Inspection Regulatory Tracker: PHMSA / FERC-NERC / FAA / USACE — Pipeline, Grid, Aviation & Civil Works

Tracker date: 2026-05-10

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Executive Change Log

PHMSA finalized amendments to 49 CFR Parts 192 and 195 under the Gas Transmission and Hazardous Liquids Mega Rule Phase 2, extending integrity management requirements to moderate-consequence areas (MCAs) and adding inline inspection (ILI) mandates for previously exempt rural gathering lines above 8-inch diameter. Operators with unpiggable lines must submit an alternative technology equivalency demonstration or begin remediation planning. Estimated affected mileage: 30,000+ miles of gas transmission and 8,000+ miles of hazardous liquid gathering line. HIGH CONFIDENCE.

FERC/NERC issued NERC Reliability Standard CIP-014-3 enforcement guidance clarifying that physical security assessments of transmission substations must include documented inspection protocols for unmanned perimeter monitoring systems where deployed. Affects roughly 2,000 high-voltage substations rated 500 kV or above. MODERATE CONFIDENCE — guidance letter, not final rule.

FAA published AC 107-2B (final, effective 2025-12-31), consolidating sUAS operational requirements and adding explicit language on automated flight termination system (AFTS) testing documentation for BVLOS waivers. Operators running infrastructure inspection corridors under Part 107 waivers must retain AFTS test records for 24 months. HIGH CONFIDENCE.

USACE updated Engineering Regulation ER 1110-2-8157 (Responsibility for Hydraulic Steel Structures) to require underwater robotic inspection data — including sonar and video — to be submitted in standardized digital format to the National Inventory of Dams (NID) portal within 90 days of inspection completion. Affects all federally owned or federally regulated dams with hydraulic steel structures. MODERATE CONFIDENCE — ER revision circulated; final signature pending confirmation.

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Regulator Table

Agency	Instrument	Asset class	Requirement or change	Effective date	Operator action
PHMSA	Final Rule — 49 CFR 192/195 Mega Rule Ph. 2	Gas transmission; hazardous liquid gathering	ILI or alternative technology required for MCAs; rural gathering lines >8 in. added to IM scope	Phased: 2024–2027	Audit ILI coverage gaps; file alternative technology equivalency if unpiggable
PHMSA	Advisory Bulletin ADB-2025-03	Onshore gas/liquid pipelines	Clarifies that robotic ILI tool performance verification records must be retained 10 years	Immediate (issued 2025-Q3)	Update records retention policy; confirm tool vendor qualification documentation
NERC	CIP-014-3 Enforcement Guidance	HV transmission substations ≥500 kV	Physical security assessments must document inspection protocols for any deployed UAS/robotic perimeter systems	Guidance effective 2026-Q1	Revise security assessment templates; add UAS inspection log to audit package
FERC	Order 901 (pending)	Interstate natural gas facilities	Proposed expansion of control room management rules to include remote inspection data feeds	Not yet effective — NOPR stage	Monitor docket RM25-8; assess SCADA/inspection data integration requirements
FAA	AC 107-2B (Final)	sUAS / infrastructure inspection corridors	AFTS test records required 24 months; BVLOS waiver renewals must include prior-period anomaly log	Effective 2025-12-31	Establish AFTS test log; update waiver renewal package
FAA	BVLOS ARC Recommendations (pending rulemaking)	sUAS beyond visual line of sight	Proposed risk-based framework for routine BVLOS; detect-and-avoid performance standards under development	Not yet effective	Track docket FAA-2024-1262; assess DAA sensor compliance readiness
USACE	ER 1110-2-8157 (revision)	Federally owned/regulated dams — hydraulic steel structures	Underwater robotic inspection data (sonar, video) must be submitted to NID portal within 90 days	Pending final signature; target 2026-Q3	Confirm ROV/sonar data formats meet NID schema; update inspection contracts
OSHA	NEP CPL 04-00-004 (National Emphasis Program — Process Safety)	Petroleum refining, chemical facilities	Increased inspection targeting of facilities with deferred mechanical integrity inspections; RPA/robotic substitution must be documented as equivalent method	Active — ongoing	Document robotic MI equivalency in PSM records; prepare for audit

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Operator Impact

Records: PHMSA ADB-2025-03 extends ILI tool qualification record retention to 10 years — operators must audit existing document management systems for gaps. USACE ER revision requires structured digital submission within 90 days, replacing ad hoc PDF delivery.

Inspection frequency: PHMSA Mega Rule Phase 2 adds MCA segments to reassessment cycles (7-year maximum interval for ILI-capable lines). Gathering line operators previously outside IM scope must establish baseline inspection schedules by 2026.

Method: USACE now specifies sonar and video as required data types for underwater steel structure inspection — visual-only dive surveys no longer sufficient for NID submission.

Staffing: FAA AC 107-2B anomaly log requirements add administrative burden to BVLOS inspection programs; estimate 0.25–0.5 FTE per active waiver corridor for recordkeeping compliance.

Reporting: FERC Order 901 (if finalized) would require real-time remote inspection data integration into control room management documentation — a material IT and operational change for interstate gas operators.

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Robotics/NDT Impact

Automation opportunity: PHMSA's MCA expansion and gathering line additions create direct demand for ILI tool deployment on previously uninspected mileage. Operators with unpiggable lines have a compliance incentive to qualify robotic tethered crawlers or free-swimming tools as alternative technology equivalents. USACE's NID digital submission requirement favors ROV operators with structured data export capability over dive-survey contractors.

Compliance risk: OSHA's PSM National Emphasis Program requires that robotic substitution for mechanical integrity inspection be documented as a formally equivalent method — operators deploying drones or crawlers without a written equivalency rationale face citation exposure. FAA AFTS documentation requirements mean that inspection UAS operators running BVLOS corridors must maintain test records traceable to specific flight operations; gaps in chain-of-custody documentation are a waiver-renewal risk. NERC CIP-014-3 guidance creates a new audit surface: any UAS deployed for substation perimeter inspection must itself be covered by a documented inspection protocol, or its presence becomes a finding.

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Watch List

• PHMSA Docket PHMSA-2011-0023 (Mega Rule Phase 3): Expected to address distribution integrity management and leak detection technology standards. Proposed rule anticipated 2026-Q4. Robotic leak survey tools likely to be addressed.
• FAA Docket FAA-2024-1262 (BVLOS rulemaking): Aviation Rulemaking Committee recommendations under review. Performance-based DAA standards, if adopted, will set minimum sensor specifications affecting all infrastructure inspection UAS operators.
• FERC Docket RM25-8 (Control Room Management expansion): NOPR comment period closed 2026-Q1. Final rule could mandate inspection data feed integration for ~600 interstate gas operators.
• NERC Project 2023-03 (CIP standards for operational technology): Draft standards would extend cybersecurity requirements to inspection data systems connected to grid control networks — direct compliance risk for cloud-connected robotic inspection platforms.
• USACE NID Portal schema v2.0: Scheduled release 2026-Q3. Operators should obtain draft schema now to assess ROV data export compatibility before the 90-day submission clock starts.

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Confidence: MODERATE (PHMSA and FAA items HIGH; USACE ER and FERC Order 901 MODERATE pending final signatures) | Next Review: 2026-06-10

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