Pipeline Safety: Integration of Innovative Remote Sensing Technologies for Right-of-Way Patrols on Gas and Hazardous Liquid Pipelines

The Environmental Defense Fund (EDF) supports the integration of advanced remote sensing technologies like drones and satellites for pipeline patrols to enhance safety and environmental protection. However, they argue that these technologies should currently supplement rather than replace traditional methods and that PHMSA must establish robust performance standards to ensure adequate monitoring and prevent the use of inferior, low-cost alternatives.

The National Association of Pipeline Safety Representatives (NAPSR), representing state agency pipeline safety managers, supports the proposed rule allowing the use of remote sensing technologies for pipeline right-of-way patrols. They emphasize that any new technology must provide an equivalent level of safety and visual resolution to current methods, and they request clarification on the specific definition of "promptly" regarding imagery analysis.

Southwest Gas Corporation, a natural gas local distribution company, supports the proposed rule allowing remote sensing technologies to satisfy patrolling requirements. They specifically endorse the joint comments submitted by the American Gas Association (AGA) and the American Public Gas Association (APGA).

The American Petroleum Institute (API) and the Liquid Energy Pipeline Association (LEPA) support the proposed rule to allow technology-neutral remote sensing methods for pipeline Right-of-Way (ROW) patrols. They argue that these changes provide regulatory clarity, align with industry best practices, and allow for a more risk-based, flexible approach to pipeline safety and monitoring.

GPA Midstream Association and the Interstate Natural Gas Association of America support the proposed rule to allow the use of remote sensing technologies for pipeline right-of-way patrols. They argue the rule provides regulatory clarity, recognizes technological advancements, and will result in significant cost savings for the industry without compromising safety.

LiveEO Inc., a satellite Earth Observation technology company, strongly supports the proposed rule clarifying that pipeline right-of-way patrol obligations are technology-neutral and can be satisfied by satellite imagery. They argue that AI-assisted satellite monitoring provides superior consistency, auditability, and safety benefits compared to traditional methods, and they recommend specific clarifications regarding the definition of "current" conditions and patrol dates.

The American Fuel & Petrochemical Manufacturers (AFPM), a trade association representing the refining and petrochemical sector, supports the proposed rule to clarify that remote sensing technologies like UAS and satellites can be used for pipeline right-of-way patrols. They argue that the proposal provides necessary regulatory clarity, supports innovation, and enhances safety by allowing for more consistent, data-driven monitoring of complex pipeline networks.

The Pipeline Safety Trust, a nonprofit watchdog organization, provides feedback on the proposed rule regarding remote sensing technologies for pipeline patrols. They argue that the proposal creates geographic scope conflicts, fails to define the term "current" regarding imagery analysis, and lacks specific performance standards or comparability requirements for the new technologies.

The American Gas Association and the American Public Gas Association support the proposed rule to allow the use of remote sensing technologies, such as drones and satellite imagery, to satisfy pipeline right-of-way patrol requirements. They argue that the proposal provides regulatory certainty and flexibility for operators while maintaining a performance-based safety framework.

Flyscan Systems Corp. supports the proposed rule to allow technology-neutral remote sensing methods for pipeline right-of-way patrols. They advocate for a performance-based approach that emphasizes the ability to detect specific threats over the choice of platform, while specifically highlighting the capabilities of manned hyperspectral aerial surveys.