Interpretation Response #PI-19-0005
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. David Van der Vieren
Founder, New Terrain Technologies
2119 S Yukon Street
Lakewood, CO 80227
Dear Mr. Van der Vieren:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Parts 192 and 195. Specifically, you requested an interpretation on the requirements of §§ 192.705 and 195.412(a) as related to pipeline right-of-way inspection.
You asked whether satellite imagery qualifies as suitable methods for traversing the right-of-way to observe surface conditions on and adjacent to the right-of-way. You stated that satellite patrols utilize various sensors/telemetry units to analyze the conditions on and adjacent to the right-of-way up to once a day to monitor for mechanical threats, land disturbance, soil washouts/movement, vegetation health, and the presence of liquid hydrocarbons. You provided a sample of the satellite imagery. You asked PHMSA if the regulations allow the use of satellite imagery technology for pipeline right-of-way inspection.
Both §§ 192.705 and 195.412 allow right-of-way inspection that include walking, driving, flying or other appropriate means.
Other appropriate means may include satellite imagery if this method compares to the other specified methods. However, the satellite imagery in your examples did not provide sufficient resolution to provide the necessary details of the surface conditions on or adjacent to each pipeline right-of-way. Therefore, the satellite imagery as you submitted, cannot be used as an appropriate means. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
John A. Gale
Director, Office of Standards
|§ 195.412||Inspection of rights-of-way and crossings under navigable waters|