4. The Issues

In its application, SoCalGas discussed the issues that it believes need to be addressed by the Commission. Interested parties were provided an opportunity to raise issues in their protests, and responses to the application, and at the prehearing conference.

The issues to be addressed in this proceeding were identified in the November 7, 2005 scoping memo as follows:

a. Whether the Commission should authorize the rework of the wells to free up 4 Bcf of cushion gas?

b. Whether authorization under Public Utilities Code Section 851 is needed to reclassify 4 Bcf of cushion gas as working gas and to transfer that gas at book value to customers of the CARE program?

c. Whether the rework of the wells is exempt from California Environmental Quality Act (CEQA) review?

d. How should the costs of the rework project be paid for?

e. By doing the rework on the wells, will non-core customers benefit from the additional gas storage capacity that will be created?

f. How should the revenues from the sale of the additional 4 Bcf of gas storage capacity be treated?

In addition to the above issues, SoCalGas' application requests a waiver of Rules 35 and 36 of the Commission's Rules of Practice and Procedure (Rules), to the extent those rules apply at all.

We address all of these issues in the Discussion section below.