When it comes to rules changes that affect the midstream industry, an important part of the process has been to schedule a meeting with the Office of Information and Regulatory Affairs. The OIRA is part of the White House Office of Management and Budget and was created under an executive order in place for three decades.

A proposed effort to streamline the meeting process, however could diminish the level of public input on regulatory changes and reduce the overall quality of the reviews by the OIRA.

In comments filed with the OMB June 6, GPA Midstream told the reviewing agency that association members are subject to extensive federal regulation, including dozens of regulatory actions subject to OIRA review.

We asked the office to take a thoughtful, transparent approach to implementing directives that would reform how the executive order works and allow for a robust stakeholder engagement process, including opportunities to make further comment and phasing in new reforms without throwing out established meeting procedures that have served the government and the public well.

Another part of the proposed reform is to encourage those who have not historically requested meetings with the OIRA to do so. Unfortunately, the existing draft proposal oversteps the reform directives and unnecessarily curtails access to groups that have had a long-standing engagement with the OIRA.

The proposed changes also try to avoid duplication of meetings. We have asked for clarifying language that would ensure that GPA could request a meeting at each stage of the regulatory process and not prevent member companies from attending more than one meeting when they belong to more than one trade association.

A proposal to consolidate meetings for efficiency runs the risk of creating greater inefficiencies. It is unclear from the draft if “consolidated” translates into as few as two organizations or individuals or many more. It also begs the question of if a meeting with several GPA Midstream members at once constitutes a consolidated meeting.

We have asked for clarification on this point, especially because the meetings are limited to only 30 minutes and too many voices in the room would give little time for the each viewpoint to be shared with the OIRA.

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