IV. Parties' Positions

The parties generally contend that PG&E's application is premature and that the open season proposal lacks information about critical aspects of the rates, rate design, and capacity being offered. Parties are concerned that the "indicative rates" proposed by PG&E offer no certainty and that the open season should be conducted at the end of the Commission's approval process of the Gas Accord II structure.

We summarize the critical points raised by parties below.