12. Revisions to Scheduling Priorities
SDG&E/SoCalGas must apply the following scheduling priorities for gas deliveries:64
Firm primary scheduled quantities in the Evening Cycle (i.e., Cycle 2) will have priority over a new firm primary nomination made in the Intraday 1 Cycle (i.e., Cycle 3).
a. Firm Alternate Inside-the-Zone scheduled quantities in the Evening Cycle will have priority over new Firm Alternate Inside-the-Zone nominations made in the Intraday 1 Cycle.
b. Firm Alternate Outside-the-Zone scheduled quantities in the Evening Cycle will have priority over new Firm Alternate Outside-the-Zone nominations made in the Intraday 1 Cycle.
c. Interruptible scheduled quantities in the Evening Cycle will have priority over new Interruptible nominations made in the Intraday 1 Cycle.
SDG&E/SoCalGas must apply the same hierarchy of priorities in going from Intraday 1 Cycle to Intraday 2 Cycle (i.e., Cycle 4). This hierarchy of priorities does not apply to Intraday 3 (i.e., Cycle 5) nominations or the elapsed pro rata rule. SDG&E/SoCalGas must not give priority to nominations scheduled in Cycle 1 over those scheduled in Cycle 2.
The adopted scheduling priorities may be re-examined in the 2012 SDG&E/SoCalGas Customer Forum to be convened in Second Quarter, 2012, in accordance with the Customer Forum process set forth in the BCAP Phase II Settlement adopted in D.09-11-006.65 Any proposed changes to the adopted scheduling priorities must be approved by the Commission via the Tier 2 advice letter process.66
Gas deliveries are scheduled into the SDG&E/SoCalGas transmission system on a daily basis in five "cycles."67 The practice in place at the start of this proceeding was to accept all nominations for each cycle and to prorate those nominations when there is not enough capacity. Nominations for Cycle 1 and Cycle 2 had the same priority.68 In addition, within a given cycle, some nominations have priority over others.69
In response to complaints that scheduled nominations made in earlier cycles were "bumped" or cut as a result of new nominations made in a later cycle, SDG&E/SoCalGas initially proposed to change scheduling priorities so that nominations scheduled in earlier cycles would have priority over new nominations in a subsequent cycle. Some parties opposed SDG&E's/SoCalGas' proposed scheduling priorities, arguing that proposed scheduling priorities would increase uncertainty for shippers and reduce reliability for electric generators (EGs) that make their initial nominations in Cycle 2.70
The parties agreed to address the causes of past OFOs and potential solutions outside of this proceeding. In particular, the parties' agreed that SoCalGas would file an advice letter modifying scheduling priorities and the allocation of receipt point capacity when there are system capacity limitations during an OFO event.71
The adopted scheduling priorities are similar to those applicable to OFOs established through SoCalGas AL No. 4139 but apply every day of the year in addition to OFO days. The adopted scheduling priorities are reasonable because they increase certainty for shippers, and resolve concerns that scheduled nominations made in earlier cycles will be cut as a result of new nominations made in later cycles.
It is reasonable to provide parties an opportunity in the 2012 SDG&E/SoCalGas Customer Forum, to revisit the scheduling priorities adopted in this decision, and to consider for approval via advice letter process any proposed changes to the adopted scheduling priorities.
64 This adopts Recommendation No. 6 of Exhibit No. JRO-1.
65 The Customer Forum process established by the BCAP Phase II Settlement adopted in D.09-11-006, among other things, provides parties an opportunity to review additional tools to support system operations and potential system improvements to reduce or eliminate the need for any minimum flowing supply requirements (Section II.B.v). SDG&E and SoCalGas must seek Commission authority for any additional tools (other than system modifications that can be completed without an application under current Commission rules) necessary to meet the Southern System flow requirement by filing an application (Section II.L.).
66 See General Order 96-B, Appendix B, Energy Industry Rules.
67 Cycle 1 is the "Timely Cycle", Cycle 2 is the "Evening Cycle", Cycle 3 is the "Intraday 1 Cycle", Cycle 4 is the "Intraday 2 Cycle", and Cycle 5 is the "Intraday 3 Cycle." See SoCalGas Rule No. 30.
68 Although capacity may be sufficient to accommodate all Cycle 1 nominations, those Cycle 1 nominations are rolled-over into and are combined with Cycle 2 nominations. If the total Cycle 1 and Cycle 2 nominations exceed capacity, both Cycle 1 and Cycle 2 nominations are cut/prorated on the same basis.
69 "Firm primary" nominations for a receipt point have priority over "firm alternate within-zone" nominations, which have priority over firm alternate outside-of-zone nominations, which have priority over interruptible nominations.
70 EGs do not know their dispatch requirements from the California Independent System Operator (CAISO) until the CAISO provides its day ahead notification, which occurs after the close of Cycle 1 but before the close of Cycle 2.
71 On July 28, 2010, SoCalGas filed AL No. 4139 for approval to revise Rule No. 30 to modify the allocation of receipt point capacity due to a system capacity limitation during an OFO event. In addition, AL No. 4139 requested approval to revise Rule
No. 41 to modify one of the components used in the Evening Cycle OFO calculation, and to provide a minimum one-hour notice for calling an Evening Cycle OFO event prior to the Evening Cycle nomination deadline. SoCalGas AL No. 4139 was approved on August 27, 2010 and became effective on September 1, 2010.
The parties agree that, if the changes made via advice letter result in an increased number of OFOs or increased cuts to FARs, the parties may meet with SDG&E/SoCalGas to discuss their concerns. Prior to the meeting, SDG&E/SoCalGas will work in good faith with the parties to provide relevant and useful OFO-related information for purposes of discussion at the meeting. The parties also agree to the timing and content of information that will be provided in advance of the Customer Forum (established by the BCAP Phase II Settlement adopted in D.09-11-006) scheduled for November 2010.
