Advocacy Comments & Filings

GPA Midstream and a coalition of more than three dozen businesses and industry groups sent a letter to leaders of House and Senate Armed Services committees recommending exclusion of Section 815 of S. 4784 of the National Defense Authorization Act for Fiscal Year 2027. The measure would prohibit defense contractors, regardless of contract size or industry, from repurchasing stock, paying dividends, or making other capital distributions without a government waiver. These restrictions would discourage companies from participating in the defense industrial base, reduce income for investors and retirees, and establish a troubling precedent of federal intervention in routine corporate governance.

GPA Midstream and allied energy industry trade groups urged congress to enact a comprehensive bipartisan pipeline safety reauthorization measure before the 119th Congress adjourns. This action would ensure that PHMSA has clear congressional direction, modern authorities, and the resources necessary to carry out its mission.

GPA Midstream and a coalition of business organizations urged congressional leaders to bring the Bipartisan American Affordability and Jobs Act of 2026 to a vote and deliver much-needed reform to America's infrastructure permitting system.

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.