With New Regulations Coming (Maybe), Will You Adopt or Adapt? Matthew Thomas, Novara GeoSolutions Jacob Parakadan, Enbridge

Transcription

1 With New Regulations Coming (Maybe), Will You Adopt or Adapt? Matthew Thomas, Novara GeoSolutions Jacob Parakadan, Enbridge

2 adopt /əˈdäpt/ verb 1. start to use or follow 2. formally accept (a report or suggestion) GIS CONTEXT: Accept industry trends as the your organization s desired state ; follow guidelines prescribed in regulations. adapt /əˈdapt/ verb 1. make suitable for a new use or purpose; modify 2. adjust to new conditions GIS CONTEXT: Modify the industry approach to better serve your organizational objectives; adjust and help define regulatory best practices.

3 Adoptive Approach Pros & Cons Less direct risk by not being on bleeding edge Relative stability in implemented program Clarity of intent and interpretation Trailing indicators Delayed operational decision support Planning against dated/obsolete information Unplanned/unscheduled costs If others are leading, you are not

4 Adaptive Approach Pros & Cons If you are not following, you are leading Preparing for changes makes change more acceptable Leading indicators; what if scenarios Fosters culture that welcomes technology and new techniques Decision points factored into budgeting calendar Bleeding edge means exactly what it implies there is risk If program is not effectively positioned, costs can increase Requires increased institutional knowledge

5 Summary: Adoptive vs. Adaptive, Which is Best? Adoptive approach reacts to rule changes as they come, or even on a delayed time scale; change dictated to you and response (to change) may be hurried and subject to additional stress Adaptive approach can be applied AHEAD of regulatory change; allows for some opportunity to potentially drive changes through demonstration of value gained by using your approach Let s review a generic example

6 Initiate Project Compile Leak Data Review & Update C/L Apply Lessons Learned DIMP & TIMP Update Class & HCA Review & Update TVC Data

7 Class/HCA MAOP Map Updates Map/Data Verification TVC Review Leak Form Pipeline Maintenance Form CP Test Read Form Model What If Scenarios Modular/Component Scaling Execute Scheduled Tasks Agility to Adjust to Regs Empower Field Users Incremental Assessments Technology Base Supports Further Integration Database Operations Workforce ArcGIS Survey123 Collector Implemented Dashboard Pro DIMP TIMP

8 Pending Regulatory Actions Status Update

9 Federal Register updated on April 8, 2016 to include the Safety of Gas Transmission and Gathering Pipeline Docket Stated objectives include Increasing safety of pipelines not in HCAs and enhance integrity management requirements in HCAs Rule will establish MCA & will categorize Type A gathering P/Ls in class 1 areas 8 or greater as jurisdictional (limited to regs pertaining to damage prevention, corrosion control, public awareness programs, MAOP, line marking and emergency planning) Rule eliminates grandfather clause & requires operators to consider spatial relationships of threats GPAC meeting held mid-january, second meeting scheduled for early March but postponed (no date) Currently, tentative effective date for this rule is December 11, 2017 Safety of Hazardous Liquids Pipelines rule signed January 13, 2017 Increased focus on risk-informed approach to pipeline safety, requiring operators to integrate available data & expanding the list of conditions requiring immediate repair Implement system for detecting leaks (w/in 1-year for new, 5-years for existing) Establish a timeline for inspecting affected pipelines following an extreme weather event or natural disaster Evaluation of protective measures annually on pipeline segments that operate in HCAs, including use of internal inspection tools where possible NPMS OSAVE tool released 12/16; submission standard changes requested have been denied

10 The Effect On January 20, 2017, the White House issued a directive to federal agencies to freeze the promulgation of new regulations by sending no regulations to the Office of the Federal Register ( OFR ) for publication and withdrawing any regulations sent to OFR but not yet published. The directive permits agencies to seek an exception from the Director or Acting Director of the Office of Management and Budget ("OMB") for certain health and safety regulations. Unless PHMSA seeks such an exception for the Liquids Final Rule (which was withdrawn from FR 1/24), estimated new FR date is 12/01/17 Regulations WILL be impacted

11 Safety Commitment Working together towards a common goal of providing complete, accurate, and timely information for safe, reliable, and efficient operations of our pipelines.

12 Foundational OBS Vision accurate, accessible, real-time information Collaboration Convergence (SE) Data as a Strategic Asset Convergence (US) Technological Advancement (Integration) OBS Mission innovative solutions well-defined processes data integrity Technological Advancement (New Systems) OPERATIONAL BUSINESS SYSTEMS Strategic Plan ( )

13 Value of Adaptive Approach Consciously moved from build approach to buy approach Realized goal of reducing GIS platform from 12 (in-house) custom tools to a single COTS solution (Intrepid ) Currently have implemented Novara s compliance, work-in-progress (WIP), and bulk data loading (PDL) tools Over time, strategy will allow us to greatly reduce as-built workload through bulk data loading and further system integration Reporting capabilities drive compliance and allow us to meet and adjust to changing regulations Integration strategy created much more robust data management needs, our GIS strategy had to evolve to allow scaling to support those needs Longer term goal of supporting future strategic initiatives (e.g. Esri s ARP solution).