Date: April 4, 2024
To:
The Honorable Pete Buttigieg, Secretary
The Honorable Tristan Brown, Deputy Administrator, PHMSA
U.S. Department of Transportation
Re: Docket Nos. PHMSA-2024-0005 & PHMSA-2021-0039
Environmental, Public Safety, and Community Organizations Oppose Industry Associations’ Request to Extend the Comment Period on the Proceedings of the Gas Pipeline Advisory Commitee Regarding the Proposed Rule, Pipeline Safety: Gas Pipeline Leak Detection and Repair, 88 Fed. Reg. 31,890 (May 18, 2023)
Dear Secretary Buttigieg and Deputy Administrator Brown:
We strongly oppose the oil and gas industry’s request to extend the comment period on the proceedings of the Gas Pipeline Advisory Committee regarding the Gas Pipeline Leak Detection and Repair Proposed Rule.
The rule is urgently needed to improve community safety and reduce methane emissions from millions of miles of pipelines across the United States. The Pipeline & Hazardous Materials Safety Administration (“PHMSA”) must swiftly finalize protective standards for the use of advanced leak detection technologies and faster leak repair on U.S. natural gas pipelines.
This rulemaking is already far behind schedule. The bipartisan PIPES Act of 2020 directed PHMSA to finalize advanced leak detection standards by the end of 2021. And the Gas Pipeline Advisory Committee was expected to complete its review of the proposed rule in December 2023, but the process was extended to provide for an additional meeting in March 2024.
An extension is not merited, as there has been ample opportunity for stakeholders to provide input to PHMSA on the proposed rule—including oil and gas industry trade groups. First, comments were accepted on the proposed rule in August 2023, and all of the industry groups now seeking an extension filed detailed comments. Second, the industry groups declined to submit substantive comments to PHMSA during the comment period after the first Advisory Committee meeting in November 2023. Third, the industry groups now seeking an extension were present at the Advisory Committee meetings and provided hours of verbal comments at the meetings—in addition to the five industry members of the Committee.
PHMSA should retain the 30-day comment period regarding the Gas Pipeline Leak Detection and Repair Proposed Rule. PHMSA should finalize, as soon as possible, the proposed protective standards to improve public safety and cut methane pollution from gas pipelines.
Thank you for your consideration,
Heidi Leathwood, Climate Policy Analyst, 350 Colorado
V. Sean Mitchell, MSN, APRN-BC, Alliance of Nurses for Healthy Environments-Colorado
Ben Pendergrass, Vice President, Government Affairs, Citizens' Climate Lobby
Natasha Leger, Executive Director, Citizens for a Healthy Community
Clean Air Council
Darin Schroeder, Methane Legal and Regulatory Director, Clean Air Task Force
Hana Vizcarra, Senior Atorney, Earthjustice
Luke Metzger, Executive Director, Environment Texas
Magdalen Sullivan, Attorney, Environmental Defense Fund
Bill Bradlee, Senior Organizing Director, Interfaith Power & Light
Ranjana Bhandari, Executive Director, Liveable Arlington
Celerah Hewes, National Field Manager, Moms Clean Air Force
David Doniger, Senior Strategist, Natural Resources Defense Council
Sr. Joan Brown, Executive Director, New Mexico & El Paso Interfaith Power and Light
Ashfaq Khalfan, Climate Justice Director, Oxfam America
Erin Sutherland, Policy & Program Director/Counsel, Pipeline Safety Trust
Ashley Korenblat, Managing Director, Public Land Solutions
Oscar Simpson, Public Lands /Conservation Chair, Rio Grande Indivisible, New Mexico
Tricia Cortez, Executive Director, Rio Grande International Study Center
Chad Franke, President, Rocky Mountain Farmers Union
Andres Restrepo, Senior Attorney, Sierra Club
Becca Edwards, Climate Action Fellow, Texas Interfaith Power and Light
Julie McNamara, Senior Analyst, Union of Concerned Scientists
Jacki Esposito, Advocacy Director, Waterkeeper Alliance
Autumn Crowe, Interim Executive Director, West Virginia Rivers Coalition
Gwen Lachelt, Executive Director, Western Leaders Network
cc: Associate Administrator Alan Mayberry
Director of Standards and Rulemaking John Gale