· The elections for Core Firm Storage will be made as specified for transportation capacity. That is, a gas ESP will determine, prior to each April through March year, the percentage of its pro rata share of Core Firm Storage rights that it wishes to accept. That percentage of the pro rata share will be in effect for the gas ESP for the remainder of the storage year. A monthly adjustment structure will replace the generally optional mid-year and winter adjustments. Under this structure, if the gas ESPs' pro rata share of inventory changes by more than 10,000 therms, the supplier will have the opportunity to adjust its assignment. If the share changes by more than 100,000 therms, the adjustment will be mandatory. PG&E contends that the change to monthly adjustments will simplify administration of this program.

· The pro rata share for each CPG will be based upon peak January loads, instead of historical winter load, to be consistent with the core Winter Firm Capacity Requirement specified in Chapter 4 of Exhibit 1.

· The minimum monthly amount of gas that each CPG must hold in accepted Core Firm Storage will also be adjusted to account for the two minimum capacity steps of the Winter Firm Capacity Requirement. Minimum inventory limits will be enforced by monthly balancing adjustments during injection months, and by withdrawal limits during withdrawal months.

· All rejected capacity will become part of PG&E's Core Procurement Department portfolio and be part of the CPIM benchmark.

· Schedule G-CFS, Core Firm Storage, will apply to PG&E's Core Procurement Department and gas ESPs as discussed in Chapter 6 of Exhibit 1. Schedule G-CFS rates are discussed in Chapter 14 of Exhibit 1.

98 In D.97-05-093 (72 CPUC2d 669), PG&E was authorized to unbundle the interstate portion of the transportation charges to core customers on the Pacific Gas Transmission Company (PGT) and El Paso pipelines for 1997. In D.97-12-032 (77 CPUC2d 100), PG&E was authorized to continue offering unbundled transportation rates on the PGT pipeline for 1998 and beyond. 99 Currently, gas ESPS are offered, on a monthly basis, a pro rata share of core customer rights on the GTN, Redwood, and Baja paths. 100 According to PG&E the approximate customer population or mix of each CPG is known prior to each month based on the Direct Access Service Requests that have been received. 101 PG&E proposes that all rejected or returned capacity become part of PG&E's Core Procurement Department portfolio and be part of the CPIM benchmark, and recovered in core procurement rates. 102 SPURR/ABAG request that the Commission take official notice of PG&E's proposed treatment of its newly acquired El Paso capacity and its Transwestern capacity, as set forth in PG&E's prepared testimony in R.02-06-041. 103 See 73 CPUC2d at 771. 104 Since we are rejecting PG&E's proposal, there is no need to address the tying arrangement argument.

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