Attn: Pipeline and Hazardous Materials Administration
Docket Number: PHMSA-2021-0039
I am writing to express my strong support for PHMSA's Advanced Leak Detection rulemaking as necessary and consistent with the department's statutory authority. It is my belief that public safety means keeping the product in the pipeline, and this rule's requirements to monitor and repair pipeline systems and prevent emissions conveys substantial health, safety, and climate benefits.
This rule is an important recognition of the serious nature of leaks on natural gas pipelines. For too long, leaks and venting were considered operationally normal for gas pipelines, but we know more now about the serious health, safety, and climate impacts of methane emissions. It is also true that environmental justice communities experience the impacts of climate change and pipeline leaks at a disproportionate rate. Beyond explosions and fires, which have killed or injured hundreds of people, emissions have been extremely detrimental to public health and climate. Methane is an extremely potent greenhouse gas with 80 times the global warming power of carbon dioxide in its first 20 years. We should be expediting policy that mitigates further GHG emissions and protects our infrastructure, natural resources, and public health.
As proposed, there are a few issues I would like to see addressed by PHMSA in the final rule. First, this rule should require the mitigation of intentional emissions. Operators should not be allowed to use scheduled maintenance activities as justification to release massive amounts of methane into the atmosphere, especially when mitigation technologies are available and already used by many operators. Second, all leaks should be considered hazardous, regardless of size. While "small" or seemingly "non-hazardous" leaks have been discounted for decades, we now know that cumulatively, these leaks add up. Over time, the effects of those small leaks are large and impactful to both humans and the environment, including our climate. Third, as proposed, these rules would not cover all gathering lines. Research shows that gathering lines contribute an outsized role in overall pipeline methane emissions and are leaking at a rate that exceeds estimates. These new regulations should cover all gathering lines to ensure that the largest methane emitting sources are reducing their emissions. Lastly, the rule's proposed reporting standard of 1 million cubic feet is much too high to meet the agency's climate goals and protect public safety. I would like PHMSA to consider coalescing its proposal to match EPA's subpart W greenhouse gas reporting standard for large release events, which places the threshold at 500,000 scf of natural gas.
In recognition of these concerns, I ask that PHMSA promulgate the rule as expediently as possible. Thank you for the opportunity to comment on this important matter.
Sincerely,
[your name]