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Interpretation Response #PI-19-0005

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: New Terrain Technologies

Individual Name: Mr. David Van der Vieren

Location State: CO Country: US

View the Interpretation Document

Response text:

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
and Rulemaking

Regulation Sections

Section Subject
192.705 Transmission lines: Patrolling
195.412 Inspection of rights-of-way and crossings under navigable waters