The current Off-System Delivery rules could undermine the effectiveness of a High OFO by allowing customers to gas in their OSD account for three “park” days without incurring Buy-Back Charges. Notice of AL 4976-G was made by publication in the Commission’s Daily Calendar. SoCalGas states that a copy of the Advice Letter was mailed and distributed in accordance with Section 4 of General Order 96-B. SoCalGas’s Advice Letter AL 4976-G was timely protested by Southern California Edison on July 5, 2016. SoCalGas filed a timely reply to SCE’s protest on July 12, 2016. SCE Protest Southern California Edison raises three objections to SoCalGas’s proposal. 1. SCE argues that a customer’s Off-System Delivery and on-system imbalances should be aggregated; Buy-Back Charges should only be applied if the aggregate imbalance is greater than the High OFO tolerance. SCE provides the following example to illustrate its concerns: A High OFO is called with a tolerance of +5% A shipper actually burns 100,000 MMBtu on that day The High OFO tolerance is 5,000 MMBtu The shipper’s total receipts on the High OFO day are 105,000 MMBtu Under the SoCalGas proposal in Advice 4976-G, if the hypothetical shipper were to attempt to move 5,000 MMBtu of its supply to an OSD that was not cleared by the end of the day, the 5,000 MMBtu in the OSD account would be subject to the Buy-Back, even though the shipper was within its High OFO tolerance.
The current Off-System Delivery rules could undermine the effectiveness of a High OFO by allowing customers to “park” gas in their OSD account for three days without incurring Buy-Back Charges. Notice of AL 4976-G was made by publication in the Commission’s Daily Calendar. SoCalGas states that a copy of the Advice Letter was mailed and distributed in accordance with Section 4 of General Order 96-B. SoCalGas’s Advice Letter AL 4976-G was timely protested by Southern California Edison on July 5, 2016. SoCalGas filed a timely reply to SCE’s protest on July 12, 2016. SCE Protest Southern California Edison raises three objections to SoCalGas’s proposal. 1. SCE argues that a customer’s Off-System Delivery and on-system imbalances should be aggregated; Buy-Back Charges should only be applied if the aggregate imbalance is greater than the High OFO tolerance. SCE provides the following example to illustrate its concerns: A High OFO is called with a tolerance of +5% A shipper actually burns 100,000 MMBtu on that day The High OFO tolerance is 5,000 MMBtu The shipper’s total receipts on the High OFO day are 105,000 MMBtu Under the SoCalGas proposal in Advice 4976-G, if the hypothetical shipper were to attempt to move 5,000 MMBtu of its supply to an OSD that was not cleared by the end of the day, the 5,000 MMBtu in the OSD account would be subject to the Buy-Back, even though the shipper was within its High OFO tolerance.
166300781.docx