The Distribution Rule Advances: What Happened at the GPAC Meeting and What Comes Next

PHMSA's Technical Pipeline Safety Standards Committee, also known as the Gas Pipeline Advisory Committee (GPAC), met on May 28, 2026, to work through one of the more significant rulemakings the gas distribution industry has seen in years - the Safety of Gas Distribution Pipelines rule, commonly called the ‘Distribution Rule’.

The rulemaking traces back to the September 2018 Merrimack Valley gas incident in Massachusetts, which resulted in fires, explosions, and the displacement of thousands of residents after a low pressure distribution system was overpressurized. Congress responded with the PIPES Act of 2020, directing PHMSA to tighten distribution pipeline safety requirements. PHMSA issued a Notice of Proposed Rulemaking (NPRM) in August 2023 to address these congressional mandates. This meeting specifically addressed the August 2023 NPRM. It is important to note that this is not the last say - a Final Rule will not be published until PHMSA considers both the GPAC recommendations and the public comments received on the proceedings of the meeting – which are due by June 29, 2026.

The GPAC worked through six main topic areas at the meeting. Here's a breakdown of what was on the table, what the committee recommended, and what operators should be watching now.

A Reconstituted Committee

One thing worth noting upfront: the current administration disbanded and reconstituted the GPAC in its entirety before this meeting. All 15 members are serving new terms, though four have previous GPAC experience. That's unusual, and it made the committee's direction harder to predict going in.

What emerged was a committee that endorsed the core proposals - but with conditions attached in each voting motion. From a high level, these conditions primarily dealt with aligning and limiting the proposed changes to the actual mandates in the Pipes Act of 2020. In every topic area, the committee found the proposed rule technically feasible, but recommended PHMSA address specific concerns around scope, clarity, and compliance timelines.

Topic 1: Overpressurization: Low-Pressure Systems

This topic sits at the heart of what drove the rulemaking in the first place. PHMSA proposed requiring each regulator station serving a low-pressure distribution system that is new, replaced, relocated, or otherwise changed to have secondary overpressure protection, remote monitoring of gas pressure near overpressure protection devices, and measures to minimize overpressurization risk. The proposal under §§ 192.195, 192.741, and 192.1007(d) would require existing systems to confirm they have secondary protection and remote monitoring or identify and implement measures to address the risk of overpressurization of low pressure systems.

Based on public comments received during the NPRM comment period, PHMSA signaled it is considering several modifications before the Final Rule:

• Clarifying that operators may use the same method of protection twice (two means of the same type), rather than requiring two distinct methods
• Requiring secondary protection on all low-pressure distribution systems consistent with the mandate, while providing significantly more time for any necessary upgrades to existing stations
• Articulating where it would be appropriate to allow an existing system to use an alternative to the secondary protection requirement, such as impracticable design or where the operator has plans to replace the low-pressure system
• Allowing existing low-pressure distribution lines to have remote monitoring or mechanical pressure devices, while continuing to require remote monitoring of gas pressure going forward
• Not including an additional requirement for minimizing overpressurization risk in § 192.195(c), since this is already addressed by § 192.199(g) and can be covered through DIMP amendments

The committee voted to support the proposal as technically feasible, reasonable, cost-effective, and practicable - on the condition that PHMSA review the mandate and consider allowing performance-based alternatives to replacement, reconsider compliance timelines, clarify and limit the no-objection approval process, and take a hard look at the Regulatory Impact Analysis.

Near-term action item for operators: perform a record review of regulator stations now to ensure documentation of required attributes - configuration, set-points, and location of sensing lines. For systems with low-pressure distribution, evaluate existing overpressurization methods at district reg stations and start developing a prioritization for any stations that need to be addressed.

Topic 2: DIMP — Threat Identification and Risk Evaluation

PHMSA proposed expanding DIMP threat identification requirements under § 192.1007(b). Operators would be required to evaluate risks from cast iron, bare steel, unprotected steel, wrought iron, and historic plastics with known issues. The proposal also expands natural forces threat identification to include extreme weather, land movement, and geological hazards, creates an explicit overpressurization threat category for low-pressure systems, and requires operators to consider the age of the entire system when identifying and ranking threats.

Under § 192.1007(c) and (d), PHMSA also proposed expanded risk evaluation factors: operators would need to consider non-abnormal operating conditions on low-pressure systems, evaluate overpressurization risks to connected equipment, analyze low-probability consequences on low-pressure systems, and address age and material associated risks.

Based on public comments received, PHMSA is considering narrowing its approach:

• Limiting the specified materials to cast iron and historic plastics with known issues, and reducing repetition of these materials across multiple DIMP elements
• Removing the proposed natural forces additions
• Treating age as a consideration in evaluating the risk of other threats under § 192.1007(c), rather than as a standalone threat category

The committee voted to support the DIMP proposals - with the conditions that PHMSA reconsider the scope of materials based on the congressional mandate, clarify and limit notification and no-objection requirements, and ensure that any amendments are consistent with DIMP principles and terminology, particularly around age, overpressurization, and the threats of incorrect operation and equipment failure.

Near-term action item: ensure your DIMP plan clearly demonstrates consideration of cast iron as a threat, and states whether low-pressure distribution exists in your system.

Topic 3: O&M Procedures - Overpressurization Response and MOC

This is a topic that warrants close attention from distribution operators.

PHMSA proposed two new O&M requirements under § 192.605. First, operators would need written procedures for responding to, investigating, and correcting overpressurization indications - including a specific course of action and order of operations for reducing pressure or shutting down gas flow. Second, operators would be required to implement a formal Management of Change (MOC) process for significant changes affecting pressure control, with a requirement that relevant qualified personnel – such as a P.E. or subject matter expert - review and certify construction plans.

The MOC requirement is a meaningful shift. Until now, only transmission operators have been required to have formal MOC programs. Many distribution operators simply don't have them.

Based on public comments received, PHMSA is considering modifications:

• Adding language to the overpressure response requirement to take actions "as necessary" rather than as an absolute mandate in all cases
• Limiting the MOC requirement to "significant" changes affecting pressure control
• Excluding emergency work from MOC requirements
• Excluding simple in-kind replacement work that does not require design plans
• Specifying that the person reviewing and certifying construction plans must be a P.E. or SME, rather than someone qualified under Subpart N (since construction plan review is not a covered task under Subpart N)

The committee voted to support the proposal on the conditions that PHMSA better define the scope consistent with the mandate by clarifying what constitutes a significant change, focus the rule on changes that affect overpressure-related risks, and consider a 2-year implementation timeline.

Near-term action item: establish and test an MOC process for significant changes affecting pressure control now, before the Final Rule publishes. Develop a process for having SMEs certify construction plans when there is a risk of overpressurization. These are the kinds of programs that take time to build and operationalize - waiting for Final Rule might be a problem.

Topic 4: Emergency Response Plans

PHMSA proposed expanding § 192.615 to require written procedures for direct, immediate notification to Public Safety Answering Points (PSAPs - i.e., 911 centers) upon confirmation of a pipeline emergency. Operators would also be required to maintain communication with the affected public throughout an emergency, and to implement a voluntary opt-in notification system allowing customers to receive immediate alerts during emergencies.

The proposed triggers for emergency notification were also expanded. Under the NPRM, "pipeline emergency" would include: a gas release with a fatality, an unintentional release causing an outage for 50 or more customers (or 50% of a small system), a notification of potential rupture, and any other emergency the operator deems significant.

Based on public comments received, PHMSA is considering:

• Not pursuing gathering line requirements in this rulemaking, as they are outside scope
• Not adding "notification of potential rupture" as an emergency type applicable to all operators
• Revisiting the significant outage threshold based on further data analysis
• Amending the requirement to communicate with the "general public" to instead specify the "affected public," clarifying limited applicability with odor calls
• Allowing more clearly for operators to employ a third-party opt-in notification system
• Cutting down prescriptive, unnecessarily lengthy requirements around notification content and written procedures for opt-in and general public notifications

The committee voted to support the proposal with conditions: revise the scope of emergency notifications consistent with the mandate and public comments, allow operators to meet communication requirements through coordination with existing state frameworks, reconsider the significant outage threshold, and review implementation through § 192.615 with further improvements to existing plan requirements.

Near-term action item: ensure your Emergency Response Plans fully address communication with emergency responders, the affected public, and customers. Explore voluntary opt-in notification systems - even if not yet required, PHMSA and the committee clearly expect them to be part of the final framework, though the exact triggers are not yet decided.

Topic 5: Presence of Qualified Personnel

PHMSA proposed a new § 192.640 requiring a Subpart N-qualified person to be present and monitoring gas pressure during any construction project with potential to cause an overpressurization event. The proposal includes an exemption for district regulator stations that already have remote monitoring or automatic shutoff valves.

Based on public comments received, PHMSA is considering two modifications: removing a specific requirement for the qualified person to have stop-work authority, and limiting "construction activity" to exclude third-party work not related to the pipeline.

The committee voted to support the proposal as written.

Topic 6: Pressure Control Records

PHMSA proposed a new § 192.638 requiring distribution operators to identify and maintain traceable, verifiable, and complete (TVC) records documenting characteristics critical to proper pressure controls - including configuration, set-points, and sensing line locations at regulator stations. Operators would need to update these records as needed, implement procedures for collecting missing records on an opportunistic basis, retain records for the life of the facility, and make them accessible to personnel responsible for performing or overseeing relevant work.

Based on public comments received, PHMSA is considering:

• Confirming that "traceable, verifiable, and complete" carries the same meaning as "traceable, reliable, and complete" - aligning with existing industry terminology
• Noting that the components covered by this requirement are aboveground or otherwise easily visually observed, which means compliance does not trigger § 192.607 (the buried pipe material records requirement)

The committee voted to support the proposal with two conditions: clarify records availability requirements consistent with the mandate and clarify that the rule applies to pressure control records - not material property records.

Near-term action item: perform a record review of regulator stations to ensure documentation of required attributes. If records are incomplete, develop a plan for opportunistic data collection - capturing missing information each time crews are in the field at a given station.

What Happens Next

Post-GPAC comments are due June 29, 2026 - less than two weeks from now. This is the next formal opportunity to weigh in on the specific issues raised at the meeting, including the conditions the committee attached to each voting motion.

From there, PHMSA is expected to publish a Final Rule after reviewing the GPAC recommendations and comments received. The timeline may be tighter than it sounds. MOC programs, overpressurization response procedures, and pressure control record systems are not things that can be stood up quickly. Operators who start now will be better positioned than those who wait for the Final Rule.

Bottom Line

The Distribution Rule is moving forward and the direction is clear. The GPAC endorsed every core proposal - the conditions attached to each vote reflect concerns about remaining within the scope of the mandates, implementation time, and regulatory precision - not fundamental opposition to the requirements themselves. PHMSA has signaled throughout this process that it is listening to comments, and several of the modifications it is considering track directly from what the industry submitted in response to the 2023 NPRM.

For operators, the most important near-term steps are to engage on the post-GPAC comment process, conduct a regulator station record review, and start building the internal processes - particularly around MOC and overpressurization response - that the Final Rule will require.