National Fuel Gas FEDPAC • 6363 Main Street • Williamsville, NY 14221-5887 National Fuel Gas NYPAC • 6363 Main Street • Williamsville, NY 14221-5887

National Fuel Gas PAPAC • 1100 State Street • Erie, PA 16501

April 27, 2015

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VIA USPS CERTIFIED/PRIORITY EXPRESS MAIL ^ o

4 Maureen Benitz , is:> « Senior Campaign Finance & Reviewing Analyst ^ 2 Reports Analysis Division g;

Federal Election Commission _!1 999 E. Street NW •* p"i

4 Washington, DC 20463 fj ^ 1 ... ^ Identification Number: C00083758

^ Reference : Amended October Quarterly Report (07/01/2014 - 09/30/2014)

9 Dear Ms. Benitz:

This letter is in response to your March 22, 2015 request for additional information regarding National Fuel Gas Company Federal Political Action Committee's ("NFG FEDPAC" or the "Committee") Amended October Quarterly Report covering the period 7/1/2014 - 9/30/2014. Thank you for allowing NFG FEDPAC to further explain the details regarding the political contributions from employees designated for a state PAC affiliated with National Fuel that were erroneously sent to NFG FEDPAC. Despite the clerical error, which was corrected through the $10,713.99 disbursement in question, these funds were not used to finance activity in connection with federal elections.

In the first quarter of 2013, a clerk in the Houston, Texas payroll department of Seneca Resources Corporation erroneously changed the payroll deduction contribution allocations of several employees causing contributions that were designated for a state PAC (National Fuel Gas Pennsylvania Political Action Committee) to be erroneously sent to NFG FEDPAC. These contributions occurred from that time until the error was discovered in the second quarter of 2014. All such contributions were reported in the originally filed EEC reports, either as itemized or unitemized individual contributions.

The attached spreadsheet sets forth the reporting periods and the amounts of the contributions. Significantly, NFG FEDPAC had maintained a sizeable cash balance in its Federal campaign account and at no time were the misapplied state PAC contributions utilized by NFG FEDPAC to finance activity in connection with federal elections. The cash balance in the Committee's account is listed in the final column of the spreadsheet by reporting period.

In the third quarter of 2014, the Committee rectified the $10,713.99 error which resulted in excess contributions through six separate transactions. These six checks, copies of which are attached, were sent

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to NFG PAPAC, the appropriate designee. These disbursements match the erroneous contributions that were received in 2013-2014.

Please let me know if you need anything further. 1 am happy to answer any questions you may have.

Sincerely,

Evan Crahen Treasurer

Summary of National Fuel Gas Company Federal Political Action Committee Activity

Contributions Disbursements to Cash on Hand at

Reporting Period Received Due to Correct Clerical Close of Reporting

Clerical Error Error Period

1/1/2013 - 3/31/2013 $334.44 $0.00 $13,722.88

4/1/2013 - 6/30/2013 $3,676.05 $0.00 $29,272.44

7/1/2013 - 9/30/2013 $1,881.12 $0.00 $45,096.34

10/1/2013 - 12/31/2013 $2,199.86 $0.00 $58,893.31

1/1/2014 - 3/31/2014 $1,964.52 $0.00 $70,610.74

4/1/2014 - 6/30/2014 $658.00 $0.00 $75,526.29

7/1/2014 - 9/30/2014 $0.00 $10,713.99 $60,677.40

Total $10,713.99 $10,713.99

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Note: During the 7/1/2014 - 9/30/2014 reporting period, a clerical error was discovered with the checks

that were issued to the National Fuel Gas Company Federal Political Action Committee, during the

reporting periods identified above. The disbursement of $10,713.99 to the National Fuel Gas

Pennsylvania Political Action Committee during the 7/1/2014 - 9/30/2014 reporting period, corrects the

clerical error by sending these contributions to the Pennsylvania state PAC which should have received

these contributions originally.

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