Regulatory Submissions

February 2, 2015 - APGA signed the National Gas Council comments that there would be disruption to the natural gas industry from the proposed change to the start of the Gas Day. APGA respectfully submits that for the reasons set forth in its November 26, 2014 comments herein and above, there simply is no credible record basis for a determination that the current 9 a.m. CCT Gas Day start is unjust and unreasonable, as required by NGA Section 5 to justify a change, or that a 4 a.m. CCT Gas Day would be a suitable, much less just and reasonable, substitute. If anything, the record confirms the importance of retaining the current 9 a.m. CCT Gas Day start, accepting the NAESB-proposed and industry supported changes to the gas nomination cycles, and directing the electric industry to take important self-help steps to foster greater reliability, including but not limited to securing firm transportation capacity to move their gas supplies to generators or installing adequate dual fuel capability or investing in gas storage facilities or making other infrastructure investments to ensure the availability of a firm power supply during peak periods. Read the full comments here

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