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

Summary: The Interstate Natural Gas of America (INGAA), American Gas Association (AGA), and GPA Midstream Association are submitting supplemental comments to support a performance-based approach to pipeline repair criteria. They argue that current regulations are overly prescriptive and advocate for the use of advanced engineering evaluations, data analytics, and reliability-based cost-benefit analyses to reduce unnecessary excavations and costs.