes could have on their operations and consider active participation in the PHMSA s rulemaking process. Interested parties can submit comments in response to the PHMSA s natural gas notice by Dec. 2, 2011, and provide the agency with information on the potential cost impacts, quantifiable safety and societal benefits, potential impacts on small businesses and the potential environmental impacts associated with modifying the existing regulatory requirements. Following the close of the comment period, the PHMSA may next develop a proposed rule on some or all of the issues presented in the notice, a process that may not be completed before the 2012 elections. Once the proposed rule is published in the Federal Register, there will be a second comment period in which companies can provide additional information on the specific impacts of the proposed rule. This same process also applies to the issues contained in the October 2010 notice covering hazardous liquid pipeline safety. In developing final regulations for both oil and natural gas pipelines, the PHMSA must take into account the information obtained during the public comment period. By Kenneth M. Simon, Sara K. Orr and Daniel C. Scripps, Latham & Watkins LLP Kenneth Simon is a partner, and Sara Orr and Daniel Scripps are associates, in the Washington, D.C., office of Latham & Watkins.

7 The opinions expressed are those of the authors and do not necessarily reflect the views of the firm, its clients, or Portfolio Media, publisher of Law360. This article is for general information purposes and is not intended to be and should not be taken as legal advice. [1] See Press Release, "U.S. Transportation Secretary Ray LaHood Announces Pipeline Safety Action Plan" (April 4, 2011) available at [2] In addition, legislation has been introduced in California, which would require automatic or remote shutoff valves on natural gas transmission pipelines. This legislation, AB56, has passed the California Assembly and is pending in the state senate. [3] Public Law (2006). [4] A number of other legislative measures have also been introduced, including the Strengthening Pipeline Safety and Enforcement Act, co sponsored by Sen Dianne Feinstein, D Calif., and Sen. Barbara Boxer, D Calif.; the Pipeline Safety and Community Empowerment Act, introduced by Congresswoman Jackie Speier, D Calif.; and the Clean Rivers Act, cosponsored by Sen. Max Baucus, D Mont., and Senator Jon Tester, D Mont.). [5] Pipeline Safety: Safety of On Shore Hazardous Liquid Pipelines; Advance Notice of Proposed Rulemaking, 75 Fed. Reg. 63,774 (Oct. 18, 2010). [6] Pipeline Safety: Safety of Gas Transmission Pipelines; Advance Notice of Proposed Rulemaking, 76 Fed. Reg. 53,086 (Aug. 25, 2011) [7] The Docket Number for this Advanced Notice of Proposed Rulemaking is PHMSA [8] States have some authority to regulate the safety of intrastate pipelines, and at times enact standards more stringent than the federal standards. These state efforts, while important, are outside the scope of this article. [9] Public Law (1968). [10] Public Law (1992). [11] Id. [12] Public Law (1996). [13] Public Law (2006). [14] The pipeline safety laws are codified at 49 U.S.C et seq. [15] The pipeline safety regulations for both oil and natural gas pipelines are codified at 49 CFR parts [16] Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines; Final Rule, 74 Fed. Reg. 63,906 (Dec. 4, 2009). The requirements are codified at 49 C.F.R. part 192, Subpart P. [17] Pipeline Safety: Applying Safety Regulations to All Rural Onshore Hazardous Liquid Low Stress Lines; Final Rule, 76 Fed. Reg. 25,576 (May 5, 2011).

8 [18] This article does not purport to summarize the comments received by PHMSA relating to its advance notice of proposed rulemaking. [19] 49 C.F.R (a)(3). [20] According to a recent Wall Street Journal article, these pre 1970 pipelines comprise over 90 percent of the pipeline miles in operation for at least one major pipeline operator, and make up over 70 percent of the pipeline miles in at least ten different states. See Daniel Gilver, "Gas Pipeline Operators Sweat Test: Companies Question Effectiveness, Cost of Proposed Requirement to Examine Older Networks for Risk of Ruptures," The Wall Street Journal, Sept. 8, [21] Id. [22] Id. at 53,100. [23] Pipeline Safety: Establishing Maximum Allowable Operating Pressure or Maximum Operating Pressure Using Record Evidence, and Integrity Management Risk Identification, Assessment, Prevention, and Mitigation; Notices; Issuance of Advisory Bulletin, 76 Fed. Reg (Jan. 10, 2011). [24] 76 Fed. Reg. at 53,091. All Content , Portfolio Media, Inc.

1st Session Part 1 PIPELINE SAFETY, REGULATORY CERTAINTY, AND JOB CREATION ACT OF 2011

1st Session Part 1 PIPELINE SAFETY, REGULATORY CERTAINTY, AND JOB CREATION ACT OF 2011 112TH CONGRESS REPT. 112 297 " HOUSE OF REPRESENTATIVES! 1st Session Part 1 PIPELINE SAFETY, REGULATORY CERTAINTY, AND JOB CREATION ACT OF 2011 DECEMBER 1, 2011. Committed to the Committee of the Whole

More information

California Public Utilities Commission Risk Assessment Unit Hazard Database Project Report on Status and Initial Recommendations

California Public Utilities Commission Risk Assessment Unit Hazard Database Project Report on Status and Initial Recommendations California Public Utilities Commission Risk Assessment Unit Hazard Database Project Report on Status and Initial Recommendations March 14, 2012 I. Introduction The California Public Utilities Commission

More information

Compliance Inspections of Natural Gas Systems

Compliance Inspections of Natural Gas Systems Compliance Inspections of Natural Gas Systems Safety Regulations Applicable to Natural Gas Systems Who are these people and why are they calling me? Where do they get their authority? USC Section 60117

More information

Re: INGAA s Comments to OSHA s Request for Information concerning Process Safety Management

Re: INGAA s Comments to OSHA s Request for Information concerning Process Safety Management March 28, 2014 OSHA Docket Office Occupational Safety and Health Administration U.S. Department of Labor Room N-2625 200 Constitution Avenue NW Washington, DC 20210 Via electronic submission: www.regulations.gov

More information

Cybersecurity and Data Breach: Mitigating Risk and How Government Policymakers Approach These Critical Issues

Cybersecurity and Data Breach: Mitigating Risk and How Government Policymakers Approach These Critical Issues Cybersecurity and Data Breach: Mitigating Risk and How Government Policymakers Approach These Critical Issues Todd Bertoson Daniel Gibb Erin Sheppard Principal Senior Managing Associate Counsel todd.bertoson@dentons.com

More information

B-327192. July 28, 2015. The Honorable Orrin G. Hatch Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate

B-327192. July 28, 2015. The Honorable Orrin G. Hatch Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate 441 G St. N.W. Washington, DC 20548 B-327192 July 28, 2015 The Honorable Orrin G. Hatch The Honorable Ron Wyden Committee on Finance United States Senate The Honorable Lamar Alexander The Honorable Patty

More information

B-327450. October 29, 2015

B-327450. October 29, 2015 441 G St. N.W. Washington, DC 20548 B-327450 October 29, 2015 The Honorable Lamar Alexander Chairman The Honorable Patty Murray Ranking Member Committee on Health, Education, Labor, and Pensions United

More information

Hazardous Materials Transportation Act Reauthorization

Hazardous Materials Transportation Act Reauthorization Before the United States House of Representatives Committee on Transportation & Infrastructure Statement of William Downey Executive Vice President for Corporate Affairs & Chief Security Officer The Kenan

More information

PIPELINE FUNDAMENTALS. texaspipelines.com

PIPELINE FUNDAMENTALS. texaspipelines.com PIPELINE FUNDAMENTALS texaspipelines.com Texas Oil & Gas: Generating $2.6 Billion for State Revenues texaspipelines.com Texas Oil & Gas Texas produces 20% of US Domestic Oil Production 1.1 Million Barrels

More information

Loan Originator Compensation Requirements under the Truth In Lending Act

Loan Originator Compensation Requirements under the Truth In Lending Act BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB-2013-0013] RIN 3170-AA37 Loan Originator Compensation Requirements under the Truth In Lending Act (Regulation Z); Prohibition on

More information

APPENDIX J GAS DISTRIBUTION

APPENDIX J GAS DISTRIBUTION APPENDIX J GAS DISTRIBUTION Ji Jii APPENDIX J GAS DISTRIBUTION NEIL G. THOMPSON, PH.D. 1 SUMMARY The natural gas distribution system includes 2,785,000 km (1,730,000 mi) of relatively small-diameter, low-pressure

More information

Case 4:15-cv-00682 Document 1 Filed in TXSD on 03/13/15 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 4:15-cv-00682 Document 1 Filed in TXSD on 03/13/15 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:15-cv-00682 Document 1 Filed in TXSD on 03/13/15 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION AMERICAN FUEL & PETROCHEMICAL MANUFACTURERS, Plaintiff, Civil

More information

FEDERAL HAZMAT LAW TO LEARN MORE... Visit our website: http://hazmat.dot.gov

FEDERAL HAZMAT LAW TO LEARN MORE... Visit our website: http://hazmat.dot.gov TO LEARN MORE... For information about hazmat publications and other training materials: Visit our website: http://hazmat.dot.gov FEDERAL HAZMAT LAW Write: Office of Hazardous Materials Initiatives and

More information

2d Session 111 232 PUBLIC TRANSPORTATION SAFETY ACT OF 2010

2d Session 111 232 PUBLIC TRANSPORTATION SAFETY ACT OF 2010 111TH CONGRESS Calendar No. 480 REPORT " SENATE! 2d Session 111 232 PUBLIC TRANSPORTATION SAFETY ACT OF 2010 JULY 26, 2010. Ordered to be printed Mr. DODD, from the Committee on Banking, Housing and Urban

More information

B-322486. September 30, 2011

B-322486. September 30, 2011 United States Government Accountability Office Washington, DC 20548 B-322486 September 30, 2011 The Honorable Barbara Boxer Chairman The Honorable James M. Inhofe Ranking Member Committee on Environment

More information

FEDERAL RAILROAD SAFETY ACT OF 1970 1/

FEDERAL RAILROAD SAFETY ACT OF 1970 1/ FEDERAL RAILROAD SAFETY ACT OF 1970 1/ GENERAL This comprehensive law authorizes the Secretary of Transportation to prescribe regulations for all areas of railroad safety (supplementing existing rail safety

More information

Clean Air Act Amendments Legislative History Senate Report No. 101-228

Clean Air Act Amendments Legislative History Senate Report No. 101-228 Clean Air Act Amendments Legislative History Senate Report No. 101-228 Chemical Safety Board Subsection (e) of the new section 129 establishes an independent safety board, to be known as the Chemical Safety

More information

ELECTRONIC SIGNATURES IN GLOBAL AND NATIONAL COMMERCE ACT

ELECTRONIC SIGNATURES IN GLOBAL AND NATIONAL COMMERCE ACT ELECTRONIC SIGNATURES IN GLOBAL AND NATIONAL COMMERCE ACT LAWRENCE WALKER, ESQUIRE COZEN AND O CONNOR 1900 Market Street Philadelphia, PA 19103 (215) 665-2000 lwalker@cozen.com Atlanta, GA Charlotte, NC

More information

PROPANE EDUCATION AND RESEARCH COUNCIL, IOWA[599]

PROPANE EDUCATION AND RESEARCH COUNCIL, IOWA[599] IAC 7/2/08 Propane Education and Research[599] Analysis, p.1 PROPANE EDUCATION AND RESEARCH COUNCIL, IOWA[599] 1.1(101C) 1.2(101C) 1.3(101C) 1.4(101C) 1.5(101C) 1.6(101C) 1.7(101C) 1.8(101C) 1.9(101C)

More information

Structuring Oil and Gas Pipeline Projects: Key Issues and Key Contracts Involved

Structuring Oil and Gas Pipeline Projects: Key Issues and Key Contracts Involved Structuring Oil and Gas Pipeline Projects: Key Issues and Key Contracts Involved International Law Institute International Oil & Gas Development June 11-22, 2012 June 20, 2012 Vince Murchison Partner T

More information

Loan Originator Compensation Requirements under the Truth In Lending Act

Loan Originator Compensation Requirements under the Truth In Lending Act BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB-2013-0013] RIN 3170-AA37 Loan Originator Compensation Requirements under the Truth In Lending Act (Regulation Z); Prohibition on

More information

Asbestos School Hazard Abatement Reauthorization Act (ASHARA) of 1990

Asbestos School Hazard Abatement Reauthorization Act (ASHARA) of 1990 --S.1893-- S.1893 Asbestos School Hazard Abatement Reauthorization Act (ASHARA) of 1990 One Hundred First Congress of the United States of America AT THE SECOND SESSION Begun and held at the City of Washington

More information

A Guide to PHMSA s Proposed Rule Expanding Natural Gas Pipeline Safety Requirements

A Guide to PHMSA s Proposed Rule Expanding Natural Gas Pipeline Safety Requirements WHITE PAPER June 2016 A Guide to PHMSA s Proposed Rule Expanding Natural Gas Pipeline Safety Requirements In response to a 2010 pipeline safety incident in San Bruno, California, the U.S. Department of

More information

State and Territory Coastal Management Program Managers

State and Territory Coastal Management Program Managers MEMORANDUM FOR: FROM: SUBJECT: State and Territory Coastal Management Program Managers Jeffrey R. Benoit Director Final Program Change Guidance Attached is the Office of Ocean and Coastal Resource Management

More information

A. Introduction B. Background

A. Introduction B. Background 1700 G Street, N.W., Washington, DC 20552 CFPB Compliance Bulletin 2015-06 Date: November 23, 2015 Subject: Requirements for Consumer Authorizations for Preauthorized Electronic Fund Transfers A. Introduction

More information

THE SEC S NEW DODD-FRANK ADVISERS ACT RULEMAKING: AN ANALYSIS OF THE SEC S IMPLEMENTATION OF TITLE IV OF THE DODD-FRANK ACT

THE SEC S NEW DODD-FRANK ADVISERS ACT RULEMAKING: AN ANALYSIS OF THE SEC S IMPLEMENTATION OF TITLE IV OF THE DODD-FRANK ACT THE SEC S NEW DODD-FRANK ADVISERS ACT RULEMAKING: AN ANALYSIS OF THE SEC S IMPLEMENTATION OF TITLE IV OF THE DODD-FRANK ACT Kenneth W. Muller, Jay G. Baris and Seth Chertok* The Investment Advisers Act

More information

THE ATTORNEYS GENERAL OF NEW YORK, IOWA, MAINE, MARYLAND, OREGON AND WASHINGTON. March 16, 2015

THE ATTORNEYS GENERAL OF NEW YORK, IOWA, MAINE, MARYLAND, OREGON AND WASHINGTON. March 16, 2015 THE ATTORNEYS GENERAL OF NEW YORK, IOWA, MAINE, MARYLAND, OREGON AND WASHINGTON Honorable James M. Inhofe, Chairman Senate Committee on Environment and Public Works 410 Dirksen Senate Office Building Washington,

More information

HOW DO WE MEASURE SUCCESSFUL OVERSIGHT

HOW DO WE MEASURE SUCCESSFUL OVERSIGHT HOW DO WE MEASURE SUCCESSFUL OVERSIGHT PIPELINE SAFETY TRUST CONFERENCE NOVEMBER 22, 2013 Austin Yang, Deputy City Attorney San Francisco City Attorney s Office San Francisco s role as a safety advocate

More information

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Adopt Rules and Procedures Governing Commission- Regulated Natural Gas Pipelines and Facilities to Reduce

More information

Housing Bill Introduced to State Committee

Housing Bill Introduced to State Committee 110TH CONGRESS REPORT " HOUSE OF REPRESENTATIVES! 2nd Session 110 521 PUBLIC HOUSING ASSET MANAGEMENT IMPROVEMENT ACT OF 2007 JANUARY 29, 2008. Committed to the Committee of the Whole House on the State

More information

March 21, 2011. Dear Ranking Member Costello:

March 21, 2011. Dear Ranking Member Costello: U.S. Department of The Inspector General Office of Inspector General Transportation Washington, DC 20590 Office of the Secretary of Transportation March 21, 2011 The Honorable Jerry F. Costello Ranking

More information

THE STATE OF THE NATIONAL PIPELINE INFRASTRUCTURE

THE STATE OF THE NATIONAL PIPELINE INFRASTRUCTURE US DEPARTMENT OF TRANSPORTATION Introduction THE STATE OF THE NATIONAL PIPELINE INFRASTRUCTURE Over the past 70 plus years, a nationwide system of pipelines has been constructed to transport almost 100

More information

SURFACE TRANSPORTATION. DOT Is Progressing toward a Performance-Based Approach, but States and Grantees Report Potential Implementation Challenges

SURFACE TRANSPORTATION. DOT Is Progressing toward a Performance-Based Approach, but States and Grantees Report Potential Implementation Challenges United States Government Accountability Office Report to Congressional Addressees January 2015 SURFACE TRANSPORTATION DOT Is Progressing toward a Performance-Based Approach, but States and Grantees Report

More information

The CFPB's 'UDAAPification' Of Consumer Protection Law

The CFPB's 'UDAAPification' Of Consumer Protection Law Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com The CFPB's 'UDAAPification' Of Consumer Protection

More information

PURCHASE OF CERTAIN DEBT SECURITIES BY BUSINESS AND INDUSTRIAL DEVELOPMENT COMPANIES RELYING ON AN INVESTMENT COMPANY ACT EXEMPTION

PURCHASE OF CERTAIN DEBT SECURITIES BY BUSINESS AND INDUSTRIAL DEVELOPMENT COMPANIES RELYING ON AN INVESTMENT COMPANY ACT EXEMPTION SECURITIES AND EXCHANGE COMMISSION 17 CFR Part 270 Release No. IC-30268; File No. S7-07-11 RIN 3235-AL02 PURCHASE OF CERTAIN DEBT SECURITIES BY BUSINESS AND INDUSTRIAL DEVELOPMENT COMPANIES RELYING ON

More information

Jeffrey D. Wiese Associate Administrator for Pipeline Safety

Jeffrey D. Wiese Associate Administrator for Pipeline Safety U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration NOV 1 Z 2015 1200 New Jersey Ave, 5.E. Washington, D.C. 20590 VIA CERTIFIED MAIL AND FAX TO: 713-646-4378 Mr. Troy

More information

H. R. 5005 11 SEC. 201. DIRECTORATE FOR INFORMATION ANALYSIS AND INFRA STRUCTURE PROTECTION.

H. R. 5005 11 SEC. 201. DIRECTORATE FOR INFORMATION ANALYSIS AND INFRA STRUCTURE PROTECTION. H. R. 5005 11 (d) OTHER OFFICERS. To assist the Secretary in the performance of the Secretary s functions, there are the following officers, appointed by the President: (1) A Director of the Secret Service.

More information

ENVIRONMENTAL PROTECTION AGENCY. 40 CFR Part 70. [EPA-R02-OAR-2015-0837; FRL-9948-31-Region 2]

ENVIRONMENTAL PROTECTION AGENCY. 40 CFR Part 70. [EPA-R02-OAR-2015-0837; FRL-9948-31-Region 2] This document is scheduled to be published in the Federal Register on 06/24/2016 and available online at http://federalregister.gov/a/2016-15004, and on FDsys.gov 6560-50-P ENVIRONMENTAL PROTECTION AGENCY

More information

October 27, 2014. Docket No. CFPB-2014-0019, RIN 3170-AA10 Home Mortgage Disclosure (Regulation C)

October 27, 2014. Docket No. CFPB-2014-0019, RIN 3170-AA10 Home Mortgage Disclosure (Regulation C) October 27, 2014 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20006-4702 Monica Jackson Office of the Executive Secretary Consumer Financial

More information

FEDERAL GOVERNMENT OVERSIGHT OF PIPELINE SAFETY

FEDERAL GOVERNMENT OVERSIGHT OF PIPELINE SAFETY Operational Safety INTRODUCTION The Millennium Pipeline Company (Millennium) is proud of the key role it plays in New York s energy infrastructure. The Millennium Pipeline is a vital link in a system that

More information

Small Business Stationary Sources and Technical Assistance Programs by the EPA

Small Business Stationary Sources and Technical Assistance Programs by the EPA GUIDELINES FOR IMPLEMENTATION OF SECTION 507 OF THE 1990 CLEAN AIR ACT AMENDMENTS FINAL GUIDELINES U.S. EPA Office of Air Quality Planning and Standards Office of Air and Radiation Research Triangle Park,

More information

HIPAA/HITECH Rules Proposed: Major Changes Looming for Business Associates and Subcontractors

HIPAA/HITECH Rules Proposed: Major Changes Looming for Business Associates and Subcontractors Health Care ADVISORY July 16, 2010 HIPAA/HITECH Rules Proposed: Major Changes Looming for Business Associates and Subcontractors On July 8, 2010, the Office for Civil Rights (OCR) of the Department of

More information

FCC Dives Headfirst Into Privacy

FCC Dives Headfirst Into Privacy Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com FCC Dives Headfirst Into Privacy Law360, New York

More information

District of Columbia Municipal Regulations UNDERGROUND STORAGE TANKS: GENERAL PROVISIONS 5500 COMPLIANCE WITH OTHER DISTRICT LAWS

District of Columbia Municipal Regulations UNDERGROUND STORAGE TANKS: GENERAL PROVISIONS 5500 COMPLIANCE WITH OTHER DISTRICT LAWS CHAPTER 55 UNDERGROUND STORAGE TANKS: GENERAL PROVISIONS Section 5500 Compliance with Other District Laws 5501 Applicability of UST Regulations 5502 Partial Applicability of UST Regulations to Particular

More information

Office of Safety and Compliance

Office of Safety and Compliance The Federal Railroad Administration (FRA) was created by the Department of Transportation Act of 1966. It is one of ten agencies within the U.S. Department of Transportation concerned with intermodal transportation.

More information

ORNL/TM-2013/133 Review of Existing Federal and State Regulations for Gas and Hazardous Liquid Gathering Lines September 4, 2013 DOCUMENT AVAILABILITY Reports produced after January 1, 1996, are generally

More information

Public Law 104-284 104th Congress An Act

Public Law 104-284 104th Congress An Act 110 STAT. 3370 PUBLIC LAW 104-284 OCT. 11, 1996 Public Law 104-284 104th Congress An Act D t 11 iqqfi '. [H.R. 1514] Propane Education and Research Act of 1996 "^^ authorize and facilitate a program to

More information

Re: FINRA Regulatory Notice 13-42: FINRA Requests Comments on a Concept Proposal to Develop the Comprehensive Automated Risk Data System

Re: FINRA Regulatory Notice 13-42: FINRA Requests Comments on a Concept Proposal to Develop the Comprehensive Automated Risk Data System Ms. Marcia E. Asquith Office of the Corporate Secretary FINRA 1735 K Street, NW Washington, DC 20006 Re: FINRA Regulatory Notice 13-42: FINRA Requests Comments on a Concept Proposal to Develop the Comprehensive

More information

STATEMENT OF THE INVESTMENT COMPANY INSTITUTE ON THE U.S. COMMODITY FUTURES TRADING COMMISSION S APPROPRIATIONS FOR FISCAL YEAR 2016

STATEMENT OF THE INVESTMENT COMPANY INSTITUTE ON THE U.S. COMMODITY FUTURES TRADING COMMISSION S APPROPRIATIONS FOR FISCAL YEAR 2016 STATEMENT OF THE INVESTMENT COMPANY INSTITUTE ON THE U.S. COMMODITY FUTURES TRADING COMMISSION S APPROPRIATIONS FOR FISCAL YEAR 2016 Subcommittee on Agriculture, Rural Development, Food and Drug Administration,

More information

340B Omnibus Guidance Would Significantly Narrow the Pool of Eligible Patients

340B Omnibus Guidance Would Significantly Narrow the Pool of Eligible Patients White Paper August 31, 2015 340B Omnibus Guidance Would Significantly Narrow the Pool of Eligible Patients By Kristi V. Kung This client alert also was published as a bylined article on Law360 on September

More information

Ponti (HB 1048) Act No. 836. Louisiana State Plumbing Code as Promulgated by the Department of Health and Hospitals: Status and Changes

Ponti (HB 1048) Act No. 836. Louisiana State Plumbing Code as Promulgated by the Department of Health and Hospitals: Status and Changes Ponti (HB 1048) Act No. 836 Louisiana State Plumbing Code as Promulgated by the Department of Health and Hospitals: Status and Changes Prior law required the state health officer through the office of

More information

RESPONSE OF THE UTILITY AIR REGULATORY GROUP TO EPA S CONSIDERATIONS IN THE DESIGN OF A PROGRAM TO REDUCE CARBON POLLUTION FROM EXISTING POWER PLANTS

RESPONSE OF THE UTILITY AIR REGULATORY GROUP TO EPA S CONSIDERATIONS IN THE DESIGN OF A PROGRAM TO REDUCE CARBON POLLUTION FROM EXISTING POWER PLANTS Introduction RESPONSE OF THE UTILITY AIR REGULATORY GROUP TO EPA S CONSIDERATIONS IN THE DESIGN OF A PROGRAM TO REDUCE CARBON POLLUTION FROM EXISTING POWER PLANTS October 2013 On September 23, 2013, the

More information

Request for Information on Evolving Treasury Market Structure (Docket No. TREAS-DO-2015-0013)

Request for Information on Evolving Treasury Market Structure (Docket No. TREAS-DO-2015-0013) , 2016 VIA ONLINE SUBMISSION (http://regulations.gov) David R. Pearl Office of the Executive Secretary U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220 Re: Request for

More information

HAZARDOUS MATERIALS TRANSPORTATION ACT Act 138 of 1998. The People of the State of Michigan enact:

HAZARDOUS MATERIALS TRANSPORTATION ACT Act 138 of 1998. The People of the State of Michigan enact: HAZARDOUS MATERIALS TRANSPORTATION ACT Act 138 of 1998 AN ACT to regulate the transportation of certain hazardous materials; to prescribe the powers and duties of certain state agencies and officials;

More information

10 Important Aspects Of The CFTC Whistleblower Program

10 Important Aspects Of The CFTC Whistleblower Program Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com 10 Important Aspects Of The CFTC Whistleblower Program

More information

AGENCY: National Telecommunications and Information Administration, U.S. Department of

AGENCY: National Telecommunications and Information Administration, U.S. Department of This document is scheduled to be published in the Federal Register on 12/15/2015 and available online at http://federalregister.gov/a/2015-31516, and on FDsys.gov Billing Code: 3510-60-P DEPARTMENT OF

More information

Final Rule: Definitions of Transmittal of Funds and Funds Transfer

Final Rule: Definitions of Transmittal of Funds and Funds Transfer FEDERAL RESERVE SYSTEM Docket No. OP- 1445 DEPARTMENT OF THE TREASURY Financial Crimes Enforcement Network 31 CFR Part 1010 RIN 1506-AB20 Final Rule: Definitions of Transmittal of Funds and Funds Transfer

More information

NUCLEAR REGULATORY COMMISSION

NUCLEAR REGULATORY COMMISSION GAO United States Government Accountability Office Report to Congressional Requesters October 2012 NUCLEAR REGULATORY COMMISSION Oversight and Status of Implementing a Risk-Informed Approach to Fire Safety

More information

NHTSA s Oversight of Vehicle Safety Defects and Highway Safety Grants

NHTSA s Oversight of Vehicle Safety Defects and Highway Safety Grants Before the Commerce, Science, and Transportation Committee Subcommittee on Consumer Protection, Product Safety, and Insurance United States Senate For Release on Delivery Expected at 2:30 p.m. EST Tuesday

More information

Federal Medical Certification Recordkeeping Requirements for Motor Carriers Effective January 30, 2015

Federal Medical Certification Recordkeeping Requirements for Motor Carriers Effective January 30, 2015 Federal Medical Certification Recordkeeping Requirements for Motor Carriers Effective January 30, 2015 Effective January 30, 2015 federal regulations require motor carriers to have a printed CDL Abstract

More information

APGA SECURITY & INTEGRITY FOUNDATION OPERATIONS CONFERENCE

APGA SECURITY & INTEGRITY FOUNDATION OPERATIONS CONFERENCE APGA SECURITY & INTEGRITY FOUNDATION OPERATIONS CONFERENCE Gas NPRMs can be found here or linked on the PHMSA website PHMSA Website Locations for Regulatory Status Interpretations (Search by date or regulation)

More information

AGENCY: National Highway Traffic Safety Administration (NHTSA), Department of

AGENCY: National Highway Traffic Safety Administration (NHTSA), Department of This document is scheduled to be published in the Federal Register on 02/04/2016 and available online at http://federalregister.gov/a/2016-02101, and on FDsys.gov DEPARTMENT OF TRANSPORTATION National

More information

CRS Report for Congress

CRS Report for Congress Order Code RS20580 Updated December 28, 2000 CRS Report for Congress Received through the CRS Web Hazardous Materials Transportation Safety Federal Program and Legislative Issues Summary Paul F. Rothberg

More information

DEPARTMENT OF TRANSPORTATION

DEPARTMENT OF TRANSPORTATION This document is scheduled to be published in the Federal Register on 07/05/2016 and available online at http://federalregister.gov/a/2016-15798, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]

More information

Case 2:10-md-02179-CJB-SS Document 14206 Filed 02/19/15 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA * * * * * * * *

Case 2:10-md-02179-CJB-SS Document 14206 Filed 02/19/15 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA * * * * * * * * Case 2:10-md-02179-CJB-SS Document 14206 Filed 02/19/15 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA In re: Oil Spill by the Oil Rig Deepwater Horizon in the Gulf of Mexico, on

More information

Congress of the United States House of Representatives COMMITTEE ON ENERGY AND COMMERCE 2125 RAYBURN HOUSE OFFICE BUILDING WASHINGTON, DC 20515-6115

Congress of the United States House of Representatives COMMITTEE ON ENERGY AND COMMERCE 2125 RAYBURN HOUSE OFFICE BUILDING WASHINGTON, DC 20515-6115 FRED UPTON, MICHIGAN CHAIRMAN ONE HUNDRED FOURTEENTH CONGRESS Congress of the United States House of Representatives COMMITTEE ON ENERGY AND COMMERCE 2125 RAYBURN HOUSE OFFICE BUILDING WASHINGTON, DC 20515-6115

More information

ENERGY TRANSFER PARTNERS, L.P. PHMSA CRM and SCADA. Joe Schmid & Anil Pinto. Tuesday, April 29th, 2014

ENERGY TRANSFER PARTNERS, L.P. PHMSA CRM and SCADA. Joe Schmid & Anil Pinto. Tuesday, April 29th, 2014 ENERGY TRANSFER PARTNERS, L.P. PHMSA CRM and SCADA Joe Schmid & Anil Pinto Tuesday, April 29th, 2014 INTRODUCTION Energy Transfer is a Texas-based company that began as a small intrastate natural gas pipeline

More information

DEPARTMENT OF TRANSPORTATION. Hours of Service of Drivers: R&R Transportation Group; Application for Exemption

DEPARTMENT OF TRANSPORTATION. Hours of Service of Drivers: R&R Transportation Group; Application for Exemption This document is scheduled to be published in the Federal Register on 10/02/2015 and available online at http://federalregister.gov/a/2015-25132, and on FDsys.gov DEPARTMENT OF TRANSPORTATION [4910-EX-P]

More information

How To Reduce Lead Content In Plumbing

How To Reduce Lead Content In Plumbing An Overview of Regulations for Lead Levels in Drinking Water System Components An Overview of Regulations for Lead Levels in Drinking Water System Components Since the establishment of the federal Safe

More information

Before the FEDERAL TRADE COMMISSION Washington, DC 20580. In re Maricopa Community College District

Before the FEDERAL TRADE COMMISSION Washington, DC 20580. In re Maricopa Community College District Before the FEDERAL TRADE COMMISSION Washington, DC 20580 In the Matter of ) ) Maricopa County Community College District ) ) ) Complaint, Request for Investigation, Injunction, and Other Relief Submitted

More information

Re: Hawaii Certificate of Need Program Requirements for Air Ambulance Operators

Re: Hawaii Certificate of Need Program Requirements for Air Ambulance Operators U.S. Department GENERAL COUNSEL 400 Seventh St., S.W. of Transportation Washington, D.C.20590 Office of the Secretary of Transportation Gregory S. Walden Counsel for Pacific Wings, L.L.C. Patton Boggs

More information

November 2, 2015. By Electronic Transmission

November 2, 2015. By Electronic Transmission By Electronic Transmission Jennifer Shasky Calvery Director, Financial Crimes Enforcement Network U.S. Department of the Treasury P.O. Box 39 Vienna, VA 22183 Re: Docket Number FinCEN 2014-0003; RIN 1506-AB10

More information

BUREAU OF CONSUMER FINANCIAL PROTECTION. Request for Information Regarding Scope, Methods, and Data Sources for

BUREAU OF CONSUMER FINANCIAL PROTECTION. Request for Information Regarding Scope, Methods, and Data Sources for Billing Code: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION [Docket No. CFPB-2012-0017] Request for Information Regarding Scope, Methods, and Data Sources for Conducting Study of Pre-Dispute Arbitration

More information

B-327451. November 2, 2015. The Honorable Orrin G. Hatch Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate

B-327451. November 2, 2015. The Honorable Orrin G. Hatch Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate 441 G St. N.W. Washington, DC 20548 B-327451 November 2, 2015 The Honorable Orrin G. Hatch Chairman The Honorable Ron Wyden Committee on Finance United States Senate The Honorable Fred Upton Chairman The

More information

SUMMARY: The Securities and Exchange Commission (the Commission ) is adopting an

SUMMARY: The Securities and Exchange Commission (the Commission ) is adopting an SECURITIES AND EXCHANGE COMMISSION 17 CFR Part 201 Release Nos. 33-10104; 34-78156; IA-4437; IC-32162; File No. S7-11-16 Adjustments to Civil Monetary Penalty Amounts AGENCY: ACTION: Securities and Exchange

More information

Public Law 113 283 113th Congress An Act

Public Law 113 283 113th Congress An Act PUBLIC LAW 113 283 DEC. 18, 2014 128 STAT. 3073 Public Law 113 283 113th Congress An Act To amend chapter 35 of title 44, United States Code, to provide for reform to Federal information security. Be it

More information

Citizens Guide to Stopping LNG Pipelines on Private Land in Oregon

Citizens Guide to Stopping LNG Pipelines on Private Land in Oregon CitizensGuidetoStoppingLNGPipelines onprivatelandinoregon OregonLNGplanstobuildover85milesofhigh pressurenaturalgaspipelinetoconnectits proposedlngterminalalongthecolumbiariverinwarrentontoaninterconnectnear

More information

Securities and Futures & Derivatives Alert

Securities and Futures & Derivatives Alert Securities and Futures & Derivatives Alert April 25, 2013 SECURITIES SEC and CFTC Issue Identity Theft Red Flags Rules I. Introduction On April 10, 2013, the Securities and Exchange Commission (SEC) and

More information

Operations and Maintenance Procedures for Natural Gas Systems

Operations and Maintenance Procedures for Natural Gas Systems Operations and Maintenance Procedures for Natural Gas Systems Contact Information John West Transportation Specialist U.S. Department of Transportation PHMSA Office of Training and Qualifications Office

More information

COMMODITY FUTURES TRADING COMMISSION. AGENCY: Commodity Futures Trading Commission; Securities and Exchange

COMMODITY FUTURES TRADING COMMISSION. AGENCY: Commodity Futures Trading Commission; Securities and Exchange COMMODITY FUTURES TRADING COMMISSION SECURITIES AND EXCHANGE COMMISSION [Release No. 33-10062; 34-77506; File No. S7-05-16] RIN 3235- AL93 Certain Natural Gas and Electric Power Contracts AGENCY: Commodity

More information

Re: Freedom of Information Act Request for Records Relating to Borrower Defenses to Repayment of Student Loans. Background

Re: Freedom of Information Act Request for Records Relating to Borrower Defenses to Repayment of Student Loans. Background YISROEL SCHULMAN, ESQ. President & Attorney-in-Charge U.S. Department of Education Office of Management Regulatory Information Management Services 400 Maryland Avenue, SW, LBJ 2W220 Washington, DC 20202-4536

More information

ABOVE-GROUND STORAGE TANKS

ABOVE-GROUND STORAGE TANKS ABOVE-GROUND STORAGE TANKS Above-ground storage tanks in Georgia are regulated by the State Fire Marshall and by the EPA. Above-ground tanks containing 1,100 gallons or less do not require any secondary

More information

U.S. COMMODITY FUTURES TRADING COMMISSION

U.S. COMMODITY FUTURES TRADING COMMISSION U.S. COMMODITY FUTURES TRADING COMMISSION Three Lafayette Centre 1155 21st Street, NW, Washington, DC 20581 Telephone: (202) 418-5977 Facsimile: (202) 418-5407 gbarnett@cftc.gov Division of Swap Dealer

More information

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. 18 CFR Parts 365 and 366. (Docket No. RM05-32-000)

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. 18 CFR Parts 365 and 366. (Docket No. RM05-32-000) UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION 18 CFR Parts 365 and 366 (Docket No. RM05-32-000) Repeal of the Public Utility Holding Company Act of 1935 and Enactment of the Public Utility

More information

Registration of Municipal Advisors [Release No. 34-63576; File No. S7-45-10]

Registration of Municipal Advisors [Release No. 34-63576; File No. S7-45-10] 1001 PENNSYLVANIA AVE., NW SUITE 500 SOUTH WASHINGTON, DC 20004 TEL 202-289-4322 FAX 202-628-2507 E-Mail rich@fsround.org www.fsround.org February 22, 2011 RICHARD M. WHITING EXECUTIVE DIRECTOR AND GENERAL

More information

Abnormal Operating Conditions Emergency Plans and Public Awareness Plans for Natural Gas Systems

Abnormal Operating Conditions Emergency Plans and Public Awareness Plans for Natural Gas Systems Abnormal Operating Conditions Emergency Plans and Public Awareness Plans for Natural Gas Systems Contact Information John West Transportation Specialist U.S. Department of Transportation PHMSA Office of

More information

Homeland Security Alert

Homeland Security Alert November 2007 Authors: Barry M. Hartman 202.778.9338 barry.hartman@klgates.com Sandra Y. Snyder 973.848.4018 sandra.snyder@klgates.com K&L Gates comprises approximately 1,400 lawyers in 22 offices located

More information

August 23, 2002. Critical Air Medicine, Inc. Corporate Headquarters Attn: Sagi Kfir, Esq. General Counsel 4141 Kearny Villa Road San Diego, CA 92123

August 23, 2002. Critical Air Medicine, Inc. Corporate Headquarters Attn: Sagi Kfir, Esq. General Counsel 4141 Kearny Villa Road San Diego, CA 92123 August 23, 2002 Critical Air Medicine, Inc. Corporate Headquarters Attn: Sagi Kfir, Esq. General Counsel 4141 Kearny Villa Road San Diego, CA 92123 Re: City of Austin, Texas Ordinance - Cease and Desist

More information

NURSING HOME PENALTY CASH FUND

NURSING HOME PENALTY CASH FUND SUNSET REVIEW OF THE NURSING HOME PENALTY CASH FUND Submitted by Colorado Department of Regulatory Agencies June 1992 June 5, 1992 The Honorable Bob Schaffer Joint Sunrise/Sunset Review Committee Chairman

More information

AGENCY: Commodity Futures Trading Commission. SUMMARY: The Commodity Futures Trading Commission (Commission or CFTC) is

AGENCY: Commodity Futures Trading Commission. SUMMARY: The Commodity Futures Trading Commission (Commission or CFTC) is 6351-01-P COMMODITY FUTURES TRADING COMMISSION 17 CFR Part 30 Foreign Futures and Options Transactions AGENCY: Commodity Futures Trading Commission. ACTION: Order. SUMMARY: The Commodity Futures Trading

More information

MIDSTREAM DEVELOPMENT IN PENNSYLVANIA

MIDSTREAM DEVELOPMENT IN PENNSYLVANIA MIDSTREAM DEVELOPMENT IN PENNSYLVANIA Midstream infrastructure consists of pipelines, processing facilities, compressor stations, and related infrastructure for transporting natural gas from well sites

More information

Summary. Background and Justification

Summary. Background and Justification Supporting Statement for the Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation YY (Enhanced Prudential Standards) (Reg YY; OMB No. 7100-0350) Annual Company-Run Stress Test

More information

1st Session 114 72 CONTRACTING AND TAX ACCOUNTABILITY ACT OF 2015

1st Session 114 72 CONTRACTING AND TAX ACCOUNTABILITY ACT OF 2015 114TH CONGRESS REPORT " HOUSE OF REPRESENTATIVES! 1st Session 114 72 CONTRACTING AND TAX ACCOUNTABILITY ACT OF 2015 APRIL 14, 2015. Committed to the Committee of the Whole House on the State of the Union

More information

Salaries of Members of Congress: Congressional Votes, 1990-2010

Salaries of Members of Congress: Congressional Votes, 1990-2010 Salaries of Members of Congress: Congressional Votes, 1990-2010 Ida A. Brudnick Analyst on the Congress February 9, 2011 Congressional Research Service CRS Report for Congress Prepared for Members and

More information

November 30, 2015. Docket No. DHS 2014-0016 -- Chemical Facility Anti-Terrorism Standards (CFATS) Appendix A. To Whom It May Concern:

November 30, 2015. Docket No. DHS 2014-0016 -- Chemical Facility Anti-Terrorism Standards (CFATS) Appendix A. To Whom It May Concern: American Fuel & Petrochemical Manufacturers November 30, 2015 1667 K Street, NW Suite 700 Washington, DC 20006 202.457.0480 office 202.552.8461 direct 202.457.0486 fax Department of Homeland Security National

More information

Mortgage Disclosure Act And Multifamily Lending: Part 1

Mortgage Disclosure Act And Multifamily Lending: Part 1 Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Mortgage Disclosure Act And Multifamily Lending:

More information

FS Regulatory Brief SEC Proposes Amendments to Broker- Dealer Financial Reporting Rule

FS Regulatory Brief SEC Proposes Amendments to Broker- Dealer Financial Reporting Rule SEC Proposes Amendments to Broker- Dealer Financial Reporting Rule Amendments call for brokerdealers assertion of compliance with the Financial Responsibility Rules, new reviews by independent auditors,

More information

TITLE 29: EMERGENCY SERVICES, DISASTERS, AND CIVIL DEFENSE CHAPTER I: EMERGENCY MANAGEMENT AGENCY SUBCHAPTER d: STATE EMERGENCY RESPONSE

TITLE 29: EMERGENCY SERVICES, DISASTERS, AND CIVIL DEFENSE CHAPTER I: EMERGENCY MANAGEMENT AGENCY SUBCHAPTER d: STATE EMERGENCY RESPONSE TITLE 29: EMERGENCY SERVICES, DISASTERS, AND CIVIL DEFENSE CHAPTER I: EMERGENCY MANAGEMENT AGENCY SUBCHAPTER d: STATE EMERGENCY RESPONSE PART 430 EMERGENCY AND WRITTEN NOTIFICATION OF AN INCIDENT OR ACCIDENT

More information

June 14, 2011. Congressional Committees. Subject: Private Health Insurance: Waivers of Restrictions on Annual Limits on Health Benefits

June 14, 2011. Congressional Committees. Subject: Private Health Insurance: Waivers of Restrictions on Annual Limits on Health Benefits United States Government Accountability Office Washington, DC 20548 June 14, 2011 Congressional Committees Subject: Private Health Insurance: Waivers of Restrictions on Annual Limits on Health Benefits

More information

SUMMARY: This rule implements provisions of the National Defense Authorization

SUMMARY: This rule implements provisions of the National Defense Authorization Billing Code: 8025-01 SMALL BUSINESS ADMINISTRATION 13 CFR Part 121 RIN: 3245-AG59 Advisory Small Business Size Decisions AGENCY: Small Business Administration. ACTION: Final rule. SUMMARY: This rule implements

More information