Details for: PGE AL 4003-G.pdf

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Erik Jacobson
Regulatory Relations

Pacif ic Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

August 3, 2018

Advice 4003-G
(Pacific Gas and Electric Company ID U 39 G)

Public Utilities Commission of the State of California

Request for Waiver of Core Interstate Capacity Planning Range for
2019 and 2020 Non-Winter Months

Pacific Gas and Electric Company (PG&E) hereby submits for California Public
Utilities Commission (CPUC or Commission) approval this advice letter seeking a
temporary, limited waiver of procuring to the capacity planning range minimum for
the 2019 and 2020 non-winter months of April through October. Specifically, PG&E
requests to hold 8,000 decatherms per day (8 MDth/day) less interstate pipelin e
capacity than the capacity range minimum for the 2019 and 2020 non-winter months.
In Decision (D.) 15-10-050, the Commission directed PG&E to set its Non-Winter (April
through October) core interstate pipeline capacity planning range between 80% and 105%
of forecast average annual daily core demand, and its Winter (November through March)
core interstate pipeline capacity planning range between 100% and 115% of forecast
average annual daily core demand.
As described in D.15-10-050, the corresponding capacity volume range calculation is to
be based on the PG&E Core load forecast in the biennial California Gas Report,
published in July of even-numbered years. The capacity planning range volumes are
to be updated after issuance of the California Gas Report, to be effective the following
April 1.
In compliance with D.15-10-050, PG&E submitted Advice Letter (AL) 3997-G to revise
the portfolio capacity planning range volumes—as shown in Table 1 below—based on
PG&E’s core load forecast a s published in the 2018 California Gas Report.1 The
updated capacity range calculations are detailed in Appendix A of AL 3997-G.



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Advice 4003-G -2- August 3, 2018 Table 1 – Revised Capacity Planning Ranges under AL 3997-G Season Minimum Capacity Holding (MDth/d) Maximum Capacity Holding (MDth/d) 618 811 772 888 Non-Winter APR 2019 – OCT 2019 APR 2020 – OCT 2020 Winter NOV 2019 – MAR 2020 NOV 2020 – MAR 2021 Assuming AL 3997-G is approved by the Commission, the volume ranges shown in Table 1 will become effective April 1, 2019, and remain in effect through March 31, 2021. Limited Waiver of Interstate Capacity Non-Winter Minimum Standard Assuming the revisions to the Interstate Capacity Planning Range described above are approved by the Commission, PG&E’s current interstate capacity portfolio would be approximately 8 MDth short of the 2019 and 2020 non-winter minimum capacity planning standard. PG&E currently holds 610 MDth of interstate capacity for these non-winter months, beginning April 1, 2019. Typically, PG&E would contract for the additional interstate capacity needed to meet the minimum of the capacity range. However, in this case, the amount of capacity needed to meet the standard (8 MDth) is extremely small, constituting only 1.3 percent of the overall capacity currently held for Core customers (610 MDth). Procuring such a small amount of interstate capacity would present an undue administrative and financial burden because PG&E would have to allocate the 8 MDth to Core Transport Agents (CTAs); the amount of capacity allocated to each CTA would be so small as to be impractical to use in a manner that benefits core customers. PG&E further notes that peak core gas demands do not occur during the non-winter months, and PG&E expects to have ample gas supplies to meet all customer demands and storage injection requirements. To avoid the unnecessary expense for both PG&E and CTAs of procuring such a small amount of interstate capacity, PG&E requests Commission approval to temporarily lower the Core Capacity Planning Range minimum for the non-winter months of April-October, in both 2019 and 2020, from 618 Mdth to 610 MDth. 2 2 Note that this waiver request is consistent with PG&E’s request in its 2019 Gas Transmission and Storage (GT&S) Rate Case, whereby PG&E Core Gas Supply (CGS) “requests the ability to seek Energy Division approval for an exception to the requirement to pro cure up to the
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Advice 4003-G -3- August 3, 2018 Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than August 23, 2018, which is 20 days after the date of this submittal. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Capacity Planning Range minimum if it anticipates a shortfall of no more than 50 MDth/day during a given month.” A.17-11-009, Chapter 19, page 19-13. The waiver request under this advice letter is a temporary exemption only and would serve as a bridge until PG&E’s related request in the 2019 GT&S Rate Case is evaluated.
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Advice 4003-G -4- August 3, 2018 Effective Date PG&E requests that this Tier 33 advice submittal become effective upon Commission approval. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and/or via U.S. mail to parties shown on the attached list and the service lists for R.04-01-025, A.13-12-012, and A.13-06-011. Address changes to the General Order 96-B service list should be directed to email For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter submittals can also be accessed electronically at /S/ Erik Jacobson Director, Regulatory Relations cc: 3 Jean Spencer - Energy Division Belinda Gatti - Energy Division Eugene Cadenasso – Energy Division Jonathon Bromson - Legal Division R. Mark Pocta - Office of Ratepayer Advocates Nika Rogers – Office of Ratepayer Advocates Pearlie Sabino - Office of Ratepayer Advocates Marcel Hawiger - The Utility Reform Network Service list for R.04-01-025 Service list for A.13-12-012 Service list for A.13-06-011 Past Capacity Range advice letters, including Advice Letter 3997 -G, were submitted as Tier 2 advice letters. Since this letter seeks a limited, temporary waiver, it is submitted as a Tier 3 advice letter.
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CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER SUBMITTAL SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No. Pacific Gas and Electric Company (ID U39 G) Utility type: Contact Person: Annie Ho  ELC  GAS  PLC  HEAT Phone #: (415) 973-8794  WATER E-mail: and EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat (Date Submitted/ Received Stamp by CPUC) WATER = Water Advice Letter (AL) #: 4003-G Tier: 3 Subject of AL: Request for Waiver of Core Interstate Capacity Planning Range for 2019 and 2020 Non-Winter Months Keywords (choose from CPUC listing): Core, AL submittal type:  Monthly  Quarterly  Annual  One-Time  Other _____________________________ If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.15-10-050 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: ____________________ Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No Confidential information will be made available to those who have executed a nondisclosure agreement: N/A Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: __________________________________________________________________________________________________ Resolution Required? Yes No Requested effective date: Upon Commission Approval N No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed: N/A Pending advice letters that revise the same tariff sheets: N/A Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: California Public Utilities Commission Energy Division EDTariffUnit 505 Van Ness Ave., 4 th Flr. San Francisco, CA 94102 E-mail: Pacific Gas and Electric Company Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 E-mail:
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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