In response to the Applicants’ claims, SCGC, Sierra Club, TURN, and POC all cite the low probability of an unplanned outage on Line 3010. According to SCGC: There has only been one unplanned outage lasting one day on Line 3010 during its entire 57 year operating history, and there was no loss of service to customers. Of course, planned outages for maintenance purposes may occur, but there have only been twenty planned outages in the 57 year operating history of Line 310. The planned outages lasted between half a day and three days with seventy percent of the outages lasting one day, again with no loss of service to customers. (SCGC Opening Brief at 47.) SCGC observes, “The frequency factor for Moreno outages is even smaller than for Line 3010.” (SCGC Opening Brief at 4748.) It notes that occasionally an individual compressor engine can fail at Moreno and that the Applicants have recorded nineteen individual engine failures between 2006 and 2015. However, the duration of the outages have been short and has not impacted the overall throughput at Moreno. SCGC challenges the Applicants’ claims that Line 3010 outages impact the system at large. “The Applicants erroneously assume that the SDG&E system is completely dependent on deliveries from Rainbow.” (SCGC Opening Brief at 48.) It challenges the Applicants’ claim that “currently 3.2 million people are essentially dependent on a single pipeline” for transmission service. SCGC subscribes to a broader perspective that SDG&E is interconnected at Otay Mesa with TGN which can receive gas either as delivered from Energia Costa Azul or gas that is delivered from Ehrenberg through North Baja and Gasoducto Rosarito. “Moreover, there are options for reinforcing the SDG&E electrical systems for insuring against shedding of electric load in the event of the highly
In response to the Applicants’ claims, SCGC, Sierra Club, TURN, and POC all cite the low probability of an unplanned outage on Line 3010. According to SCGC: There has only been one unplanned outage lasting one day on Line 3010 during its entire 57 year operating history, and there was no loss of service to customers. Of course, planned outages for maintenance purposes may occur, but there have only been twenty planned outages in the 57 year operating history of Line 310. The planned outages lasted between half a day and three days with seventy percent of the outages lasting one day, again with no loss of service to customers. (SCGC Opening Brief at 47.) SCGC observes, “The frequency factor for Moreno outages is even smaller than for Line 3010.” (SCGC Opening Brief at 4748.) It notes that occasionally an individual compressor engine can fail at Moreno and that the Applicants have recorded nineteen individual engine failures between 2006 and 2015. However, the duration of the outages have been short and has not impacted the overall throughput at Moreno. SCGC challenges the Applicants’ claims that Line 3010 outages impact the system at large. “The Applicants erroneously assume that the SDG&E system is completely dependent on deliveries from Rainbow.” (SCGC Opening Brief at 48.) It challenges the Applicants’ claim that “currently 3.2 million people are essentially dependent on a single pipeline” for transmission service. SCGC subscribes to a broader perspective that SDG&E is interconnected at Otay Mesa with TGN which can receive gas either as delivered from Energia Costa Azul or gas that is delivered from Ehrenberg through North Baja and Gasoducto Rosarito. “Moreover, there are options for reinforcing the SDG&E electrical systems for insuring against shedding of electric load in the event of the highly
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