The nation needs oil and gas pipelines. That's why you need us.

World demand for oil and natural gas has never been higher. In supplying the world's energy needs, pipeline companies face unprecedented environmental and regulatory challenges. As the country expands its energy infrastructure, the safe and reliable delivery of oil and gas via the nation's pipelines has come under intense scrutiny.

The Hunton & Williams pipeline practice has national experience resolving the environmental and enforcement issues that arise during the construction, permitting, operation and maintenance of oil and gas pipelines. Leveraging the talent and experience of more than 75 environmental lawyers, and strong working relationships with the federal and state agencies that regulate pipeline activities, Hunton & Williams addresses its clients' evolving legal and business needs as efficiently and effectively as possible.

What's New

• August 23, 2010: Comments due to PHMSA on Notice of Proposed Rulemaking regarding Low-Stress Liquid Pipelines
  On June 22, 2010, PHMSA issued a Notice of Proposed Rulemaking that seeks to amend existing pipeline safety regulations at 49 C.F.R. Part 195 to make them applicable to all low-stress hazardous liquid pipelines. PHMSA takes the position that the Pipeline Inspection, Protection, Safety, and Enforcement (PIPES) Act of 2006 mandated that PHMSA subject low-stress hazardous liquid pipelines to the same standards and regulations as other hazardous liquid pipelines. Comments are due on August 23, 2010. See 75 Fed. Reg. 35366
• July 28, 2010: Part 194 Updated Spill Response Plans Due to PHMSA
  On June 28, 2010, in response to the Gulf oil spill, PHMSA issued an Advisory Bulletin to all liquid pipeline operators, requring operators to review and, if necessary, revise and update their spill response plans. Such plans are required under 49 C.F.R. Part 194 (DOT's implementation of OPA-90 spill response requirements). PHMSA notes that in addition to submitting updated plans to the Agency, copies of plans must be maintained at field facilities, and it is expected that PHMSA will ask for them during audits. See 75 Fed. Reg. 36773
• July 20: 2010: Homeland Security Alert for Malicious SCADA Virus
  A new virus specifically aimed at SCADA systems has been discovered. The virus works on the Microsoft platform, and Siemens' SCADA software appears particularly vulnerable. Pipeline operators are encouraged to contact Microsoft, or Siemens, for advice on investigation and fixes. The Department of Homeland Security encourages all operators of SCADA systems to be vigilant in securing their systems from these kind of attacks.
• June 30, 2010: EPA and Coast Guard Suspend Spill Response Times for Some Operators
  EPA and the Coast Guard issue an emergency interim rule suspending oil spill response times and response contractor obligations, but only for those operators who have actually sent resources to support the Gulf spill. Notably, the emergency rule omitted OPS in its coverage, making the suspension of less utility to pipeline operators. See 75 Fed. Reg. 37712
• Reauthorization of Pipeline Safety Act
  Congressional funding for PHMSA must be reviewed and renewed every four years, which typically results in some legislative amendments as part of reauthorization. The last reauthorization was in 2006 (PIPES Act), thus 2010 is a reauthorization year. The first Congressional hearings on reauthorization began in the House on May 24 (notably after the Gulf spill occurred). Although Congress is focused on applying 'lessons learned' from the Gulf spill to the pipeline industry, even citizen watchdogs have commented that PHMSA is 'a very different organization than the MMS', and the pipeline industry has made significant improvements in its safety record over the past 10 years (statement of Carl Weimer, Pipeline Safety Trust, before the House Transportation & Infrastructure Cmte, May 24, 2010).
  
  Several Congressional hearings on PSA reauthorization have been held from May through July, 2010. A final bill is expected no sooner than end of this year.