Legal, Codes & Standards, and Other Filings

On October 16, APGA submitted formal comments pertaining to the North American Energy Standards Board’s (NAESB) Standards Request R23001, which deals with proposed revisions to the NAESB Base Contract for Sale and Purchase of Natural Gas (Base Contract).  The standards request is intended to improve the clarity associated with the force majeure provisions in the base contract.

Publicly-owned natural gas utilities utilize the Base Contract on a regular basis to contract for the purchase of natural gas in order to serve their customers, so any changes to the language will have a direct impact on APGA’s members.  In the recent past, APGA members have encountered a number of concerns pertaining to the implementation of the force majeure provisions in the Base Contract, which are ripe for discussion at NAESB.  Through the comments, APGA noted its belief that the language in the standards request, while not perfect, is a good starting point for important discussions on how best to update NAESB contract language in order to best serve the changing needs of the industry.  Accordingly, APGA opposed any efforts to halt discussions on the topic before they have even had the chance to begin.

While the recommendation to cease discussions on any changes to the force majeure provisions is greatly opposed by APGA members and other LDCs, producers, pipelines, and other end users will likely vote to stop consideration of the standards request.

APGA is also aware that the following members submitted comments in opposition stopping these important discussions, and we are appreciative of their engagement:  City of Tallahassee, Jo-Carroll Energy, and National Public Gas Agency.