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Within the past several years the United States has begun to experience a diminishing supply of natural gas.' As early as 1970, not only were proven reserves already largely committed to sales to established customers and thus unavailable to new customers,' but gas pipeline companies3 were finding themselves unable to meet even their existing contract demands.4 As a result of this shortage, numerous gas pipeline companies sought the assistance of the Federal Power Commission (FPC)5 in implementing plans to curtail gas deliveries to customers that employed the gas for "inferior" uses.' Because of

The Liability of Natural Gas Pipeline Companies for Breach of Contract Due to FPC-Ordered Curtailment