Approving contracts that result from an RFO or an open season process via an expedited Advice Letter process. The System Operator regularly uses its ability to buy and sell spot gas to maintain minimum flows in the San Diego area. As required by D.0911006 and SoCalGas Rule 41, SoCalGas is required to provide an Annual Compliance Report summarizing all the purchases and sales of gas made by the System Operator to maintain the Southern System minimum flow requirements. Section 17 of Rule 41 permits the Gas Control Department of the System Operator to make spot purchases at Otay Mesa or move supplies from Blythe to Otay Mesa when it is necessary to meet minimum flow requirements. In addition, a new tool was recently added as a temporary addition to Rule 41 (Section 29) permitting SoCalGas to enter into summertime baseload contracts. Parties’ Positions Applicants observe that only ORA supports the concept of an “open season.” Applicants argue that the “open season” concept is not applicable to the Proposed Project, which is a safety and reliability project. (SDG&E/SoCalGas Opening Brief at 52.) D.0211073 also indicates that open seasons are a vehicle to allocate firm noncore capacity between existing customers, new customers, incremental new load of customers and new customers. But Applicants argue that “[s]uch situations, however, do not exist here...[i]n stark contrast, the PSRP is proposed to enhance the safety and reliability of SDG&E’s existing gas system.” (SDG&E/SoCalGas Opening Brief at 52.) In D.0609039, the Commission stated that utilities may not rely on results of open season bidding in designing their local transmission system, but rather they must ensure that it remains reliable. Applicants argue that ORA suggested
Approving contracts that result from an RFO or an open season process via an expedited Advice Letter process. The System Operator regularly uses its ability to buy and sell spot gas to maintain minimum flows in the San Diego area. As required by D.0911006 and SoCalGas Rule 41, SoCalGas is required to provide an Annual Compliance Report summarizing all the purchases and sales of gas made by the System Operator to maintain the Southern System minimum flow requirements. Section 17 of Rule 41 permits the Gas Control Department of the System Operator to make spot purchases at Otay Mesa or move supplies from Blythe to Otay Mesa when it is necessary to meet minimum flow requirements. In addition, a new tool was recently added as a temporary addition to Rule 41 (Section 29) permitting SoCalGas to enter into summertime baseload contracts. Parties’ Positions Applicants observe that only ORA supports the concept of an “open season.” Applicants argue that the “open season” concept is not applicable to the Proposed Project, which is a safety and reliability project. (SDG&E/SoCalGas Opening Brief at 52.) D.0211073 also indicates that open seasons are a vehicle to allocate firm noncore capacity between existing customers, new customers, incremental new load of customers and new customers. But Applicants argue that “[s]uch situations, however, do not exist here...[i]n stark contrast, the PSRP is proposed to enhance the safety and reliability of SDG&E’s existing gas system.” (SDG&E/SoCalGas Opening Brief at 52.) In D.0609039, the Commission stated that utilities may not rely on results of open season bidding in designing their local transmission system, but rather they must ensure that it remains reliable. Applicants argue that ORA suggested
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