APGA Weekly Update, September 15, 2016
APGA and AGA Address Lost and Unaccounted for Natural Gas
On September 6, APGA and the American Gas Association (AGA) filed a work paper 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. It was requested 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 interstate pipelines, storage operators, intrastate pipelines, and local distribution
companies. NAESB serves as an industry forum for the development and promotion of standards that
will lead to a seamless marketplace for wholesale and retail natural gas and electricity, as recognized by
its customers, business community, participants, and regulatory entities.
In the work paper, APGA and AGA express serious concerns regarding NAESB taking action on the
proposed standardization of the LAUF determination for several reasons. First, as a standards
development organization, it is not in NAESB’s best interest to embark upon the exercise set forth in the
LAUF Request. LAUF is not a one-size-fits-all determination and is system-specific. LAUF results from
many factors, is impacted by many factors, and is dealt with in different ways among the various
jurisdictions. By attempting to standardize the methodology to determine LAUF, NAESB would be
determining unsettled policy pertaining to ratemaking concepts. The filing also communicates that the
request to standardize the determination of LAUF for interstate pipelines and interstate storage
operators improperly encroaches on Federal Energy Regulatory Commission (FERC) policy matters.
Lastly, the filing states that The Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES)
Act of 2016 signed into law earlier in the year already requires that the Pipeline and Hazardous
Materials Safety Administration (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.
A copy of the filing to NAESB is available on the APGA website at www.apga.org. On September 8, the
NAESB Triage Subcommittee, which is composed of NAESB Executive Committee members, held a
conference call to discuss the proposal. The call began with general discussion on the proposal with a
large number of participants expressing opposition to NAESB undertaking this effort. The group then
held a vote on the proposal to determine whether it should be considered within the scope of NAESB
activities. There was strong opposition to this request being considered in NAESB scope, which is the
outcome that APGA had hoped for. The next step is that the proposal will be forwarded to the NAESB
Board for consideration. It is our understanding that it is very unlikely that the Board will overrule a vote
so overwhelmingly opposed to the request being in scope. For questions on this article, please contact
Dave Schryver of APGA staff by phone at 202-464-2742 or by email at email@example.com.
APGA and the AGA Ask for Furnace SNOPR Comment Period Extension
On September 12, APGA and the American Gas Association filed a request with the Department of
Energy (DOE) for a 60-day extension in the furnace Supplemental Notice of Proposed Rulemaking
(SNOPR) comment period—bringing it to a total of 90 days in the comment period. Under the furnace
SNOPR, DOE is proposing a nationwide mandate of 92 Annual Fuel Utilization Efficiency (AFUE) for
natural gas furnaces with a small furnace exemption for furnaces of 55,000 Btu or less. Furnaces under
the small furnace exemption would be allowed to be non-condensing; all furnaces above that threshold
would have to be condensing. Because of the difference in combustion technology, condensing furnaces
have additional venting requirements associated that add significant dollars to the cost of installation.
APGA has maintained that the additional venting requirements associated with replacing a noncondensing
natural gas furnace with a condensing furnace will push many residential customers—
particularly those in warmer climates—to purchase and install less efficient home heating alternatives
with potentially higher greenhouse gas emissions and higher monthly utility bills.
In its pre-publication SNOPR, DOE set a 30-day deadline for comments which is wholly inadequate and
unreasonable. In addition to the 488-page rule, DOE has released seven additional files and models,
including a 1,198-page Technical Support Document. All of this data must be interpreted and
understood to comment meaningfully on the proposal. The request to DOE also asks that DOE make a
decision on the request for an extension no later than seven days after the date of this request to allow
stakeholders to “appropriately manage the time constraints associated with the review, analysis and
drafting of meaningful comments.”
A copy of the extension request letter is available on the APGA website at www.apga.org. Given the
importance of this issue, APGA has asked its members to contact their congressional delegations and
urge them to contact DOE to express support for the request for an extension in the comment period.
For questions on this article, please contact Dave Schryver of APGA staff by phone at 202-464-2742 or
by email at firstname.lastname@example.org.
USDOT Invites You to Nominate a Future Community Leader
Secretary Anthony Foxx recently announced that U.S. Department of Transportation (USDOT) will launch
the Every Place Counts: Leadership Academy to help members of the public learn how to participate
effectively in transportation decisions in their communities. The Academy will engage future community
leaders who have limited experience with the transportation decision-making process, but want to
increase transportation equity, break down existing transportation barriers, and prevent new barriers
from being built.
The Leadership Academy will be developed over time to include multiple components:
A downloadable, printable Transportation Toolkit that simplifies the transportation decisionmaking
process through plain language and graphic design, and provides information about how
and when the public can meaningfully engage in transportation decisions in their communities;
A Facilitator Guide to empower future community leaders who want to organize a Leadership
Academy in their own communities; and,
An Online Library of Resources to connect future community leaders with resources for deeper
learning and with transportation agencies in their communities, regions, and states.
On October 5, Secretary Foxx will launch the Leadership Academy with a kickoff event at USDOT
Headquarters in Washington, D.C. He will bring together hundreds of community members from across
the country to learn how they can become aware of transportation decisions, and bring their insights to
the decision-making process.
Participants will also have a unique opportunity to provide feedback on the initial version of the
Transportation Toolkit. USDOT will use this feedback to improve the quality, clarity, readability and
usability of the document.
We would like to invite your organization to nominate participants from your communities. Those
nominees who are selected will be invited to participate in the kickoff event. Nominees should have
limited experience with transportation decision-making, and should not be paid to work in the field of
transportation. USDOT encourages nominations of future community leaders who are interested in
transportation equity and who would like to expand opportunities in their communities. Please also
share this opportunity to your local, neighborhood- and community-based partner organizations so they
can nominate future community leaders.
Nominations must be received at APGA no later than September 18. For questions on this article, please
contact John Erickson of APGA staff by phone at 202-464-0834 or by email at email@example.com.
Nominations for APGA Public Gas Policy Council Now Available
APGA invites you to nominate your locally-elected and appointed officials, such as mayors and city
councilmembers, from your communities to the APGA Public Gas Policy Council (PGPC).
The primary purposes of the PGPC are to assist APGA in moving legislation forward that is important to
its members, to oppose harmful legislation, and to provide advice on other legislative related issues of
importance to APGA. Locally-elected and appointed public officials have strong, persuasive, and
authoritative voices in Washington, D.C., with their elected representatives in both the House and
Senate. Having a core group of elected officials carry the public natural gas message to Congress
significantly strengthens APGA’s advocacy efforts.
The PGPC meets annually, usually in the spring, in Washington, D.C. During this meeting, participants
receive updates from APGA and congressional staff on legislative issues affecting public natural gas
systems and meet with key members of Congress and their staff to discuss issues of concern to public
natural gas systems. This year’s meeting included a reception in the Senate Agriculture Committee
Room, briefings by key congressional staff, and there were over 35 meetings between PGPC/APGA
members and congressional offices. The 2017 Government Relations meeting is scheduled for May 7-10
and there may be an additional PGPC meeting in Washington D.C., in September for PGPC members to
meet with their congressional delegations and key regulatory officials depending upon the
Once nominations are received, appointments to the PGPC will be approved by the APGA Board of
Directors. If you have an elected or appointed official from your community that would be a good
advocate for public gas, APGA strongly encourages you to submit a nomination for that
individual. Please note that if you already have an official serving on the PGPC, there is no need to renominate
The deadline for submitting nominations is December 31, 2016. You can send your nominations or any
questions you might have to Scott Morrison at APGA by fax at 202-464-0246 or by e-mail at
firstname.lastname@example.org. You can also submit your nominations completely online at www.apga.org/pgpc.
For questions about this article, please contact Scott Morrison of APGA staff by phone at 202-464-2742
or by email at email@example.com.
Energy Bill Conference Committee Holds First Meeting
On September 8, the House-Senate Conference Committee, which was established to resolve
differences between the comprehensive energy bills passed by the House and Senate, held its first
meeting. The primary purpose of the meeting was to hear opening statements from conferees. Bills and
amendments were not considered. The meeting began with Chairwoman Murkowski (R-Alaska) from
the Senate Energy and Natural Resources Committee stating that, “Our task now is to develop a final bill
that can be signed into law. That’s my goal here. My goal is to update our energy policies in this country
and get a conference report, a bill that can be signed into law by the president.” Chairman Upton (RMich.)
of the House Energy and Commerce Committee also stated that he wants to get a bill signed into
law and was not going to waste time by sending the President a bill he won't sign into law. He also
communicated that lifting the oil export ban was a huge success and we know it is appropriate to
expand this success to LNG exports by addressing permitting restrictions. He stated a need to focus on
the responsible production of needed infrastructure and stressed a "need to balance new efficiency
provisions with markets ability to meet consumer demands for more efficient products."
Both the House and Senate energy bills include several provisions supported by APGA. These include,
among other things: language that addresses the Department of Energy’s furnace rule; repeal of Section
433 of the Energy Independence and Security Act of 2007, which mandates the elimination of all fossil
fuel-generated energy use in new or renovated federal buildings by the year 2030; building codes
legislation that seeks to improve the process by which these codes are developed by increasing
transparency and promoting cost-effectiveness; the HEAT Act, which addresses regulatory hurdles that
prevent or slow the adoption of combined heat and power and waste heat to power technology; and,
the SAVE Act, which is intended to increase consumer awareness of home energy use and spur demand
for energy efficient and cost-effective appliances, including those fueled by natural gas.
The meeting concluded with Chairwoman Murkowski stating that discussions at the staff level have
been occurring, and will continue to occur, as they work to resolve differences between the two
bills. The next meeting of the conference committee has not been scheduled yet. For questions on this
article, please contact Dave Schryver of APGA staff by phone at 202-464-2742 or by email at
EIA Reports Storage Increase of 62 Bcf to Put Working Gas Storage at 3,499 Bcf
Here is the weekly EIA Summary Report issued on Thursday, September 15, 2016, which reports the
week’s storage report highlights for Friday, September 9, 2016. A 36 Bcf increase has been reported.
Working gas in storage was 3,499 Bcf as of Friday, September 9, 2016, according to EIA estimates. This
represents a net increase of 62 Bcf from the previous week. Stocks were 184 Bcf higher than last year at
this time and 299 Bcf above the five-year average of 3,200 Bcf. At 3,499 Bcf, total working gas is above
the five-year historical range.