PHMSA Final Rule on Class Location Changes for Gas Transmission Pipelines

Introduction:
On January 14, 2026, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule codifying a new compliance option for operators affected by class location changes on gas transmission pipelines. This rule marks a significant shift in how operators may address increased population density near pipelines, enabling continued operation without automatic MAOP reductions or pipe replacement—provided stringent conditions are met. This rule becomes effective on March 16, 2026.

Background:
Historically, when population growth along a pipeline segment triggered a class location change as defined under 49 CFR § 192.5, operators faced limited and often operationally challenging compliance options. These included:

• Reducing the segment's maximum allowable operating pressure (MAOP) to meet the safety factors for the revised class location.
• Performing a new pressure test, which frequently required taking the pipeline out of service.
• Replacing the affected pipe with higher-grade or thicker-wall material.

These legacy options often proved impractical—particularly in constrained systems where downtime or pressure reductions would compromise system capacity or reliability. To mitigate such constraints, PHMSA previously allowed class location special permits - on a case-by-case basis, contingent upon documented material and pressure test records and application of Integrity Management (IM) principles.

Since 2004, PHMSA has issued 46 such permits—with no reported leaks or ruptures on affected segments—underscoring the viability of an IM-based alternative.

New Rule Overview:
The final rule formalizes an Integrity Management-based compliance option, eliminating the need for special permits in certain scenarios. Under this alternative:

• Operators may confirm or restore MAOP in Class 3 locations if pipe operates at ≤72% specified minimum yield strength (SMYS) and is in-line inspection (ILI)-capable.
• The segment must have a pressure test record of at least 1.25x MAOP, with traceable, verifiable, and complete (TVC) documentation.
• Bare pipe, pipe with ineffective coating, wrinkle bends, certain longitudinal seam issues, or pipe lacking adequate (TVC) material/test documentation is ineligible.

Implications for Previously Adjusted Segments:
Operators that previously reduced MAOP or operated under special permits may now elect this Integrity Management alternative. For MAOP restoration under § 192.611(d):

• A design and operations review is required per § 192.555(b)(1) and (2).
• All initial Integrity Management steps must be complete, including:
  • Baseline assessment and remediation of anomalies.
  • Fulfillment of § 192.611(a)(4)(i) programmatic requirements.
  • Compliance with § 192.917(e)(3)–(4) regarding threat identification and remedial actions.

MAOP may then be restored incrementally under § 192.555(e)—either in 10% steps or 25% of the total increase, whichever requires fewer increments.

Regulatory Boundaries:
While MAOP may be restored to previously established levels, the following limits apply:

• ≤72% SMYS for Class 1 design pipe.
• ≤60% SMYS for Class 2 design pipe.

Summary and Operator Guidance:
The final rule provides a clearly defined, permanently available path for eligible operators to retain or restore MAOP following class location changes, provided they can meet stringent assessment, testing, and documentation standards. Importantly, the rule affirms Integrity Management as a viable compliance strategy—not only to maintain regulatory alignment, but also to preserve system capacity in growing regions.

Operators should carefully evaluate pipeline segment eligibility, documentation integrity, and prior MAOP reductions to determine if this new compliance path is applicable.

If you or your team need help navigating this piece of regulation, we have experts on staff ready to help you align to this potential change. Contact us today.

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