Advocacy Comments & Filings

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.

GPA Midstream urged Congress to reauthorize PHMSA pipeline safety programs, supporting practical, performance-based regulations that enhance safety, eliminate redundant oversight of in-plant gas piping, and provide long-term regulatory certainty for critical U.S. energy infrastructure.

GPA Midstream filed an amicus brief in American Gas Association v. Department of Energy urging the U.S. Supreme Court to review DOE rules that would effectively eliminate noncondensing natural gas furnaces and commercial water heaters. GPA Midstream argues DOE failed to show the rules are economically justified, relying on flawed analysis that understates consumer costs. The case potentially has far-reaching effects on fuel choice, heating costs, and long-term energy affordability.

GPA Midstream and a coalition of organizations urged the U.S. Senate to pass bipartisan, comprehensive permitting reform. The coalition letter points out that outdated and inefficient permitting processes are delaying critical infrastructure projects, driving up costs, and holding back investment in energy, transportation, broadband, and water systems. The coalition calls for a modernized, predictable permitting system to accelerate economic growth and deliver needed energy infrastructure.