Issues Raised in Protests of AL 1210-G

Protests to AL 1210-G were filed by the Electric Generator Alliance, California Independent System Operator, Air Resources Board, the San Diego County Air Pollution Control District, Utility Consumers' Action Network and Environmental Health Coalition, City of Carlsbad, and the American Lung Association of San Diego and Imperial Counties.

In summary, these protests raised the following issues:

1. Curtailment of gas supply to electric generators will result in those generators capable of burning fuel oil to switch to fuel oil, resulting in increased generating expenses as well as increased air pollution emissions.

2. SDG&E has recently started service to the Rosarito plant which has contributed to increased gas consumption.

3. SDG&E has not demonstrated that its gas transmission capacity is insufficient so as to require emergency curtailment.

4. The Commission should investigate SDG&E's gas supply capacity.

5. Curtailment of electric generators may jeopardize the reliability of SDG&E's electric system.

6. SDG&E may have a conflict of interest due to Sempra's co-sponsorship of a pipeline project called the North Baja pipeline project.

7. Noncore customers who elected not to install fuel-switching capability were being given preferential treatment over electric generators.