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 an NPRM in August 2023 to address these congressional mandates.

Note: 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 A Final Rule will not be published until PHMSA considers both the GPAC recommendations and the public comments received on the proceedings of the meeting.

A Reconstituted Committee

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. What emerged was a committee that endorsed the core proposals — but with conditions attached in each voting motion, primarily dealing with aligning and limiting the proposed changes to the actual mandates in the Pipes Act of 2020.

Topic 1: Overpressurization of Low-Pressure Systems

This topic sits at the heart of what drove the rulemaking. 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 and remote monitoring of gas pressure near overpressure protection devices.

Based on public comments, PHMSA is considering several modifications: clarifying that operators may use the same method of protection twice, providing significantly more time for upgrades to existing stations, and allowing existing low-pressure distribution lines to have remote monitoring or mechanical pressure devices.

Near-term action item: Perform a record review of regulator stations now to ensure documentation of configuration, set-points, and location of sensing lines. For low-pressure distribution systems, evaluate existing overpressurization methods at district reg stations.

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, and creates an explicit overpressurization threat category for low-pressure systems.

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

PHMSA proposed two new O&M requirements. First, operators would need written procedures for responding to, investigating, and correcting overpressurization indications. Second, operators would be required to implement a formal Management of Change (MOC) process for significant changes affecting pressure control.

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.

Near-term action item: Establish and test an MOC process for significant changes affecting pressure control now, before the Final Rule publishes. These programs take time to build and operationalize.

Topic 4: Emergency Response Plans

PHMSA proposed expanding § 192.615 to require written procedures for direct, immediate notification to Public Safety Answering Points (911 centers) upon confirmation of a pipeline emergency, plus a voluntary opt-in notification system for customers.

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.

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 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 records documenting characteristics critical to proper pressure controls — including configuration, set-points, and sensing line locations at regulator stations.

Near-term action item: Perform a record review of regulator stations. If records are incomplete, develop a plan for opportunistic data collection — capturing missing information each time crews are in the field.

What Happens Next

PHMSA is expected to publish a Final Rule after reviewing the GPAC recommendations and public comments. 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 reflect concerns about scope, implementation time, and regulatory precision, not fundamental opposition to the requirements. For operators, the most important near-term steps are to engage on the comment process, conduct a regulator station record review, and start building the internal processes the Final Rule will require.