Advocacy Comments & Filings

GPA Midstream provide detailed comments regarding EPA's proposed National Emission 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, April 22, 2026). The comments are designed to assist EPA in developing a final rule that is technically sound, reasonable, and practicable.

GPA Midstream supports FAA Section 2209 implementation, and seeks changes to critical infrastructure eligibility criteria. Section 2209 addresses operation of unmanned aircraft (drones) near fixed site infrastructure facilities.

In comments filed with the New Mexico Environment Department, GPA Midstream supported the New Mexico Oil and Gas Association refinements to the agency's proposed methane abatement rule (20.2.51 NMAC). Refinements would support reducing methane emissions by enabling technically sound programs that improve environmental performance while remaining operationally feasible, legally durable, and consistent with existing state and federal requirements.

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 and five other national energy associations urged Congress to pass the Widespread Information Management for the Welfare of Infrastructure and Government Act as part of the Fiscal Year 2027 National Defense Authorization Act. The legislation reauthorizes the foundational tenets of the Cybersecurity and Information Sharing Act of 2015 for an additional 10 years, while also accounting for important updates to the enacting legislation that address the evolving cybersecurity threat landscape.

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.