Working with you to protect the environment for wildlife September 18, 2020 Sharon Weber Massachusetts Department of Environmental Protection 1 Winter Street Boston, MA 02108 Submitted via email:
[email protected] Program review of the 310 CMR 7.73: Reducing Methane Emissions from Natural Gas Distribution Mains and Services regulation Dear Ms. Weber, Thank you for the opportunity to submit our comments on the program review of the Reducing Methane Emissions from Natural Gas Distribution Mains and Services regulation. Please accept these comments from Berkshire Environmental Action Team (BEAT) and it’s No Fracked Gas in Mass program. BEAT works to protect the environment for wildlife in support of the natural world that sustains us all. No Fracked Gas in Mass works to stop the expansion of fossil fuel infrastructure in the Northeast states and to promote energy efficiency and sustainable, renewable sources of energy and local, permanent jobs in a clean energy economy. In answer to questions asked by DEP at the Stakeholder Meeting: ● Should the decreasing annual emissions limits be extended beyond 2020? Yes. With even the LDC spokesperson agreeing at the stakeholder meeting, continuing decreasing the annual emissions limits should be the bare minimum baseline scenario. If anything there should be a steeper rate of incremental decrease in emissions each year while we phase out fossil fuels to comply with our state’s 2050 Decarbonization goals1. 1 “Determination of Statewide Emissions Limit for 2050,” Karen Theoharidies, Executive Office of Energy and Environmental Affairs. April 20, 2020 https://www.mass.gov/doc/final-signed-letter-of-determination-for-2050-emissions-limit/download ● What are the most appropriate emission factors or other metrics to determine emission limits and evaluate progress? The current method is to only count known leaks from specific utility-identified self-reported locations.