The Top 5 Takeaways from Regulation Navigation: Inside the GPAC Vote on PHMSA’s Safety of Gas Distribution Pipelines Rule

Chris Taylor, ITS Vice President of Regulatory and Industry Affairs, hosted Erin Kurilla, Executive Vice President of Advocacy and Operations at the American Public Gas Association (APGA), for the latest episode of Regulation Navigation, ITS’ quarterly webinar on pipeline industry news and trends. APGA represents publicly owned natural gas utilities across the country, most of them small systems that rely on a network of subject matter experts to meet every part of the Part 192 requirements. Erin was in the room for the Gas Pipeline Advisory Committee meeting on this rule, and she walked through where PHMSA’s Safety of Gas Distribution Pipelines rulemaking stands, what the committee asked PHMSA to change, and what operators should expect in the final rule.

The rulemaking traces back to the September 2018 Merrimack Valley overpressurization event, which killed 18-year-old Leonel Rondon, sent 22 people to the hospital, damaged 130 structures, and led to an evacuation request affecting more than 50,000 people. Congress responded through sections 202 through 206 of the 2020 PIPES Act, and the NTSB issued its own recommendations. PHMSA published the resulting NPRM in August 2023, and comments closed that November. The GPAC took the rule up in May 2026 and held seven roll call votes, all of which passed unanimously. Five of those votes carried conditions the committee asked PHMSA to address before finalizing.

Here are the five takeaways operators can act on now.

1. Stand up a management of change process for overpressure protection, and start testing it. Even though GPAC asked PHMSA to consider a two year timeline, building the process deliberately now beats building it under a deadline. Management of change has never been incorporated into Part 192, so this is new ground for many of the roughly 1,500 distribution operators in the country. The GPAC discussion centered on scope: if everything is significant, then nothing is significant.

2. Do a record review of your regulator stations. Confirm you have documentation of the attributes expected to be required, including station configurations, regulator set points, valve closure positions, and the locations of sensing lines. Operators typically collect these records opportunistically, which means slowly, so gaps are common. Much of the GPAC discussion here was about whether the final rule keeps qualifiers like “traceable,” “reliable,” and “complete” or simply prescribes the records themselves.

3. Know your low pressure station situation. Evaluate the overpressurization protection already in place at each low-pressure district regulator station and build a prioritization list to address the gaps. Any station that is new, replaced, or relocated will need at least two methods of overpressure protection, along with remote monitoring. Industry pushed back hard on the original one-year evaluation deadline and the no-objection “Mother May I” approval process behind it. This is the one takeaway specific to low pressure systems. The rest apply to distribution operators generally.

4. Look at your emergency response plan through the lens of communication. Congress’ mandate adds four new triggering events to emergency response plans, and PHMSA is realigning the requirements around communication with emergency responders, the affected public, and customers. The provision most likely to catch operators by surprise is a voluntary opt-in customer notification system. Start exploring options now, including whether you can leverage a system your city or county already runs.

5. Stay engaged while the rule is being finalized. PHMSA came to the committee having visibly moved on several provisions in response to public comment, including narrowing the DIMP material list back to cast iron and vintage plastics and withdrawing the natural forces expansion. Much of the DIMP conversation was about keeping terms in their proper place, since overpressurization and age are not themselves threats but the outcome of a failure or a contributing factor to a time-dependent threat. Those word choices flow straight into your written plans. Work through your state and national trade associations to make sure your voice is in the record.

The rule is now in the interim period between the GPAC meeting and publication. PHMSA staff are finalizing the text, after which it moves through the Office of the Secretary of Transportation and the Office of Management and Budget for approval. Erin’s estimate: Q2 2027. She also expects PHMSA to set a short effective date of 30 to 60 days while giving operators a year or two of on-ramp for the heavier lifts like MOC and records review, which would push the most challenging provisions toward January 2028.