Advocacy Comments & Filings

GPA Midstream and a coalition of 40 industry associations sent a letter supporting the U.S. Environmental Protection Agency proposed update of National Environmental Policy Act implementation procedures, and encouraged EPA and other federal agencies to continue improving permitting, and implementation of digital tools.

GPA Midstream submitted comments to the Federal Energy Regulatory Commission expressing support for the commission's proposed revisions to the blanket certification program under Section 7 of the Natural Gas Act. The association made specific suggestions and recommendations to reflect modern operations and promote efficiency,

GPA Midstream joined a coalition of national industry associations in supporting EPA's proposed revisions to the New Source Review (NSR) preconstruction permitting program. The comments support clarifying that permits are required only before construction of pollutant-emitting equipment begins, allowing non-emitting site work to proceed while maintaining Clean Air Act protections. The coalition also recommends technical revisions to improve regulatory clarity and promote consistent implementation by state permitting programs.

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.

GPA Midstream requested that the Environmental Protection Agency extend the public comment deadline for the National Emissions Standards for Hazardous Air Pollutants: Crude Oil and Natural Gas Production Facilities and Natural Gas Transmission and Storage Facilities; Technology Review and Reconsideration (91 FR 21672) by at least 45 days beyond the June 22, 2026, deadline. The proposal includes multiple complex elements that require substantial technical, legal, and operational analysis by our member companies.