In September 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed a regulation to improve the safety of certain gas pipelines. The standards include a suite of reforms to help prevent incidents like the catastrophic 2018 gas pipeline explosions in Merrimack Valley, Massachusetts. In a comment letter, we explain that, while the Proposed Rule and its accompanying regulatory impact analysis are well grounded in applicable statutes and guidance, PHMSA should take further steps to bolster its analysis.
Comments on the Consideration of Climate Benefits in Proposed Rule to Limit Methane Leakage from Gas Pipelines
In May, the Pipeline and Hazardous Materials Safety Administration released a draft regulation to prevent methane leaks from gas pipelines. The agency monetized the climate benefits of the regulation using the social cost of methane, finding that monetized benefits exceeded monetized costs by at least $340 million per year. In our comment letter, we support the agency for applying the social cost of greenhouse gases to estimate the climate benefits of the proposed rule. We also suggest that PHMSA apply additional analysis to each rule using draft updated climate-damage valuations that the Environmental Protection Agency released in November 2022.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to gather additional data on pipeline accidents and fires, including data on injuries, property damage, and loss of natural gas. We submitted comments supporting PHMSA’s efforts to better assess the social cost of accidents and encouraging the agency to estimate greenhouse gas emissions that result from pipeline fires.
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