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PIPA Recommended Practice BL12

BL12 "Notify Stakeholders of Right-of-Way Maintenance Activities"

Practice Statement Transmission pipeline operators should notify affected stakeholders of right-of-way maintenance activities, including vegetation management.

Audience(s): Transmission Pipeline Operator

Practice Description

After a transmission pipeline is installed, the pipeline right-of-way (ROW) must be maintained by the pipeline operator to allow for inspection of surface conditions as required by federal law. The transmission pipeline operator must maintain the ROW vegetation so that it will not hinder pipeline inspection and maintenance activities. Extensive landscaping or other obstructions can block the view of and impede the operator's access to the pipeline.

Prior to implementing ROW maintenance activities, the pipeline operator should make a reasonable effort to contact the affected stakeholders and provide an explanation regarding the need for vegetation management activities. This should include a discussion of the rights granted under easements for the pipeline operator to maintain the ROW, and the anticipated start and completion dates for the maintenance activities. Timely notification should be provided to the affected stakeholder. Notification may take place via methods such as mailed letters, door hangers, phone calls, or face-to-face contacts, depending on the location and situation.

Re-establishing a right-of-way that has not been previously maintained may require additional advance communications between the property owner and the transmission pipeline operator prior to initiating the activity.

Following is a discussion regarding the bases for maintaining the ROW. The transmission pipeline operator may want to include a discussion of these bases in its communication with affected stakeholders.

The transmission pipeline right-of-way must be maintained in order to facilitate the identification of surface conditions such as:

  • Unauthorized activities on or near the right-of way
  • Heavy equipment on the right-of-way without authorization
  • Urban encroachment
  • Construction activities on or near the right-of-way
  • Soil defects
  • Erosion at water crossings, flooding on the right-of-way or sedimentation in streams
  • Damage to company property
  • Missing or moved aerial markers, pipeline line markers or identification signs
  • Evidence of leaking gas or liquid

A transmission pipeline ROW that is adequately maintained free of obstructions is an important visual indicator of the existence of transmission pipeline facilities for anyone performing construction or other work near the pipeline. Third-party incidents are a leading cause of damage to transmission pipelines and often occur when excavation or other construction activity occurs near the pipeline and the pipe is accidentally struck.

If pipeline damage occurs, the pipeline operator may need direct and immediate access to the pipeline and this will be facilitated by an adequately maintained ROW. In the event of an emergency, a clear ROW is necessary to facilitate access by both the pipeline operator and emergency response personnel. Obstructions on the ROW can prohibit their ability to respond.

A clear ROW makes conducting inspections, often performed via aerial patrol, more efficient and effective. Other methods of inspecting transmission pipelines, such as vehicle and foot patrols, also require a clear ROW.

A clear ROW enables the transmission pipeline operator to conduct inspections and testing to verify pipeline integrity and to perform general maintenance and repairs as needed. According to pipeline safety regulations, transmission pipeline operators must have a patrol program to inspect and observe surface conditions on and adjacent to the transmission line right-of-way for indications of leaks, construction activity, and other factors affecting safety and operation. While an operator may choose to perform inspections more frequently, hazardous liquid transmission pipeline operators must inspect 26 times a year at an interval that does not exceed 21 days. Natural gas transmission pipeline operators must inspect 1 to 4 times a year at an interval that does not exceed 4.5 to 15 months, depending on the population density near the pipeline. The pipeline ROW should be maintained at a frequency that allows the operator to inspect surface conditions at the minimum required inspection intervals.

The ROW maintenance frequency should also be in keeping with the surrounding environment. For example, a greenway in a suburban development may be maintained more frequently than a ROW through a forested park.

Although maintaining the ROW for 25 feet on each side of the pipeline is typical, the easement agreement may dictate otherwise. A smaller maintenance distance may be adequate, depending on local conditions and methods used for ROW inspection, as long as it is adequate for access and inspection of the ROW surface conditions.

Side trimming of the tree canopy may be necessary for aerial surveillance to be effectively performed. For aesthetic purposes, operators may "feather cut" in more urban and developed areas while they may "hard cut" in more rural areas. Whichever technique is used, the result should be a clearly defined ROW to help keep the public aware of the pipeline's presence and provide for operation and maintenance needs.

In addition to side trimming, operator vegetation maintenance practices should include scheduled mowing and brush-hogging where necessary. Typically, pipeline operators use herbicides in a limited way to control weeds, vines and woody vegetation near valve locations, fences, above-ground facilities and difficult to access locations.

Trees should not be allowed within the boundary of the ROW. Tree roots have the potential to damage pipeline coatings which may contribute to the loss of integrity of the pipeline. With prior approval from the transmission pipeline operator, grass and certain types of shrubs may be permitted within the ROW, provided that the plantings do not interfere with the maintenance, inspection and operation of the pipeline and related facilities. Typically these would include seasonal crops that would be consistent with the area, flower beds, vegetable gardens and lawns. Rights-of-way can provide useful and functional habitats for plants, nesting birds, small animals, and migrating animals. Plants that are native to the area are desirable.

References