14. Proposal to Exempt the System Operator from
Paying FAR Charges.

During the upcoming FAR cycle, the SDG&E/SoCalGas System Operator⁷⁴ (System Operator) must pay FAR rates, including the in-kind fuel factor, when transporting supplies needed to maintain flowing gas requirements on the SoCalGas system.⁷⁵ This means that the System Operator will continue to be treated like other BTS customers.

Requiring the System Operator to continue to pay FAR rates, including the in-kind fuel factor, is consistent with Resolution (Res.) G-3435 that required the System Operator to pay applicable firm or interruptible access charges during the first three-year FAR cycle.⁷⁶ Requiring the System Operator to continue to pay the FAR rate when transporting supplies needed to maintain flowing gas requirements on the SoCalGas system is reasonable.

⁷⁴ The System Operator includes the departments within SDG&E/SoCalGas that are responsible for the physical and commercial operation of the pipeline and storage systems, specifically excluding the Utility Gas Procurement. The mission of the System Operator is to maintain system reliability and integrity while minimizing costs at all times. SoCalGas Gas Rules Nos. 1 and 41.

⁷⁵ This adopts Recommendation No. 5 of Exhibit No. JRO-1.

⁷⁶ D.07-12-019, among other things, transferred the responsibility for managing minimum flow requirements for system reliability from the SoCalGas Gas Acquisition Department to the System Operator. In doing so, D.07-12-019 deferred to the BCAP the issue of whether the System Operator should pay the FAR charge. Resolution (Res.) G-3435, in implementing D.07-12-019, determined that the System Operator must pay the FAR charge until the issue was decided in the BCAP proceeding or in this proceeding.