Regulatory Submissions

On June 24, APGA submitted joint comments supporting the Federal Energy Regulatory Commission’s (FERC) proposed rulemaking to update its pipeline filing requirements to require the submission of native format filings.

Last year, APGA joined several other trade associations in filing a petition for rulemaking. The petition was filed in response to concerns that some pipelines have been filing their statements/schedules in FERC rate case proceedings only in a PDF format, as opposed to their native formats like Excel spreadsheet. This practice has impeded APGA members and other parties in the given proceeding from performing routine analyses on the data.
Through the comments, APGA and the other commenters supported FERC’s proposed rulemaking to revise its regulations or update its filing procedures to require the submission of all statements and schedules in their native/Excel format with all cells/links/formulas intact. Commenters reiterated how this would facilitate efficient review of relevant data by both FERC staff and other stakeholders, consequently minimizing delays in establishing just and reasonable rates. In addition to APGA, joint commenters included the American Gas Association (AGA), American Forest & Paper Association (AF&PA), Industrial Energy Consumers of America (IECA), Process Gas Consumers Group (PGC), and Natural Gas Supply Association (NGSA).