available for PG&E’s use, even if CTAs procure alternate resources, and even if PG&E is able to resell such withdrawal capacity to another party. Gas would be put in storage that could be withdrawn if needed. It is not clear that for CTA Self-Managed Storage, alternative resources that PG&E or ISPs would provide would be an “alternate” to initially obtained storage that could be withdrawn, nor how such “alternate resources” would practically function. The workshops ordered in the Draft Resolution, however, will explicitly address whether and how alternative resources to CTA self-managed storage can be achieved, rather than merely accepting that it cannot be done, or can be done. Commercial Energy also acknowledges that the Draft Resolution notes D.16-06-056 did not prohibit alternate resources in the context of CTA’s Self-Managed Storage program. But it takes issue with the Draft Resolution having accepted PG&E’s proposals for the first two years of the seven-year phase-out period of PG&E-allocated storage to CTAs. Their comment contends the Draft Resolution “concludes without substantive discussion that CTAs will be limited for two years to PG&E or ISP storage.” Commercial Energy requests the Draft Resolution be revised to allow CTAs to use alternate resources, and that this be mandated, instead of the present reference to PG&E being required to file an Advice Letter in terms of “including specific mechanisms to potentially allow CTAs the use of alternate resources.” Commercial Energy also states that PG&E’s recent application A.17-11-009 proposes significant changes and downsizing of the IOU’s gas storage assets and capacity. In that context, Commercial Energy requests the Draft Resolution be withdrawn and the Self-Managed Storage program be examined as part of A.17-11-009. The second set of comments is from CTAC which contends that the Commission has erred in removing alternate resources as an option for CTAs. CTAC requests that the Draft Resolution be amended to allow alternate resources and to reduce the proposed approval from two years to one year, which would be used by PG&E to propose and implement tariff changes to provide the alternate resources option. It supports discussion
available for PG&E’s use, even if CTAs procure alternate resources, and even if PG&E is able to resell such withdrawal capacity to another party. Gas would be put in storage that could be withdrawn if needed. It is not clear that for CTA Self-Managed Storage, alternative resources that PG&E or ISPs would provide would be an “alternate” to initially obtained storage that could be withdrawn, nor how such “alternate resources” would practically function. The workshops ordered in the Draft Resolution, however, will explicitly address whether and how alternative resources to CTA self-managed storage can be achieved, rather than merely accepting that it cannot be done, or can be done. Commercial Energy also acknowledges that the Draft Resolution notes D.16-06-056 did not prohibit alternate resources in the context of CTA’s Self-Managed Storage program. But it takes issue with the Draft Resolution having accepted PG&E’s proposals for the first two years of the seven-year phase-out period of PG&E-allocated storage to CTAs. Their comment contends the Draft Resolution “concludes without substantive discussion that CTAs will be limited for two years to PG&E or ISP storage.” Commercial Energy requests the Draft Resolution be revised to allow CTAs to use alternate resources, and that this be mandated, instead of the present reference to PG&E being required to file an Advice Letter in terms of “including specific mechanisms to potentially allow CTAs the use of alternate resources.” Commercial Energy also states that PG&E’s recent application A.17-11-009 proposes significant changes and downsizing of the IOU’s gas storage assets and capacity. In that context, Commercial Energy requests the Draft Resolution be withdrawn and the Self-Managed Storage program be examined as part of A.17-11-009. The second set of comments is from CTAC which contends that the Commission has erred in removing alternate resources as an option for CTAs. CTAC requests that the Draft Resolution be amended to allow alternate resources and to reduce the proposed approval from two years to one year, which would be used by PG&E to propose and implement tariff changes to provide the alternate resources option. It supports discussion
210022085.docx