Comment from GHGSat

Introduction: GHGSat operates manned aircraft and satellites for greenhouse gas detection and measurement for oil & gas and other production industries. We use our aircraft technology to measure methane emitted from pipelines for customers today. As an operator of remote sensing technology and data, we are supportive of this PHMSA proposal clarifying that right-of-way patrol requirements are technology neutral. Background: We would like to comment on the proposed revision to 192.705(c), which is proposing the new wording: “(c) Methods of patrolling include observation or imaging from walking, driving, flying via manned or unmanned aerial systems, satellite, or appropriate means for observing current surface conditions in the right-of-way.” We would also like to comment on 195.412(a), which is proposing the new wording: “(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times each calendar year, inspect the surface conditions on or adjacent to each pipeline right-of-way. Methods of inspection include observation or imaging from walking, driving, flying via manned or unmanned aerial systems, satellite, or appropriate means for observing current surface conditions in the right-of-way.” Analysis: There may surface activity in the pipeline right-of-way that may not be evident from a sin-gle occurrence of any of the listed inspection methods, but may become more evident by comparing observation data (ex: imaging) made on different dates. Constraining the scope of the methods to assessment of current surface conditions is overly restricting. Remote sensing technology can provide operators with the ability to not only observe current surface conditions, but compare against previous observations, which can pro-vide a deeper understanding of changes in surface conditions, historical activity, trends, anomalies, and deeper context. Recommendations: Therefore, we recommend 192.705(c) be revised to “…for observing surface conditions in the right-of way and identifying changes that have occurred since the previous obser-vation(s).” Similarly, we recommend 195.412(a) be revised to “…for observing current surface con-ditions in the right-of-way and changes between successive observations.” In addition, it would be helpful to clarify in 195.412(a) that an operator may combine methods, i.e. all 26 observations do not need to be made by the same method. Conclusion: To summarize, we recommend revising the proposed text to account for the value and capability of remote sensing methods to detect changes in surface conditions, to avoid unnecessarily over-constraining the ruling to observations of current surface conditions only. We also recommend clarifying that a combination of methods could be used to satisfy the requirement of 26 annual inspections.