PG&E

PG&E agrees that GTN may have to raise rates due to shippers switching to the Ruby Pipeline. In fact, PG&E's analysis of the costs and benefits of its Ruby contract, which was addressed previously in today's decision, included an estimated GTN rate increase of $0.095/Dth.

PG&E argues that GTN's estimated rate increase of $0.214/Dth is based on unsupported speculation that existing shippers other than PG&E will not renew their transportation agreements when they expire. At hearing, GTN's witness conceded that not a single existing shipper other than PG&E has informed GTN that it plans to de-contract if the Ruby Pipeline moves forward.⁶⁵

PG&E also claims that GTN's calculation of the $0.214 rate increase excludes potential revenues that GTN may receive from the de-contracted capacity. For example, GTN's witness testified that the last time GTN had uncontracted capacity, "we made a lot of money on that capacity when it was unsubscribed . . . It was great to have it unsubscribed."⁶⁶

PG&E contends that even if GTN does increase rates by $0.214/Dth, PG&E's ratepayers would still be better off with the Ruby Pipeline compared to the status quo. Several of PG&E's forecasts show that the net direct benefits of Ruby more than offset the $0.214 rate increase on GTN. For those forecasts that show net direct costs if GTN achieves a rate increase of $0.214, PG&E represents that the net direct costs are more than offset by indirect benefits (e.g., lower gas prices from gas-on-gas competition, supply diversity, and pipeline reliability).

⁶⁵ 7 TR 783: 3-14, GTN/Ferron-Jones.

⁶⁶ 7 TR 788: 19-22, GTN/Ferron-Jones.