In this episode of the Pipeliners Podcast, host Russel Treat sits down with Keith Coyle to discuss their experiences at the recent Gas Pipeline Advisory Council (GPAC) meeting on leak detection and repair. 

The episode provides insights into the process, changes observed in PHMSA’s approach, and the challenges the committee faces in reaching a consensus on key issues. The conversation also covers the differences in perspectives between public representatives, industry, and state regulators, and the varying viewpoints on the efficiency of existing programs and the need for changes.

GPAC Meeting for Leak Detection & Repair Show Notes, Links, and Insider Terms

• Keith Coyle is a shareholder and attorney with the law firm of Babst Calland. Mr. Coyle is a member of the firm’s Washington, D.C. office and a Shareholder in the Pipeline and HazMat Safety practice. Connect with Keith Coyle on LinkedIn.
  • Babst Calland’s Energy and Natural Resources attorneys work collaboratively across legal disciplines to serve the needs of energy companies across the United States. Based in Washington, D.C., the Firm’s Pipeline and Hazardous Materials Safety practice represents clients on all types of pipeline safety and hazardous materials transportation matters.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) is responsible for providing pipeline safety oversight through regulatory rule-making, NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
• Leak Detection and Repair (LDAR) is the process by which oil and gas, chemical, and/or petrochemical equipment is monitored for the location and volume of unintended leaks
• Gas Hazardous Leak according to PHMSA is any release of gas from a pipeline that is uncontrolled, that could be an existing probable or future hazard to a person’s property or the environment, or that is or can be discovered using equipment sites, sound, smell, or touch.
• LPAC (Liquid Pipeline Advisory Committee) and GPAC (Gas Pipeline Advisory Committee) are statutorily mandated advisory committees that advise PHMSA on proposed gas pipeline and hazardous liquid pipeline safety standards, respectively, and their associated risk assessments. The committees consist of 15 members with membership evenly divided among Federal and State governments, the regulated industry, and the general public. The committees advise PHMSA on the technical feasibility, reasonableness, cost-effectiveness, and practicability of each proposed pipeline safety standard.
• Notice of Proposed Rulemaking (NPRM) is a stage in the rulemaking process that happens before an agency adopts a final regulation. It is like the first draft of a regulation and gives the public an idea of what is to come.
• Protecting Our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020 addresses pipeline safety and infrastructure with respect to natural gas and hazardous liquid pipelines. It authorizes appropriations through FY2023 for specified pipeline safety programs under the Pipeline Safety Improvement Act of 2002 and related enactments.
• NTSB (National Transportation Safety Board) is a U.S. government agency responsible for the safety of the nation’s major transportation systems: Aviation, Highway, Marine, Railroad, and Pipeline. The entity investigates incidents and accidents involving transportation and also makes recommendations for safety improvements.
• Natural Gas Pipeline Safety Act of 1968 (Pipeline Safety Act) was authorized by the Secretary of Transportation to prescribe safety standards for the transportation of natural and other gas by pipeline, and for other purposes. 
• Downstream means the direction and area the product is traveling toward. It can also mean the process involved in converting oil and gas into the finished product, including refining crude oil into gasoline, natural gas liquids, diesel, and a variety of other energy sources. The closer an oil and gas company is to the process of providing consumers with petroleum products, the further downstream the company is said to be.
• Gathering Lines are pipelines that transport natural gas from production facilities to a transmission line or distribution main lines.
• Valve and Rupture Rule is a newly updated PHMSA regulation. This rule establishes requirements for rupture-mitigation valves, such as spacing, maintenance and inspection, and risk analysis. The final rule also requires operators of gas and hazardous liquid pipelines to contact 9-1-1 emergency call centers immediately upon notification of a potential rupture and conduct post-rupture investigations and reviews.
• Total Calculated Volume (TCV) is the total volume of all petroleum liquids and sediment and water, corrected by the appropriate volume correction factor (Ctl) for the observed temperature and API gravity, relative density, or density to a standard temperature.
• Rupture Mitigation Valve (RMV) is any automatic shut off or remote-controlled valve that an operator uses to minimize the volume of gas released to mitigate the consequences of a rupture.
• A risk assessment is a process of identifying potential hazards and analyzing the eventualities if a hazard occurs. This procedure consists of three steps: Hazard identification: identify internal and external hazards, and risk factors that have the potential to cause harm.

GPAC Meeting for Leak Detection & Repair Full Episode Transcript

Russel Treat: Welcome to the “Pipeliners Podcast,” episode 313, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System, compliance and operations software for a pipeline control center to address control room management, SCADA, and audit readiness. Find out more about POEMS at enersyscorp.com.

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Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.

Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time. To show that appreciation, we give away a customized YETI Rambler to one listener every episode. This week, our winner is Christina Parker with Plains All American Pipeline. Congratulations, Christina. Your YETI is on its way.

To learn how you can win this signature prize, stick around until the end of the episode. This week, Keith Coyle is joining us to talk about the recent Gas Pipeline Advisory Council meeting on leak detection and repair.

I am sitting here at the Westin in Crystal City in Washington, DC. I have spent the last four days in very long, very slow-moving meetings at the Gas Pipeline Advisory Council. I’ve got Keith Coyle sitting here with me. We’re going to do our first in-person podcast.

It’ll be something a little different. I’ve caught him. He hadn’t had a chance to write his normal brief. We’ll see how he does with the questions.

Keith Coyle: Yeah. Russel is catching me a little bit late in the day here. We’re on day four of this advisory committee process. It’s a little bit like Groundhog Day. You wake up every day, you’re in the same place going to the same meeting.

Things are moving along probably not nearly as fast as I expected, but it’s been a very interesting process.

Russel: I guess I’ll just ask a general question and just ask what’s your take? For the listeners to build a little context. They’re reviewing the leak detection and repair rule, and they’re going through it element by element. I just start, what are your general comments about what you’re seeing and how is this the same or different than other GPACs you’ve been to?

Keith: Process‑wise, the biggest change that I’ve seen is in previous meetings, PHMSA took a bit more of an aggressive role in presenting things to the committee, trying to take more firm positions on recommendations for the committee to consider, probably a little more active in moving the committee process along.

They’ve taken more of a hands-off approach with this advisory committee process, this time, these meetings. I’m not sure if that’s directly related to some other concerns with the rulemaking process that have come up lately. Is it something that’s unique to this rule? I don’t know.

Maybe the agency has made a decision, whether it’s for legal reasons or policy reasons, to maybe step back a little bit and let the committee do more of the work on its own, and come up with its own recommendations more organically. That’s definitely slowed the process down, but it’s also made it, I think, more interesting.

Russel: Yeah, maybe I guess. As I reflect, I think in some of the other GPACs I’ve been to that there seems like PHMSA presented more of a foundation like, “Here’s why we put the rule together.” Then they would present some data behind and so forth.

They’ve not really done that. They’ve gone through the comments and summarized the comments as in the past, but they’ve not really presented the data-backed or the historically backed foundation for this rulemaking. That’s a little different and unique in my experience.

Keith: Yeah. They’ve said a lot less than they have in the past. They have summarized the comments. They’ve provided responses to direct questions during the meetings when they’ve been asked. It’s definitely a lot more hands-off than what they’ve done in the past.

That has affected the pace of the meeting to be quite honest. We’re on day four. We’ve gone through 5 of the 10 items on the agenda. We’ve got 5 items scheduled for tomorrow. I don’t think anybody expected us to be on item 5 out of 10 on the fourth day of a five‑day meeting.

Russel: Yeah, it’s been really slow-moving. One of the things I would say, and I don’t know why this is necessary, it could be that for some of the public representatives on the GPAC, they just don’t have the technical knowledge.

It seems like we’re talking more about should this be five years or seven years, or should it be a half an MCF or an MCF, or…We’re arguing about that kind of very pedantic thing and missing some bigger questions about “What should the process be? Should we be doing something that’s risk‑based? What might that look like? How might we write the rule that way?” What’s your take on that?

Keith: For some of the public members of the committee ‑‑ this has just been my general experience ‑‑ they favor more of a command and control approach to regulations. They’re more willing to go with prescriptive requirements, prescriptive deadlines, maybe with an understanding that there’ll be some sort of process where you could get relief through an exception or approval.

That’s just a philosophical approach on how regulation should work. On the industry side, we’ve always been a lot more comfortable with risk‑based approaches, giving operators flexibility. Set a goal for us. Then let us go out and figure out the best way to optimize our resources to meet that goal.

Maybe the best approach isn’t the 10‑year deadline or the 5‑year deadline. Maybe the approach is set a target for us in terms of things you want us to fix or maybe some kind of overall goal you want us to reach. Then let us go do it.

When we set prescriptive rules, when we set prescriptive timelines, there’s always going to be arbitrariness in that. There’s always going to be operators that are going to need relief.

Russel: There are unintended consequences too. People will make decisions to achieve compliance that may actually move backward in terms of safety performance.

Keith: Exactly. If you have a fixed, hard deadline to do a certain activity for leak detection…You have limited resources. You’re going to have to funnel your more limited resources to that activity. Those resources aren’t going to be available for something else that you might do that would probably have a better impact on safety, and efficiency, even from the environmental side.

That’s been one of the more interesting things in this whole process. We’ve had a lot of really good conversations about one side of the meeting wanting the leaks to be fixed really quickly, every leak really fast.

Even during the conversation from the industry side, we’ve said, “If you make us go fix that really small leak, you may end up generating more methane emissions from the process of the repair than we would actually get from making the repair.”

Russel: That’s really good point. There were a couple of specific examples given where you talked about fixing a small leak on a mainline valve stem. To do that, I have to depressurize the line upstream and downstream. All of a sudden, I’ve got to depressure 50 miles of 36‑inch pipeline. I’m going to need 125 years to balance those methane emissions out because that leak was so small.

Keith: You caused me to generate emissions that, if I’d let that small leak do its thing, that’s 125 years’ worth of emissions to fix this small leak. Those are the kind of things when you’re doing regulation…You have the comment process. You have the advisory committee review. That’s an example of rulemaking, hopefully making the people involved more thoughtful.

Like, “Oh, we clearly could not have met that.” Nobody wants that. Nobody wants to generate more emissions fixing small leaks.

Russel: Of course not. That’s silly.

Keith: [laughs] At least not the reasonable folks.

Russel: I don’t think anybody in the process is unreasonable. I think they’re just coming from very different perspectives.

The other thing I would say too is there was a lot of PHMSA people there in the room that were just listening and taking notes, that I’m sure are going to be participating in the analytical and drafting process behind the meeting. I don’t know that I’ve seen that, at least not at the same level in the past.

Keith: They definitely had a lot of people in the room learning a lot about the rule that they proposed. My heart goes out to those folks. I’ve been involved in the rulemaking process. It’s never easy to have a room full of 150 people take a look at your work and “Oh, you didn’t think about this. You didn’t think about that. This regulation isn’t drafted clearly. What about this issue?”

That can be tough. Think about any work that you’ve done in professional life or your personal life. You have a room full of 150 really smart people who know what they’re doing.

Russel: I’ve been there. It’s not easy.

Keith: It’s not easy. I think and I hope that the PHMSA people that are there…They’re all professionals. I hope they understand that the comments that are being provided, they’re intended to make a better rule at the end of the day. They want to have a final rule that’s sound, that’s going to cause people to make good decisions. This is a part of the process.

Russel: A couple things that people that are listening to this are probably going to want to know. Number one, at this GPAC, there’s no way they’re getting through all of the agenda. That’s going to stall the process until they can get another GPAC meeting scheduled.

Keith: When we got here Monday morning, they were supposed to be two proposed rules discussed, this leak detection and repair rule and then a separate rule related to class location. They’ve already taken that second rule off the agenda. The class location rule, that’s going to be talked about at a GPAC meeting that’s going to happen sometime next year.

Are we going to get through all of the five agenda items that are left tomorrow? I don’t know. [laughs]

Russel: I know where I’d put my money. [laughs]

Keith: The safe bet, from the beginning of this, has been to bet the over, but I know there’s going to be a lot of desire, from PHMSA, from the committee, to try to wrap up all the work tomorrow. There are some really important issues that are still on the agenda. One of them is gathering, which is one of the things that’s near and dear to my heart.

Then we have some other big things to talk about. We’ve got LNG facilities, hydrogen pipelines, reporting for releases. Then we’ve got compliance deadlines, which we haven’t talked about. We’ve got some five big ticket items tomorrow. There’s only, give or take, eight hours in the day minus lunch. We’ll see.

Russel: I just don’t think they’re going to get through it. I don’t see the pace accelerating tomorrow. It’s going to continue to be more of the same in terms of just the conversation that needs to occur and the things that need to be expressed into the record.

That was interesting too, something I saw that was…Every time you do one of these, you learn a little bit more. One of the things I picked up here that’s new is the committee members were being very deliberate about what they were getting read into the record or what facts they were presenting to make sure those things show up on the record. That’s actually a good thing.

For the people who are going to be trying to understand how to implement this rule and, probably more to the point, for those compliance officials and attorneys and so forth that are going to be trying to understand how they react to the rule, they need to hear what was going into the record.

Keith: One of the things on the GPAC process, by statute, the GPAC is supposed to prepare a report with recommendations on the rulemaking proposal that’s before it. What PHMSA has done in the GPAC charter is made the transcript of the public meeting the committee’s report, along with the slide decks and the other materials.

Everything that’s being said at this meeting is in the GPAC’s report. By statute, that’s part of the record. It’s a very important part of the record. It helps to inform the agency as they move forward in the rulemaking process.

It helps parties, later on down the road, when we’re dealing with…Now we have the opportunity to submit additional comments. When the final rule comes out, we’ll be able to consult the GPAC transcript to see…

What did the agency do in response to the recommendations? Did they consider everything that was in the record? Are we going to have to seek further administrative review of this rule or do something with judicial review? The one thing I’ll say about the GPAC is the transcript is a very important part of the record. It serves as that statutory report that they’re supposed to prepare.

Russel: I have taken the time in the past to read the transcript. There’s a lot of very good information in there. It’s tedious. It’s a lot of work to get through all of it, but it’s good stuff.

Keith: I read a little bit to my kids at night when they’re not able to go to bed.

Russel: [laughs]

Keith: I’ll pull out the oldies but goodies, like an old 2019 GPAC transcript. You’d be surprised at how fast three girls can go to sleep when you’re reading a little GPAC transcript.

Russel: [laughs] I think it’d put me to sleep too. I want to talk a little bit about where it looks like this is all heading. Again, I’ll make just some general comments, and I’ll let you respond, Keith.

Here’s what I think is certainly true. There is going to be an increased emphasis on getting leaks repaired, particularly type 2s, that’s more aggressive than historical. Also, there’s going to be an increased requirement for record‑keeping and probably reporting to PHMSA around all of this.

For people that are thinking about what am I going to need to do with my program, they’re going to have to be looking at how are they going to do surveying and then how are they going to take the results of those surveys and actually do leak identification.

Then they’ve got a whole process they’re going to have to make sure works, that is the “How do I grade, classify, and work those leaks” through what’s, as I’m listening to all the things that are being talked about, a fairly complicated work process.

Keith: One of the most interesting things that’s come out of this meeting is there’s very significant differences in what the committee is talking about in terms of recommendations about how this rule should look and what was in the original proposal from the agency.

For example, the foundation of the advanced leak detection program that the agency put out was the five parts per million within five feet threshold for leak detection technology. We had a really long debate. I think it was a couple of days ago.

A lot of people said, “That standard’s not going to work. It rules out too many technologies. It’s not a great place to be on an advanced leak detection program.” We had significant recommendations that were just very different from that foundational principle, giving operators more options on the technology front.

Then we’ve had some other changes in terms of using metrics on how we’re grading leaks that weren’t necessarily in the proposed rule either. This is one of those ones where I sit back. I’m going through the meeting. I’m looking at it. These aren’t edits to rule text or tweaks to rule text.

Some of this stuff is big changes in principle or significant changes in approach or principle that the agency’s going to have to take a hard look at in shaping the final rule. We’ll see what comes out on the back side. I wouldn’t feel comfortable going back to people right now and saying, “I know how this rule is going to look,” because I don’t.

Russel: That’s a really excellent point. I think in other GPACs that I’ve been to, it was pretty clear coming out what the rule was going to look like. You had it dialed in, maybe with, “Well, here are the variabilities,” but in this case, I couldn’t even speculate.

Keith: Yeah, and we used to spend a lot of time editing rule text during the GPAC meeting, and that hasn’t been what’s happened here. It’s been more about laying out principles of things for the agency to consider, and some of those principles are really different than what was in the proposed rule.

Russel: There’s a fairly big divide between where industry is, where the state regulators are, and where the public representatives are. More so than I’ve seen in other conversations, at least in my experience. I think that makes for more complexity for the agency on how am I going to write this to try and arbitrate those differences of opinion.

Keith: We’ve seen some interesting conversations from…One of the things chairman Berman from New York, she spent a lot of time talking about the leak rating and repair requirements that are in New York because she feels like that’s a really effective program.

That really effective program that they’re administering in New York doesn’t line up with the proposal that PHMSA had in the NPRM on how to do a leak rating and repair program. She spent a lot of time over the last few days explaining to the other members of the committee, “Hey, look, I don’t want a set of regulations that is going to render this very effective program in New York invalid overnight.”

That’s an interesting conversation that I haven’t seen before at GPAC.

Russel: Yeah, I agree. It’s a pretty strong argument too. We’ve got a program, it’s working. We’re making progress. We’re reducing the numbers of our leaks. We’re reducing the amount of methane we have. We’re replacing the old pipe and we’re making good progress.

It’s being done in a way that’s…She spent a lot of time talking about what are the other things we need to consider beyond methane emissions. We’ve got to look at where the work’s being performed. We got to look at who’s impacted by the work.

We’ve got to look at, what’s the impact on ratepayers and what they’re having to pay for their natural gas. When you start thinking all of that through, you’re like the level of complexity of this, it’s increasing exponentially.

One of the other comments in this, I think was made across the industry and the regulators was, “Look we’ve got things that are working and we don’t want to just change them.” If we do, then we’re going to be focused on the wrong things. We’re not going to get…Ultimately we’re all trying to do the same thing as reduce methane emissions.

Keith: Yeah, and some of that goes back to the old adage, if it ain’t broke, don’t fix it. What Chairman Berman was bringing to the meeting was, “Here’s the reality. I’m in this state. We have a lot of infrastructure that’s subject to these replacement programs. We’ve been doing this for a long time. We’re getting good results.”

When people start talking about replacing all leak-prone pipes within ‑‑ pick your timeline ‑‑ five years, seven years. Here’s the reality of how that’s actually going to happen on the ground. Even some of the best infrastructure replacement programs in the country are not going to be able to meet that kind of timeline.

It’s not because they don’t want to be safe. It’s because there are a lot of things that go on when you’re trying to do infrastructure replacement in a heavily urbanized community like New York, where you’re dealing with roads and people that need to use the roads, permitting, scheduling things. “Oh, by the way, I can’t turn somebody’s gas off.”

It’s just a lot more complicated than, “Hey, look, we should replace everything in five years.” That would be great but it’s not practical.

Russel: Absolutely. In fact, we’re having this conversation a little earlier. There are about 10,000 miles of cast iron pipe and about 40,000 miles of old steel distribution that need to be replaced. I don’t even know if we could roll that much pipe in this country in seven years.

Keith: If you think about it too, if you go back and look at the historical mileage, those numbers have come way down and they started with the stuff that was easier to get to. Now we’re dealing with the harder parts of the puzzle at the end…

Russel: Yeah, like a gas main running down a main street in Manhattan versus the lines that were in rural New York, as an example.

Keith: Look, if that was an easy line to get to, we probably would have gotten to that sooner. When we’re talking about these very complex programs and you have to optimize all this stuff with other work that you’re doing to create efficiencies.

Again, you don’t want to be going out and doing something, a replacement program, that’s going to generate more emissions. We don’t want to be going out and fixing a leak on a pipe that’s otherwise not hazardous if I know that pipe is going to be replaced really soon.

That’s either going to result in an operator investing a lot of money and fixing something that’s only going to be used for a couple of years, or it’s going to create a scenario where an operator that may otherwise have replaced that piece of pipe, they’ll fix that leak.

Then there’s no utility in making the replacement. Those are complicated questions. You can’t just say, “That should be done in five years.”

Russel: No. It’s juvenile, frankly, to think that that’s even a possibility.

Keith: The other side of the equation comes from a good place. They want to have the safest infrastructure that we can have. They want to replace things that need to be replaced. They want to fix leaks. Those are all extremely laudable, very laudable goals.

I do think some of what we’ve seen over the last few days is…There’s the reality of that too. We live in a world with scarce resources. We have companies that have scarce resources.

Russel: Not to just throw the environmental advocates under the bus completely. They made a lot of really good points about what is the public expectation and what are landowners telling them that have land and that are living next to pipelines.

There’s a lot of valid reasons for what they want to do, but there’s fairly big gulf, I guess. [laughs] I don’t envy the agency for what they’re going to need to do to really get this rule run to ground.

Keith: This is one of those ones where…Most PHMSA rulemakings are very technical. We’re dealing with discrete safety issues. This rule, we’re dealing with much bigger policy issues. We’re dealing with things like greenhouse gas emissions, methane, climate change. We’ve got a congressional mandate that’s thrown into the mix, which is adding more complications.

We’re wrestling with bigger issues about repair and replacement and infrastructure programs. There’s a lot more, I would say, big‑picture policy going on here in this debate than we generally see in a “Hey, should I go make this obscure regulatory change to the integrity management program?”

Russel: Yeah, or even when they were bringing new programs in like control room management or DIMP or that sort of thing. It was more about how do we make the pipeline safer. There was science behind it and research. It’s like, “How are we going to implement this?”

In this case ‑‑ it’s a good point you make ‑‑ it’s much more of a rethink of what operators need to have as priorities in their operating models.

Keith: There’s definitely a bigger environmental piece to this. That’s being dictated by the statutes that were dealing with here in this rulemaking. Those concerns are being raised by new members who are on the committee who are making their voices heard, as they should.

Some of those concerns are running into what we usually traditionally deal with, which is safety concerns, risk‑based programs, and cost considerations. When we left, we just went through it. It might have been a couple of hours.

Then they had to vote on something at the end where there was a lot of back and forth. It looked like, in the end, we weren’t going to get a vote, or it would be split down the middle. They had a vote. It ended up being 13 to 2.

There were two people who voted against something because they felt really passionately, but there were more than a few people who changed their vote to vote in favor of something because human beings sat in a room and talked for a couple hours and compromised. That’s a good thing.

Russel: The representative from Williams made a really good point that, a lot of times when you’re doing these types of things, you know you’re getting to a good place when nobody’s happy but nobody’s mad at each other. [laughs] It is. It’s difficult.

I said to several people in conversations. Every time I come up here and watch one of these, it actually gives me a lot of pride in what we have as a country. I really think the Founders were brilliant. They intentionally set our process up to be deliberative and ugly and messy. They did not make our government efficient. Frankly, I think that’s a good thing. [laughs]

I don’t want to live in a country with an efficient government. That’s a little intimidating. I like the fact that we’re so very deliberate. We do bring opposing viewpoints in and thrash it out. It’s not fun. It’s not comfortable, but the output moves our economy, moves our country in a good way, usually.

Keith: This is one of those ones where you’ve seen a lot of education on both sides. I’ve learned a lot about things that I didn’t know very much about coming in.

Russel: Even in the committees, there was a lot of good interaction across the table, about “Help me understand. Help me get the context.” There was a lot of that. There was movement on both sides because of that.

Keith: There was a lot of “I’m not an expert on this issue, but the other member of the committee might be. Can you tell me, can you help me learn where you’re coming from, what your point is?” That was on both sides, all sides of the committee. It was really helpful. It was a good discussion.

There was a lot of the human element to what went on over the last few days and watching people who came into a meeting probably at different sides on a lot of these issues. At the end, after four days of talking, they’ve come together on some things. Not everything, but we’ll see. There’s still a lot more work to be done.

Russel: What I would tell the listeners to take away from this conversation is that the process is moving. There’s a lot of conversation. If I were to shake the Magic 8 Ball, the answer would be “Outcome unclear.”

Keith: It would probably be “Outcome uncertain.” Definitely. The other thing, if you shook the Magic 8 Ball, it would say, “Bet the over…”

Russel: [laughs]

Keith: “…on the next time I schedule one of these public meetings.” I suggested to my wife a few days ago, “We might be done by Thursday.” She’s texting me today. I’m like, “Nope. We’re going to go till 5:30 on Friday. I’m not sure we’re going to be done. We’ll see.”

Russel: I don’t think we’ll be done. Well, I don’t know that you’ll be done.

Keith: [laughs]

Russel: I’ll be done because I’m flying home tomorrow. It’s interesting. This kind of stuff is challenging for me to sit through. It’s not really what I do. Hearing the conversation and getting the context when a rule rolls out and you’re sitting down with a customer, you’re just so much better equipped to help them understand what is really being asked.

Keith: One of the things that I’m super-impressed, there’s some really good people that can stay on their feet for eight hours and still be sharp and addressing all of these different regulatory components, everything in this massive rulemaking that they’re trying to have a handle on.

I certainly couldn’t do that for eight hours a day and still be sharp and still make all the good points that everybody on both sides has been making. Just the stamina of it, it’s really impressive.

Russel: There’s a lot of intellectual intensity, for sure, in doing that.

Keith: Even at 6:00 PM on a Thursday of the fourth day. That part of it, I’m humbled by it, some of the folks that we have.

Russel: Thanks for taking some time out to talk to me. I know you’re probably pretty whipped. You didn’t have the time to do the prep that you like to do. I appreciate you taking the time. Hopefully, this is of benefit to the listeners. When it all shakes out, we’ll do it again, when the 8 Ball shakes out and has a little bit more of a clearer expectation as to where we’re headed with all this.

Keith: Always happy to come back on the show, Russel. Have a safe trip home.

Russel: Thank you, Keith. I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Keith. Just a reminder before you go. You should register to win our customized Pipeliners Podcast YETI Rambler. Simply visit pipelinepodcastnetwork.com/win and enter yourself in the drawing.

If you’d like to support us, the best way to do that is to leave us a review. You can do that on Apple Podcast, Google Play, Spotify, wherever you happen to listen. You can find instructions at pipelinepodcastnetwork.com.

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Russel: If you have ideas, questions, or topics you’d be interested in, please let me know on the “Contact Us” page at pipelinepodcastnetwork.com, or reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.

Transcription by CastingWords