December 8, 2025
Regulation Navigation Takeaways from “The Regulator’s View: National Enforcement Trends with NAPSR’s Chair”
During the December 3rd Regulation Navigation webinar, Chris Taylor, ITS Vice President of Learning and Product, hosted a discussion with Alex Kirschling, National Chair of the National Association of Pipeline Safety Representatives (NAPSR) and Director of the Bureau of Natural Gas Analysis & Safety for the Public Service Commission of Wisconsin. Kirschling provided a state regulator’s viewpoint on PHMSA’s stated enforcement priorities, as well as some of the long-range enforcement trends over the past five years. The webinar also provided a summary of PHMSA’s enforcement categories, the responsibilities of state and federal regulators, audit preparation, and the latest industry news.News items
- Notice: New Customer Notifications for Excess Flow Valves; Notification Requirements for Gas Transmission Pipelines; and Amendments to Annual Reports for Gas Distribution Operators. (link)
- Updates July 1st notices. (link)
- Periodic Standards Update II. (link)
2025 National Enforcement Trends by Case Type
PHMSA’s top five enforcement priorities
A memo from Associate Administrator Linda Daugherty directed PHMSA I&E staff to concentrate their enforcement efforts on pipeline safety, including five priority areas:- Incidents and accidents
- High and moderate consequence areas
- Control room management and leak detection
- Damage prevention
- Transactions and due diligence
Top five takeaways for Regulation Navigation
- Review your program against PHMSA’s top five priorities.
- Preparing for inspections is critical (for example, records review and staff availability/expectations).
- Establish a relationship with your regulator and keep communication open.
- Although there are fewer federal enforcement actions in 2025, inspections and severe penalties continue.
- Pay attention to direct final rules coming into effect in 2026.
