IX. Comments on Draft Decision
The draft decision in this matter was mailed to the parties in accordance with Pub. Util. Code § 311(g)(1) and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed on _____________, and reply comments were filed on ______________________.
1. Baring unforeseen circumstances or unlikely weather events, PG&E should have adequate gas supplies to meet system needs over the next 12 months.
2. Baring unforeseen circumstances, SoCalGas should have adequate gas supplies to meet system needs over the next 12 months.
3. Investments in compressors and the authority to use cushion now pending before this Commission should increase the SoCalGas system reserves of gas and provide a margin that makes a gas curtailment or diversion extremely unlikely in the next 12 months.
4. Since gas supplies over the next 12 months are adequate for all core and noncore customers, it is not reasonable to expect that granting gas service priorities to electric generators will avoid any service curtailments.
5. Electric generators with gas storage can avoid gas curtailments even when supplies are short by placing gas in storage.
6. Although all gas storage in California is currently subscribed, there is no information in this record on the need for additional gas storage by electric generators.
7. Providing electric generators who hold gas in storage with preferred access to flowing gas in times of shortfalls is not a reasonable policy.
8. Granting a gas priority to all electric generators is an overly broad and unreasonable policy.
9. The link between a change in gas curtailment policies and the avoidance of blackouts is weak. In the event of a shortfall, CGC's proposed priorities could curtail gas to non-electric generators even when no blackouts are imminent.
10. Granting special gas priorities to electric generators imposes unfair burdens on other non-core gas customers.
11. Some non-electric generating gas customers perform services vital to the California economy and public health and safety.
12. Because electric generators make up two-thirds of the noncore gas demand, granting electric generators preferences in the event of a supply shortfall will amplify the impacts of gas shortages on other customers. A supply shortfall to noncore customers of one-third would have zero impact on electric generators but lead to the curtailment of all other gas uses.
13. Granting gas service preferences to certain gas end-users will prove complex to implement and require enforcement.
14. Changing gas service priorities at this time is not reasonable or in the public interest because it is not needed, will produce no benefits, will discourage the use of storage, may have unintended adverse consequences that make gas supply less reliable, and will incur implementation and enforcement costs.
15. The adequacy of PG&E's and SoCalGas' gas supplies over the next 12 months makes changes in storage regulations pertaining to these companies unnecessary at this time.
16. Under tariffs, PG&E has the ability to reclaim unused firm storage capacity for use by other customers.
17. All gas storage held by PG&E, SoCalGas, and independent storage companies is currently sold out in California.
18. TURN has failed to demonstrate that there is an immediate need for its Excess Core Storage Program.
19. Because TURN's Excess Core Storage Program in southern California was intended for the summer of 2001, it is now moot.
20. There is no information demonstrating that additional monitoring and disclosure concerning the amount of gas in storage would serve the public interest.
21. There are no remaining open issues in this proceeding.
1. Pursuant to § 451 and § 453, the Commission should not modify the gas tariffs of PG&E and SoCalGas to grant gas service priorities to electric generators.
2. Pursuant to § 451 and § 701.1(a), the Commission should not modify regulations affecting gas storage at this time.
3. The Commission should deny TURN's June 1, 2001 Motion for Clarification and Modification of the April 17, 2001 Assigned Commissioner Ruling and Scoping Memo.
IT IS ORDERED that:
1. The Utility Return Network's June 1, 2001 Motion for Clarification and Modification of the April 17, 2001 Assigned Commissioner Ruling and Scoping Memo is denied.
2. Respondents shall, and interested parties may, file opening comments on January 15, 2001 and reply comments on February 1, 2002 on the question of whether and how the Commission should allocate gas among electric generators during times of gas curtailments. Comments should directly address whether allocations based on considerations of the generations facility's heat rate or other factors can effectively improve the supply and reliability of electricity during times of natural gas curtailments.
This order is effective today.
Dated , at San Francisco, California.
