Advocacy Comments & Filings

After careful review by GPA Midstream subject matter experts, the association submitted comments to the Bureau of Land Management recommending changes to the agency's proposed revisions to its commingling rules. As drafted, BLM's proposed revisions are vague, unnecessarily burdensome, and, in some cases, even more restrictive than the measurement requirements found within the current rules. GPA Midstream's comments offer suggestions to address these issues.

GPA Midstream submitted comments to the U.S. Fish and Wildlife Service in response to the agency's status review for the lesser prairie-chicken. The comments urge FWS to evaluate population data in the context of long-term trends, recognize the effectiveness of existing conservation programs, and consider the comparatively limited habitat impacts of midstream energy infrastructure.

GPA Midstream submitted comments to the Pipeline and Hazardous Materials Safety Administration supporting ExxonMobil’s request for a federal preemption determination under the Hazardous Materials Transportation Act. The outcome has major implications for safe, consistent national transportation of energy products.

GPA Midstream and other trade groups representing pipelines and refineries sent a letter to congressional leaders urging them to end the shutdown at the U.S. Department of Homeland Security and restore normal operations at federal cybersecurity agencies.

GPA Midstream urged Congress to reauthorize PHMSA pipeline safety programs, supporting practical, performance-based regulations that enhance safety, eliminate redundant oversight of in-plant gas piping, and provide long-term regulatory certainty for critical U.S. energy infrastructure.

GPA Midstream filed an amicus brief in American Gas Association v. Department of Energy urging the U.S. Supreme Court to review DOE rules that would effectively eliminate noncondensing natural gas furnaces and commercial water heaters. GPA Midstream argues DOE failed to show the rules are economically justified, relying on flawed analysis that understates consumer costs. The case potentially has far-reaching effects on fuel choice, heating costs, and long-term energy affordability.

GPA Midstream and a coalition of organizations urged the U.S. Senate to pass bipartisan, comprehensive permitting reform. The coalition letter points out that outdated and inefficient permitting processes are delaying critical infrastructure projects, driving up costs, and holding back investment in energy, transportation, broadband, and water systems. The coalition calls for a modernized, predictable permitting system to accelerate economic growth and deliver needed energy infrastructure.

GPA Midstream and a coalition of energy trade associations filed comments supporting EPA’s proposed revisions to its Clean Water Act Section 401 certification regulations. The coalition supports the proposal because it would restore clarity and appropriate limits to the Section 401 process, ensuring reviews focus on water quality impacts and preventing misuse that can delay or block major infrastructure projects.

In response to a letter from GPA Midstream, PHMSA has withdrawn its previously issued response to Paradox Pipeline’s request for a regulatory interpretation concerning Section 114 of the 2020 Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act.

GPA Midstream and a coalition of 84 allied organizations submitted joint comments supporting the U.S. Bureau of Ocean Energy Management's proposed lease sale in planning areas throughout the Outer Continental Shelf.

GPA Midstream filed joint comments with API and INGAA urging PHMSA to base gathering line diameter determinations for steel-reinforced composite pipe on the steel layer, not outer coatings. Clear rules would encourage use of advanced materials that enhance pipeline safety, integrity, and reliability.

GPA Midstream submitted comments to the Environmental Protection Agency and the U.S. Army Corps of Engineers recommending principles to guide the agencies in implementing Waters of the United States (WOTUS) rules consistent with a Supreme Court ruling that struck down many agency rules.

GPA Midstream collaborated with nine other trade associations to submit comments to the U.S. Fish and Wildlife Service, and the National Oceanic and Atmospheric Administration regarding proposed revisions to Endangered Species Act (ESA) regulations.

GPA Midstream and a coalition of more than 80 business and industry organizations sent a letter to members of the U.S. House of Representatives urging passage of the SPEED Act.

GPA Midstream Sends Support Letter for API/LEPA Cost Benefit Analysis