Details for: PGE AL 4128-G.pdf

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Erik Jacobson
Regulatory Relations

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

August 6, 2019

Advice 4128-G
(Pacific Gas and Electric Company ID U 39 G)

Public Utilities Commission of the State of California

Expedited Advice Letter Pre-Approval of Six Natural Gas Transport

Pacific Gas and Electric Company (PG&E) respectfully requests California Public
Utilities Commission (Commission or CPUC) pre-approval of six existing firm
transportation service agreements (FTSA) with TransCanada’s NOVA Gas
Transmission Ltd. (NGTL), Foothills Pipe Line Ltd. (Foothills) and Gas Transmission
Northwest (GTN) pipelines which connect the supply basins in Western Canada to the
California/Oregon border at Malin, Oregon for a period of 7-years.
The purpose of this expedited advice letter is to request pre-approval for pipeline
transportation contracts under the interstate capacity acquisition procedure approved in
Decision (D.) 04-09-022.1 Under these procedures, pipeline contracts endorsed by the
CPUC Public Advocates Office (Cal PA) and The Utility Reform Network (TURN) may
be submitted for pre-approval to the Commission by an Expedited Advice Letter.
TURN’s participation in the approval process is voluntary, and TURN has declined to
participate in the review of these contracts. PG&E has consulted with Cal PA and they
have confirmed their support for the proposed pipeline contracts.
Under D.04-09-022, contracts for pipeline capacity may be submitted by expedited
advice letter, seeking Commission pre-approval within 21 days of the advice letter
submittal date. PG&E requests that the Commission approve this advice letter by
August 27, 2019.
Description of Contract
The terms of the proposed contracts are confidential as described in the accompanying
Declaration dated August 6, 2019 and are described in Confidential Appendix A.

Order Instituting Rulemaking to Establish Policies and Rules to Ensure Reliable, Long-Term
Supplies of Natural Gas to California (Gas Capacity OIR), R.04-01-025.


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Advice 4128-G -2- August 6, 2019 Confidential Appendix A is submitted to the Energy Division, Legal Division and Cal PA and is also confidential as described in the accompanying Declaration dated August 6, 2019. In addition, the confidential contract terms will be provided to PG&E’s Core Transport Agents (CTAs) who agree to the terms of a nondisclosure agreement. All costs associated with the contracts will continue to be recovered from PG&E’s core gas customers, in accordance with the interstate pipeline capacity contract procedures established in D.04-09-022 and D.15-10-050, through PG&E’s Core Pipeline Demand Charge Account, and PG&E’s gas tariffs, and from CTAs through the provisions of Tariff G-CT. This advice letter will not affect any other rate or charge, cause the withdrawal of service, or conflict with any other rate schedule or rule. Protests – Ten Day Expedited Period Anyone wishing to protest this advice letter may do so by letter sent via U.S. mail, facsimile or E-mail, no later than August 16, 2019, which is ten (10) days from the date of this submittal, in accordance with the expedited protest period authorized in D.04-09022. Protests should be mailed 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 also should be sent via U.S. mail (and by facsimile and electronically, if possible) to PG&E 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 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177
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Advice 4128-G -3- August 6, 2019 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). Effective Date In accordance with the comment and evaluation period provided in D.04-09-022, PG&E submits this advice letter as a Tier 2, and requests Commission approval of this submittal effective August 27, 2019, which is 21 days after the date of this submittal. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the service lists for R.04-01-025 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 filings can also be accessed electronically at /S/ Erik Jacobson Director, Regulatory Relations cc: Confidential Version (with Confidential Appendix A) Franz Cheng - Energy Division Belinda Gatti - Energy Division Eugene Cadenasso – Energy Division Jonathon Bromson - Legal Division R. Mark Pocta – Public Advocates Office Nika Kjensli– Public Advocates Office Pearlie Sabino - Public Advocates Office Public Version (without Confidential Appendix A) Marcel Hawiger - The Utility Reform Network Service list for R.04-01-025 Service list for A.13-06-011
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39G) Utility type: ELC PLC ELC = Electric PLC = Pipeline ✔ GAS WATER HEAT Contact Person: Yvonne Yang Phone #: (415)973-2094 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 4128-G Subject of AL: Expedited Advice Letter Pre-Approval of Six Natural Gas Transport Contracts Keywords (choose from CPUC listing): Contracts AL Type: Monthly Quarterly Annual ✔ One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.04-09-022 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: ✔ Yes No See attached confidential declaration Dennis Gee,, 415-973-4337 Yes ✔ No 8/27/19 No. of tariff sheets: 0 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: Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests 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: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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DECLARATION SUPPORTING CONFIDENTIAL DESIGNATION ON BEHALF OF PACIFIC GAS AND ELECTRIC COMPANY l. 1, Dennis Gee, am a Principal of Core Gas Supply of Pacific Gas and Electric Company a Califomia corporation. Fong Wan, the Senior Vice President of Energy Procurement of PG&E, delegated authority to me to sign this declaration. My business office is located at: Pacific Gas and Electric Company 77 Beale Street Mailstop BSA San Francisco, CA 94105 2. PG&E will produce the information identified in paragraph of this Declaration to the California Public Utilities Commission (“CPUC”) or departments within or contractors retained by the CPUC in response to a CPUC audit, data request, proceeding, or other CPUC request. Name or Docket No. of CPUC Proceeding: Advice Letter 4l28—G 3. Title and description of document: Expedited Advice Letter Pre-Approval of Six Natural Gas Transport Contracts, dated August 6, 2019 4. This document contains confidential information that, based on my information and belief, has not been publicly disclosed. This document has been marked as confidential, and the basis for confidential treatment and where the confidential information is located on the document is identified on the following chart:
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zck Basis for Confidential Treatment Customer-specific data, which may include demand, loads, I names, addresses, and billing data (Protected undcr Civ. Code 1798 erseq.; Govt. Code 6254; Public Util. Code 8380; Decisions 14-05-016, 04-08-055, 06-12-029; and General Order (GO.) 77-M) Personal information that identifies or describes an individual (including employees), which may include home address or phone number; SSN, driver’s license, or passport numbers; education; financial matters; medical or employment history (not including PG&E job titles); and statements attributed to the individual (Protected under Civ. Code 1798 el seq and G.O. 66-C) Physical facility, cyber-security sensitive, or critical energy infrastructure data, including without limitation critical energy infrastructure information as defined by the regulations of the Federal Energy Regulatory Commission at 18 CFR. 388.113 (Protected under Govt Code 6254(k), (ab); USC. 131; CFR §29.2) Accident reports (Protected under PUC 315 and GO. 66-C, 21) Commercial records that, if revealed, would place PG&E at an unfair business disadvantage, including market-sensitive data; business plans and strategies; long-term fuel buying I and hedging plans; price, load, or demand forecasts; power purchase agreements within fliree years of execution; and intemal financial information (Protected under Govt Code 6254, 6276.44; Evid Code 1060; Civ. Code 3426 ex‘ seq; and GO. 66-C, 2.2 Proprietary and trade secret information or other intellectual property (Protected under Civ. Code 3426 et seq Govt Code 6254.15) Corporate financial records (Protected under Govt Code 6254.15) ]&E Confidentiality Declaration
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Third-Party information subject to non—disclosure or confidentiality agreements (See, eg., D.11-01-036) Other basis: 5. The importance of maintaining the confidentiality of this information outweighs any public interest in disclosure of this information. This information should be exempt from the public disclosure requirements under the Public Records Act and should be withheld from disclosure. 6. I declare under penalty of perjury that the foregoing is true, correct, and complete to the best of my knowledge. 7. Executed on this 6111 day of August, 2019 at San Francisco, Califomia. PG&E Confidentiality Declaration Dennis Gee Principal Pacific Gas and Electric Company
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Confidential Appendix A Advice 4128 – G Proposed Capacity Contracts Between Pacific Gas and Electric Company and Nova Gas Transmission Ltd. (NGTL), Foothills Pipe Lines Ltd. (Foothills), and Gas Transmission Northwest (GTN) CONFIDENTIAL MATERIAL Confidential in its Entirety as Described in the Accompanying Declaration Dated August 6, 2019
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PG&E Gas and Electric Advice Submittal List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Cameron-Daniel, P.C. 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 East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Engineers and Scientists of California 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 Peninsula Clean Energy Pioneer Community Energy Praxair Redwood Coast Energy Authority 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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