Comment from American Petroleum Institute, GPA Midstream Association, and Interstate Natural Gas Association of America
American Petroleum Institute, GPA Midstream Association, and Interstate Natural Gas Association of AmericaSupportTrade association
Summary: The American Petroleum Institute, GPA Midstream Association, and the Interstate Natural Gas Association of America support the proposed rule to codify an in-plant piping exception in Part 192 to provide regulatory clarity and reduce burdens. They request further clarifications to align the gas exception with the existing hazardous liquids framework in Part 195 and advocate for including an exception for short, low-stress transfer lines less than one mile long.
See attached for comments from the American Petroleum Institute (API), GPA Midstream Association (GPA), and the Interstate Natural Gas Association of America (INGAA). Thank you!