On September 6, 2016, APGA and AGA filed a work paper (attached) with the North American Energy Standards Board (NAESB) in response to a request from the Environmental Defense Fund, Citizens Utility Board, Tennessee Valley Authority, Massachusetts Attorney General’s Office and the California Public Utilities Commission that NAESB develop a uniform and transparent industry-wide standard for calculating lost and unaccounted for natural gas (LAUF) for use by any entity providing natural gas delivery service that is required to report LAUF including without limitation, (1) interstate pipelines, (2) storage operators, (3) intrastate pipelines, and (4) local distribution companies.
As you can see in the attachment, APGA and AGA are expressing opposition to NAESB undertaking this effort for several reasons including that it is far outside of the scope of NAESB’s typical standardization-related work and that the PIPES Act signed into law earlier in the year already requires that PHMSA submit a report to Congress on the metrics related to LAUF from distribution pipelines and systems, including an examination of different reporting requirements or standards, analysis of alternative requirements, and other safety-related assessments. We will keep you informed as to the decision NAESB makes on whether or not to go forward.#NAESBworkpaper #APGACorrespondence #NAESB
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