Advocacy Comments & Filings

In submitted comments, GPA Midstream asks the U.S. Department of Energy to delay the compliance deadline for water heating equipment and consumer furnace rules, and issue new rulemakings that preserve consumer choice and do not raise costs for homeowners and businesses already dealing with high energy prices. GPA Midstream suggests establishing separate product classes with different efficiency standards so that both condensing and non-condensing appliances remain available to consumers.

In comments submitted to the U.S. Army Corps of Engineers, GPA Midstream suggested ways the Corps could improve the efficiency of the nationwide permitting program.

GPA Midstream supports EPA’s proposal to revisit the RMP regulations. We encourage the agency to adopt a targeted, performance-based approach that focuses on the highest-risk activities and regulated substances — and that recognizes differences among sectors as appropriate. This approach will ensure a highly effective program while reducing undue burdens.

GPA Midstream submitted to PHMSA a rebuttal to certain comments made in opposition to ExxonMobil’s preemption request, arguing that state common law requirements conflict with federal hazardous materials transportation law and undermine national uniformity. The rebuttal defends PHMSA’s authority under the Hazardous Materials Transportation Act and pushes back against opposing claims of federalism and constitutional overreach.

GPA Midstream, API and AFPM filed comments urging PHMSA to overhaul its pipeline safety enforcement procedures to be more transparent, predictable, and efficient. Specifically, we're seeking clearer inspection timelines, automatic disclosure of key enforcement documents, fair treatment of warning letters, and an end to redundant or parallel investigations.

GPA Midstream and other energy trade associations signed a joint letter urging leadership in the US House of Representatives to advance legislation that modernizes the Clean Air Act.

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.