State Activity Report A Publication for AGA Members

August 17, 2015

AGA State Affairs Committee Meeting—Updated Draft Agenda What’s Next?: EPA’s CPP and AGA State Engagement Strategy State Legislative Tracking Updates Rate & Regulatory Updates 2015 Events

AGA State Affairs Committee Meeting—Updated Draft Agenda Now Available! The AGA State Affairs Committee will hold its Fall Committee Meeting October 4-7, 2015 at the Omni San Diego Hotel in San Diego, CA. The meeting will feature panels and presentations from public utility commissioners, state representatives, utility representatives and other noted speakers covering legislative and regulatory topics, as well as new and innovate rate issues of interest. An updated draft agenda for the meeting is now available and can be found by clicking here. We will continue to update the agenda as speakers are added and confirmed. Participation in this meeting is open to all employees of AGA member companies, including pipeline members and Canadian members and is not limited to members of the State Affairs Committee. The Committee’s associate members are also welcome to attend this event. REGISTRATION IS OPEN! Please click here to be directed to additional information and a link to register for the meeting. You will need your AGA website log-in and password to be able to access the site.

Please make your hotel reservations as soon as possible. Omni San Diego Hotel

675 L Street San Diego, CA 92101 (619) 231-6664

Published cut-off Friday, September 12, 2015 Group Rate $219.00 Hotel Contact (619) 231-6664 Web Link http://cms.omnihotels.com/hotels/san-diego/meetings/aga-state-affairs-committee-and-legislative-affairs-issues-10 To reserve:

1. By Phone: 1-800-THE-OMNI (1-800-843-6664) and mention American Gas Association, AGA, or State Affairs Committee

2. *Online: http://www.omnihotels.com/MeetingsAndEvents/BookYourStay.aspx and use your Special Group Code: 17300105839 OR use this link to book your room directly http://cms.omnihotels.com/hotels/san-diego/meetings/aga-state-affairs-committee-and-legislative-affairs-issues-10

If you have further questions or need assistance, please do not hesitate to contact Kyle Rogers (krogers@aga.org) or Ashley Duckman (aduckman@aga.org).

What’s Next?: EPA’s Clean Power Plan & AGA Draft State Engagement Strategy Although AGA has not taken an official position on the Clean Power Plan (CPP), we have worked diligently over the course of the last several years to impress upon EPA and other key state policymakers the importance of providing states with flexible pathways to compliance, thus laying the foundation from which we can build a more comprehensive state action plan now that the CPP has been finalized. Specifically, we have been developing products that we can use in creating opportunities for promoting the use of natural gas CHP and direct use applications as compliance options under the CPP. With respect to specific state policymaker groups, as you know, we have strong working relationships with such key groups as NARUC, NASUCA, NASEO, NCSL, CSG, LEHI as well as others (see list and agenda below). Each of these groups is analyzing the CPP to determine exactly what actions they will take in the future. As they are doing so, we want to make certain we are creating, or otherwise seizing, all opportunities to deliver our messages relative to CHP and direct use, and the role each can potentially play as a cost effective method within a state’s compliance strategy. By refining our messaging and delivering our new source materials (see below) in a wide array of stakeholder forums, we hope to ensure these two important options are fully considered. However, we also recognize that each AGA member company will make decisions relative to CHP and direct use based on their individual goals and strategies. As such, we wanted to lay out a state engagement plan and solicit your feedback. Please take a moment to review the information below and let us know where you and your company might like to participate. As we negotiate for speaking opportunities at conferences, forums, partnerships on studies and reports, etc. we want to have your support and participation. We are constantly having conversations with a variety of stakeholder groups and are always looking for member company reps to take on key speaking roles. 2015 EVENTS / OPPORTUNITIES National Conference of State Legislatures (NCSL) Natural Gas Institute, September 9-11

AGA staff recently attended the NCSL Legislative Summit in Seattle, Washington, where we participated in the Energy Supply Task Force’s meeting and presented on a variety of issues ranging from pipeline safety/replacement, CHP, direct use and DOE’s proposed furnace rule. We now have an opportunity to follow up on that work by working on an agenda for NCSL’s Natural Gas Institute which will be held September 9-11. AGA is one of the host sponsors of the meeting, and we anticipate about 75 legislators from around the country will participate. Please let me know if your company would like to participate as a possible speaker on the specifics of CHP and direct use. National Association of Energy Officials (NASEO), September 13-16 AGA will be participating in the upcoming NASEO Annual meeting, where there will be a CPP Workshop specifically for state policymakers on the last day. In addition to state energy officials, NASEO has invited representatives from EPA, DOE, state utility commissions and state air offices, as well as private sector experts to participate. The workshop will be constructed around priority plan issues, such as inclusion of energy efficiency and renewable energy, as well as reliability and other administrative and analytical issues. Please let me know if you would like to 1) participate in a meeting and/or conference call with NASEO leadership prior to this meeting to discuss CHP and direct use, or 2) attend the NASEO meeting. Southern States Energy Board (SSEB), September 25-27 AGA staff has worked to put together a natural gas industry sectors plenary session at SSEB’s Annual Meeting. The panel description is provided below and we will work to have CHP and direct use woven into the narrative that the speaker representing AGA presents at the meeting. The American Shale Revolution: Powering the Economy, Empowering Consumers and Shaping Our Energy Future The U.S. is now the world’s largest producer of natural gas due to the surge in shale resource development made possible by the combination of hydraulic fracturing and horizontal drilling. While this is viewed (and rightly so) by many as a highly beneficial development from an energy supply standpoint, what is less widely recognized is that the shale revolution has profound impacts all across the natural gas supply chain, including for residential consumers, businesses, and the petrochemical and finished-goods manufacturing sectors. Natural gas is being touted by many as an environmentally friendly fuel. And at the same time, increased shale production supports 1,500,000 jobs when direct and indirect natural gas employees introduce their income back into the economy; according to IHS, increased shale production will increase real disposable income by more than $2,700 for the average American household. Representatives from AGA, ANGA and AFPM will discuss the range of economic opportunities provided by the development of our nation’s shale gas resources

Legislative Energy Horizon Institute (LEHI) October 8-10 AGA will once again be hosting the Legislative Energy Horizon Institute (LEHI) meeting in October. The Institute is designed to educate state legislators on the North American energy infrastructure and delivery system. High turnover in state legislative bodies decreases the institutional knowledge concerning complex energy issues. Legislators who develop state energy policy often lack a comprehensive understanding of how infrastructure operates. Through the Institute, legislators learn how to make responsible and informed policy choices by increasing their knowledge of the complex issues associated with electricity, natural gas, and petroleum infrastructure, regulation governing this infrastructure, and the interdependencies of our energy sectors. We anticipate 50-65 state legislators from around the country attending this 3 day meeting. Please let me know if you would like to participate and speak to the issues of CHP and direct use. Council of State Governments (CSG) Natural Gas Policy Academy , October 14-16 AGA will once again be sponsoring the annual CSG Natural Gas Policy Academy. Roughly 50 state legislators from around the country will be participating in this meeting. We will be delivering messages on all of AGA’s key issues. However, if you would like to participate in the meeting and speak about CHP and direct use specifically, please let me know. NARUC Annual Meeting, November 8-11

We will be discussing how CHP and direct use can serve as a CPP compliance option on the NARUC Gas Staff Subcommittee’s September call. The purpose of the discussion will be to build interest in the topic(s) and set a panel for the NARUC Annual meeting in November. Please let me know if your company would be interested in serving as a panelist. NASUCA, November 8-11 AGA staff continues to bring issues to the NASUCA leadership and organize webinars and set agenda items for their individual meetings. Most recently AGAL’s David Weaver represented AGA at a NASUCA meeting, discussing smart modernization and the DOE furnace rule. Please let me know if your company would be interested in participating in a similar meeting with NASUCA regarding CHP and direct use. AGA will also be providing a presentation during a session titled: Winter Fuels Outlook. State Government Affairs Council (SGAC) Leaders Policy Conference November 22-25 AGA has secured a slot on an energy panel, which will be comprised of representatives from all sectors. This meeting is attended by approximately 80 legislators from around the country as well as private sector state government affairs professionals. Please let me know if you would like to participate in this meeting. Governors There are a number of RGA, DGA and NGA meetings occurring throughout the remainder of the year. Please let me know if you plan on attending any and we will coordinate messaging and possible one-on-one meetings with Governors and staff. RESOURCE MATERIALS: AGA, along with the American Chemistry Council and American Forest & Paper Association, commissioned David Gardiner & Associates and the Institute of Industrial Productivity to develop a resource document designed for states to use for evaluating whether CHP could be a meaningful and cost-effective component of their compliance plans for achieving whatever goal EPA ends up establishing in the final rule. The report from this project, Combined Heat and Power (CHP) as a Compliance Option under the Clean Power Plan: A template and Policy Options for State Regulators, demonstrates that CHP can be a valuable approach for reducing emissions and helping states achieve their targets. While actual plans will vary dependent upon state-specific factors and determinations, the report provides the tools and methodology that states will need to begin the process. It provides key background information to help states incorporate CHP into their plans and it demonstrates that CHP can be a cost effective option for reducing emissions. The report also provides information on the accountability principles EPA has established for state 111(d) compliance plans, including methodologies for ensuring CHP projects can meet monitoring, evaluation and verification criteria. Likewise, we are in the midst of finalizing a report titled: Dispatching Direct Use: Achieving Greenhouse Gas Reductions Through the Increased Use of Natural Gas in Homes and Businesses. The intent of the report is to advance the direct use of natural gas in homes and businesses as an emissions reduction tool. The document is meant to be a narrative and an information resource for companies, policymakers, and other stakeholders. The report is structured as follows: Section one articulates how direct use achieves reductions in energy and emissions. It quantifies and compares the emissions from select household appliances to allow for easy comparison of consumer options as it pertains to carbon dioxide emissions. Section two reviews gas utility programs already in place that achieve emissions reductions, including ratepayer funded efficiency portfolios, conversion programs, and consumer education campaigns that encourage customers to switch from electricity to natural gas. Section three outlines considerations for policymakers and stakeholders that may wish to use direct use as an emissions reduction tool or compliance option under the EPA Clean Power Plan.

AGA staff continues to work with the CPP Steering Committee on the development of this document. If you are interested in participating in the Steering Committee, please let us know. As outlined above, these opportunities relate only to CHP and direct use. Of course, we continue to push a number of other key issues (pipeline safety and replacement, innovative rate structures, expansion, etc.) at these venues as well. We are looking for those companies that wish to carry the torch on the CHP and direct use messaging in these venues. Please let us know if you have any concerns with the proposed strategy and/or if you would like to participate. AGA staff will be attending each of the meetings listed above and can facilitate your participation where appropriate.

State Legislative Updates & Tracking NY: Infrastructure Expansion Legislation On August 3, State Senator Joseph Griffo (R) introduced legislation aiming to extend natural gas distribution infrastructure to unserved or underserved areas. SB 6024 requires that each natural gas distribution company file a petition with the commission proposing a pilot or permanent program, including any necessary tariffs, to extend natural gas distribution service to end users in unserved or underserved areas within its certificated service territory. LDCs must do so no later than January 1, 2015 or 60 days after the effective date, whichever is later, under the terms of the proposed legislation. The bill requires that proposed programs shall include the following: (a) a process for managing and prioritizing customer requests from end-users for extensions of the natural gas distribution system; (b) a cost-benefit analysis to determine if a customer contribution is required; (c) a method for determining the amount of a required customer contribution in aid of construction; (d) a program to enhance the affordability of required contributions in aid of construction to customers, including the following provisions: (i) the program shall provide for on-bill financing for a term of no less than five years; (ii) a customer shall be able to pay a required customer contribution in full at any time, without incurring penalties or fees; and (iii) the form of financing may include a surcharge, third-party financing or any other method of recovery approved by the commission; (e) a provision outlining whether and how refunds or credits will be provided to customers as other customers receive service from a completed distribution system extension project; (f) a provision addressing the treatment and eligibility of customers participating in a customer assistance program who request and receive service from a distribution system extension project; (g) a provision addressing situations where a customer fails to pay a required surcharge or other on-bill financing mechanism; (h) a customer's natural gas distribution service shall not be terminated solely for nonpayment of a surcharge or other on-bill financing mechanism; and

(i) any other provisions that will promote economic distribution system extension to end-users in unserved and underserved areas in a manner that is affordable to customers. SB 6024 was referred to the Senate Committee on Rules on August 3rd where it awaits further action.

Legislative Tracking AGA staff continues to monitor state legislative activity occurring around the country. In an effort to keep you up-to-date on legislative action, we continue to compile information on those bills that have been pre-filed, introduced and/or are moving that are relevant to our sector. Please click here for our full AGA state legislation tracking document. Note that the following states’ sessions have ended and are considered “closed out” in the tracking document: Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Kentucky, Maine, Maryland, Minnesota, Missouri, Mississippi, Montana, New Hampshire, New Mexico, North Carolina, North Dakota, Oklahoma, Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia West Virginia, Wyoming and the District of Columbia.

Rate & Regulatory Updates Commission Updates Idaho On July 30, Governor Butch Otter (R) re-appointed former Commissioner Marsha Smith (D), who had retired in February 2015, to the Idaho Public Utilities Commission (PUC) on an interim basis. Ms. Smith replaces Commission Mack Redford (R), who passed suddenly in June 2015. Commissioner Smith’s interim appointment is set to expire on January 15, 2016. At that time, a new commissioner will be appointed. Michigan On July 22, Governor Rick Snyder appointed Norm Saari (R) to a six-year term on the Michigan Public Service Commission. Saari’s term will extend to July 2, 2021. As well, his appointment is considered confirmed unless it is rejected by the Michigan State Senate within 60 days. He may serve on the PSC during that 60-day period. Missouri On July 30, Governor Jay Nixon appointed Maida Coleman (D) to a six-year term on Missouri Public Service Commission (PSC) that will extend to August 2021. As well, on August 10, Governor Nixon appointed Commissioner Daniel Hall (D) to chairman of the PSC. Chairman Hall replaces former Chairman Robert Kenney (D). New Hampshire On July 22, the New Hampshire Executive Council confirmed Governor Maggie Hassan’s June 23 nomination of Kate Bailey to the New Hampshire Public Utilities Commission (PUC) for a six-year term extending through June 30, 2021. Bailey previously served as Director of Regulatory Innovation and Strategy at the PUC. New Jersey On August 13, the New Jersey State Senate confirmed Governor Chris Christie’s re-appointment of New Jersey Board of Public Utilities (BPU) President Richard Mroz (R) to a term extending to March 2021. The Senate also approved the re-appointment of Joseph Fiordaliso (D) to a term extending to March 2019.

CA: CPUC Considers Pilot Program Regarding Communication with Utilities The California Public Utilities Commission is set to consider a pilot program that would change the nature of communication between the regulator and the state's utilities. The program, presented at an August 12th CPUC committee meeting, would ban substantive ex parte communications between the commission and utilities for selected rate-setting proceedings and require more public discussion among parties and regulators.

Under the proposal, once a proposed decision is issued in a case, the participating parties would come before the commission during CPUC voting meetings. The parties could use that time to address any questions or concerns the commissioners have, creating a space for open and public conversation between regulators and utilities. The commissioners would then have the opportunity to discuss among themselves the proceeding record, including these in-meeting exchanges with the parties.

The pilot program is feasible under current statute, so the CPUC would not have to wait for state legislative action before implementing this proposal. The pilot's revised ex parte rules would apply only to new proceedings and ongoing ones that have not been affected by ex parte communication already.

CT: Applicants re-file for PURA Review of Iberdrola-UIL merger On July 31, UIL Holdings Corp. (UIL), Iberdrola, S.A., and Iberdrola USA (and its subsidiaries) jointly filed a new application for Connecticut Public Utilities Regulatory Authority (PURA) approval of Iberdrola USA's proposed acquisition of UIL. The companies had withdrawn their initial application on July 7, 2015 to address concerns raised by the PURA in a June 30 draft decision that called for the transaction to be rejected. In its draft decision, the PURA determined that the applicants had not provided sufficient evidence to demonstrate that the proposed transaction would meet the statutory requirements for approval and that the public interest of the ratepayers would not be harmed by this transaction.

FL: Consumer Advocate, Industrial Group Appeal FPL Gas Investment Decision As an update to an item reported earlier this summer, on August 12, , the Florida Office of Public Counsel filed notice that it will appeal to the state Supreme Court the approval by state regulators for Florida Power & Light Co. (FPL) to invest up to $500 million annually in natural gas reserves. The Florida Industrial Power Users Group also filed a notice of appeal against the decision, which the Florida Public Service Commission approved on June 18, 2015 by a voice vote. The guidelines established by the PSC's order allow FPL to negotiate more quickly to secure direct investments in natural gas reserves, and recover that spending through its fuel cost recovery clause. Doing so will allow the utility to lock in lower prices for gas, hedging against volatility on fuel markets. By way of background, in 2014, FPL requested approval to invest $191 million through a joint venture with PetroQuest Energy Inc., in the Woodford Project, a natural gas reserve project located in southeastern Oklahoma. FPL proposed to recover the costs of that investment through its fuel cost recovery clause. In its filing, the company also requested that the PSC establish guidelines under which the company could participate in future gas reserve projects without prior PSC approval and recover those costs through the fuel clause, subject to the Commission’s process for reviewing fuel-related transactions. The PSC approved FPL’s investment in the Woodford Project in December 2014, but did not rule on the company’s request for future gas reserve investment opportunities at that time.

On June 18, the PSC approved a maximum allowed annual investment in gas reserves of $500 million, versus the $750 million requested. To ensure continued fuel savings and other customer protections, the Commission will review the guidelines every three to five years. The Commission also strengthened the audit requirements to require detailed analysis of gas reserve performance throughout the company. Furthering customer protection, the Commission reduced FPL’s requested annual average daily natural gas burn percentages and capped the maximum allowed volume at 20 percent.

MD: PSC Ramps Up Electric Utility EE Programs On July 16, the Maryland Public Service Commission released an order on several key energy efficiency issues. The order established a new annual energy savings goal of 2% of baseline retail weather-normalized gross electric sales for each utility, for the five largest electric utilities in the state. Each utility will have until 2020 to reach the 2% annual goal, with a requirement to update 2017 efficiency plans to ramp up 0.2% annually to reach the goal. The order also established new standards for testing programs for cost effectiveness. Previously, Maryland primarily relied on the total resource cost test to screen programs. The new order specifies that the societal cost test will also be used to evaluate programs. This test considers costs and benefits of a program from a societal perspective and is not as limited as the total resource cost test, which only includes a narrow list of benefits. Lastly, the order also directed utilities to include the multiple, non-energy benefits of energy efficiency when evaluating programs, such as increased comfort, reduced utility carrying cost for arrearages, and air pollution benefits. The non-energy benefits approved by the Commission include multiple benefits beyond the societal prospective, including participant and utility-specific non-energy benefits.

MI: CE Request Gas Rate Increase On July 17, Consumers Energy (CE) filed a request with the Michigan Public Service Commission (PSC) for an $84.7 million gas base rate increase premised upon a 10.7% return on equity. CE indicates that the rate increase request is driven by: ongoing investments in its gas utility system in order to provide safe, reliable, and efficient service to customers, and to comply with environmental and legal requirements; increased operation and maintenance expenses; and, an increased cost of capital. CE also requested PSC approval of an Investment Recovery Mechanism (IRM) and a full revenue decoupling mechanism (RDM). The IRM would allow the company to increase rates by an additional $146.7 million in total from 2017 through 2019 to reflect incremental capital expenditures and the associated direct expenditures to be made during that time frame, subject to reconciliation. CE proposes the following incremental rate increases under the IRM: $47.8 million in 2017; $49.5 million in 2018; and, $49.5 million in 2019.

MN: CenterPoint Requests Gas Rate Increase On August 3, CenterPoint Energy Resources (CER) filed a request with the Minnesota Public Utilities Commission (PUC) for a $54.1 million gas base rate increase premised upon a 10.3% return on equity. The company indicated that the primary driver of the rate increase request is increased capital expenditures that are necessary to maintain a safe and reliable system and to implement technological improvements that will modernize the company's system. As part of its request, CER proposes to increase the monthly fixed charge for residential customers to $11.50 from $9.50. A final decision in this proceeding is expected by June 3, 2016.

NJ: BPU Initiates Update of Energy Master Plan On July 22, the New Jersey Board of Public Utilities (BPU) issued a notice that public hearings had been scheduled to commence a review of the state's Energy Master Plan (EMP).

In the notice, the BPU noted that since the release of the 2011 EMP, a host of additional issues must be considered. These issues include protecting critical infrastructure; improving emergency preparedness and response times; increasing the use of micro-grids and distributed energy resources; and, financing for long-term resiliency measures. By way of background, New Jersey's EMP statute, directs the governor to issue a new EMP every 10 years, with an update every three years. The last EMP was released in 2011. Of note, promoting the expansion of the natural gas pipeline systems is included. Specifically, the plan encourages New Jersey’s gas utilities to evaluate the economic and environmental merit of distribution system expansions to areas where natural gas is not presently available or where there is a relatively high saturation of oil-fired hit; The plan also includes a recommendation to establish a Transportation Infrastructure Bank to explore the potential of establishing a funding source that can assist in financing the development of needed infrastructure to support the increased use of AFVs (including NGVs) Also of note, the Plan empowers the New Jersey Division of Energy to intervene in matters of the Board of Public Utilities if a proceeding is thought to impact the Energy Master Plan.

Lastly, the Plan recognizes CHP as a viable energy efficiency option in many sectors of the economy, as well as the fact that DG and CHP are “dispatchable” and can decrease the burden on the transmission grid and on generating plants during peak demand hours, thereby reducing wholesale power costs and the price of electricity to all customers.” The Plan also acknowledges that the implementation of DG and CHP projects would require legislative support providing incentives and lowering barriers to the development of these projects. The Plan specifically mentions offering loans and loan guarantees as well as a streamlined permitting process as ways to boost DG and CHP development. The Energy Master Plan (EMP) set a target to develop "1,500 MW of new DG and CHP" resources over the next decade where net economic and environmental benefits can be demonstrated. Commercial and industrial applications are projected to contribute 1,400 MW, and district energy systems the remaining 100 MW.

TX: RRC Dismisses Atmos Mid-Tex Gas Rate Proceeding On July 28, the Texas Railroad Commission (RRC) dismissed a gas distribution rate proceeding that Atmos Energy had initiated in February 2014 for the non-Dallas cities in its Mid-Tex Division. The RRC's action was in response to a request by the parties' to withdraw the proceeding in light of a May 7, 2015 settlement that provides for Atmos to implement an approximate $65.7 million "system-wide" rate increase for the non-Dallas cities that reflects a previously specified 10.5% return on equity. While calculated system wide, the approved increase does not apply to the City of Dallas and certain unincorporated "environs," which together represent about 20% of revenue for Atmos Mid-Tex. As a result, implementation of the stipulated rates will result in incremental annual revenue of approximately $52.6 million.

2015 Events Calendar

August 2015

GOPAC State Legislative Leaders Summit August 24-27 | Columbus, OH ECOS Fall Meeting August 31-September 2 | Newport, RI

September 2015

DAGA Fall Policy Conference September 8-9 | Richmond, VA RLCC Midwest Regional Meeting September 9-10 | Chicago, IL NASEO 2014 Annual Meeting September 13-16 | San Diego, CA DLCC Eastern Leadership Conference September 23-24 | Bethlehem, PA RGA Corporate Policy Summit September 24-25 | Indianapolis, IN SSEB Annual Meeting September 27-29 | White Sulphur Springs, WV RSLC Annual Retreat September 27-29 | Sun Valley, ID

October 2015

AGA State Affairs Committee Meeting October 4-7 | San Diego, CA REGISTRATION IS OPEN! Please click here. CSG Policy Academy October 14-16 | New Orleans, LA

November 2015

NARUC Annual Meeting November 8-11 | Austin, TX NCSL Emerging Leaders Summit November 12-14 | TBD RAGA Fall National Meeting November 14-17 | Scottsdale, AZ RGA Annual Conference November 18-19 | Las Vegas, NV RLGA Policy Retreat November | New York, NY

December 2015

CWAG Winter Dinner December 1 | Charleston, SC

ALEC States and Nation Policy Summit

December 2-4 | Phoenix, AZ DGA Holiday Party & Annual Meeting December 7-8 | Location TBD NCSL Fall Forum December 8-11 | Washington, DC DAGA Holiday Party December 9 | Washington, DC CSG National Conference December 10-13 | Nashville, TN WGA Winter Meeting December | Las Vegas, NV

Kyle Rogers | Vice President, Government Relations Ashley Duckman | Director, State Affairs 202.824.7218 | krogers@aga.org 202.824.7212 | asmith@aga.org American Gas Association | 400 N. Capitol St., NW | Washington, DC 20001 | www.aga.org | www.truebluenaturalgas.org

This document has been prepared by the American Gas Association for members. In issuing and making this publication available, AGA is not undertaking to render professional or other services for or on behalf of any person or entity. Nor is AGA undertaking to perform any duty owed by any person or entity to someone else. The statements in this publication are for general information only and it does

not provide a legal opinion or legal advice for any purpose. Information on the topics covered by this publication may be available from other sources, which the user may wish to consult for additional views or information not covered by this publication. © Copyright 2015 American Gas Association. All Rights Reserved. www.aga.org