Joaquin J. Affones - Comments

Consumers Energy supports: 1) The change in 192.121 to raise the design factor for PA-11 pipe in sizes up to 4 inch with a SDR of 11. 2) The change to 192.123 to allow PA-11 a design pressure limit of 200 psig for SDR 11 and sizes up to 4 inch in class 3 & 4 locations. Consumers Energy does not support: 3) The last paragraph of the proposed rule change for 192.123 (f) (4). This change requires PA-11 pipe installations with design pressures above 100 psig and also following the other requirements of 192.121 & 192.123 to be buried with a warning tape or other device sufficient to warn an excavator of the presence of a high pressure gas line near the tape or other device before reaching the burial depth of the pipeline. Installation of a tape would require a second stage backfill which is costly and separation between the tape and the pipe may be difficult to maintain. Other devices are not identified but might include pipeline markers for high pressure plastic pipe even in class 3 & 4 locations. Neither of these requirements is acceptable. Strengthening damage prevention programs and excavator awareness training is an acceptable alternative.