FINDINGS

1. SoCalGas filed Advice Letter 2951 for approval of an amendment to an existing transportation service contract with SWG.

2. ORA filed a protest asserting that the offer of an ITCS crediting mechanism only to SWG is discriminatory against other noncore customers.

3. SoCalGas distributed Advice Letter 2951 to 25 public and municipal utilities and public agencies and posted the advice letter on its website. Notice of the advice letter was also made on the Commission's Daily Calendar. No party other than ORA filed a protest.

4. There is inadequate justification for an open season for the ITCS crediting mechanism.

5. The contract amendment would not affect the costs borne by SoCalGas customers other than SWG.

6. The contract amendment as a whole is in the public interest and is not unduly discriminatory.

7. We should deny ORA's protest.

8. The contract amendment would provide SWG with an opportunity to obtain firm EPNG interstate pipeline capacity at 100% of the as-billed rate. The contract amendment would also allow for a reduction in ITCS payments to SoCalGas.

9. SWG serves predominately core customers, and currently purchases gas at the southern California border for those customers. Gas prices at the southern California border are currently much higher-priced than prices in southwest basins plus interstate transport costs.

10. The opportunity to obtain El Paso capacity may help Southwest Gas to lower its gas costs.

11. The contract amendment would also provide for a transportation rate reduction for SWG.

12. We should approve SoCalGas' Advice Letter 2951.