Dear AIIS Members:

At the end of January, the White House released the attached memorandum which calls for the development of a plan to require American-made pipe and equipment in pipeline projects in the United States.

The memorandum directed the U.S. Department of Commerce (DOC) to develop a plan to implement the memorandum’s objectives, and the DOC has published a request for public comments on the following subjects in connection with the White House memorandum:

(a)  What is your role regarding U.S. pipelines?  Operation; Construction; Pipeline manufacturing; Steel manufacturing; Wholesale distribution; Other (if, “Other”, please describe).

(b)  Your North American Industry Classification System (NAICS) code(s)?

(c)  What types of pipelines does your company operate, construct, manufacture, or distribute?

(d)  Where are your operations located?

(e)  How many employees?

(f)  Approximate sales revenue?  (Presumably on an annual basis.)

(g)  Approximately how many miles of pipeline did your company construct, repair, fabricate, or distribute in 2016?

(h)  In a few sentences, describe your assessment of U.S. pipeline demand (such as miles of pipeline planned for construction) for the next few years.

(i)  To what extent are your companies’ pipeline materials sourced domestically?  What factors influence this decision (price, quality, supply shortages, pipeline requirements, domestic sourcing requirements, etc.)?

(j)  If applicable, please estimate your company’s capacity to fabricate pipelines or steel for pipelines.  What was your capacity utilization in 2016?  If applicable, what factors prevented your company from operating at capacity?

(k)  If applicable, please estimate in days or months supply your existing inventories of pipe.  What share of your inventory is fully produced in the United States?

(l)  To what extent are materials other than iron and steel the primary materials used in your pipelines?

(m)  To what extent is technology changing the material requirements and construction techniques in the pipeline industry?

(n)  If applicable, how many permits from a Federal agency are required for pipeline construction or repair?  Which Federal agencies require permits and how long does it take to obtain them?

(o)  Please describe in a few sentences how domestic content requirements would affect your operations.

For purposes of this notice, the term “pipeline” refers to any conduit of pipe used for conveyance of gases, liquids or other products.  The physical facilities include: Pipes, valves, fittings, connectors, and other iron and steel assemblies or apparatus attached

to the pipe.  Also for purposes of this notice, the term “materials and equipment” refers to the iron, steel and all precursors, alloys or substitutes used in the fabrication of pipelines as well as pipeline coatings, and the term “equipment” refers to valves and other steel and/or iron apparatus attached to pipe.

Comments must be submitted to the DOC by April 7, 2017.

Presidential Memorandum on Construction of Pipelines (24-January-2017)

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