December 2019, Vol. 246, No. 12


Unmanned Underwater Vehicles Have Role in Pipeline Security

By William H. Walsh and Anusha E. Pillay, Attorneys, Cozen O’Connor  

In June of this year, the General Accounting Office (GAO) published its findings related to critical infrastructure protection in a congressional report entitled “Key Pipeline Security Documents Need to Reflect Current Operating Environment.”  (GAO-19-426).    

Generally, the report called for an update of pipeline security protocols produced by the Transportation Security Administration (TSA) in 2010, specifically recommending that the updated plan “reflects changes in pipeline security threats, technology, federal law and policy, and any other factors relevant to the security of the nation’s pipeline system.”  

The scope of the review included oceanic pipelines in the Gulf of Mexico and in the territorial waters of Alaska, Hawaii and Puerto Rico.  

With regard to technology, the GAO focused exclusively on cyber and terror threats and did not delve deeply into the role that current non-cyber technology might play in monitoring and securing pipelines, including those under water. Nevertheless, any robust security plan should include implementation of updated non-cyber technology given that such technology can equally contribute to increased threats.   

Among other things, this raises the question of the role unmanned maritime systems (UMS) and, specifically, unmanned underwater vehicles (UUVs) might play in pipeline monitoring and security.  In order to be effective, however, the new technology must be viable.  

In 2007, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published its final report on the “Use of Unmanned Water Vehicle (UUAV) for Pipeline Safety to Improve Safety and Lower Cost.”  (DTPH56-05-0004).  The objective of the underlying study was to determine the feasibility of using UUVs to detect leaks, locate encroachments, record encroachments and related damage and reduce the cost of pipeline surveillance.    

The overarching conclusion at the time was that UUVs were not a commercially viable alternative to divers for these tasks at that time. However, there have been dramatic developments in the various technologies incorporated into UUVs and the commercial use of UUVs has, in turn, risen dramatically in the dozen years since PHMSA report, strongly suggesting that the commercial viability of UUVs within the oil and gas industry has changed significantly.   

Improvements in range, communications, navigation, robotics (autonomy) and data collection have attracted industry attention and led to increased commercial use.  Most recently, development of micro-UUVs are providing commercial and scientific operators a highly effective and relatively cost-efficient means of underwater monitoring and surveying.    

It follows that the current state of UUV technology suggests a role that UUVs can play serve in any pipeline security or risk management plan.  The threats to our nation’s pipeline system are by no means limited to cyber-attacks and being able to deter, detect and prevent physical damage is just as essential.   

As reiterated in the 2019 GAO Report, privately-owned pipeline operators bear responsibility for implementing asset-specific security protection.  The TSA, in turn, is primarily responsible for the oversight of pipeline physical security.    

PHMSA, within DOT, bears the primary responsibility for regulating the safety of hazardous materials transportation via pipeline and the safety of pipeline systems.  The safety of pipeline operation and maintenance are both addressed within PHMSA’s regulatory programs.  Via PHMSA’s pipeline safety program, pipeline operators are tasked with the primary responsibility for ensuring the integrity of their pipelines.   

Threats to pipeline safety and security identified in the 2019 GAO Report include but are not limited to mechanical failure, corrosion, operator error, physical attack and natural disasters.   Although pipeline releases have caused relatively few injuries and deaths compared to other modes of product transportation, a single accident can have catastrophic – and costly – effects on public safety and environmental damage.1   

Aging offshore pipelines highlight a growing need for automated risk management tools to detect possible leaks and corrosion.  In February 2017, for example, a natural gas leak was detected in a 52-year-old pipeline in the Cook Inlet.  Federal regulators indicate the leak occurred as early as late December 2016.  At 80-feet deep, repairs required multiple dives to the sea floor.  Thick layers of sea ice posed further challenges for divers, thereby delaying repair efforts until the ice had sufficiently melted.2   

According to the PHMSA’s 2007 Report, UUVs lacked sufficient range to rapidly locate a specific underwater pipeline leak, unless the leak was large enough to be followed visually to the source.  The study further noted challenges with sub-sea leak detection, as most of the sensors developed for use in the air will not work underwater.    

Past challenges also involve difficulties in underwater autonomous devices transmitting data and communications.  Above ground, traditional wireless communications rely on electromagnetic waves to transmit data.  Those same electromagnetic waves have extremely limited range underwater.  Instead, underwater signals are sent via acoustic waves.  

The global market for UUVs is estimated to reach $5 billion USD by 2025,3 warranting significant updates to PHMSA’s 2007 studies on their commercial viability.  UUVs already provide a means to inspect pipelines as an alternative to human divers and tethered, remotely-operated systems.   

As early as 2012, Lockheed Martin launched the Marlin, an extra-large UUV with extended endurance and depth and advanced sensors that can generate real-time, 3-D, geo-referenced models of its surrounding environment based on the data it collects. The Marlin has already conducted several subsea inspections in the Gulf of Mexico.     

Ongoing developments in UUVs have focused on surmounting challenges presented by harsh, Arctic underwater environments.  In September 2016, MIT students deployed General Dynamics’ Bluefin Robotics-built UUV at the U.S. Navy’s Ice Exercise in the Arctic region.4    

The UUV had to be specially equipped for unique Arctic conditions, for example, accounting for thick and constantly moving ice that could otherwise crush sensitive equipment. Unlike traditional navigation methods which rely on a fixed reference point or surface guidance, the Bluefin UUV featured a navigation and log system that enabled autonomous operation by measuring the velocity and movement of the ice.    

With continuing investment in robotics and artificial intelligence, autonomous repair capabilities may not be far behind.  Earlier this year, the U.K. approved over $4.95 million (£4 million) in funding to develop a cross-sector system combining an autonomous vessel, drones and a robot to repair offshore wind farms. Although the robotic element is still in the “experimental stage,” the project is reported to have widespread applications in the offshore oil and gas operations.5   

Domestically, Missouri University of Science and Technology has been testing drones and robots to help inspect and repair bridges.6  The drones can carry a repair arm to seal cracks and prevent moisture from breaching the rebar.  The ongoing research extends to sensor technology that enables sensors to detect strain, temperature and degree of corrosion loss in the cross section of the structure.   

On top of these advancements, NATO has developed and in 2017 adopted the first ever digital underwater communications standard. Named Janus for the Roman god of gateways, NATO’s protocol enables devices made by different manufacturers to communicate with one another underwater.  Janus establishes a single frequency reserved for initial communications between two robots or systems.  Once the two devices make contact, they can then move onto a different frequency for extended communication.  Think of Janus as paving the way towards an underwater internet equivalent.    

Naturally, as the technology proliferates in pipeline applications, questions arise over the appropriate regulatory structure for UUVs.  To that end, existing FAA regulations over Unmanned   

Aircraft (UAS) provide a possible blueprint for their underwater counterparts.  UAS are increasingly used to monitor onshore pipelines.  Part 107 of FAA regulations covers rules for small, commercially-used drones, including certification of commercial drone pilots.    

In summary, UUVs have the capacity to play an integral role in pipeline safety and security.  Their use would be benefited by the development of regulations similar to Part 107 for UAS, at least to set the ground framework as UUV technology continues its rapid evolution.


1 2019 GAO Report (citing to, e.g., Bureau of Transportation Statistics, Table 2-2: Injured Persons by Transportation Mode, and Table 2-4: Distribution of Fatalities by Mode).   








Authors: William “Bill” Walsh is co-chair for the Aviation Practice Group at Cozen O’Connor. He concentrates his practice on a variety of general litigation matters with particular emphasis on aviation litigation.   

Anusha Jones is an attorney in the Commercial Litigation Department at Cozen O’Connor in Seattle, WA. An experienced litigator, she focuses her practice on defending clients against state and federal consumer protection claims, class actions, premises liability, wrongful death, and maritime litigation.  


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