Service

Average Injection25

(MDth/d)

Inventory26

(MMDth)

Withdrawal on January 15th (MDth/d)

Monthly Balancing Service27

76

4.1

76

Core Firm Storage G-CFS

164

33.5

1,15028

Standard Firm Storage G-SFS

76

9.4

13429

Total

316

47

1,360

Theoretical Service

Date

Injection

(MDth/d)

Estimated

Inventory

(MMDth)

Withdrawal

(MDth/d)

Firm Rights

Counter-Cyclical

(MDTH/d)

October 31

113

33.5

0

50 - withdrawal

November 1

0

33.5

1,442

50 - injection

January 15

0

13.2

1,150

50 - injection

February 15

0

6.2

1,000

50- injection

March 31

0

1.0

761

50 - injection

April 1

211

0

0

50 - withdrawal

Season

Average Injection

(MDth/d)

Inventory

(MMDth)

Average Withdrawal

(MDth/d)

April - October

76

9.4

13431

November and

March

76

9.4

75

December -

February

0

9.4

134

Services

Average Injection

MDth/d

Inventory

MDth/d

Average Withdrawal

MDth/d

Balancing Service

76

4.1

76

Core Firm Storage

156.6

33,477.7

1111.2

Standard Firm Storage

22.4

4,782.5

158.7

Total

255

42.4

1345.9


"The fixed withdrawal rights are set in proportion to the minimum withdrawal capacity that PG&E Core Procurement must support, through the holding of inventory, to meet its Winter Firm Capacity Requirement. A comparable fixed injection right is also set for these smaller CPGs. All CPGs that accept a share of Core Firm Storage capacity will be required to maintain their storage inventory at sufficient levels to support withdrawal rates consistent with the Winter Firm Capacity Requirement." (Ex. 1, p. 6-10.)

22 PG&E's storage assets are operated by PG&E's California Gas Transmission (CGT) unit. 23 Market storage services does not include firm storage that is assigned to core customers. Market storage services cover Standard Firm Storage, negotiated firm storage, negotiated as-available storage, and parking and lending services. Core Firm Storage customers may also use market storage services to supplement their core service or to purchase additional storage capacity. 24 Table 1 comes from Table 6-2 of Exhibit 1. 25 The storage injection capacities shown in the table include rented compressor units installed during the Gas Accord period. 26 The amounts shown for inventory are the maximum inventory assigned. 27 The amounts shown for balancing are for year-round injection and withdrawal capacity. 28 The withdrawal right for G-CFS reflects the required withdrawal to meet the proposed core Winter Firm Capacity Requirement. 29 The withdrawal right shown for G-SFS is the average assigned withdrawal for December through February. 30 Should a flood occur causing the rental compression at McDonald Island to become inoperable, PG&E proposes to provide service to Core Firm Storage customers and monthly balancing first, and then to Schedule G-SFS customers, and lastly to remaining market storage services customers. In other circumstances where firm injection capacity is constrained, PG&E proposes to prorate all firm injection rights equally. 31 For the period April - October, each G-SFS customer will be allowed to select its own three months for counter-cyclical service from the seven-month season. The customer may choose any three months, consecutive or non-consecutive. 32 Since we are not adopting PG&E's proposed assignment of an additional 75 MDth/d of withdrawal capacity to Core Firm Storage, there is no need to address the peaking arrangement arguments. The issue about whether third-party storage providers can provide this service has also been addressed.

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