There is a wide range of practice among pipeline operators right now. Some RA is admittedly in need of improvement, not yet meeting the intent of the IMP regulation. However, I believe that is not due to lack of good intention, but rather incomplete understanding of risk. Risk is a relatively new concept, and is not easy to fully grasp. To address PHMSA’s concerns, we as an industry need to improve our understanding of risk and how to measure it.