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
While federal enforcement actions decreased overall in 2025, this does not necessarily mean that state and federal regulators are any less vigilant.
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
This was an unprecedented action, but it confirmed many existing enforcement and inspection priorities already in place.
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.
Learn more about pipeline regulation and industry trends
Watch the entire Regulation Navigation video and save your place for the March 4th Regulation Navigation webinar.
