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2026 Pipeline Compliance Quick-Reference Checklist

Top-line compliance requirements for PHMSA, EPA, CPUC & CARB — distilled into one practical checklist for pipeline operators and compliance teams.

PHMSAEPACPUCCARB

2026 Compliance Quick-Reference

PHMSAPipeline & Hazardous Materials Safety Administration

Verify MAOP (Maximum Allowable Operating Pressure) records are complete and traceable for all pipe segments
Confirm material documentation (pipe specifications, seam type, vintage) meets Part 192 Subpart J requirements
Validate integrity management plan (IMP) covers all High Consequence Areas (HCAs) and is current
Ensure corrosion control records (CP system surveys, close-interval surveys) are up to date
Confirm rupture detection / leak detection system meets current PHMSA requirements
Verify operator qualification (OQ) program covers all covered tasks with current evaluations on file
Check Emergency Response Plan (ERP) has been reviewed and exercised within required intervals
Confirm public awareness program notifications have been sent within the 12-month window
Ensure annual report (PHMSA Form 7100.2-1) is submitted by June 15, 2026
Review Mega Rule (Part 192, Subpart O) compliance milestones — onshore gas transmission re-assessment deadlines

EPAEnvironmental Protection Agency

Identify all equipment subject to 40 CFR Part 60 Subpart OOOOa / OOOOb methane emission standards
Confirm fugitive emission monitoring (LDAR) surveys are scheduled and documented for 2026
Ensure all applicable compressor stations have completed required Part 60 performance tests
Verify equipment replacement or control schedules meet 2026 implementation milestones under OOOOb
Confirm GHG reporting obligations under 40 CFR Part 98 (Subpart W) and validate data collection processes
Check super-emitter response protocol is documented and staff are trained on rapid notification requirements
Review Part 98 annual report submission timeline (typically March 31) and verify data quality controls

CPUCCalifornia Public Utilities Commission

Verify compliance with General Order 112-F (California gas pipeline safety standards)
Confirm all transmission pipeline segments in CA have completed required pressure testing or have equivalent records
Ensure Distribution Integrity Management Program (DIMP) documentation is current for CA intrastate segments
Validate that CPUC safety certification filings are up to date
Check that any CPUC enforcement orders or corrective action plan milestones have been met
Confirm public awareness and damage prevention program satisfies CPUC requirements in addition to federal rules

CARBCalifornia Air Resources Board

Identify facilities subject to CARB Mandatory Reporting Regulation (MRR) — transmission compressor stations, underground storage
Verify MRR annual report data collection is complete; report due April 10, 2026
Confirm oil and gas methane annual report is submitted by July 1, 2026 (where applicable)
Ensure third-party verification statements are submitted by August 10, 2026 for facilities requiring them
Check SB 1371 compliance obligations — leak detection and repair requirements for gas distribution operators
Verify CARB component-level leak survey frequency meets applicable requirements
Confirm any corrective action timelines from prior CARB inspections are met

Disclaimer: This checklist is a high-level quick-reference tool and does not constitute legal or regulatory advice. Regulatory requirements vary by operator type, state, and facility configuration. Consult your compliance counsel and refer to current agency publications for authoritative guidance.

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