Advocacy


APGA represents America's publicly owned natural gas local distribution companies (LDCs).

APGA advocates on behalf of our members to help them strengthen their systems by providing access to the latest industry trends on safety standards, competitiveness, regulations and other important issues that affect their system.

Learn more about APGA's current advocacy issues by clicking the topics below.

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As a small municipal system we have a limited budget. APGA membership allows us to keep up on policy and rule changes. They fight for the small systems at the legislative level.

Kelli Neiberger, Gas Department Supervisor, Town of Rangely Gas Department, Colorado
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Direct Use of Natural Gas

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APGA members have been and desire to be good stewards of the environment, evidenced by the way they maintain and operate their utilities. They have long advocated for energy efficiency in their communities, believing public natural gas utilities and the existing pipeline infrastructure should continue to play an integral role in reducing greenhouse gas (GHG) emissions. They also recognize natural gas can provide energy affordability and reliability to all Americans.

The direct use of natural gas is a key reason for both GHG reduction and consumer affordability. What does this mean? On a full-fuel-cycle basis, natural gas appliances are 92% efficient. That is, 92% of the energy produced is delivered and directly consumed by the appliance at the point of use. Comparatively, electric appliances are only 30% efficient, as there are steps in the supply chain where energy is lost due to conversion or transmission. Consider the data in this table to further illustrate.1 Directly using energy in a natural gas furnace produces less GHG emissions and cost less to the consumer.


Comparison of Residential Space Heating Appliances
1 AGA, “A Comparison of Energy Use, Operating Costs, and Carbon Dioxide Emissions of Home Appliances – 2018 Update,” https://www.aga.org/globalassets/research--insights/reports/ea-2018-02-appliance-cost-and-emissions-comparison-2018-update.pdf.
Despite this data on direct use, there is currently a push for mandatory electrification of homes and businesses, believing this to be the most effective way to lower GHG emissions. APGA would suggest a balanced solution that includes the direct use of natural gas can supply clean energy in an efficient and cost-effective manner.

Policy Positions

Below are a few more specific APGA positions regarding the natural gas direct use. Please click on the policy position to view its description and details.

A few cities have gone to the extreme of banning natural gas, mostly in new construction. This heavy-handed approach eliminates consumer choice, stifles innovation, and diminishes the flexibility to respond to GHG emissions goals, with the least-cost solutions for consumers. Appliances will have to be replaced, and there is no doubt, electric infrastructure will need to be upgraded. In addition, consumers will be impacted with higher energy bills. All of this with no evidence the environmental impacts are substantial enough to warrant forced fuel switching. APGA hopes any policy development will be considerate of environmental benefits balanced with consumer affordability, and APGA and its members stand ready to work on this type of solution.

The impact to the consumer for electrification policies is staggering. With the removal of natural gas as a fuel option, New Jersey’s “State Energy Master Plan (EMP)” would eliminate more than $11.5 billion saved by households in energy expenses, and nearly $9.7 billion saved by businesses, all without establishing whether this is the least cost and most effective pathway to reduce emissions2. A survey of California families shows it will cost $7,300 to retrofit a home with electric appliances and $387/year more in energy bills, yet the state’s laws lead to that result3. Further, a national study shows families would have to spend, on average $4,847, to replace four common household appliances: range, dryer, water heater, and furnace4. APGA encourages consideration of these dramatic costs when evaluating policies. Energy efficiency gains should not come at undue consumer expense.

[2] Consumer Energy Alliance, “A Steady Stream of Natural Gas Provides Affordable Energy to New Jersey Residents and Helps the Garden State Grow,” https://consumerenergyalliance.org/cms/wp-content/uploads/2019/06/061219_NJ-Energy-Savings-Report_FINAL.pdf.

[3] Navigant Consulting, “Impacts of Residential Appliance Electrification,” https://c4bes.org/wp-content/uploads/2018/09/Navigant-Report-Impacts-of-Residential-Appliance-Electrification.pdf.

[4] Consumer Energy Alliance, “Green New Deal Would Cost American Consumers Almost $244 Billion in Just Four Appliances,” https://consumerenergyalliance.org/2019/02/green-new-deal-would-cost-american-consumers-244-billion-four-appliances/.

Natural gas distribution emissions dropped 73 percent since 1990, while utility companies added more than 760,000 miles of pipeline to get energy to an additional 20 million customers5. This is a testament to APGA members’ tireless work to safely provide clean-burning natural gas to state-of-the-art appliances, lowering emissions regionally and nationally. Every sector must do their part to reduce GHG emissions. Natural gas utilities and their customers are leading the way. With the right legislation, regulatory framework, and support from the federal government, these endeavors will continue.

5 AGA, “Understanding Updates to the EPA Inventory of Greenhouse Gas Emissions from Natural Gas Systems.” https://www.aga.org/contentassets/f4227be971f545bf8a869234d7220526/ea-2019-02-updating-the-facts-of-ghg-inventory-003.pdf.

The direct use of natural gas promotes and supports a more robust and resilient energy system. A recent report asserts that, “The operational characteristics of the natural gas transportation network, in combination with the physical properties of natural gas, effectively minimize the likelihood and severity of service disruptions. In the rare event of a disruption, impacts are typically localized and brief. History demonstrates that disruption of firm pipeline transportation and/or storage services resulting from severe weather events are extremely rare.”6 This resilience stands contrary to other energy sources used for appliances and equipment in homes and businesses. As an example, above-ground infrastructure makes electric utilities susceptible to natural events, such as wind storms. In California, damaged power lines have caused wildfires, resulting in major utility companies shutting down electricity as a precaution to the threats from nature. Rather than putting “all eggs in one basket” through electrification, there should be a balanced energy approach to achieve comprehensive reliability.

6 Natural Gas Council, “Natural Gas: Reliable and Resilient,” http://naturalgascouncil.org/wp-content/uploads/2019/04/Natural-Gas-Reliable-and-Resilient.pdf.

Allowing consumers to have a fuel choice for their appliances shouldn’t be overlooked in policymaking. Data shows that Americans prefer natural gas for cooking and space and water heating. Less than 10% of California residents would choose an all-electric home, and 80% oppose prohibiting the use of gas appliances.7 Another study indicates that the preferred energy source is natural gas for home heating, water heating, and cooking.8 As the Committee contemplates legislative options to reduce GHG emissions, APGA encourages the Committee not to pick a single solution but instead allow for maximum flexibility in meeting environmental goals with low costs.

7 California Building Industries Association, “California Natural Gas Poll - Consumer Survey of 3000 California Voters.”

8Woodland, O’Brien, and Scott, “New Homeowner Energy Preference Survey Closings March 2015 through February 2016.”




Low Income Home Energy Assistance Program (LIHEAP)

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APGA has urged Congress to provide full funding for the Low-Income Home Energy Assistance Program (LIHEAP) and have pushed for full funding in meetings and letters to Congress.

LIHEAP, administered by the Department of Health and Human Services, continues to play a critical role in helping low-income families meet their energy needs. Approximately 35 million households across the nation are eligible for LIHEAP assistance. Without LIHEAP funding assistance many low-income families face the difficult choice between paying their energy bills or paying for other necessities, such as healthcare, food and childcare.

While LIHEAP has been authorized at a funding level of $5.1 billion, it has historically received funding at a level in the low $3 billion range.
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Natural Gas Vehicles

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APGA strongly supports the growth and development of the natural gas vehicle (NGV) industry. NGVs provide a key alternative fuel option for many businesses and consumers across the country. Many APGA members not only supply gas to NGV fueling stations, but also maintain and manage fueling stations or operations of their own. NGVs’ low emission profile and relative price stability make them an attractive option for urban fleets, long-haul shipping, and municipal and local vehicles.

What are the Benefits of Natural Gas Vehicles?

NGVs are some of the cleanest vehicles on the road. The newest NGVs emit zero or near-zero NOx emissions and significantly reduce greenhouse gas emissions when compared to gasoline or diesel engines. NGVs are an available alternative to conventional engines an pratical means to reduce emissions from the transportation sector, particularly from heavy-use applications. NGVs have helped bring localities into compliance with federal ambient air quality standards and other state and local pollution laws and regulations. NGVs also provide acute emissions reductions benefits – switching from a diesel to natural gas school bus, garbage truck, or other municipal vehicle can significantly reduce harmful tailpipe emissions and ensure that localities have cleaner air.

Further advancing the environmental benefits of NGVs is the ongoing development of renewable natural gas (RNG). RNG is methane extracted from the decomposition of biodegradable sources, such as from landfills and agriculture waste. RNG is collected from the breakdown of organic materials, treated and cleaned, and redistributed as pipeline-grade methane. Often, RNG is used for transportation purposes. The RNG process ultimately takes methane out of the air. Thus, a waste collection company or agency that installs an RNG plant for its collections could actually have negative net greenhouse gas emissions.

Due to developments in production and transportation, natural gas prices have remained mostly stable over the last several years. Based on current supply and production levels, prices of natural gas are not expected to significantly fluctuate in the near term. Prices of liquefied natural gas (LNG) and compressed natural gas (CNG) for transportation use have accordingly remained stable. Fleets that use NGVs have been able to fairly accurately plan their fuel prices and optimize business investments due to the flat price regime of natural gas.

NGVs are available in every vehicle class, including light duty, and are used in commercial, municipal, freight, port and transit, and other applications. APGA members are proud to supply and operate NGV fleets and fueling stations across the country.

NGV Policies

Below are a few more specific APGA positions regarding the natural gas direct use. Please click on the policy position to view its description and details.

A few cities have gone to the extreme of banning natural gas, mostly in new construction. This heavy-handed approach eliminates consumer choice, stifles innovation, and diminishes the flexibility to respond to GHG emissions goals, with the least-cost solutions for consumers. Appliances will have to be replaced, and there is no doubt, electric infrastructure will need to be upgraded. In addition, consumers will be impacted with higher energy bills. All of this with no evidence the environmental impacts are substantial enough to warrant forced fuel switching. APGA hopes any policy development will be considerate of environmental benefits balanced with consumer affordability, and APGA and its members stand ready to work on this type of solution.

Under current law, the federal highway excise tax on both LNG for use in motor vehicles and diesel are taxed on a volumetric basis at 24.3 cents per gallon. LNG is less energy dense than diesel, as it requires 1.7 gallons of LNG to equal the energy content of 1 gallon of diesel. Based on this fact, LNG trucks will consume more fuel than their diesel counterparts and therefore will pay more in federal highway taxes than their diesel counterpart.

This additional tax burden provides a strong disincentive for consumers to purchase an LNG-powered truck. Taking into account the incremental cost of an LNG truck, which can be up to $60,000, the additional fuel tax burden may be sufficient to prevent fleets from using cleaner-burning LNG.

This legislation should be passed to remedy that disincentive by taxing LNG on an energy content basis, as CNG is taxed. This would level the playing field between LNG and diesel.

Federal & State Incentives

FEMP provides guidance and assistance to help implement Federal legislative and regulatory requirements mandating reduced petroleum consumption and increased alternative fuel use. FEMP's efforts include assisting agencies with implementing and managing energy-efficient and alternative fuel vehicles and facilitating a coordinated effort to reduce petroleum consumption and increase alternative fuel use annually. http://www1.eere.energy.gov/femp/program/fedfleet_management.html

State governments have demonstrated a long-standing commitment to reducing our dependence on foreign energy sources and pollution emitted by light and heavy-duty vehicles. The health and national security benefits of reducing both are clear, as sending money abroad to potentially hostile regimes harms our security and reducing emission of criteria pollutants and greenhouse gases improves public health and helps to protect the environment.

Sates have historically offered and continue to offer various incentives for NGVs and fueling infrastructure because of the critical benefits they confer.

NGVAmerica

To learn more about state incentives for NGVs, please visit our strategic partner, NGVAmerica at www.ngvamerica.org


NGV Links and Resources

The Alternative Fuels and Advanced Vehicles Data Center (AFDC) provides information, data, and tools to help fleets and other transportation decision makers find ways to reduce petroleum consumption through the use of alternative and renewable fuels, advanced vehicles, and other fuel-saving measures.

Vehicle Cost Calculator: http://www.afdc.energy.gov/afdc/calc/ This calculator utilizes information about your driving habits to calculate total cost of ownership and emissions for many vehicles, including NGVs.

Clean Cities is the U.S. Department of Energy's (DOE) flagship alternative-transportation deployment initiative, sponsored by the Vehicle Technologies Program. Clean Cities has saved nearly 3 billion gallons of petroleum since its inception in 1993.

Clean Cities helps vehicle fleets and consumers reduce their petroleum use. Clean Cities builds partnerships

  • Alternative and renewable fuels
  • Idle-reduction measures
  • Fuel economy improvements
  • New transportation technologies, as they emerge

Clean Cities' goals and accomplishments are listed at http://www1.eere.energy.gov/cleancities/accomplishments.html

The Official U.S. Government Source of information on Fuel Economy. http://www.fueleconomy.gov

DOE National Laboratories: http://energy.gov/offices. This site provides contact information for the DOE National Laboratories and Administrative offices.

Other Federal Government Agencies: Several other government agencies implement programs and regulations (as well as incentives) related to alternative fuels and advanced vehicles. http://www.afdc.energy.gov/afdc/laws/fed_summary/Agency.

The National Association of State Energy Officials contains a list of state and territory energy office websites and contacts (http://www.naseo.org/members/states/).

NAFA is the world's premier not-for-profit association for professionals who manage fleets of sedans, public safety vehicles, trucks, and buses of all types and sizes, and a wide range of military and off-road equipment for organizations across the globe. NAFA provides its members a full range of products and services, including statistical research, publications, regional chapter meetings, government representation, seminars, online information, and an annual Institute & Expo. http://www.nafa.org/

ICLEI is an association of over 1220 local government Members who are committed to sustainable development. Our Members come from 70 different countries and represent more than 569,885,000 people.

ICLEI provides technical consulting, training, and information services to build capacity, share knowledge, and support local government in the implementation of sustainable development at the local level. Our basic premise is that locally designed initiatives can provide an effective and cost-efficient way to achieve local, national, and global sustainability objectives. http://www.iclei.org/

The EIA collects data on alternative-fueled vehicles in the U.S. http://www.eia.gov/renewable/alternative_transport_vehicles/index.cfm

CNG Station Finder Mobile Application Now Available for iPhone and Android: http://www.cngnow.com/Blog/Post.aspx?ID=21

FEMP provides guidance and assistance to help implement Federal legislative and regulatory requirements mandating reduced petroleum consumption and increased alternative fuel use. FEMP's efforts include assisting agencies with implementing and managing energy-efficient and alternative fuel vehicles and facilitating a coordinated effort to reduce petroleum consumption and increase alternative fuel use annually. http://www1.eere.energy.gov/femp/program/fedfleet_management.html

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Natural Gas Act Reform


The Natural Gas Act (NGA) establishes the Federal Energy Regulatory Commission’s (FERC) role in regulating gas utilities, just as the Federal Power Act (FPA) does for electric utilities. Part of both laws outline the processes to deal with over-collections , instances in which shippers are charged an “unjust and unreasonable” rate as determined by FERC.

For electric utilities if FERC finds that an electric transmission company has charged an “unjust and unreasonable” rate, then FERC may order that entity to refund overcharged funds from the time that the complaint was filed.

The NGA offers no such protections for gas consumers. Under Section 5 of the NGA, entities can still file a complaint against an interstate natural gas pipeline – just like the FPA. However, unlike the FPA, FERC does not have authority to order refunds of over-collections under Section 5.  This has resulted in billions of dollars in overcharges to gas consumers, and no recourse to recoup those losses.

 

Policy Position

Congress should amend the NGA (15 U.S.C. 717d(a)) to allow FERC to set a refund effective date for Section 5 rate cases and give FERC the authority to order refunds from overcharges. This would mirror the FPA and allow FERC to require a pipeline to pay back overcharged funds from the date that the Section 5 complaint was filed with FERC.

 

What can you do?

APGA urges distribution utilities to contact their Members of Congress and ask them to support the MPACT Act.

Contact your Senator

Contact your Representative

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Section 433 of the Energy and Security Act of 2007

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In 2007, the Energy Independence and Security Act of 2007 (EISA) was passed.  Section 433 of that legislation would eliminate all fossil fuel-generated energy from federal buildings by the year 2030. This ban would apply to all new or renovated Federal buildings.  The law does not allow for the direct use of natural gas, combined heat and power (CHP), or distributed generation and eliminates all fossil fuel-generated electricity regardless of emissions.  The fossil-fuel reduction would start at 55% by 2010 and would increase to 65% by 2015, 80% by 2020, 90% by 2025 and 100% by 2030.

Currently, there is bipartisan support in both the House and Senate to replace section 433 with fuel-neutral energy efficiency provisions that achieve real energy efficiency gains in federal buildings.

Policy Position

Congress should eliminate the ban on fossil fuel generated energy in EISA 2007 Section 433. 

  • The ban restricts adoption of high-efficiency technologies such as CHP. This technology is currently being installed to power the capitol complex.  DOE has acknowledged the challenge of simultaneously using energy efficient CHP and waste heat recovery technology while complying with the mandated reduction in fossil fuel-generated energy.   
  • The ban ultimately works against energy efficiency in federal buildings. Under the legislation, a very inefficient federal building may be built or renovated in an inefficient manner as long as it draws its energy from non-fossil fuel sources.
  • The threshold amount for renovations is very low and would mean almost all renovations to federal buildings would trigger mandatory compliance, resulting in many agencies not undertaking retrofits at all.
  • The ban runs counter to an “all of the above” national energy strategy.

APGA supports bipartisan legislation that would repeal Section 433 of EISA and replace it with policies that improve the efficiency of federal facilities, such as the All-of-the-Above Federal Building Energy Conservation Act of 2019.  

What can you do?

APGA urges locally-owned natural gas utilities to contact their Members of Congress and ask them to pass legislation to reform Section 433. 

Contact your Senator

Contact your Representative

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Policy Resolutions

The American Public Gas Association (APGA) exists to serve the needs of its members. The Association’s activities are guided by policy positions as memorialized in the APGA Policy Resolutions. APGA maintains permanent, detailed records of its evolving Policy Resolutions. Any APGA member in good standing is eligible to participate in APGA’s standing Committees. The Committees are responsible for reviewing the Policy Resolutions throughout the year and for bringing forth suggested amendments to the Policy Resolutions. The APGA staff shall ensure that all APGA members in good standing receive copies of the draft Policy Resolutions at least thirty (30) days before each Annual Meeting. At each Annual Meeting, the membership will vote on adopting the Policy Resolutions as presented. The current Policy Resolutions shall be displayed at all times on the public side of the APGA website.

At each Annual Meeting, APGA membership reviews and approves the Association’s Policy Resolutions. Members are encouraged to participate in the ongoing Committee process to propose changes to continuing resolutions and to bring forth new resolutions that reflect emerging issues relevant to public gas systems.

Current Policy Resolutions


Please click on the link below to view the current 2019-2020 APGA Policy Resolutions.

Policy Resolutions Library


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Conferences, Webinars, and Committees

APGA Member Meetings on the Hill


APGA members meet in Washington, D.C., every year for the APGA Member Meetings on the Hill to meet with lawmakers on Capitol Hill. In addition to receiving updates on key natural gas issues, another critical component of this event is APGA members meeting with their congressional delegations. Having congressional representatives hear directly from their constituents on key issues of interest to public natural gas systems has greatly helped APGA’s advocacy efforts. In previous years, many members of the APGA Public Gas Policy Council attend and participate in meetings on the Hill. The Public Gas Policy Council is made up of elected and appointed officials from public natural gas communities. Learn more about the Member Meetings on the Hill here.

APGA Educational Webinars


APGA holds many government relations-focused webinars during the year. View upcoming webinars and recordings of past webinar at www.apga.org/webinars. Attending and viewing APGA Educational Webinars are a benefit of APGA membership.

Committees & Councils


APGA has many various avenues for members to enhance and further the policy positions of public gas industry. Our committees met four times a year in person during the Quarterly APGA Board & Committee Meetings. Interested in joining an APGA committee? We encourage any interested APGA members to join our committees! Send an email to info@apga.org or fill out this form.

Legislative Committee
APGA's Legislative Subcommittee advocates the interests of public gas systems in Congress. Learn more here.

Public Gas Policy Council
The APGA Public Gas Policy Council is open to all elected and appointed officials (e.g. mayors and city council members) from public gas communities. Locally-elected and appointed public officials have a strong, persuasive, and authoritative voice in Washington, D.C. with their elected representatives in both the House and Senate. Having a core group of elected officials carry the message of public gas systems to Congress significantly strengthens APGA’s advocacy efforts. Learn more here.

Regulatory Committee
APGA's Regulatory Subcommittee develops APGA's regulatory positions based on the policies reflected in the Association resolutions and on member needs and viewpoints, and communicates and advocates these positions in the relevant regulatory forums. Learn more here.



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Federal Correspondence



As the only association representing America's publicly owned natural gas local distribution companies (LDCs), APGA often sends letters to Congress and joins with others in our industry to make sure our members' perspectives are on record on issues from safety standards, regulations and other important issues that affect their system.



Latest Filed Correspondence

  • November 19 2010 - Industry Letter in Favor of Bipartisan PHMSA Reauthorization

    one month ago

  • APGA and other Associations Send Letter in Support of Section 5 Legislation

    2 months ago

  • November 11 2019 - APGA Supports Tax Extender Legislation As a Congressional Priority for 2019

    2 months ago

  • Developments in Natural Gas Index Liquidity and Transparency, Docket No. AD17-12-000

    2 months ago

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Federal Comments



APGA often files comments to Congress and other federal entities representing our members' perspectives are on record on important rulemakings on important issues that affect their system.



Latest Filed Comments

  • (Sept 9 2019) Notice of Proposed Interpretive Rule and Response to Petition for Rulemaking: Energy Conservation Standards for Residential Furnaces and Commercial Water Heaters

    one month ago

  • November 1 2019: APGA Comments on MA DPU PE Stamp Proposal

    2 months ago

  • October 31 2019: Petition for Reconsideration - Gas Transmission Rule

    2 months ago

  • APGA Motion to Intervene in PennEast Pipeline Request for Declaratory Order Impacting Eminent Domain

    3 months ago

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