Advocacy Comments & Filings

GPA Midstream filed comments refuting petitions seeking to challenge PHMSA’s preemption of state common law claims related to hazardous material transportation under the Hazardous Materials Transportation Act.

GPA Midstream joined a coalition of more than three dozen industry organizations urging congressional leaders to support passage of Bipartisan American Affordability and Jobs Act of 2026 before the end of the 119th Congress in January 2027. The permitting reform bill would provide necessary permitting efficiencies and certainty for projects requiring federal permits to move forward.

Drawing on the extensive experience of member companies implementing Subpart OOOOa, GPA Midstream recommends that EPA take the following targeted steps to maintain effective emission control while reducing unnecessary compliance costs and to align technical provisions across subparts: Recognize advanced sealing technologies as alternatives to fixed rod-packing replacement intervals where equivalent emission reductions are demonstrated and provide practical approval pathways for those alternatives. Reassess gathering and boosting compressor-station fugitive monitoring using sector-specific operating data and current costs and simplify compliance coordination across applicable federal and state programs. Align outdated technical provisions under Subpart OOOOa with Subparts OOOOb and OOOOc, including requirements governing maximum flare tip velocity design and operation.

GPA Midstream supports a clear, reach-specific "perennial water" standard in formal comments filed with the EPA and the U.S. Army Corps of Engineers regarding the supplemental notice of proposed rulemaking for the "Waters of the United States" definition. The filing argues that federal Clean Water Act jurisdiction should strictly align with year-round surface flows and clear Supreme Court precedent to provide regulatory certainty for pipeline infrastructure development. GPA Midstream's comments outline that federal oversight must explicitly exclude groundwater, temporary storm runoff, and operationally controlled ditches.

GPA Midstream joined a coalition of more than a dozen industry groups in an amicus brief to the Supreme Court in the linked cases KENTUCKY, et al. vs. Environmental Protection Agency and Chamber Commerce, et al. vs. EPA. The court is considering challenges to the EPA's authority to revise national air quality rules under the Clean Air Act before the regular five-year cycle. The brief argues that the D.C. Circuit Court's ruling unconstitutionally strips the administration of its executive authority to reconsider the policies of it predecessor by blocking EPA from factoring in economic costs and practical feasibility.

GPA Midstream supports PHMSA repair criteria updates, urges agency to review technical feedback.

Following the July 2026 GPAC meeting, GPA Midstream and industry allies submitted comments to PHMSA expressing support for the agency's proposal to implement performance-based, technology-neutral regulations allowing operators to observe surface conditions on rights-of-way to achieve the agency's safety objectives.

Following the July 2026 GPAC meeting, GPA Midstream and industry allies urged PHMSA to finalize the proposed $153,600 damage reporting threshold and inflation adjustment mechanism.

Following the July 2026 GPAC meeting, GPA Midstream submitted comments supporting PHMSA's proposal to extend the period within which a rupture mitigation valve (RMV) or alternative equivalent technology installed on a new or entirely replaced segment must be made operational, from 14 days to 90 days after the segment is placed in service.

Following the July 2026 GPAC meeting, GPA Midstream, joined by API, AFPM, AGA, and APGA, filed comments encouraging PHMSA to finalize its proposal to move the annual report deadline for gas distribution, gas transmission, regulated onshore gathering, Type R gathering, underground natural gas facilities, and liquefied natural gas facilities, as well as submissions to the National Pipeline Mapping system from March 15 to June 15.

Following the July 30, 2026 meeting of PHMSA's Gas and Liquid Pipeline Advisory Committees GPA Midstream, joined by API and AFPM, in expressing support for the agency's proposed in-plant piping rule. The proposed amendment would align the Part 192 framework with PHMSA’s longstanding approach to in-plant piping under Part 195, codify longstanding industry practice and agency interpretations, and provide greater clarity regarding the boundary between PHMSA-regulated transportation facilities and in-plant piping systems that are subject to OSHA requirements.

Following the July 2026 GPAC meeting, GPA Midstream, joined by API and INGAA, filed comments supporting PHMSA's proposal to codify enforcement discretion regarding incidental gas gathering lines.

GPA Midstream, API, and Liquid Energy Pipeline Association released a document articulating the midstream industry's commitment to engage stakeholders and communities where pipelines are located throughout the lifecycle of the pipeline.

GPA Midstream supports BLM proposal to modernize federal oil and gas royalty rule

GPA Midstream recommends EPA finalize minor New Source Review permitting requirements