V. Citygate Pooling Service
A. The Proposal and Parties' Responses
SDG&E and SoCalGas propose that a citygate pooling service be established to facilitate the transfer and delivery of gas within the transmission system after the gas has been scheduled through the receipt points.63 This citygate pooling service is an optional service that allows for the aggregation and disaggregation of natural gas at the citygate, and creates a pricing point for customers to buy and sell gas. The service facilitates the delivery of gas from a receipt point or pool account to end-use customers, storage accounts, other pool accounts, and off-system deliveries, and the receipt of gas from a receipt point, storage account, or other pooling accounts.64 Under the pooling service proposal, the pool accounts will be required to balance during each scheduling cycle each day. For at least the first six months of the pooling service, there will be no transfer charges for a pool-to-pool transfer.65
No one expressed opposition to the creation of the pooling service.
Several parties contend that a citygate pooling service can be established even if a system of FAR is not adopted.
B. Discussion
Several parties explained why the pooling service proposed by SDG&E and SoCalGas will be beneficial to market participants. The pooling service facilitates the delivery and transfer of gas among the pool participants in an effortless manner, and provides market participants with greater flexibility in managing their gas supplies. The pooling service allows market participants to manage and reconcile gas flows in real time, provides them with an alternative to the use of hub and storage services, and minimizes imbalance and contractual non-performance exposure that market participants currently face.
Some parties seem to suggest that the pooling service should be implemented sooner rather than later. SDG&E and SoCalGas propose in their implementation schedule that the pooling service be implemented in conjunction with the start of the FAR system. Although the utilities did not address the type of changes that may be needed to allow their systems to accommodate the pooling service, we assume that some time is needed to make these kind of changes. Due to the adoption of the FAR system and the changes needed to implement that system, the best course of action is to allow the pooling service to go into effect at the same time the FAR system becomes operational at the receipt points. That should result in a pooling service that is fully integrated with the FAR system.
To the extent the costs of implementing the pooling service are not already included in the FAR system implementation costs, SDG&E and SoCalGas shall be allowed to track and recover the costs of implementing this service. Although the pooling service is likely to be used by marketers, shippers, and large noncore customers, the pooling service benefits all end-users on the system. The reasonable costs of implementing this service, which we shall limit to a maximum of $500,000, shall be recovered from all ratepayers.
The proposal to offer a pooling service is approved. SDG&E and SoCalGas shall file an AL with the tariff and service needed to implement the pooling service. The AL shall be filed within 45 days of the effective date of this decision. The tariff and service shall be consistent with our discussion of this service. The AL is subject to protest, and such protests shall be filed within 20 days after the AL has been filed. The AL shall be served as described in the FAR system discussion.
63 The proposed tariff for the pooling service is attached to Exhibit 15 as Schedule No. G-POOL.
64 See the diagram at page 26 of Exhibit 15 and Special Condition 11 of the proposed Schedule No. G-POOL in Exhibit 15 for the various pooling transactions that can take place.
65 Proposed Schedule No. G-POOL provides that SoCalGas reserves the right to review the status of the transfer charges no earlier than six months following the effective date of the tariff.
