Date: January 31, 2024
To: John Gale, Director of Standards & Rulemaking
Office of Pipeline Safety
U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration
1200 New Jersey Avenue SE
Washington, DC 20590
CC:
Office of Public Engagement, U.S. Department of Transportation
Alan Mayberry, Associate Administrator for Pipeline Safety, Pipeline Safety within the Pipeline and Hazardous Materials Safety Administration
Re: Equitable Access to Gas Pipeline Advisory Committee Meetings
Dear Office of Standards and Rulemaking Director John Gale,
We are writing as frontline community members on behalf of GreenLatinos Colorado, Moms Clean Air Force, and the Protect Our Water Heritage & Rights Coalition that attended the Gas Pipeline Advisory Committee (GPAC) meeting last November to testify in support and strengthening of the Pipeline and Hazardous Materials Safety Administration’s Pipeline Safety: Gas Pipeline Leak Detection and Repair Rule.
First and foremost, we want to thank GPAC for providing the opportunity for members of the public to testify. This rule will have important implications for climate and safety, especially those living closest to gas pipeline infrastructure. We look forward to working with the committee to engage with communities across the country.
Second, we urge GPAC to schedule its second and final review as quickly as possible this February, and in the most accessible format possible, to ensure timely adoption of the rule this spring. PHMSA must act decisively to finalize protective standards for pipeline leak detection and repair, particularly as the agency has failed to meet its Congressionally mandated deadline to complete this rulemaking by December 2021.
To better facilitate transparency and community engagement, PHMSA should make the upcoming GPAC meeting virtual and provide clear testimony times for members of the public. At the November 2023 meeting, the Advisory Committee members and PHMSA staff heard hours of “public” comments from oil and gas industry lobbyists and consultants. But traveling to Washington, DC is both time- and cost-prohibitive for many frontline and environmental justice community organizations and leaders. A virtual meeting is one of the best options to facilitate engagement.
Setting aside specific time for public testimony would allow participants to better prepare and manage schedules.
According to a March 2022 study, leaks on gas pipeline infrastructure disproportionately affect high-density neighborhoods with people of color and lower-income households. Given the importance of this rule to those communities, GPAC would be better served creating a more accessible format to hear directly from them.
Again, thank you for the opportunity to testify last year and considering these comments ahead of the next GPAC meeting.
Sincerely,
Laurie Anderson
Colorado Field Organizer
Moms Clean Air Force
Broomfield, CO
Maury Johnson
West Virginia Co-Chair
POWHR (Protect Our Water Heritage & Rights) Coalition
Greenville, WV
Patricia Garcia-Nelson
Fossil Fuel Just Transition Advocate
GreenLatinos Colorado
Greeley, CO