In this week’s episode of the Pipeliners Podcast, host Russel Treat is joined by Erin Kurilla, VP of Operations and Pipeline Safety at American Public Gas Association, to discuss the impact of the PHMSA Gas Distribution rule on public gas.

Listen to the episode now to learn more about the APGA and its members and the challenges posed by the gas distribution rule, particularly for the smaller public gas companies.

Impact of the PHMSA Gas Distribution Rule on Public Gas Show Notes, Links, and Insider Terms

• Erin Kurilla is the Vice President of Operations and Safety at the American Public Gas Association. Connect with Erin on LinkedIn.
  • The American Public Gas Association is the only not-for-profit association for public and community-owned gas utilities. Representing over 700 members in 37 states, APGA is The Voice and Choice of Public Gas in Washington, DC. APGA also works on the national level to educate our members on legislative issues, best safety practices, effective business and operational strategies, as well as host conferences that promote the benefits of natural gas as a responsible and efficient energy source.
• AGA (American Gas Association) represents companies delivering natural gas safely, reliably, and in an environmentally responsible way to help improve the quality of life for their customers every day. AGA’s mission is to provide clear value to its membership and serve as the indispensable, leading voice and facilitator on its behalf in promoting the safe, reliable, and efficient delivery of natural gas to homes and businesses across the nation.
• SGA (Southern Gas Association) is a community of natural gas professionals across the U.S. and Canada. SGA’s membership comprises 200 businesses across the distribution, pipeline, and gas supply marketing sectors as well as more than 300 industry partners serving the industry as vendors, suppliers and consultants.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) is responsible for providing pipeline safety oversight through regulatory rulemaking, NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
• DIMP (Distribution Integrity Management Program) activities are focused on obtaining and evaluating information related to the distribution system that is critical for a risk-based, proactive integrity management program that involves programmatically remediating risks.
• SHRIMP (Simple, Handy, Risk-Based Integrity Management Program) is an online tool that operators of natural gas distribution systems use to create a complete, written Distribution Integrity Management Program (DIMP) plan customized for the specific needs of their system.
• 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.
• Standard operating procedure (SOP) is a detailed written procedure used to safely execute a recurring work process in a consistent manner
• Pipeline SMS (Pipeline Safety Management Systems) or PSMS is an industry-wide focus to improve pipeline safety, driving toward zero incidents.
• The Merrimack Valley gas explosion in Massachusetts in September 2018 was the result of excessive pressure build-up in a natural gas pipeline owned by Columbia Gas that led to a series of explosions and fires.
• Upstream is the operation stage in the oil and gas industry that involves exploration and production. 
• Midstream is the processing, storing, transporting and marketing of oil, natural gas, and natural gas liquids.
• Downstream is 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.
• 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.
• FEMA (Federal Emergency Management Agency) mission is to support the citizens and first responders to promote that as a nation we work together to build, sustain, and improve our capability to prepare for, protect against, respond to, recover from, and mitigate all hazards.
  • National Incident Management System (NIMS) guides all levels of government, nongovernmental organizations and the private sector to work together to prevent, protect against, mitigate, respond to and recover from incidents.

Impact of the PHMSA Gas Distribution Rule on Public Gas Full Episode Transcript

Russel Treat: Welcome to the “Pipeliners Podcast” “Episode 305,” sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellent Management System, compliance and operation software for the pipeline control center to address control room management, SCADA, and audit readiness. Find out more about POEMS at EnerSysCorp.com.

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, and to show the appreciation, we give away a customized YETI tumbler to one listener every episode. This week, our winner is Jay Reyes with Tellurian. It’s about time that Jay got a YETI. To learn how you can win this signature prize, stick around until the end of the episode.

This week, we spoke to Erin Kurilla with the American Public Gas Association about the impact on public gas companies of the recent PHMSA distribution notice of preliminary rulemaking. Erin, welcome to the Pipeliners Podcast.

Erin Kurilla: Thank you for having me. I’m excited to be here.

Russel: If you would, tell us a little bit about your background and your role there at APGA.

Erin: Sure, I’d love to. I am the Vice President of Operations and Safety at the American Public Gas Association. Been here for six years now. It’s gone fast, for sure, but it definitely feels like home. Before I joined APGA, I had the blessing of working over at the American Gas Association for almost five years as well, working with their pipeline safety in their operations and engineering groups.

I got my start in the industry in the field. I worked for, at the time, it was Equitable Resources, known by some as Equitable Gas. I worked in the Midstream department, now they’re known by EQT. I was there during the rebranding, actually. I had the pleasure of stumbling into this wonderful industry a little farther upstream, but instantly knew that the folks and the people in the pipeline industry were home.

Don’t ask me why or how I wandered to DC, but I did, and really learned about pipeline safety, advocacy, and the important work of trade associations at AGA before coming back over here to APGA.

Russel: It’d probably be helpful for the listeners. We’ve had people on before and we’ve talked about this, but it’s probably helpful to cover it again. How is APGA different from AGA and SGA, and those other gas associations?

Erin: It’s an important question. The American Gas Association represents local distribution companies, which majority of those are investor owned or privately owned utility companies.

Then, the American Public Gas Association, we represent the nearly 1,000 public gas systems around the country. We try to focus on the unique aspects of being municipally owned and how that might complicate or benefit a gas utility in conversations here in DC.

That, I guess, is how we separate ourselves also from this SGA, Southern Gas Association. Suzanne and her team do wonderful things over there, especially around education and training, and providing those unique opportunities to bring the industry together in some of the great events that they have.

Yes, we have events, but we, by and large, do advocacy. We like to say we are the voice of public gas here in DC. There’s only 10 of us, which some people don’t realize. We try to punch above our weight, as they say.

When people think of operations and safety at APGA, you’re looking at it. You’re listening to it. It’s truly me at APGA doing all the things that I can to make my members’ lives just a little bit easier when it comes to pipeline safety, operational best practices, compliance, you name it. Trying to find ways to improve pipeline safety, but do it in a well thought out and justifiable way.

Russel: I think the other thing too about the APGA is that many of your members are, by comparison to the AGA members, small.

Erin: True.

Russel: Many of those public gas companies, it’s one guy working for the city, one person working for the city, running their gas system. They still have to do all the things that the company with 2,500 employees has to do.

Erin: Right. People are surprised to learn that of the roughly, I’ll say 1,300 LDCs, distribution systems, that report an annual report to PHMSA, almost 1,000 of them. I think we’re at 997, are municipally owned. Of those 997, roughly 500 or so serve less than 1,000 customers.

When you have less than 1,000 customers, you might have someone in the office doing all the paperwork and compliance stuff, someone overseeing gas operations, and maybe one or two folks in the field.

Oh, by the way, they probably work on the water system as well.

Russel: Or the electrical system or the streets or the sanitary or the stormwater or all of that.

Erin: Public works, you name it. One of the big things people notice when they get to know public gas is how deep of knowledge individuals at public gas have on everything to do with running a gas utility, from gas purchasing to regulatory compliance. They have to know it all. They don’t get the luxury of being in a silo because they are the silo.

Their depth of knowledge on everything is just truly impressive and, I think, sometimes underappreciated. It’s been a true blessing to get to work with these folks.

Russel: Just like all other pipeliners, these folks are consummate professionals. They understand how important their job is. If there’s a cold snap, they’re the ones that are up in the middle of the night, running to the regulator stations, making sure they’re all still going. It takes a certain kind of person and a certain kind of commitment to do that job.

Erin: We always say that public gas, because they don’t have investors, they serve their city. They serve their community in every way, shape, and form. They’re working each and every day to reliably and safely provide natural gas at a reasonable rate as they possibly can. Because it’s their neighbors. They live in the town.

Russel: Yeah, that’s right. They go to the high school football games with their friends and neighbors. They all know that’s the gas guy.

Erin: Whether or not they want to be known or not.

Russel: Look, I asked you to come on to talk about the new distribution rule that recently got published as a notice of preliminary rulemaking. Let me tee this up a little bit. I have not had the chance to sit down and read the rule in detail. I know that there’s a lot in it. I know that there’s a lot of things that impact DIMP and DIMP plans and how they’re executed.

I know that the big gas companies are very energetically reading and responding to what’s in this thing. I guess my first question is, what’s your take on the rule and its impact on the public gas companies?

Erin: Just like large investor owned, public gas is interested in preventing pipeline incidents. When you look at the origin of the provisions in the Safety of Gas Distribution Pipelines rule, they, by and large, come out of the PIPES Act of 2020, which was legislation that looked to remedy anything that was viewed as a root cause to the Merrimack Valley incident.

Just like our investor owned counterparts, APGA members want to ensure that it never happens again. When we look at the provisions in the rule around protecting against overpressurization, ensuring adequate oversight of activities that could lead to overpressurization and communication with first responders and the public, we get it.

We understand how important those are. We agree with Congress and the National Transportation Safety Board that we need to make sure that we address any kind of, I guess, holes that might potentially have existed in the pipeline safety regulations. We need to fill those holes.

I think, for public gas, it’s always going to come back to “Let’s figure out what’s going to fill that gap, and let’s go do it.” We’ve seen this trend since I’ve been doing this, that there is a movement away from prescriptive regulations, “Thou shall go do X,” to “Justify why you’re doing X and justify why you’re doing X and justify why you’re not doing Z.” That is very cumbersome.

We talked about the person in the office and the guy in the field that’s supervising maybe two or three individuals. That’s a lot of work for a system of less than 1,000 miles, maybe serving 350 customers.

The regulations and the desire to understand every thought process from a gas distribution operator and the opinion of a lot of public gas systems, is getting away from filling those potential gaps in the pipeline safety regulation to documentation for the sake of documentation.

You’ll see APGA’s positions largely be around “Sure, we’re OK with doing that, but I don’t want to create a mountain of paperwork justifying why I just did what you asked me to do.” That’s where our comments and that’s where our positions are. Sure, we’re fine with buttoning up some stuff, but let’s focus on what matters and not the mountain of paperwork that goes with it sometimes.

Russel: I have a premise. I’d like to get your take on it. When you look at Merrimack, Merrimack, in my view, was primarily an engineering failure. It was a project management and engineering failure. They had a project. They designed it. They started it.

It was kind of on the shelf for a while. They picked it up off the shelf. Then different people went out and executed it. They failed to account for a sensing line and the specifics of how it was connected.

In the larger companies, where people are moving around and where they’re managing larger, more complex systems or where they’re managing older systems where people are not around that are familiar with those systems…

I think you have a very different kind of human risk than you do in the public gas companies, where you have a smaller group of people that are more intimately familiar with a smaller system and understand the interactions.

The Merrimack incident happened in a large operator, large gas utility. I’m not sure that the risk factors are the same for a small gas utility. Can you speak to that? Do you have an opinion about that?

Erin: In some ways, I agree with you. It’s funny.

When you think about management of change, whether it’s management to change or change management, whichever direction you’re coming at the change from, there is a school of thought that when you are in an intimate operating environment, that the management of the change happens organically versus through a systematic structure like what is maybe expected from a compliance purpose.

Again, we’re getting to that documentation thing. When a complex organization needs to run a change through multiple different work groups to verify their sign off of the change, you have people thinking about “Hey, I’m thinking about the sensing lines” or “Hey, I’m thinking about the the training that might impact whether or not…”

Russel: Their focus becomes rather vertical and narrow.

Erin: Whereas a small public gas system is one person. They get to think about all that, all the time. They don’t think about these changes in a narrow sense. They’re constantly being forced to think about changes from every aspect of their operations.

In some ways, you’re like – pick a name – “Mike is going to sign off 15 times on the same change because he’s the M&R guy. He’s the OQ guy. He’s that procedure guy. He updates the procedures. Oh, by the way, he updates SOPs and everything else.”

Sure, we can create the document and have Mike sign it 15 times, but does that…Maybe it is. Maybe it’s making him think about each one of those things and put the various hats on through the process, but the juice isn’t as much worth the squeeze.

Russel: I’ll say it this way. An individual running a comprehensive checklist is different from a bunch of departments checking off different items. Those are fundamentally different problems. They have fundamentally different risks associated with their execution.

Erin: Needless to say, yes, I think your assessment is fair. There’s less potential or room for error, but I don’t think we would walk all the way back and say there aren’t enhancements that could be made to how even the smallest of small public gas systems systematically think through things.

I just did it. I tied it to SMS, which is OK, that I just did that. I always talk about lowercase SMS. The concept of safety management systems is applicable regardless of size, but the rigor around some of this stuff is suited for larger organizations.

Russel: There’s a lot of places you can go and get different kinds of analysis and studies and such about this, but the size and complexity of an organization, there’s a corollary between the systems necessary.

If I have a system that’s appropriate for a large organization it won’t work for a small one. Likewise, the system that’s appropriate for a small organization won’t work for a large one. They’re just fundamentally different.

Erin: PHMSA had the challenge ahead of them. There’s only one set of pipeline safety regulations that apply to everybody. The challenge is how do you craft code language, 192 code language, to meet all of that. We’re looking forward to trying to provide comments on all of the provisions and how to use the words in 192 to get to the heart of the matter.

Russel: I know that when the DIMP rule first came out, there was a lot of challenge in the public gas companies trying to figure out how we are going to do this. Where the large companies all went through it and built their own plans, there was an industry initiative to write a standard plan that would work for all public gas companies.

Erin: I’m going to challenge you on standard plan, but go ahead.

Russel: Fair enough. Fair enough. You guys didn’t see. I had a visual reaction. I actually bounced back away from the microphone…

She’s right. They came up with a standard way of putting a plan together. That’s probably a better way to say it.

Erin: There you go. I’ll take that one.

Russel: The point being that they solved it at the industry level versus the company level. How does this new DIMP rule get addressed in the context of I think what was called SHRIMP?

Erin It’s still called SHRIMP. You can’t run away from it. Once something’s branded, you’ve just got to stick with it.

Russel: That’s a pretty sticky name right there.

Erin: First I’ll address your question. Then I want to challenge you on something else too. The requirements within this proposed rulemaking related to Distribution Integrity Management are really interesting.

That is because PHMSA has really tried to focus on addressing risks related to over-pressurization of low pressure systems. Low pressure being, for all intents and purposes, utilization pressure or less than one pound. Again, linked to the Merrimack Valley incident.

If you look at the provisions, they’re by and large very specific to that subset of distribution systems. I wish I had a statistic on the number of distribution utilities out there that have low pressure systems, but I don’t have that number offhand. I will share that it’s not the majority, but where they are located means that they have a lot of impact on the customer base.

You look at your historic cities, cities that had historically cast iron, and they are the ones that utilize utilization pressure. By and large, there are active accelerated cast iron replacement programs, and in some situations, the utility has the luxury of bringing that portion of their system up to, I guess, a more traditional medium pressure type system.

There are very urban areas in this country where even once the cast iron is replaced with a more modern material, because of the way the system is structured, they will always operate it at utilization pressure. Just because…

Russel: Let me ask you to define utilization pressure versus medium pressure.

Erin: Utilization means the pressure that it enters the customers’ home. A typical distribution system operating will pick a number 60 pounds. It’s going to have a meter set regulator. At every premise, it’s going to drop from 60 pounds to whatever pressure you’re using at your stove, your furnace, etc.

Whereas, in these more historic, older, whatever systems, they drop that pressure all the way back at the district regulator station, or some reg. station further down…I guess I should be saying “upstream.” The entire system is being fed at the same pressure your appliances used, so there is no meter…

Russel: There’s no meter reg. set at the house?

Erin: Right, which is what the system was in Merrimack Valley, so there was no last line of defense at the premise to prevent any overpressurization that occurred on the pipeline system for making it all the way to the appliance.

That’s what’s the DIMP piece of this role is trying to address say, “Hey, Congress mandated that PHMSA rider regulation that forces or directs operators of low pressure, utilization pressure aka less than 1 pound systems, to make sure that they address the risk of overpressurization on their system and thus, overpressurization all the way to their customers’ appliance.”

It doesn’t apply to everybody. Most, if not all – I’m going to make sure I don’t have this wrong – I guess there is one piece, but most of the burden associated with the potential changes to the DIMP plan are going to be borne by operators of utilization or low pressure systems.

Russel: Those are going to be typically older systems, because nobody would build a modern gas distribution system that way.

Erin: Not from scratch, right. Like I said, they’re all replacing this pipe.

Russel: They’re replacing the pipe but they’re not at the same time dropping meter regulator sets at all the houses?

Erin: Not 100 percent of the time. That’s the hope. That’s the goal. They would like to be able to do that. It adds capacity to their system and everything else, so there’s a lot of benefits to being able to raise that pressure, put a meter set regulator on the premise. I can run my whole system at a higher pressure and there’s added capacity, etc.

But in some situations, it’s just not feasible to be able to do that. PHMSA and Congress, essentially, are asking those operators to more specifically address the threat of overpressurization within their DIMP plans.

Russel: That’s a whole new set of information for me. I’ve read the Merrimack NTSB reports. I didn’t catch that detail. For those of us that are not familiar with those kinds of systems, you wouldn’t assume that they would even be existing.

Erin: To the credit of the operators out there that have a significant percentage of their system or mileage operating at these pressures, they’re thinking innovatively about how to add that last layer of protection between their jurisdictional piping and their meter and the customer’s premise. Historically, they haven’t had to think about overpressurization that far downstream.

Russel: That’s a big deal. From an engineering perspective, that’s not that easy of a thing to solve.

Erin: To go back to your original question, I also get the pleasure of overseeing the SHRIMP tool for Distribution Integrity Management. When this final rule is promulgated, we will address these additional considerations and prescriptive considerations that PHMSA and Congress want us to address. We’ll build it in. We’ll build it into all the considerations.

There’s some weirdness that the industry will push back on, that is in the proposal. I know that you have listeners that are really, really smart on this subject, so I even hesitate to dip my toe into it. At its most fundamental, risk equals likelihood times consequence.

PHMSA has some funky language in there about operators having to “Evaluate potential consequences associated with low probability events, unless demonstrated through supported and documented engineering analysis that the event results in no potential consequence and therefore there is no potential risk.”

That makes my little engineering head spin. I can’t quite figure out how an operator could ever do that, even if…

Russel: Zero is a very tough number.

Erin: Right. For a long time, our industry has recognized the need to “not eliminate” threats from a risk analysis. We understand that. I think people have done a pretty good job of that, but this is PHMSA coming back and saying that they still believe there’s more work to be done in this area and that operators need to show, through a documented engineering analysis, when they say…

An example I always give on this is when an operator in South Dakota says they’re not getting hit by a hurricane, they still have to somehow show, through a supported engineering analysis, that the likelihood of that is so minuscule that they don’t need to apply, say, preventative measures for a hurricane in South Dakota, that they’d be better served addressing higher risk items. 

Russel: That’s really a great illustration, Erin. That’s a great illustration. You said you were going to call me out on something else. I don’t want to steal that opportunity from you.

Erin: I think, for a large portion of the industry, they might think that this rule is around DIMP, but there’s a lot of other stuff in here. The piece that, while it’s focused on distribution, could have the biggest trickle down impact to the industry as a whole is related to the emergency response plan provisions, again rooted in a Congressional mandate from Merrimack Valley.

This looks at how operators communicate with both the public and public officials and first responders. “During, after an unsure incident…” Excuse me. I shouldn’t say, “Incident.” An emergency. PHMSA defines emergency, effectively, within 192.613(a)(3). They’ve expanded that list per the Congressional mandate.

We’re having really interesting conversations within the distribution industry. Maybe I should mention that AGA and APGA are working, linked up, on our comments on this rule. We’re really trying to unpack what Congress asked of PHMSA to do versus what PHMSA has proposed and what some of the really complicated, unintended consequences could be of PHMSA’s proposal.

Now that I’ve teased it, I have to share it with you. By and large, a lot of distribution operators and even some of the smallest of small are embracing and implementing FEMA’s National Incident Management System framework for incident response.

That means if there is an emergency on the distribution system…911 is called. The gas utility is called. Both arrive on scene. There’s some emergency that has taken place. We can just take an excavation damage, a hit line.

An incident command structure is stood up. The gas distribution operators fit into that incident command system with the first responders. They are linked up in response. Maybe the fire department might be evacuating premises and buildings while the gas utility is making safe the damage. There’s traffic control that happens.

Within that structure is a rigor around how information is disseminated. What some of the proposed provisions do will come into conflict with how these individuals are trained per FEMA NIMS, National Incident Management System, per FEMA NIMS incident command system, and how they are supposed to disseminate information.

In large scale incidents, there’s a public information officer, PIO, that is assigned, often not from the gas utility, sometimes but not often. All information disseminated to the public is routed through that individual.

For PHMSA’s regs to come and layer on top and says, “You must promptly notify the public. You must share these 15…” Not 15. I’m being facetious. “These eight things or so with the public.” It’s going to create conflict between what they know and have been trained on via NIMS and what the PHMSA regulation is prescriptively asking them to do.

I look forward to trying to put all of that into some written comments and contemplating that. I think it’ll be interesting to figure out how we address Congress’ request, which is for more timely information to be shared with the public, while also recognizing this really important partnership between first responders and the gas utilities in the event of an incident.

Russel: I’ve talked about this on other podcasts. The whole way we as an industry interact with first responders and how we try to get ahead of things when we’re having an emergency or we think we may be having an emergency, how we get ahead of those things, it’s challenging, for sure. The many hands of the government do not always talk to one another. I’ll just say it that way.

Erin: It’ll be interesting conversations. Especially, how this all shakes out, it is largely specific to the distribution industry. As we know well, provisions tend to bleed into each other, into other modes or, I should say, other pipeline asset types over time. I know a lot of folks are going to pay very close attention to how that all shakes out.

Russel: What should the public gas companies be doing right now with regards to this new DIMP rulemaking?

Erin: My advice is always to balance between wait and see and also doing some sort of side by side comparison of what they’re doing today and what’s being proposed. I have to point out your previous podcast with Keith Coyle because I think he said it really best right. He explained, in that podcast, for those that weren’t able to listen, a lot of…

There is a structured process through rulemaking. The notice of proposed rulemaking kind of really is where it begins.

There is a long process of both formal public comment writing, as well as advisory committee meetings, as well as comments after advisory committee meetings, and then other things that can happen once a final rule comes out that can change what we first see in a proposed rule to what is actually put into practice, into pipeline safety regulation, when all things are said and done.

I hesitate, especially for public gas, to tell anyone to spend too much time changing procedures or changing how they’re training folks or switching out equipment or whatever, until we figure out where this is all going to fall. Because I don’t want it to be for naught, if you are only doing it because you think that’s a regulatory requirement.

If you see something in the proposed rule that you think is a good idea, that will enhance your system, that might make you more efficient or safer, by all means, no one is stopping you. Go ahead and do it.

That’s why I always suggest. It’s boring, the side by side comparison of what you’re already doing and what’s being proposed, what in the proposal is a good idea that you could potentially go ahead and do over the next year or so. Getting out ahead is not going to hurt you.

But also being a little bit cautious on suggesting to go do things tomorrow because we don’t know where this is going to end. We don’t know when. We don’t know when it’s going to end either.

Russel: I would say that for anybody with a public gas company that’s reading through this thing and finding things, they ought to be communicating it to their industry association so that those comments can get incorporated into the response.

Erin: We always are looking to make the comments real. We, AGA and I, have formulated eight task groups to look at the eight big buckets that are in this rule. We’ve just talked about two of them, really, DIMP and emergency response. There are six others, fun little nuggets in the rule.

We have, I’ll say, roughly 20 to 30 operators representing both trades on each of those task groups, but we’re always looking for fresh and unique perspectives about how these provisions will impact your operations or not impact. Maybe you’re already doing them, which is good and informative for us to know as well.

Russel: Lots of eyes makes for good counsel.

Erin: Ideally. 

Russel: It’s important. I say this all the time. Really, working in our business, even working with Washington in our business, it does give you faith in our system. It is slow. It is painful. It is aggravating, but it’s deliberative. It brings together a very rich variety of viewpoints and experiences and backgrounds that causes us to be…

There’s a reason the rest of the world follows what we do and the way we govern these kinds of things in our country, because of the process we follow.

Erin: I agree. For what it’s worth, I also like to just try to get the word out that we say PHMSA – we say a five letter acronym – but there are people that work for PHMSA. It turns out there are humans there and that there are engineers. There are people that know regulatory code language. There are lawyers. There are economists. There’s everything else.

They’re trying. I give them a lot of credit. I always say I could never work for the federal government because it’s too slow for me. No. I give them credit. They try really hard. They have a lot of inputs coming at them at any given moment. It cannot be easy. Just trusting the process a little bit and knowing that there’s all sorts of levers that can be pulled when things go awry, and that there is a method to do even that action.

The saying I had for the leak detection rule was, don’t panic yet, I’ll let you know when to panic. I don’t think there’s really panicking happening with the safety of gas distribution rule. There are some concerns. There’s some language stuff. We always say when we get to the advisory committee point, words matter.

The actual text in 192 is so critical to get right. This is another one of my sayings, is, I got a longer career ahead of me. I’m blessed to have been able to work in this industry and what I do pretty early in my career, which means I get to do this for a long time. I don’t want Aaron 20 years from now to be screaming, “That is not what we meant. We meant something else.” That’s why…

I’m already seeing it. I’ve been doing it for 11 years and I already see, oh, my gosh, we’re talking about this again. Trying to get it right is really, really important, even if it’s just for a selfish reason of I don’t want to be screaming at some industry meeting in 20 years that that is not what we meant for that to say. It is being interpreted wrong.

Russel: I’m on the different side of that coin than you do. I have a couple folks that I’ve been working with for many years, and we talk about that commonly about, well, that was old Russel that did that, and old Russel didn’t have these facts.

Again, it’s a process that we’re following. I don’t even think we’re at the prepare to panic level on either of those two rulemakings. We do have work ahead of us, and we need to lean into the process.

Listen, thank you so much for taking the time to do this. I really value your perspective. I want to commend you for a couple things. One, you really are very knowledgeable about the public gas companies and their unique needs and challenges. Also, I don’t get called out very often, I appreciate it when it happens.

Erin: Pleasure being here. I really enjoyed our conversation, and just thank you for the opportunity.

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

If you’d like to support the podcast, please leave us a review on Apple Podcast, Google Play, Spotify, wherever you happen to listen. You can find instructions at PipelinePodcastNetwork.com. If you have ideas, questions, or topics you’d be interested in, please let me know on theContact 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