2. Background

Wild Goose Storage, LLC (Wild Goose), a subsidiary of Niska Gas Storage, is an independent natural gas storage owner and operator of storage facilities in Butte County, approximately 50 miles north of Sacramento, California. The Wild Goose facilities are located on the site of a depleted gas field consisting of
12 reservoirs located at depths from 2,550 to 3,450 feet and separated by impervious rock formations. In 1997, Decision (D.) 97-06-091 granted Wild Goose its initial certificate of public convenience and necessity (CPCN), and in 2002, D.02-07-036 amended that CPCN to authorize Wild Goose to expand its facilities. Under its current authority, Wild Goose has no captive ratepayers, it provides storage services under market-based rates, and its shareholders are at risk for the costs of construction and operation.