I'm under the impression that the only remaining restriction that relates to the $17 billion in NOLs is the "old and cold" ownership requirement. If that's not the case, then yes, APR should be followed to a much stronger degree if the restrictions on the $17 billion in NOLs will make them nearly impossible to use.
The problem is that the EC's support letter is ambiguous. Are they referring to the $6 billion in NOLs from WMB stock abandonment, or are they referring to the $6 billion in street value of the $17 billion NOLs? They didn't qualify which it was.