Legal, Codes & Standards, and Other Filings

APGA submitted informal comments in response to North American Energy Standards Board (NAESB) Standards Request R23001, which deals with proposed revisions to the NAESB Base Contract for Sale and Purchase of Natural Gas (Base Contract) to improve the clarity associated with the force majeure provisions in the contract.

The idea of updating the Base Contract’s force majeure language has predominantly arisen post-Winter Storm Uri, for which there is still ongoing litigation. More recently, the idea was included as one of the recommendations arising from NAESB’s Gas-Electric Harmonization Forum, and APGA’s Gas Supply Committee had the opportunity to thoroughly discuss this particular proposal earlier this year during the APGA Spring Board & Committee Meetings in Huntsville, AL. APGA's recently submitted comment letter to the NAESB's Wholesale Gas Quadrant's (WGQ) Contracts Subcommittee that points to several generalized experiences public gas systems and their purchasing entities have recently experienced, which raise significant concerns surrounding the current force majeure framework and the need for potential amendments.

Through the comment letter, APGA urged the WGQ Contracts Subcommittee to continue discussions pertaining to potentially making changes to the Base Contract. APGA is engaging in this effort as many public gas systems utilize the Base Contract on a regular basis to contract for the purchase of natural gas in order to serve their customers, and any changes to the language will have a direct impact on our members.