Comment from Interstate Natural Gas Association of America, American Gas Association, GPA Midstream Association, INGAA, AGA

Summary: The Interstate Natural Gas Association of America (INGAA), American Gas Association (AGA), and GPA Midstream Association submit comments supporting the modernization of pipeline repair criteria. They argue for a performance-based approach that allows for the use of advanced technologies and engineering analyses to distinguish between benign manufacturing defects and genuine integrity threats, thereby reducing unnecessary costs while maintaining safety.