IV. Critical Points of Parties' Positions

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. NCGC/TURN argue that PG&E has the process backwards. These parties contend that an open season should be conducted at the end of the Commission's approval process of the Gas Accord II structure, not before PG&E has even filed such an application. They note that the current Gas Accord was conducted in the correct order: after approval of the tariffs, PG&E conducted its open season.

In addition, NCGC/TURN and ORA are concerned that this expedited approach will benefit PG&E and gas marketers and disadvantage end-use customers. We summarize the critical points raised by parties below.