II-O0014

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Sent:

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Attach:

Currier, Patrick T. <pcurrier@hunton.com>

Friday, September 24, 2010 5:04 PM

dfadefinitions <dfadefinitions@CFTC.gov>

rule-comments@sec.gov; OTCDefinitions <OTCDefinitions@CFTC.gov>

Definitions Contained in Title VII of Dodd-Frank Wall Street Reform and

Consumer Protection Act

GPA_ANOPRComments09 24 2010.pdf

Via Electronic Delivery

Dear Secretary Stawick and Ms. Murphy:

On behalf of the Gas Processors Association ("GPA"), Hunton & Williams LLP hereby submits this letter in

response to the request for comments set forth in the advanced notice of proposed rulemaking published in the

Federal Register on August 20, 2010, addressing the definition of various key terms adopted in Title VII of the

Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act").

The GPA is a non-profit trade organization founded in 1921 that represents 122 member companies with interests

in the midstream industry. Midstream operations include gathering, compression, treating, processing, marketing

and storage of natural gas, as well as fractionation, transportation, storage and marketing of natural gas liquids.

GPA appreciates the opportunity to submit these comments and looks forward to working with the Commodity

Futures Trading Commission and Securities and Exchange Commission to further define and clarify these

definitions as part of the formal rulemaking process implementing Title VII of the Act.

If you have any questions, or if GPA may be of further assistance, please do not hesitate to contact me at the

number below or Mark Sutton, Executive Director of GPA, at 918.493.3872.

Respectfully submitted,

Patrick T. Currier

Associate

Hunton & Williams LLP

1900 K Street, N .W.

Washington, DC 20006

202.419.2001

pcurrier@hunton.com

<<GPA_ANOPRComments09 24 2010.pdf>>
GAS PROCESSORS

ASSOCIATION

September 24, 2010

Mr. David A. Stawick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Ms. Elizabeth M. Murphy

Secretary

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-1090

Re: Comments of the Gas Processors Association Regarding Definitions Contained in

Title VII of Dodd-Frank Wall Street Reform and Consumer Protection Act (RIN

3235-AK65; 3038-AD06)

Dear Mr. Stawick and Ms. Murphy:

The Gas Processors Association ("GPA") is a non-profit trade organization founded in

1921 that represents 122 member companies with interests in the midstream industry.

Midstream operations include gathering, compression, treating, processing, marketing and

storage of natural gas, as well as fractionation, transportation, storage and marketing of natural

gas liquids. GPA’s membership accounts for approximately 92% of all NGLs produced in the

United States and operate approximately 190,000 miles of domestic gas gathering lines. The

operations of GPA members represent a significant portion of the total revenue of several states

that are heavily reliant upon the oil and natural gas industry, including states such as New

Mexico, Oklahoma, and Texas. The midstream industry is an essential link between energy

producers and energy consumers providing American businesses and households with

domestically produced energy.
GPA Comments

September 24, 2010

Page 2

GPA appreciates the opportunity to comment on the Advanced Notice of Proposed

Rulemaking regarding the definitions of key terms outlined in the Dodd-Frank Wall Street

Reform and Consumer Protection Act (Dodd-Frank Act). GPA and its members support the

views expressed in the comments of the Coalition of Physical Energy Companies and the

Working Group of Commercial Energy Firms with regard to their general interpretations,

comments and principles.

We appreciate the opportunity to provide these comments and look forward to the

formal rulemakings that will be issued to implement the Dodd-Frank Act.

Sincerely,

Mark Sutton

Executive Director

Gas Processors Association  ̄ 6526 E. 60al St.  ̄ Tulsa, OK 74145

Phone (918) 493-3872  ̄ Fax (918) 493-3875

www.GPAglobal.org