Article:
Duke R. Ligon, Problems of Contractual Authorization to Collect NGPA Wellhead Prices, 57 Texas L. Rev. 551 (1979).

Abstract:
Since the enactment of the Natural Gas Policy Act of 1978 (NGPA), the Federal Energy Regulatory Commission (FERC) has struggled with the major problem of determining whether existing contracts provide necessary authorization of producers to charge and collect NGPA ceiling prices. To carry out what it perceived to be congressional intent, FERC cautioned producers “not to assume entitlement to any NGPA ceiling price which is higher than their contract prices” and issued a series of interim and proposed regulations limiting the operation of certain price escalation provisions in existing interstate and intrastate contracts. The author fears that unless FERC takes positive steps to dispel the uncertainty that its regulations have created over the question of contractual authorization, the benefits to producers of NGPA price incentives will be substantially offset by increased federal regulation. This result is clearly inconsistent with the goals of Congress in enacting the NGPA.