Tuesday, May 5 – PIPELINERS PODCAST – EPISODE 126 – SKIP ELLIOTT sponsored by Energy Worldnet
The Pipeliners Podcast is honored to speak with PHMSA Administrator Howard “Skip” Elliott about his role as a President-appointee overseeing pipeline safety at the federal level.
In this conversation with host Russel Treat, you will learn about the role of PHMSA in the federal government, what is required to close the small gap in pipeline safety to reach the industry goal of zero incidents, the circle of how technology, standards, and rulemaking interact, and the opportunity for advanced pipeline safety testing programs at the Transportation Technology Center.
We encourage you to listen to this informative episode and share the podcast with other pipeline professionals that are interested in growing their capabilities to drive toward zero incidents.
Russel Treat: Welcome to the Pipeliners Podcast, episode 126, sponsored by Energy Worldnet, a worldwide service provider to the oil and gas industry, making the world a safer place by providing pipeline operators and contractors innovative technology for operator qualification, safety training, content authoring, and guidance as pipeliners operate in compliance with PHMSA, OSHA, and other regulatory requirements. To find out more about Energy Worldnet, visit energyworldnet.com.
Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now, your host, Russel Treat.
Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time, and to show that appreciation, we’re giving away a customized YETI tumbler to one listener each episode. This week, our winner is Gaga Saiini with ExxonMobil. To learn how you can win this signature prize pack, stick around to the end of the episode.
This week, our guest on the Pipeliners Podcast is Skip Elliott, the Administrator for PHMSA. Without further introduction, let’s jump right in.
Russel Treat: Skip, welcome to the Pipeliners Podcast.
Skip Elliott: Thanks, Russel. I’m glad to be here today.
Russel: It’s a pleasure for me, for sure. I’d like to ask maybe you can tell us a little bit about your background and how you got into pipelining as a way to start.
Skip: I’d be happy to. Actually, as most people know, I’m a longtime railroader. Actually spent 40 years in the freight rail industry and retired in March of 2017.
Interestingly enough, I had a lot of different opportunities in the railroad. It gave me an opportunity to learn how to manage organizations. And, do as many leaders do, and try to do well multi task.
How I got into pipelining, I guess perhaps the most interesting way to answer that is it came along with my background in hazardous materials. As you know, the Pipeline and Hazardous Materials Safety Administration is really two modal administrations in one.
You’ve got the 2.8 million miles of the nation’s pipeline system, transmission, gathering, and distribution. That’s enough to go around the earth 110 times.
Russel: I did not know that number. [laughs]
Skip: PHMSA is also responsible for 1.2 million shipments of hazardous materials, by all modes of transportation, each and every day. That’s 14 shipments every second. We also have the responsibility to promulgate all the hazardous material rules for all modes of transportation.
My real background is in hazardous material transportation safety. You might say that the pipeline job came along with it.
Interestingly enough, because of my background in the railroad, the Office of Government Ethics saw fit for me to have a two-year recusal on just about everything that had to do with railroad. I had to focus really predominantly on the pipeline side. That’s probably how I get to be known as the pipeline guy.
Russel: My interpretation. By becoming a railroad expert and retiring out of that business, you ended up having to focus on pipelines and hence got drug into pipelines.
Skip: Right. I remember going through — before my confirmation hearing — I went around the week before the confirmation hearing, and meeting with all the members of the Senate Commerce Committee so they could ask questions of me before the hearing.
I remember one of the questions, really from one of the Senators saying, “You really don’t have much of a pipeline background, do you?”
I found myself explaining, with great detail, the similarities in distribution networks between the U.S. pipeline system and the U.S. railroad system. When you think about what they do in their real basic essence, about moving commodities from origin to destination, in the pipeline industry, it’s predominantly gas and oil, flammable materials.
In the rail industry, it’s basically thousands of commodities, including hundreds of different types of hazardous materials.
Russel: I’ve often thought that the liquids guys, particularly the guys that are doing refined products and sending batches, that’s a lot more like running a railroad than it is like running a pipeline, per se. There’s probably a lot more in common in those two industries than different. Certainly, the hazardous materials aspects of that is very common across those two things.
Skip: I must have done a pretty good job answering that question for that Senator because I don’t recall any really hard questions from him during the confirmation hearing. I must have satisfied his question.
Russel: Maybe we’ll transition a little bit and talk about what does PHMSA do. Our listenership is mostly folks that work in the business. Their experience with PHMSA is largely from a perspective of being audited. I know that’s one aspect of what the agency does, but it’s really not the mission.
Maybe talk a little bit about the mission and how you view it and what you try to communicate to the employees at PHMSA.
Skip: Russel, that’s a very, very important question. Perhaps the way to do that is compare how the Pipeline and Hazardous Materials Safety Administration fits within the larger overall Department of Transportation. PHMSA in and of itself is one of the smaller modal administrations at DOT, but we probably have one of the more pure safety responsibilities.
We have dollars that go towards R&D and grants, but unlike some of the other larger modal administrations that deal basically predominantly in issuing grant dollars that go to help improve the nation’s transportation infrastructure, we really just focus on safety.
Russel: If I might interrupt you, I just want to ask you to define a term. That’s modal administration. What does that mean, modal administration?
Skip: That’s probably DOT’s fancy way of saying the individual transportation safety entities within DOT. A modal administration would be, in our case, the Pipeline and Hazardous Materials Safety Administration, PHMSA or whatever variation of PHMSA you want to call it, Federal Railroad Administration, Federal Transit Administration, Federal Aviation Administration.
Russel: Each of those would be a modal administration, a sub-administration…
Skip: Beneath the office of the Secretary of Transportation.
Russel: I think we all need translation help when we start getting through the government lingo. [laughs] I’m sorry, go ahead, please.
Skip: From a formal mission part of it, the formal mission for PHMSA is to protect people and the environment by advancing the safe transportation of energy products and other hazardous materials that are essential to our daily lives. When you think about that mission, that’s a pretty meaningful mission.
There’s a lot to that, but, again, I think what really sets us apart is we’re a relatively small modal administration, about 580 employees. Split 50 percent that work in Washington, D.C. and 50 percent that work in our region headquarters spread throughout the United States. I guess the best way to say that about PHMSA is we’re a safety agency.
We focus on the nation’s pipeline systems, and we focus on the safe transportation of other hazardous materials by all modes of transportation. We do that through a number of ways. Yes, you’re right, we do a lot of inspections and investigations.
That’s kind of the core of our mission, to ensure that the regulated community both from design, to construction, to operation and maintenance are following the hazardous material regulations and the pipeline safety regulations. We also have a rulemaking responsibility that comes along with that.
Russel: Right, and the rulemaking process is kind of advanced civics, and it’s where for many of us the real work of the government meets the work of the governed, if you will. To me, it’s a really fascinating process. I’ve been learning a lot about it in the last few years, particularly since I started this podcast. Tell me a little bit about how you view rulemaking and how that supports the mission.
Skip: Well, again Russel, that’s a great question. I will tell you that in my 40 years in the freight rail industry and spending a significant amount of time in Washington testifying and visiting members of Congress, I thought I knew a lot about the rulemaking process.
When I actually became the administrator of PHMSA, I realized how little I actually knew about the rulemaking process and how complicated and convoluted it really can be, and how challenging sometimes it can be with changes in administrations.
For us, the rulemaking process, again, focuses not just on pipeline but on hazardous material transportation safety. In any given day we’re probably working on 30 different rulemakings pretty much equal between pipeline and hazardous materials.
As you know, I think there has been a lot of interest over the last several years about a number of incomplete mandates that go back to 2011 and 2016, the Pipeline Safety Reauthorization Act.
It was probably one of the first lessons I got after I was confirmed in my first go-around of hearings, how it was made very clear to me that we needed to move forward the mandates.
Russel: I listened to those hearings, and, yes, I would assert that it was made very clear.
Skip: Well, I listened closely. Then what happens after those hearings, I think is every bit as important. I spent a fair amount of time going back and meeting with members of the committees and the subcommittees. I really understood this was not necessarily one side of the aisle or the other, but both sides of the aisle really wanted PHMSA to focus on getting those mandates done.
There were quite a few of them, there were probably about 30 at the time we really needed to focus on. We set about doing that, and I give great credit to the rulemaking team and the support teams at PHMSA, because it took us a little while, but I think now we can hold our heads up high and say that we’ve really done a good job.
Matter of fact, I think we may hold the record at DOT because it was about four or five months ago, we actually issued three final, important final pipeline safety rules on a single day. Since then we’ve issued one more final rule and another notice of proposed rulemaking.
Russel: That release kept me and a lot of other people in the pipeline business up late that night reading the release.
Skip: That will also tell you, for example, one of the original mandates that we issued dealing with the gas transmission side of the regulation, had been affectionately referred to as the “mega rule.”
Understanding just how difficult it would have been to move that rule through as it stood, the team, the pipeline safety team under the good leadership of Alan Mayberry, who is the associate administrator, I think really made a good, smart decision that that rule needed to be cut into sections.
Actually, we cut it into three sections, but what we did was move the first part that really was the heart of the mandates, and I think that was an important first step for us to get those mandates through and then we could focus on the rest of the rule.
Russel: I want to transition a little bit in this conversation about rulemaking, because rulemaking relates to how PHMSA is a safety agency, if you will. And, that relates to safety management. Of course, there’s a lot of talk in the pipeline world about safety management systems and about Pipeline SMS.
A lot of companies are working to adopt it. I’d like to kind of get your take, if you might, about how does being a safety agency related to or not relate to for that matter, safety management systems?
Skip: We are, if nothing else, a fact-based safety agency. We look at data, we look at numbers, and we try not to be diverted from anything else other than the facts.
I think one of the facts that sets the foundation when we talk about the nation’s pipeline system and the safety that goes with it, is that we are truly at a 99.997 percent safe rate of moving products through pipelines each and every day.
As I said, that’s 2.8 million miles of pipeline, and that’s trillions and trillions of barrels a year. My 40 years in the railroad taught me — because in 40 years in the railroad, which in and of itself, was a pretty unforgiving place, and it still is today — I had the opportunity to witness first-hand some of the changes that come when an industry such as the railroad started to change its culture. It’s not just the culture, the leadership but the culture of all the employees about safety.
I really do believe, and I’ve said it many times that the only way we’re going to get that last .003 percent that we’re looking for is not through more prescriptive regulations, although there will always be prescriptive regulations, and there will also be additional performance-based regulations.
I do think that the next-step change in safety, the thing that’s going to get us to my ultimate goal, which is zero incidents, is going to be through changes of culture through safety management systems. Some of the most interesting conversations that I have today with my colleagues in the oil and gas pipeline industry is to hear their commitment to safety management systems.
I think as an industry, they really understand the value, and we’re right with them on that. Regulations will always play a part. We will always have regulations that we feel are necessary. Congress will always tell us that there are regulations that we need to move through.
I will tell you that, ultimately, it’s going to be through the potential change that we can make through safety management systems on the culture that’s going to get us that last bit of safety. When you think about it, it’s actually a marvelous achievement that the oil and gas pipeline industry has arrived at to be able to say 99.997 percent.
However, the trouble with that is what we see and what garners most of the attention on Capitol Hill and through the media are those infrequent occurring but high-consequence incidents. That still happens today.
Russel: Yeah, the high visibility. The ones that get the other stakeholders surprised, I guess is the way to say that.
Skip: For me, one casualty, whether or not it’s an injury or fatality, any kind of impact to the environment, as long as those things happen even though they’re infrequent, we always have to do better so that we can get better.
Russel: Right. At least in my experience, the cultural change is more challenging than the technology change. I would say, I’ve been in the oil and gas world for 30 years. I’ve certainly seen a very material shift in just attitude about safety. I think we probably need another material shift to get that last .003 percent, but I’m not sure I know what that shift is.
I think it probably has something to do with technology. What would be your thoughts about technology and what’s the role PHMSA plays in that domain?
Skip: Russel, I want to step back just a second and make one point about safety management systems. I think companies that are committed to safety management systems — and we had a discussion recently that’s the same with integrity management systems — I think we see a spectrum of people that are wholly committed to doing as good as they can, and then those that are not.
When you talk about, ‘What do we have to do different with regards to culture change and safety management systems?’ for me, I think it’s not necessarily many, many of the really good companies that I get the opportunity to work with on a regular basis, but I think it’s their subcontractors.
I think as you go down through the supply chain, we are so dependent in today’s industrial environment — the dependence that we have on subcontracting and subcontractors to do the work, at least from my experience, I think that’s where we really have to focus.
I worry more about how a good safety management system permeates not through the parent company, but down through the subcontractors that everyone is so dependent upon. I think that’s a pretty difficult challenge.
Russel: I would agree. As you’re making the comment, I’m thinking about myself, and I would qualify as a subcontractor in this industry. What I would say about that is there’s a lot of challenges that we face as subcontractors because each of the operators has certain different details that they want you to follow. That can be a real problem when you’re trying to train crews and train people and such.
Safety management, we have to get there as an industry. We can’t get there as operators, we have to get there as an industry. It’s all of us together that are going to raise that tide.
Skip: Now, how does technology connect with all of that? I have said from my first days at PHMSA that I really think that the counterbalance to safety management systems, the thing that will help move safety forward long besides this change in culture will be the advancements in technology that we’re seeing.
Again, I draw from my railroad experience. I used to sit with every new employee that came to work for the departments I oversaw in my time in the railroad. I had a stock phrase. I said, ‘I wish I were 30 years younger so I could start my railroad career all over again.’ Because what I anticipate seeing in the railroad industry with regards to innovation and technology over the next 5 to 10 to 15 years, in my opinion, will eradicate all the significant causes of major derailments that have impacted people and the environment.
I see the same analogy in the pipeline industry. I am absolutely amazed at the speed and the rapidness that technology and innovation is moving in the oil and gas pipeline industry. We get criticized, rightfully so, for not being able to keep up with that technology.
As technology advances, especially technology that’s going to improve pipeline safety, I think the bureaucracy that exists does not allow a government agency such as ours to be able to allow that new technology to go into widespread use as quickly as the industry might like.
I think the other point that one of my colleagues who’s here with me today mentioned this morning, is that the other trouble is the comparison of technology and rulemaking.
One of the reasons that we don’t want to regulate technology is because the length of time that it takes for a government agency such as PHMSA to begin and finalize a regulation, the pace of technology will so quickly outpace it that by the time you finalize the rule it’s obsolete. That’s not good.
Russel: Basically three major iterations in technology lifecycles in one rulemaking lifecycle.
Skip: I do think we have, and we’re working very hard at PHMSA, and will keep working on it, to find ways to encourage and support technology research and development innovation, and to be able to move that from innovation to test to actual application faster than we’re able to do it today.
Russel: I would say, being a technology person myself, that the challenge in this day and age is not the technology, the challenge is in getting it from proven in the lab to useful in the field.
That to me is much more challenging than just getting something proven in the lab, because as we all know, there’s the domain of what we know and what can control in the lab, and then there’s the domain of what we don’t know and will discover in the field. One is significantly larger than the other.
Skip: Very true, very true. If you look at the fast pace of improvements in inline inspection technology gathering the information, running the device through the pipeline is one thing, but then also matching that with the capability and big data to be able to be more accurate in looking at the data that’s coming in to be able to give the operator that indication that they need.
And in turn, that we can have the assurances that what is being seen by the inline inspection device is good enough so there doesn’t necessarily have to be a physical inspection of the pipeline.
Russel: There’s a whole series of podcasts on that little subject right there. It’s a big deal, and we’re going to continue to get better tools. Not just in integrity, but in other areas and they’re all going to generate more data and they’re all going to require more analysis to make that data useful.
That has to be automated and systematized in order to move the needle, if you will. It’s a big bite, I’ll say it that way.
Skip: Add to that, we need to make sure that all pipeline can be piggable, too, so that as this technology advances, we can apply it.
Russel: I get that point, and all pipeline is inspectable, and economically so would be more the way I would frame that. There’s somebody in a garage some place working on a technology that’s going to do inspection without running a pig inside the pipeline. If I’m lucky I’ll see that before I retire, right? I think it’s very difficult.
Certainly, technology’s going to help move the needle, but it’s very difficult to predict what that technology’s going to be. It’s probably something that none of us can come up with right now, that’s really going to be the change driver.
Skip: I think that’s almost the fun part about technology, is that you’re right as we sit here having this discussion that there are smart people out there coming up with what the next step change in safety technology in pipelines is going to be. That’s something we need to be encouraging.
Russel: Yes, absolutely. From PHMSA’s perspective, we had talked about this off mic a little bit, and I thought your view of this was really interesting. You talked a little bit about rulemaking and standards and technology, and how that kind of all relates. Maybe you could talk about that a little bit.
Skip: I think it goes back to some of what I alluded to earlier. There’s a place for all three, an important place for all three.
I do think at least when you look as far as we have come today on the nation’s system of pipeline and the safety that goes along with it, is that a lot of the standards I think that the industry is developing really provides more of the roadmap directionally that I think the industry needs to move in order to have the flexibility, the latitude to keep up with the technology that’s going to continue to drive the standards.
To me it’s like a self-licking ice cream cone. That’s a term I use.
Russel: A self-licking ice cream cone? I’m going to co-opt that term, I’m probably using it again.
Skip: You have to have all three. Technology standards can drive technology, or technology can drive standards. Rulemaking helps formalize the standards.
To me, it’s this circle that if we do it right — in other words, from a regulatory point of view — if we do what we need to do and that’s to recognize technology and the standards that a lot of the trade associations that focus on standards come up with, our job is to basically make sure that we keep up with those standards and we formalize them where we need to formalize them. We recognize them in regulations that these standards are what we want the industry to follow.
We also have to understand that with the pace of technology, that self-licking ice cream cone is going to happen quicker, and quicker, and quicker, and we have to figure out how we can make sure that that works well.
Russel: My frame, if you will, is that one of the benefits that PHMSA provides in the rulemaking is they kind of level the playing field, and they move everybody in a direction. The challenge with it is it’s slow and painstaking, which is actually a good thing.
Then you have technology on the other side that’s running way out in front of all that, and there’s this kind of constant tension, if you will, between the two. Again, I think that’s a good thing for the industry.
Skip: Remember, we set minimum standards. We are always, always encouraging the industry to go beyond those minimum standards. So that’s a factor. It is a built-in part of the rulemaking process that we have that we do set just those minimum standards.
We know that in intrastate pipelines we have a number of states that have an agreement with PHMSA that allows them to do the inspections of the intrastate pipelines. We know that many of those states have gone beyond the minimum standards and have applied those at the state level. That’s the kind of thing we encourage.
Each state is unique. They have their own nuances and what they see as the most valuable way to proceed with pipeline safety. We encourage that. As long as there isn’t conflict with the federal regulations, to go beyond it to help make a pipeline system safer is something we encourage.
Russel: I wanted to wrap this conversation up and give you an opportunity to talk about what PHMSA is doing out at the TTC. Maybe you could talk about that a bit?
Skip: I could talk hours about what we hope to accomplish at the Transportation Test Center.
Skip: For your listeners, this is all born out of the discussion that Russel and I have had in this conversation about the need for PHMSA to be able to move more quickly, to be more of an enabler for advancements in innovation and technology.
The Transportation Technology Center is located just outside of Pueblo, Colorado. It is a DOT-owned facility, actually owned and overseen by the Federal Railroad Administration. If you go back, really to the mid-’60s when the site was first conceived and started to be built, it actually was the site where DOT did its first testing of the Maglev system.
After those tests were done, the FRA took over the site and for 40-plus years they’ve actually had a very good working relationship with TTCI, which is a wholly-owned, for-profit entity of the Association of American Railroads.
What the site has turned into — and it’s 52 square miles with over 50 miles of railroad track — is this proving ground for the rail industry to test in real-time and at a very, very large scale the ability to advance rail safety innovation and technology.
Russel: Yeah, that is a big scale.
Skip: The model to me is something that fits very nicely with what we hope to do in the pipeline industry. There was an article written a few weeks ago after we talked about what we hoped to do at the Transportation Technology Center. We did some discussion at our recent pipeline safety R&D forum.
One of the attendees from one of the trade associations wrote about it, and I think made a very valid point, but if you look at most DOT modal administrations — Federal Highway, Federal Railroad, Federal Aviation — they all have large test sites. The oil and gas pipeline industry does not.
We’re proceeding much faster than I ever imagined to basically start work on developing part of this 52 square miles to allow the oil and gas industry to basically test and bring their innovations out, and be able to see at a scale that today is not available.
Case in point, some of what we envision out there is a piggable loop track that would be somewhere between a quarter to a half-mile, maybe several different diameters, being able to be propelled by compressed air. And, to have interchangeable sections of the pipe so you can put in different types of anomalies.
The sole reason for this is — as in this one case — as inline inspection technology advances, we need certain assurances and certainties that the inline inspection device does what it can do. This will give us through a third-party validation that may go on, the attestation that we need that in fact this does what it’s supposed to. Then, that gives us the certainty that we need to allow a pilot project or a much larger scale use of this.
We also envision a site that would have small-scale L&D, LNG distribution pipeline area. The ability to do underground detection of both liquid and gas pipelines using crawlers, drones, fixed wings, or satellites. Kind of an area that would focus on welds and corrosion, cathodic protection.
I didn’t know this until I took this job, but one of the more common concerns that the pipeline industry is the damage to pipe while it’s being transported in rail transportation.
One of our early projects that PHMSA is going to fund out there — because they have the infrastructure there from the railroads — is actually we’re going to do stress-testing of pipe on railcars. In their rail dynamics shed, they have the ability to do these vibration tests with full-scale railcars.
The other test area we’re going to do — because the site lends itself with it with its already existing infrastructure — is to do real-time stress-testing of uncased pipe under railroad right-of-ways, which has been a sore subject for pipeline operators for many years.
The school also has a world-class emergency responder fire training school. We envision one of the things we’ll work with soon out there is basically create the ability for emergency responders to also train responding to gas pipeline incidents.
We’ve got about — depending on the day — 12 to 15; we envision 12 to 15 different sites. Here’s the important thing about it. This, we hope, will be much like the railroad model. We hope it will encourage the oil and gas industry to use this large-scale facility to basically be able to move more quickly and to do a better job of testing the new tools they’re bringing into the market.
Over the five years that we envision building this facility out, much of the prioritization is going to be set by the industry. They’re going to be the ones that really work with our talented engineers at PHMSA to decide, ‘what are we going to build first, how are we going to build it, what do we want to be able to test.’
Russel: My personal take on that is that something of that scale, given the resources required to build it and maintain it and operate it — much less the things to curate the testing and the data and all that — it’s really outside of what industry can do by itself.
It’s the kind of thing that government really can do better than industry can do. Not to mention it sounds like you’re going to have plenty of cool toys. I’d like to come play. [laughs]
Skip: It truly is going to be a partnership. Again, if we follow the freight rail model and the fact that the overseers of the facility is not the Federal Railroad Administration, it is a railroad entity.
We really envision that we’ll be doing our own R&D, but interested folks from the oil and gas industry can go out and work with the site managers and work independently and not necessarily have to worry about any interference from PHMSA.
We just want to create the playground, so to speak, that will allow some of this fast pace of technology and innovation to move more quickly, and to give us the assurances we need more quickly so that we can get this out into actual application.
Russel: Last question. I want to give you an opportunity to just speak to the audience and administrator to pipeliner, what would you like to say to wrap this all up?
Skip: Great question, Russel. Thank you. The first thing I need to do is really acknowledge the extremely talented and professional women and men that make up the U.S. Pipeline and Hazardous Materials Safety Administration. It has been an absolute joy to work with them each and every day. I admire, to a person, their commitment and dedication to our important safety mission.
I have to say the same thing to the women and men in the U.S. oil and gas pipeline industry. I’ve had the ability over the last two-and-a-half years to interact in headquarters, in control rooms, at rupture sites. I have been tremendously impressed with that level of dedication and safety and commitment that I see from the oil and gas pipeline industry.
To those of you that might be listening to this conversation, thank you for that dedication. We have a simple goal at PHMSA. That’s to get to zero incidents. That’s the goal that we all need to really focus on if we’re only talking about .003 percent. I would ask you all to stay focused on helping us at PHMSA work with you to achieve that goal.
Russel: That’s great. Thank you very much, Skip. I appreciate you coming on the podcast. Been an honor. I’d like to have you back when you have more to say.
Skip: Russel, thank you. Believe me, I have more to say.
Skip: Thank you.
Russel: I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Skip Elliott.
Just a reminder, before you go, you should register to win our customized Pipeliners Podcast YETI tumbler. Simply visit pipelinerspodcast.com/win to enter yourself in the drawing.
Thanks for listening. I’ll talk to you next week.
Transcription by CastingWords