Advocacy Comments & Filings

GPA Midstream sent a letter to leaders of the House Energy Subcommittee expressing support for the subcommittee's markup of PHMSA pipeline safety reauthorization legislation.

GPA Midstream asked EPA to clarify net heating value (NHV) monitoring exemptions under Subparts OOOOb and OOOOc, confirming operators need not conduct monitoring when documented engineering analysis shows inlet gas cannot fall below minimum NHV requirements. The request seeks consistency between EPA's regulatory text, guidance and reporting.

GPA Midstream and INGAA submitted comments supporting the PHMSA proposal to adjust annual report deadlines for gas distribution, gas transmission, regulated gas gathering, Type R gas gathering, underground natural gas storage facilities, and liquefied natural gas facilities, as well as National Pipeline Mapping System submissions. Under the PHMSA proposal, the annual deadline would move from March 15 to June 15.

GPA Midstream filed comments supporting PHMSA's proposed rulemaking, “Pipeline Safety: Integration of Innovative Remote Sensing Technologies for Right-of-Way Patrols on Gas and Hazardous Liquid Pipelines”

GPA Midstream, API, and LEPA sent a letter to PHMSA supporting the agency's proposal to update its Part 195 corrosion control regulations to clarify that operators can conduct rectifier checks remotely as long as the operator also physically inspects each device at least once each year.

GPA Midstream and INGAA submitted comments to PHMSA supporting the agency's Notice of Proposed Rulemaking, which addresses previous comments from the associations and would remove ambiguity and an unnecessary compliance step for maximum allowable operating pressure reconfirmation activities.

In a letter to the U.S. Department of Energy, GPA Midstream and a coalition of industry trade groups and businesses urged the the agency to extend compliance dates for energy efficiency standards for residential natural gas and propane furnaces and commercial water heaters. The coalition also recommended that DOE initiate rulemakings to amend or revoke regulations currently in place, which harm consumers economically by leaving them with fewer appliance options that meet their household or business needs.

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.