Comments on Massachusetts’ Gas Distribution Methane Regulation

Michael J. Walsh prepared these comments for the Massachusetts Office of the Attorney General’s response to MassDEP’s review of 310 CMR 7.73. The regulation concerns methane emissions from gas distribution mains and services.

The comments support updated emissions factors and reporting in metric tons of methane. They recommend moving toward measurement-informed leak mitigation, stronger reporting, and pilots for advanced leak detection, with attention to the emissions reductions achieved for ratepayer spending.

This is a separate MassDEP submission arising from the AGO Climate Compliance Plans engagement. The accompanying DPU direct testimony provides additional technical background; its appendices are available from that publication page.