May 7, 2019 Kimberly S. Greene Chief Executive Officer Southern Company Gas Ten Peachtree Place, N.E. Atlanta, Georgia 30309 Re: Southern Company Gas Registration Statement on Form S-3 Filed May 3, 2019 File No. 333-231185 Dear Ms. Greene: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Danilo P. Castelli at (202)551-6521 with any questions. Sincerely, Division of Corporation Finance Office of Consumer Products cc: Paul Davis Fancher