To: Re: PHMSA appropriately uses breakeven analysis to support its conclusion that the

The RIA already explains how the Proposed Rule’s changes could have prevented the failures leading to the Merrimack Valley incident.28 For example, the RIA notes that Columbia Gas of Massachusetts (CMA) did not “promptly or effectively” communicate with the general public.29 Therefore, the Proposed Rule’s provision requiring gas distribution operators to establish communication systems with the ge. [...] When measuring the benefits and costs of a rule, agencies must measure against a baseline, which is an assessment of the way the world would look absent the proposed action.45 Agencies may evaluate costs and benefits against a pre-statutory baseline, which reflects the state of the world in the absence of a regulation as well as the statute that gave rise to that regulation, or they may evaluate c. [...] First, PHMSA cites studies and scientific assessments demonstrating the disproportionate burden of climate change on poorer and predominantly non-white communities, and it notes that the Proposed Rule is expected to reduce the frequency of and mitigate the effects of gas-pipeline accidents, thus reducing methane emissions that contribute to climate change.55 Second, PHMSA notes that older cast-iro. [...] PHMSA Should Also Report the Social Cost of Methane Estimates from the EPA’s November 2022 Draft Update PHMSA appropriately discusses the Interagency Working Group’s (IWG’s) valuations of the social cost of methane to conservatively estimate the Proposed Rule’s climate benefit.73 In addition, PHMSA should strengthen its analysis by discussing the Environmental Protection Agency’s (EPA’s) draft upd. [...] Reporting the EPA Draft Updated Estimates and discussing their strengths would further support the agency’s contention that the benefits of the Proposed Rule justify the costs, as discussed in the RIA’s breakeven analysis.79 VII.