Overview of PHMSA’s Pipeline Safety Program

Today, there are 2.6 million miles of pipelines that carry oil and natural gas in the U.S. The Nation relies on these pipelines and the products in them for economic growth and to support the daily lives of its citizens, and it’s PHMSA’s job to ensure they operate safely.

PHMSA establishes Federal pipeline safety, inspection and enforcement standards, and PHMSA’s state pipeline safety partners are a critical part of the Nation’s pipeline safety regime. PHMSA and its state partners are dedicated to ensuring pipeline operators comply with pipeline safety regulations. PHMSA also works with a variety of other partners, including other Federal agencies, state and local officials, emergency responders, environmental groups, and the public to ensure the Nation’s pipeline network continues to operate safely and reliably.

PHMSA’s FY 2017 request includes funding for 343 pipeline safety program positions to ensure the safe operation of pipelines in some of the most remote corners of our nation and 128 staff that manage the pipeline safety programs including developing regulations that guide the safe operation of pipelines, grant management and research.

The growth of PHMSA’s pipeline safety program advances a safe and reliable pipeline network. Resources Congress has provided over the years have enabled PHMSA to advance new functions and programs in its pipeline safety program. PHMSA launched a new pipeline safety auditing function that operates in tandem with Federal engineers to provide technical expertise, enhance PHMSA’s field presence, and enable more robust inspection and enforcement oversight.

PHMSA will also establish a pipeline Accident Investigations Division to investigate incidents and share lessons learned with all stakeholders to improve safety. PHMSA is in the process of finalizing the new Accident Investigation Division framework and resource construct, and anticipates initial stand-up later this year. The division will strengthen our capacity and focus on root cause investigations for all significant pipeline incidents and accidents; improve ability to identify lessons learned and evaluate safety data for emerging trends; develop robust process to exchange lessons learned with diverse stakeholders – internal and external – to improve safety; incorporate lessons learned into policy and planning processes as well as training; bring consistency to safety investigations; strengthen expertise through a career ladder and well-honed skill sets; and enhance training program for federal and state inspectors.

PHMSA is moving into its fourth year of a new inspection protocol for integrated inspections, where inspections are tailored to the risk profile of a pipeline operator. Inspection protocols are customized to focus resources on risks and are flexible enough to reflect new knowledge gained during an inspection. Inspections include multiple facilities and more miles of pipeline; they are performed by a team of engineers and are completed over several months.  As a result, PHMSA’s inspection results are more comprehensive, and result in more expansive enforcement cases.

PHMSA’s pipeline safety focus includes non-regulated stakeholders, such as the public, emergency responders, and others through investments in public outreach and education. Educating stakeholders through outreach activities and training programs like the 811 Call Before You Dig program plays an important role in reducing pipeline excavation damage related incidents, which continue to be one of the leading causes of pipeline incidents where people are injured or killed.

PHMSA also collaborates with industry and academic partners to fund research and development across all aspects of pipeline safety, including leak and mechanical damage detection and prevention, improved line system controls; and improved pipeline materials. Since 2002, this collaboration and investment has helped bring 47 technology demonstrations and 26 new technologies to market to prevent damage, and detect leaks and defects in difficult to inspect pipelines.

PHMSA’s Competitive Academic Agreement Program (CAAP) supports university-level pipeline safety research. Since 2013, CAAP has invested in a wide set of solutions for corrosion and other pipeline integrity challenges, and exposed a new generation of students to the field of pipeline safety.

I.         SUSTAINED EFFORTS TO SATISFY MANDATES

Safety is the Department of Transportation’s top priority and completing Congressional mandates will result in critical improvements that advance PHMSA’s safety mission.  The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (Pipeline Safety Act) included 42 new requirements. PHMSA has completed 26 of the Act’s mandates. Ten of the remaining mandates will be addressed as part of current rulemaking activities or reports. The remaining six are tied to reports and information collections that will inform future rulemaking.

A. HazardousLiquid Final Rule

PHMSA published a Notice of Proposed Rulemaking (NPRM) for the safety of hazardous liquid pipelines on October 13, 2015. The rule proposed critical updates to the way that pipelines are assessed, operated and maintained across the U.S. The rule addresses several mandates from the 2011 Act, including:

• Section 5 – integrity management, which requires PHMSA to conduct a study on whether integrity management system requirements, or elements thereof, should be expanded beyond high-consequence areas and the appropriateness of applying repair criteria, such as pressure reductions and special requirements for scheduling remediation, to areas that are not high-consequence areas and periodic reassessments changes;
• Section 8 – leak detection, which requires PHMSA to promulgate regulations that require operators of hazardous liquid pipeline facilities to use leak detection systems where practicable; and establish technically, operationally, and economically feasible standards for the capability of such systems to detect leaks;
• Section 14 – biofuels, which requires PHMSA to update the definition of hazardous liquid to include the term biofuels; and
• Section 29 – seismicity, which requires PHMSA to amend 49 CFR Part 195 to require pipeline operators to consider the seismicity of an area when evaluating potential threats to their pipeline systems.

The proposed rule also addresses two recommendations from the National Transportation Safety Board (NTSB) and the Government Accountability Office (GAO).  The rule was designed to improve protection of the public, property, and the environment by ensuring that operators detect and address unsafe conditions before an incident occurs.

PHMSA received more than 70 comments from stakeholders, including members of industry, environmental and advocacy groups, Federal, State and local government agencies and members of the public.  The Liquid Pipeline Advisory Committee met on February 1, 2016, and voted to approve the proposed rule with several recommendations.   PHMSA is considering all of the comments and recommendations, and plans to finalize the rule in the coming months.

B. Gas Transmission Proposed Rule

PHMSA plans to propose a NPRM for the safety of gas transmission lines in the next month. The NPRM will propose updates and clarifications regarding integrity management requirements and maximum allowable operating pressures for gas transmission lines and will address several mandates from the Pipeline Safety Act, including:

• • Section 5 – integrity management, which requires PHMSA to evaluate whether integrity management system requirements, or elements thereof, should be expanded beyond high consequence areas. The mandate also requires PHMSA to evaluate whether integrity management mitigates the need for class location requirements and to establish guidelines for what constitutes sufficient justification to allow operators to extend reassessment intervals for gas transmission lines by 6 months;
  • Section 23 – testing, which directs PHMSA to require operators to reconfirm the maximum allowable operating pressure of pipe lacking sufficient records and located in specific areas, and to require operators to conduct pressure testing or alternative equivalent means, such as in-line inspection programs for pipe not previously tested. The mandate also directs PHMSA to require the self-reporting of operators that do not have sufficient records to substantiate their pipeline’s maximum allowable operating pressure.

C. Other Rules: Operator Qualification, Excess Flow Valves, and Automatic and Remote Controlled Shut-Off Valves

In July 2015, PHMSA published the Operator Qualification, Cost Recovery and Accident Notification proposed rule that addresses four NTSB recommendations and the following mandates from the Pipeline Safety Act:

• • Section 9 – accident and incident notification: requiring PHMSA to revise regulations to require telephonic reporting no later than 1 hour following the “confirmed discovery” of an incident or accident; and
  • Section 13 – cost recovery for design reviews: requiring PHMSA to prescribe a fee structure and procedures for assessment and collection in order to implement authority to recover design review costs for projects that cost over $2.5 billion or that involve new technologies.

The agency is currently considering the comments received, and preparing to present the rulemaking proposal to the Gas and Hazardous Liquids Advisory Committees this spring.

The Excess Flow Valves Final Rule will fulfill Section 22 of the Pipeline Safety Act, which requires the agency to issue regulations requiring the use of excess flow valves on new or entirely replaced distribution branch service lines, or lines servicing multi-family facilities and small commercial facilities, if appropriate. The rule will also address one NTSB recommendation and would increase the level of safety for homes by requiring excess flow valves on all new and renewed gas service lines.

The Rupture Detection and Valves NPRM will address Section 4 of the Pipeline Safety Act, which directs PHMSA to, if appropriate, issue regulations requiring the use of automatic or remote-control shut-off values, or equivalent technology, where it is economically, technically, and operationally feasible, on newly constructed or entirely replaced pipelines. The rule will also address Section 8 of the Pipeline Safety Act, which requires PHMSA to study and, if appropriate, issue regulations requiring the use of leak detection systems where practicable and establishing technically, operationally, and economically feasible standards for the capability of such systems to detect leaks. PHMSA intends to release the NPRM later this year.

D. Reports and Other Actions: Study of Transportation of Diluted Bitumen

In accordance with the Pipeline Safety Act of 2011, PHMSA commissioned the National Academy of Sciences (NAS) to perform a study on diluted bitumen (dilbit) to analyze the risk of transporting dilbit, including its effects on transmission pipelines, the environment and oil spill response activities. The NAS study determined that while dilbit does not pose an increased risk in transportation, it behaves differently than light and medium crude oils in the environment following a spill. Based on their findings, the NAS issued recommendations to PHMSA, the Environmental Protection Agency (EPA), U.S. Coast Guard (USCG), National Oceanic and Atmospheric Administration (NOAA), and the oil pipeline industries to ensure an adequate response to spills of dilbit.

In response to the recommendations in the NAS study, PHMSA will:

• Develop and publish an Advisory Bulletin highlighting the findings of the study and suggest voluntary improvements that onshore oil pipeline operators should make to their oil spill response plans to address plan improvement recommendations.
• Host a public workshop in the spring of 2016 to solicit input from interested parties, government agencies and members of the public on how it can improve and enhance 49 CFR Part 194 and address the NAS recommendations.
• Work with the National Response Team (NRT) and the Interagency Coordinating Committee on Oil Pollution Research (ICCOPR) to advance the recommendations included in the report.
• Continue to work with the American Petroleum Institute’s Spill Advisory Committee, Spill Control Association of America, and other industry organizations to improve oil spill response planning and preparedness.

Completion of the mandated actions of the 2011 Pipeline Safety Act is a top priority and PHMSA is working to complete the outstanding requirements as quickly as possible. PHMSA posts regular updates about our progress in completing the outstanding requirements on our website at www.phmsa.dot.gov.

II.       RESPONDING TO EMERGING RISKS

The consequences of pipeline failures can have a tremendous impact on people and the environment.  PHMSA implements a comprehensive oversight program that is data driven to forecast and address safety issues before they occur. PHMSA also takes proactive steps to incorporate lessons learned from accidents into new policies and regulations in order to prevent future occurrences of safety issues that are affecting the American people right now.

A.  Pipeline Damage Prevention

PHMSA launched a comprehensive and transparent strategy to evaluate the adequacy of state programs, and to notify states of their adequacy determination. In addition to the final rule, PHMSA has undertaken a variety of efforts over many years to reduce excavation damage to

pipelines. These efforts include performing studies, advocacy, grant making, rulemaking, and partnership with a wide spectrum of excavation damage prevention stakeholders.

B. Underground Storage

The gas leak at the Southern California Gas Aliso Canyon underground natural gas storage facility in California has underscored the potential risks associated with the underground storage of natural gas.  PHMSA has the authority to regulate the underground storage of natural gas and hazardous liquids incidental to the movement of these products by pipeline, but there are currently no federal regulations specific to the storage of natural gas at underground storage facilities such as Aliso Canyon.

PHMSA and a number of states participated in the development of national consensus standards that were published in the fall of 2015. These standards promote best practices to ensure the safety and integrity of underground storage facilities. On February 5, 2016, PHMSA issued an advisory bulletin directing operators to immediately review the overall integrity of underground natural gas storage facilities, to identify the potential for leaks and failures, and to review and update their emergency plans.

PHMSA is considering additional safety standards for underground natural gas storage facilities. Building off of the February 5 advisory bulletin on underground storage, PHMSA will host a public workshop for all stakeholders to seek input on new regulatory enhancements. The agency will work with states that currently have regulations in place and we will work with our state partners who have or want to develop regulations that exceed the minimum federal regulations.

C. Liquefied Natural Gas

The U.S. is experiencing significant increase in the production of natural gas. This has resulted in a new market for liquefied natural gas (LNG) and the need for strong safety standards that regulate the transport and storage of LNG in the United States.

PHMSA’s regulations establish the minimum federal safety standards for the design, operation and maintenance of LNG facilities. PHMSA is working to update codes and standards for the safe design and operation of LNG facilities to include current market trends and new technology.

PHMSA also continues to offer its assistance to the Federal Energy Regulatory Commission as a coordinating agency in the siting and review of LNG facilities under the National Energy Policy Act.

D.  Water Crossings

Recent oil spills from pipelines in Montana and California underscore the importance of routinely assessing the condition, and evaluating the potential for external threats and mitigate risks associated with pipelines that cross or are close to the Nation’s waterways.

Following the 2011 ExxonMobil spill, PHMSA conducted a joint study with the State of Montana which revealed that many of the state’s pipeline water crossings could be threatened by river flooding and channel migration.  PHMSA worked closely with Montana state organizations, as well as Montana pipeline operators, to ensure that necessary steps were taken to safeguard existing crossings. These steps include: in-place safety procedures during flood conditions or increased river flow rates; increased frequency of patrols and depth of cover surveys during and after significant river-flow events; swift remediation measures, if needed; strengthening emergency response preparedness; and replacing trenched crossings with Horizontal Directional Drilled (HDD) pipelines.

While HDD pipelines are a critical and successful tool, operators must take a comprehensive approach to improving safety. PHMSA’s pipeline safety Integrity Management regulations require all operators of pipelines located in environmentally sensitive areas (“High Consequence Areas”) such as river crossings to carefully monitor their systems and take extra precautions to prevent and mitigate the potential impacts of accidents in such areas.

In April 2015, PHMSA issued an advisory bulletin to ensure operators were aware of the inherent risks associated with river crossings and remind them of the need to take extra steps to protect such environmentally sensitive areas.

III.      PRINCIPLES FOR REAUTHORIZATION

A critical part of PHMSA’s safety program is to continually strive for improvement and to find new ways to raise the bar on safety. PHMSA will continue to improve safety through the

development of data-informed regulations, investment in research and development, education and outreach, and by enhancing inspections and enforcement.

A. Incentivize High Performance Among State Partners

Through agreements and certifications, states assume authority over more than 80 percent of intrastate gas and hazardous liquid distribution and transmission pipelines by inspecting and enforcing both Federal and state regulations.  PHMSA supports pipeline safety by providing grant funding to support state damage prevention programs and technical assistance related to pipeline safety issues.

It is critical that state partners participate in activities that benefit pipeline safety on a national basis. Such activities include programs like PHMSA’s Pipeline Safety Mentoring program, which pays for state inspectors to travel to and observe inspections being conducted by Federal or state personnel, service on pipeline safety standards setting committees and work groups.

B. Establish A Workforce to Address Evolving Safety Challenges

Thanks to resources provided by Congress, PHMSA’s pipeline safety program is growing. In FY 2015, Congress funded 109 new positions (93 of those in our Field Operations), nearly a 50 percent increase in the size of PHMSA’s pipeline safety program. PHMSA has hired 91 percent of the new positions and is continuing to bring new staff on board over the coming months.

PHMSA has developed a robust recruitment and outreach strategy that uses the hiring authorities we currently have available, and is also developing new partnerships with colleges and universities with engineering programs to help the agency recruit for these critical positions.

Even so, the dynamic energy market means that PHMSA frequently has to compete with industry to hire engineers and other technical experts. Direct Hire Authority would complement our recruitment efforts by reducing the agency’s time to hire from more than 100 days to less than 30 days.

As PHMSA increases its workforce, training is critical to ensure the highest possible level of safety.  PHMSA is enhancing training opportunities for both Federal and state inspectors by tailoring training and delivering the right mix of classroom and distance learning to provide an efficient and effective training program. Federal and state inspectors train side-by-side at

PHMSA’s Training and Qualifications Center in Oklahoma City, Oklahoma. This year, PHMSA hired a new Director of Training at PHMSA’s Training and Qualifications Center and developed a new pipeline safety inspection boot camp. The first boot camp courses are scheduled this month for new Federal and state inspectors.

As PHMSA carries out this hiring surge and looks ahead to reauthorization of the pipeline safety program, the agency is committed to using the resources Congress has provided to stay ahead of industry trends, strengthen state partnerships, and ensure the highest safety standards.

C.  Balance Composition of Advisory Committees

The rulemaking process is methodical and transparent to ensure that new rules are effective, efficient, and reflect feedback from all stakeholders. In addition to advancing the gas and liquid rules, PHMSA is working to balance representation on the gas and liquid pipeline technical advisory committees to ensure that the committee recommendations are borne out of balanced and robust conversations. While the Department of Transportation continues to make progress in filling vacant seats on these advisory committees, there are challenges retaining committee members, including changes in membership due to new appointments, retirements and career changes.

PHMSA’s advisory committees, as prescribed under Section 60115 of Title 49, United States Code, contain five members on each committee, appointed from three distinct categories. The statute provides the Secretary the authority to appoint to each committee: (1) five individuals from departments, agencies, and instrumentalities of the U.S. Government and of the states; (2) five individuals from the natural gas or hazardous liquid industry, selected in consultation with industry representatives; and (3) five individuals selected from the general public. Section 60115(b)(4)(A) further directs the Secretary to appoint state commissioners to the category of individuals selected from departments, agencies, and instrumentalities of the U.S. Government and of the states.  Adding flexibility to the requirement that the two members of each committee must be members of state public utility commissions would allow PHMSA to fill these positions with individuals who represent State and local government agencies.

D. Use Data to Inform Regulation

To develop rules that are effective in mitigating risk and efficient, PHMSA needs to better understand market trends and collect and analyze reliable and accurate data. To that end, a nationwide integrated database of pipeline inspection and enforcement data is required. PHMSA inspects 20 percent of the 2.6 million miles of pipeline within the United States; the remaining 80 percent is inspected by certified state partners. Linking state and federal inspection, enforcement, and geospatial data, and providing a consolidated national view of all pipeline data, is a vital component in identifying current and emerging risks that drive improved safety performance and informed regulations.  PHMSA’s FY 2017 request includes funding for communication efforts that will enable Federal and State inspectors and pipeline operators to share critical information such as the results of inspections and the condition of our Nation’s aging network of pipelines.

Through PHMSA’s Information Sharing System, Federal and State inspection and enforcement data will be combined with current incident and annual reporting data to provide complete safety records for all pipeline operators and a more complete view of the pipeline landscape to inform future regulation. This information will help inform risk models that will enable the agency to identify pipelines that pose a higher risk of failure and, when combined with information about the location of High Consequence Areas and other locations where a pipeline failure is likely to cause the greatest amount of harm to people or the environment, will give the agency more complete information when assessing significant determinations such as enforcement actions, expected consequences of failures by location or when considering the issuance of special permits.

E. Enhance PHMSA’s Enforcement Capabilities to Maximize Safety

Pipeline safety would be enhanced by a comprehensive enforcement tool to address time- sensitive, industry-wide safety conditions through emergency orders.  Unlike a Corrective Action Order (CAO) issued to a single operator, an emergency order would affect all operators and/or pipeline systems that share a common characteristic or condition. This situation could occur when a particular component, vintage of pipe, or other condition was broadly utilized or installed by industry, and the Department needs to address a safety issue in comprehensive and timely way.

This new enforcement tool would allow the Secretary to issue an emergency order prohibiting a dangerous practice or imposing a requirement when an unsafe condition, practice, or activity in the transportation of gas/hazardous liquids in interstate pipelines poses a threat to life or significant harm to property or the environment.

F.  Drive Innovation to Enhance Pipeline Safety

PHMSA collaborates with industry and other stakeholders on research and development to identify gaps in current technology and reach consensus on the sector’s most pressing challenges. Current law requires that “at least 30 percent of the costs of program-wide research and development activities are carried out using non-federal sources.” Although this 30 percent co- funding requirement is appropriate for technology development projects, it is not appropriate for work that is inherently governmental in nature, such as research and development related to our rulemaking efforts.

Also, PHMSA needs the ability to collect and expend funds needed to recoup costs under cost recovery provisions included in the Pipeline Safety Act of 2011. The Act authorized PHMSA to recover costs for facility design safety reviews where the project has design and construction costs totaling at least $2.5 billion or involves new or novel technologies or design, such as Liquefied Natural Gas (LNG) or new materials. While the 2011 Act allowed PHMSA to recover cost for the design safety reviews, the Act did not authorize PHMSA to expend the recovered funds to take advantage of those cost recovery provisions. PHMSA seeks such authorization.

 

IV.      PHMSA 2021: A NEW DIRECTION FOR PHMSA

Given the dynamic operating environment of the energy industry and advances in technology, PHMSA has updated the transportation agency's strategic framework and developed a bold new vision and mission that better reflect the Agency’s focus on safety, innovation, and trust in the transportation of hazardous materials.

PHMSA is undergoing a transformation to better align resources and capabilities to more effectively deliver on its safety mission: To protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives.

A. Becoming the Most Innovative Transportation Safety Organization in the World

PHMSA’s transformation focuses on strategic investments in people and processes; it restructures the organization, building upon the three key principles of safety, innovation, and trust. The five goals that enable this new framework are to:

• Invest in safety innovation to become more proactive and forward-looking by building PHMSA's innovation and analytics capabilities through partnerships;
• Build stakeholder and public trust through proactive and targeted outreach, engagement, responsiveness, and transparency;
• Cultivate organizational excellence by investing in employees and key capabilities, and strengthening PHMSA's safety culture;
• Pursue operational excellence through consistent and efficient business processes and by transforming how PHMSA leverages data to drive decision-making; and
• Promote continuous improvement in safety performance, including establishment of a framework and approach for implementing Safety Management Systems (SMS) internally and externally.

These changes will transform PHMSA into a next-generation safety agency that invests in people, safety innovation and technology and sets the standard for a strong safety culture.

B.  Leading the Implementation of SMS

Safety Management Systems, or SMS, is the safety policy of the U.S. Department of Transportation. Actively advancing implementation of SMS and a strong safety culture within the pipeline and hazardous materials sectors is the next step in continuous safety improvement for America’s hazardous materials transportation system.  Continuous improvement is the foundation of SMS, and PHMSA is committed to adopting the implementation of SMS within PHMSA and supporting the broad implementation of SMS within the industries we regulate. PHMSA will focus on better informing and controlling risk, detecting and correcting safety problems earlier, sharing and analyzing safety data more effectively, and measuring safety performance more accurately.  These are just some of the benefits of an SMS focus and as PHMSA advances SMS, it is critical that industry share safety data with both regulators and other parts of industry so lessons learned can improve pipeline safety across the entire country. In 2010, the National Transportation Safety Board (NTSB) recommended that the American

Petroleum Institute (API) facilitate the development of a safety management system standard specific to the pipeline industry, in collaboration with industry, regulators and other stakeholders. PHMSA participated in the development of API Recommended Practice 1173, the recently published recommended standard for implanting Safety Management Systems in the pipeline industry.

PHMSA fully supports the implementation of RP 1173 and plans to promote vigorous conformance to this voluntary standard.  The recommended practice is a proactive, system-wide approach to reducing risks and provides operators with a comprehensive framework to address risk across the entire life cycle of a pipeline. The standard promotes pipeline safety, while implementing guidelines for continuous improvement.

Moving forward, PHMSA will leverage the powerful working relationships we have with states and other stakeholders to encourage the widespread adoption of SMS.

C.  Improving Transparency and Public Engagement

PHMSA values and will continue to create opportunities to educate and engage with all pipeline stakeholders to collaborate on ideas and actions that enhance pipeline safety and expand transparency.

PHMSA is committed to making pipeline safety data more readily available and accessible to the American public.  PHMSA maintains a public database of all our enforcement actions as well as operator incident, inspection, mapping, and other safety related records.

In addition to making pipeline safety data available, public education is vital to reducing pipeline risks. It is critical to engage local communities in the pipeline safety processes and decisions that impact their daily lives. PHMSA’s Community Assistance and Technical Services program provides local communities and other stakeholders with a direct line to PHMSA.

V.        CONCLUSION

As PHMSA works diligently to complete the remaining mandates from the 2011 Pipeline Safety Act, we must also look forward to reauthorizing and further advancing PHMSA’s pipeline safety program.   PHMSA’s vision for 2021 is to become the most innovative transportation safety organization in the world. This vision for PHMSA’s safety program will ensure the Agency is responsive and able to address emerging safety risks and other priorities. It will enable PHMSA to invest in the capabilities and skills necessary to utilize data to provide timely and effective regulations, enforcement, implementation of innovative technology, research and development investments, and public outreach to become a more forward-looking, proactive, innovative, and data-driven organization. These and future changes will transform PHMSA into a next- generation safety agency and enable PHMSA's staff and other stakeholders to take advantage of new and exciting opportunities to advance transportation safety. We look forward to working with the Congress to continue to enhance PHMSA’s safety mission.

Thank you again for the opportunity today to discuss PHMSA’s pipeline safety program.