Request to Modify Tariff Rule No. 1 to Allow Small Electric Generation Customers Authority to Elect Core Service

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1 Lee Schavrien Director Regulatory Case Management and Tariff Administration 101 Ash Street San Diego, CA Tel: Fax: Pager: September 13, 2000 SoCalGas Advice No (U 904 G) Public Utilities Commission of the State of California Subject: Request to Modify Tariff Rule No. 1 to Allow Small Electric Generation Customers Authority to Elect Core Service Sempra Energy, on behalf of Southern California Gas Company (SoCalGas), hereby submits for filing revisions to SoCalGas' tariff schedules, applicable throughout its service territory, as shown on Attachment B. Purpose This filing requests authority to modify SoCalGas Tariff Rule No. 1, Definitions, to allow small electric generation customers the option of electing core service. Description of Tariff Change Under SoCalGas current Tariff Rule No. 1, the definitions of Core Service and Noncore Service exclude gas usage for electric generation from qualifying for core service. SoCalGas requests that small electric generation (EG) customers, i.e., those customers whose usage does not exceed 20,800 therms per active month on an annualized basis for a period of any 12 contiguous months within the most recent 24- month period, be given the option to elect core service as they once had. This would require minor additions to the definitions of Core Service and Noncore Service in SoCalGas Tariff Rule No. 1, as shown below by underlining. Revised Tariff Rule No. 1 Definition of Core and Noncore Service: Core Service: Service to end-use Priority 1 or Priority 2A as set forth in Rule No. 23. Priority 1 core service includes: (1) all residential usage regardless of size; and (2) all commercial and industrial customers whose usage does not exceed 20,800 therms per active month on an annualized basis for a period of any 12 contiguous months within the most recent 24-month period, excluding usage for electric generation and reclassified to noncore service pursuant to economic practicality prior to September 29, Electric generation customers whose usage is 20,800 therms or less per active month on an annualized basis for a period of any 12 contiguous months within the most

2 Advice No September 13, 2000 recent 24-month period are eligible to elect core service for 100% of their requirements. An active month is defined as any month during which the customer s usage exceeds 1,000 therms. Priority 2A core service includes all commercial and industrial customers whose usage is 20,800 therms per active month or greater on an annualized basis for a period of any 12 contiguous months within the most recent 24- month period. Priority 2A customers have the option of electing noncore service, in whole or in part. Noncore Service: Noncore service includes: (1) all industrial and commercial usage where the customer has elected noncore service; and (2) all natural gas usage for qualifying electric generation equipment, including solar electric generation projects, where the customer has not elected core service. Industrial and commercial customers whose usage is 20,800 therms or more per active month on an annualized basis for a period of any 12 contiguous months within the most recent 24-month period are eligible to elect noncore service in whole or in part. An active month is defined as any month during which the customer s usage exceeds 1,000 therms. All customers who receive noncore service are required to choose either core subscription, firm transportation, and/or interruptible transportation service as described in the applicable noncore service rate schedule. The end-use priorities for these services are set forth in Rule No. 23. Background When the Commission first defined core customers in Decision (D.) , it identified core customers as: customers who value guaranteed access to utility system gas sufficiently that they would be willing to bear whatever added costs or risks the utility must incur from its suppliers as a condition of that supply assurance. D limited the core customer classification to smaller customers with a monthly consumption of 20,800 therms. Thus, under SoCalGas earlier definitions in Tariff Rule No. 1, small generators could be classified as either an electric generation or a core customer. In D , the decision approving the merger of Pacific Enterprises and Enova Corporation, SoCalGas was ordered to provide a single rate to electric generators (the EG Rate). Ordering Paragraph 91 of D articulated the rationale for creating a single EG Rate: The establishment of a single class for all electricity generators will provide a level playing field for all gas-fired generators that receive gas service from SoCalGas by ensuring that all generators have access to monopoly intrastate gas transportation service at equitable rates. (Emphasis added) D , SoCalGas 1999 Biennial Cost Allocation Proceeding, further refined the single rate to electric generators concept.

3 Advice No September 13, 2000 Discussion of Requested Tariff Change With this advice filing, SoCalGas seeks to restore the option of more expensive but more reliable core service to small electric generators, while maintaining for the overall class of electric generators access to the lower EG Rate. Electric generation customers electing the more costly core service could see their transportation costs for generating power almost triple (from about $.064/therm to almost $.17/therm). Under the proposed Tariff Rule No. 1 definition of Core Service, only small electric generation customers could possibly qualify for core service. This change will enhance customer choice by allowing small electric generation customers the option to choose and pay for highly reliable core service. It should be noted that the vast majority of small electric generation customers would be core customers if not for their small electric generation equipment. Some of these customers purchased this equipment for reliability purposes and not necessarily as a cost savings. In order to comply with the Commission s EG anti-gaming provisions, under D , these customers are required to separately meter their electric generation load as long as they take service on the EG Rate. By foregoing service under the EG Rate, they could avoid the cost of separate metering and the more intense administrative requirements that go along with noncore service. It is simply impractical and uneconomic for some of these customers to purchase a costly Gas Energy Measurement Systems (GEMS) for a relatively small electric generator that may run only a few hours a year. Providing these customers with the option to remain core allows them to restore the conditions under which they invested in their electric generation. In addition, D provided for a single EG Rate throughout Sempra Energy s utilities service territories. While San Diego Gas and Electric Company s (SDG&E) tariffs establish the EG Rate for its EG Customers, SDG&E s tariffs do not preclude small EG customers from electing core service but simply define these customers as using less than 20,800 therms per month (see SDG&E Tariff Rule No. 14, a copy of which is incorporated herein as Attachment C). Thus, to ensure consistency throughout the Sempra Energy utilities service territories, the Commission should approve SoCalGas request in this advice letter. Impact on Other Customers Since these small electric generation customers would be selecting a higher rate than their current rate, by electing core service, this additional revenue would be used to reduce rates to other ratepayers. SoCalGas believes, however, that this impact will actually be very small, since only a few electric generation customers have expressed interest in taking core service and the size of their electric generation systems are small.

4 Advice No September 13, 2000 Protest Anyone may protest this advice letter to the California Public Utilities Commission. The protest must state the grounds upon which it is based, including such items as financial and service impact, and should be submitted expeditiously. The protest must be made in writing and received within 20 days of the date this advice letter was filed with the Commission. There is no restriction on who may file a protest. The address for mailing or delivering a protest to the Commission is: IMC Branch Program Manager Energy Division California Public Utilities Commission 505 Van Ness Avenue, Room 4002 San Francisco, CA A copy should also be mailed to the attention of Energy Division-IMC Branch, Room 4005 (at the address shown above). It is also requested that a copy of the protest be sent via electronic mail and facsimile to Sempra Energy on the same date it is mailed or delivered to the Commission (at the addresses shown below). Attn: Sid Newsom Regulatory Tariff Administration Sempra Energy - GT14D6 555 West Fifth Street Los Angeles, CA Facsimile No. (213) snewsom@sempra.com Attn: C. Richard Swanson Regulatory Tariff Manager Sempra Energy - HQ14C 101 Ash Street San Diego, CA Facsimile No. (619) rswanson@sempra.com Questions regarding this advice letter should be directed to Mr. Paul D. Borkovich of SoCalGas at (213) Effective Date It is respectfully requested that the Commission approve this advice letter by November 1, 2000 which is more than 40 days regular statutory notice.

5 Advice No September 13, 2000 Notice In accordance with Section III.G of General Order No. 96-A, a copy of this advice letter is being sent to the parties listed on Attachment A and to the parties in A LEE SCHAVRIEN Director -- Regulatory Case Management and Tariff Administration Sempra Energy Attachments

6 ATTACHMENT A Advice No General Order 96-A Distribution List Burbank Public Service Department California Manufacturers Association City of Anaheim Public Utilities Department City of Azusa Light and Power Department City of Banning Municipal Utilities City of Lompoc City of Los Angeles City of Riverside, Public Utilities Department City of Vernon, Director, Water & Power Department Colton Bureau of Light & Water General Services Administration, San Francisco General Services Administration, Washington D.C. Glendale Public Service Department Imperial Irrigation District Long Beach Gas Department Los Angeles Department of Water and Power March Air Force Base Naval Facilities Engineering Command, Western Division Pacific Gas and Electric Company Pasadena Water and Power Department San Diego Gas & Electric Company Southern California Edison Company Southwest Gas Corporation The Utility Reform Network Vandenberg Air Force Base

7 Case Id: A Case Description: 1999 BCAP Page: 1 Patrick J. Power 1300 Clay St., #600 Oakland, CA Paul M. Premo 310 Hazel Avenue Mill Valley, CA Alcantar & Elsesser Alexis K. Wodtke One Embarcadero, #2420 San Francisco, CA Alcantar & Elsesser LLP Evelyn Elsesser One Embarcadero Center, #2420 San Francisco, CA Alcantar & Elsesser LLP Michael Peter Alcantar 1300 SW Fifth Ave., #1750 Portland, OR BETA Consulting John Burkholder 2023 Tudor Lane Fallbrook, CA Barkovich & Yap, Inc. Catherine E. Yap P. O. Box Oakland, CA Berliner, Camdon & Jimison John W. Jimison th St., N.W., Ste. 800 Washington, D.C Brady & Berliner Thomas Beach 2560 Ninth Street, #316 Berkeley, CA Butler & Binion, LLP Richard E. Powers, Jr Pennsylvania Ave., N.W. Suite 300 South Washington, DC CPUC ALJ Steven Kotz 505 Van Ness Ave., Rm San Francisco, CA CEC Scott Tomashefsky 1516 Ninth Street, MS-22 Sacramento, CA CPUC Laura Krannawitter 505 Van Ness Avenue, #3207 San Francisco, CA CEC W. William Wood 1516 Ninth Street, MS-23 Sacramento, CA CPUC - ALJ Division ALJ Robert A. Barnett 505 Van Ness Avenue San Francisco, CA CPUC - ALJ Division Steven A. Weissman 505 Van Ness Avenue San Francisco, CA CPUC - ENERGY DIV Richard A. Myers 505 Van Ness Avenue, Rm. 4-A San Francisco, CA CPUC - Energy Division Joyce Alfton 505 Van Ness Ave., Rm 4-A San Francisco, CA CPUC - Legal Patrick L. Gileau, Esq. 505 Van Ness Avenue San Francisco, CA CPUC - Legal Division Darwin Farrar 505 Van Ness Ave., Rm San Francisco, CA CPUC - ORA Dexter Khoury 505 Van Ness Avenue, Rm San Francisco, CA CPUC - ORA Robert Mark Pocta 505 Van Ness Avenue San Francisco, CA CPUC - Public Advisor Office Rosalina White 505 Van Ness Ave., #5303 San Francisco, CA California Independent Petroleum William Julian II 1127 Eleventh Street, #226 Sacramento, CA Cambridge Energy Research Associate Peter Moritzburke 1999 Harrison St., #950 Oakland, CA Cameron McKenna LLP Michael S. Hindus 2175 K Street N.W. Washington, D.C Chevron U.S.A. David R. Stevenson 1301 McKinney St., Rm Houston, TX City of Burbank Fred Fletcher 164 West Magnolia Blvd., Box 631 Burbank, CA City of Vernon Kenneth J. de Dario, Director 4305 Santa Fe Ave. Vernon, CA Davis Wright Tremaine Anita Taff-Rice One Embarcadero Center, #600 San Francisco, CA 94111

8 Case Id: A Case Description: 1999 BCAP Page: 2 Downey Brand Seymour & Rohwer Dan L. Carroll 555 Capitol Mall Sacramento, CA Downey, Brand, Seymour & Rohwer Philip A. Stohr 555 Capitol Mall, #1050 Sacramento, CA Electric Clearinghouse, Inc. Gregory T. Blue 5976 W. Las Positas Bl., #200 Pleasanton, CA Ellison & Schneider Andrew B. Brown 2015 H Street Sacramento, CA Energy Law Group LLP Andrew J. Skaff 1999 Harrison Street, 27th Floor Oakland, CA Goodin MacBride Squeri Schlotz & Brian T. Cragg 505 Sansome, Suite 900 San Francisco, CA Goodin, MacBride, Squeri, Schlotz James D. Squeri 505 Sansome St., Suite 900 San Francisco, CA Goodin, MacBride, Squeri, Schlotz & James W. McTarnaghan, Esq. 505 Sansome Street, #900 San Francisco, CA Goodin, MacBride, Squeri, Schlotz & Michael B. Day, Esq. 505 Sansome Street, #900 San Francisco, CA Harbor Cogeneration Co Scott Hawley, Exec. Director Von Karman Ave., #1700 Irvine, CA Imperial Irrigation District Ronald B. Cox 333 East Barioni Blvd. Imperial, CA Jeffer, Mangels, Butler & Marmaro Edward W. O'Neill One Sansome Street, 12th Floor San Francisco, CA Jones, Day, Reavis, & Pogue Norman A. Pedersen, Esq. 555 West 5th Street, #4600 Los Angeles, CA Jones, Day, Reevis & Pogue Gregory Klatt 555 W. Fifth Street, #4600 Los Angeles, CA LADWP Roger Pelote 111 North Hope Street, Rm Los Angeles, CA Law Office of Richard L. Hamilton Richard L. Hamilton, Esq. 100 Howe Ave., #230N Sacramento, CA Luce, Forward, Hamilton & Scripps John W. Leslie 600 West Broadway, #2600 San Diego, CA PG&E Jennifer Post 77 Beale Street, Rm B30A San FRancisco, CA PG&E Keith T. Sampson 77 Beale Street San Francisco, CA PG&E Sandy Dickinson 77 Beale Street San Francisco, CA Pacific Gas and Electric Co. Frank R. Lindh P. O. Box 7442 San Francisco, CA Pasadena - Water and Power Rufus Hightower 150 S. Los Robles St., #200 Pasadena, CA Resource Management International Charles Doering 225 W. Broadway, #400 Glendale, CA Praxair, Inc Rick Noger 175 East Park Drive Tonawanda, NY Southern California Edison Co. Gloria M. Ing 2244 Walnut Grove Ave. Rosemead, CA Reliant Energy Retail, Inc Robert B. Task P. O. Box 4455 Houston, TX Louisiana St. Houston, TX Southwest Gas Corporation John C. Walley 5241 Spring Mountain P. O. Box Las Vegas, NV Southwest Gas Corporation Keith Brown P. O. Box Las Vegas, NV Sutherland, Asbill & Brennan Keith R. McCrea 1275 Pennsylvania Ave., N.W. Washington, D.C TURN Marcel Hawiger 711 Van Ness Ave., #350 San Francisco, CA 94102

9 Case Id: A Case Description: 1999 BCAP Page: 3 Texaco, Inc. John Beall P. O. Box 4596, 1111 Rusk St. Houston, TX U. C. A. N. Michael Shames 1717 Kettner Blvd., Suite 105 San Diego, CA White & Case LLP Jerry R. Bloom 2 Embarcadero Center, #650 San Francisco, CA White & Case LLP Joseph M. Karp 2 Embarcadero Center, #650 San Francisco, CA White & Case LLP Paul Lacourciere Two Embarcadero Center, #650 San Francisco, CA Williams Companies, Inc. Alex Goldberg 1 Williams Center, #4100, MD 41-3 Tulsa, OK 74172

10 Cal. P.U.C. Sheet No. ATTACHMENT B Advice No Title of Sheet Canceling Cal. P.U.C. Sheet No G Rule No. 01, Definitions, Sheet 3 of G G Rule No. 01, Definitions, Sheet 8 of G G Table of Contents, Rules, Sheet 1 of G G Table of Contents, General and Preliminary Statement, Sheet 1 of G

11 SOUTHERN CALIFORNIA GAS COMPANY Revised LOS ANGELES, CALIFORNIA CANCELING Revised CAL. P.U.C. SHEET NO. CAL. P.U.C. SHEET NO G G Rule No. 01 DEFINITIONS Sheet 3 of 14 (continued) Contract Quantity, Monthly : The monthly natural gas delivery quantity contracted for during each contract month as set forth in the customer's applicable service agreement. This quantity is based on the customer's historical usage or negotiated based on the customer's operational forecast. Core Subscription Service : Utility procurement service available to noncore customers. Core subscription service requires a two-year contract term commitment as identified in the customer's applicable rate schedule. Core Service: Service to end-use Priority 1 or Priority 2A as set forth in Rule No. 23. Priority 1 core service includes: (1) all residential usage regardless of size; and (2) all commercial and industrial customers whose usage does not exceed 20,800 therms per active month on an annualized basis for a period of any 12 contiguous months within the most recent 24-month period, excluding usage for electric generation and usage reclassified to noncore service pursuant to economic practicality prior to September 29, Electric generation customers whose usage is 20,800 therms or less per active month on an annualized basis for a period of any 12 contiguous months within the most recent 24-month period are eligible to elect core service for 100% of their requirements. An active month is defined as any month during which the customer's usage exceeds 1,000 therms. Priority 2A core service includes all commercial and industrial customers whose usage is 20,800 therms per active month or greater on an annualized basis for a period of any 12 contiguous months within the most recent 24-month period. Priority 2A customers have the option of electing noncore service, in whole or in part. N N Critical Customer: One where danger to human life, health or safety is involved, and includes customers such as hospitals, other state-licensed health care facilities, medical research facilities, medical facilities at military installations and detention facilities, municipal water pumping plants and sanitation facilities. Curtailment: Utility initiated suspension of natural gas service. Utility may temporarily reduce the daily quantity of gas it will transport or deliver or terminate service entirely for certain service categories as needed for operational requirements. Curtailment is implemented when, in the Utility's judgment, there exists a restriction or limitation on Utility transmission or distribution pipelines necessary for the acceptance, transportation or subsequent redelivery of natural gas resulting in Utility being unable to meet its operational, contractual or gas customers' requirements or when the Utility has a deficiency of natural gas supply available to meet its operational, contractual or sales customers' requirements. Curtailment Year: The period October 1 of each year through September 30 of the next calendar year. Customer: The person or entity in whose name service is rendered as evidenced by the signature on the application, contract, or agreement for that service, or in the absence of a signed instrument, by the receipt and payment of bills regularly issued in his name. Customer-Owned Gas: Natural gas transported by the Utility for customer's own use where title to such natural gas is held by the customer and is not a part of the Utility-owned system supplies. (TO BE INSERTED BY UTILITY) ADVICE LETTER NO. DECISION NO. (continued) ISSUED BY 2958 William L. Reed VICE PRESIDENT CHIEF REGULATORY OFFICER (TO BE INSERTED BY CAL. P.U.C.) DATE FILED EFFECTIVE RESOLUTION NO. SEP 13,2000

12 SOUTHERN CALIFORNIA GAS COMPANY Revised LOS ANGELES, CALIFORNIA CANCELING Revised CAL. P.U.C. SHEET NO. CAL. P.U.C. SHEET NO G G Rule No. 01 DEFINITIONS Sheet 8 of 14 (continued) Minimum Daily Quantity : The minimum daily quantity (MinDQ) is an estimate of natural gas usage at a customers premises not served by an automated meter for purposes of compliance with winter delivery requirements as specified in Rule No. 30. Multifamily Accommodations : An apartment building, duplex, mobile home park, or any other group of permanent residential single-family dwellings located upon a single premises, provided that the residential dwellings therein meet the requirements for a single-family dwelling or accommodation. A multifamily accommodation does not include hotels, motels, residential hotels, guest or resort ranches, marinas, tourist camps, recreational vehicle parks, campgrounds, halfway houses, rooming houses, boarding houses, institutions, dormitories, rest or nursing homes, convalescent or care facilities, military barracks, or any enterprise that includes or rents to either transient tenants or transient accommodations. Noncore Service: Noncore service includes: (1) all industrial and commercial usage where the customer has elected noncore service; and (2) all natural gas usage for qualifying electric generation equipment, including solar electric generation projects, where the customer has not elected core service. Industrial and commercial customers whose usage is 20,800 therms or more per active month on an annualized basis for a period of any 12 contiguous months within the most recent 24-month period are eligible to elect noncore service in whole or in part. An active month is defined as any month during which the customer's usage exceeds 1,000 therms. All customers who receive noncore service are required to choose either core subscription, firm transportation, and/or interruptible transportation service as described in the applicable noncore service rate schedule. The end-use priorities of these services are set forth in Rule No. 23. N Non-Profit Group Living Facility : A non-profit homeless shelter that may be government-subsidized with six (6) or more beds that provides lodging day or night for a minimum of 180 days of the year; other non-profit residential-type facilities (excluding government-owned and privately-owned, "for profit" government-subsidized housing) that provide a service in addition to lodging and which may be licensed by the appropriate state agency to care for residents who temporarily or permanently cannot function normally outside of the group home environment; and non-licensed, separately metered affiliated facilities where the primary facility is eligible for CARE and is the customer of record for the affiliate, and at least 70% of the energy consumed by the affiliate is used for residential purposes. All residents must meet the CARE income eligibility standards, however a caregiver who lives in the group facility is not a resident for purposes of determining the facility's eligibility. Non-profit group living facilities that are not licensed or certified must provide any other documentation the Utility may reasonably require. Off-System Customers: A marketer, broker, supplier or other entity bidding for storage service on their own behalf for ultimate consumption outside the Utility's service territory. Parking Transaction: Shall mean when SoCalGas received natural gas for service user's account for shortterm interruptible storage. (TO BE INSERTED BY UTILITY) ADVICE LETTER NO. DECISION NO. (continued) ISSUED BY 2958 William L. Reed VICE PRESIDENT CHIEF REGULATORY OFFICER (TO BE INSERTED BY CAL. P.U.C.) DATE FILED EFFECTIVE RESOLUTION NO. SEP 13,2000

13 SOUTHERN CALIFORNIA GAS COMPANY Revised LOS ANGELES, CALIFORNIA CANCELING Revised CAL. P.U.C. SHEET NO. CAL. P.U.C. SHEET NO G G TABLE OF CONTENT S (continued) RULES Rule Number Title of Sheet Cal. P.U.C. Sheet No. 1 Definitions G,30005-G,32992-G,32731-G,32732-G,32733-G G,32993-G,32736-G,32737-G,32738-G,32739-G,32740-G,32741-G 2 Description of Service G,28357-G,28358-G G,28360-G,28361-G,28362-G 3 Application for Service G 4 Contracts G 4.1 Exemption from Public Inspection Requirements for Certain Gas Corporation Contracts G,28978-G,28979-G,28980-G 5 Special Information Required on Forms G,24601-G 6 Establishment and Re-Establishment of Credit G,28449-G 7 Deposits G 8 Return of Deposit--Interest on Deposit G 9 Discontinuance of Service G,26950-G,26422-G,26423-G G,24611-G 10 Service Charges G,30600-G,30601-G,30602-G,30603-G,30604-G G,30606-G,30607-G,30608-G,30609-G,30610-G 11 Disputed Bills G 12 Payment of Bills G 13 Meters and Appliances G,24619-G 14 Meter Reading G 15 Meter Tests G,24622-G 16 Adjustment of Bills G,24624-G,24625-G 17 Reading of Separate Meters Not Combined G 18 Notices G 19 Rates and Optional Rates G 20 Gas Main Extensions G,31801-G,31802-G,31803-G,31804-G,31805-G G,31807-G,31808-G,31809-G,31810-G,31811-G,31812-G 21 Gas Service Extensions G,31814-G,31815-G,31816-G,31817-G,31818-G G,31820-G,31821-G,31822-G,31823-G,31824-G,31825-G 22 Temporary Service G,30294-G 23 Continuity of Service and Interruption of Delivery G,24643-G,24644-G,24645-G,24646-G,24647-G G,24649-G,24650-G,24651-G,24652-G,27273-G 24 Supply to Individual Premises and Resale of Gas G 25 Company's Right of Ingress to and Egress fro m the Consumer's Premises G T T (TO BE INSERTED BY UTILITY) ADVICE LETTER NO. DECISION NO. (continued) ISSUED BY 2958 William L. Reed VICE PRESIDENT CHIEF REGULATORY OFFICER (TO BE INSERTED BY CAL. P.U.C.) DATE FILED EFFECTIVE RESOLUTION NO. SEP 13,2000

14 SOUTHERN CALIFORNIA GAS COMPANY Revised LOS ANGELES, CALIFORNIA CANCELING Revised CAL. P.U.C. SHEET NO. CAL. P.U.C. SHEET NO G G TABLE OF CONTENT S The following listed sheets contain all effective Schedules of Rates and Rules affecting service and information relating thereto in effect on the date indicated thereon. GENERAL Cal. P.U.C. Sheet No. Title Page G Table of Contents--General and Preliminary Statement G,32763-G Table of Contents--Service Area Maps and Descriptions G Table of Contents--Rate Schedules G,32990-G,32963-G Table of Contents--List of Cities and Communities Served G Table of Contents--List of Contracts and Deviations G Table of Contents--Rules G,32759-G Table of Contents--Sample Forms G,32782-G,32783-G,32784-G,32785-G T T PRELIMINARY STATEMENT Part I General Service Information G,24332-G,24333-G,24334-G,24749-G Part II Summary of Rates and Charges G,32966-G,32487-G,32488-G,32967-G,32951-G G,32492-G,32493-G,32968-G,32969-G,32496-G,32497-G Part III Cost Allocation and Revenue Requirement G,27025-G,27026-G,27027-G,32498-G Part IV Income Tax Component of Contributions and Advances G,24354-G Part V Description of Regulatory Accounts-Balancing G,32500-G,32501-G,32502-G G,32504-G,32505-G,32506-G,32507-G,32508-G,32509-G Part VI Description of Regulatory Accounts-Memorandum G,32511-G,32512-G,32513-G G,32515-G,32516-G,32517-G,32518-G,32519-G,32520-G,32521-G,32522-G,32523-G Part VII Description of Regulatory Accounts-Tracking G,32525-G,32526-G G,32528-G,32529-G Part VIII Gas Cost Incentive Mechanism (GCIM) G,31777-G,31778-G,30523-G,30524-G Part IX Hazardous Substances Mechanism (HSM) G,26200-G,26201-G Part X Global Settlement G,32531-G,32532-G,32533-G (TO BE INSERTED BY UTILITY) ADVICE LETTER NO. DECISION NO. (continued) ISSUED BY 2958 William L. Reed VICE PRESIDENT CHIEF REGULATORY OFFICER (TO BE INSERTED BY CAL. P.U.C.) DATE FILED EFFECTIVE RESOLUTION NO. SEP 13,2000

15 ATTACHMENT C Advice No SDG&E Gas Rule 14

16 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company Revised 6778-G San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE A. Service Conditions Sheet 1 The utility will use reasonable diligence and care to avoid any shortage or interruption of gas supply. The utility shall not be liable in damages or otherwise for any failure to deliver gas to the customer, which failure in any way or manner results from breakage of its facilities, however caused, war, riots, acts of God, strikes, failure of, or interruption in, gas supply, mandatory or voluntary curtailments ordered by the Public Utilities Commission, or other conditions beyond its reasonable control. B. Temporary Suspension of Service Whenever necessary for making repairs or improvements to its system, the utility may temporarily suspend the delivery of gas. In all such cases, the utility will provide as much notice as circumstances reasonably permit. Repairs or improvements will be carried out as rapidly as may be practicable, and, if practicable, at such times as will cause the least inconvenience to the customers. C. Service Level and Priority of Service Noncore customers must choose an appropriate Gas Transportation Service Level. Customers that do not choose an appropriate service level will be assigned to the lowest noncore service level and end-use priority classification for curtailment purposes. Customer denial of the utility's right of ingress and egress for the purpose of priority assignment will result in the customer being assigned to the lowest applicable priority. Where customers have more than one priority of service, those uses in a lower priority not exceeding 25 Mcf per day on a peak-day, may be placed in the customer's next higher priority. D. Curtailment Assignments Curtailment shall be first made in the lowest priority group. Priority groups may be subdivided for curtailment purposes and, to the extent practical, curtailment shall be equalized among customers in each group by rotating curtailment among the subdivisions of the group. Curtailments which exceed the total volume of gas used by all customers in the lowest priority group shall, in the same manner, be affected successively in the higher priority groups. Restoration of curtailed service shall be made in the same manner, but inversely as to priority groups. E. Changes in Curtailment Assignments System curtailments shall be based first on transportation service levels. In the event a significant change is determined in a customer's requirements or equipment, resulting in a need for reclassification to another priority, such change shall be made in the billing month following such identification of the change. F. Restoration of Service Restoration of service will be made starting with the highest priority block, and proceeding through each succeeding priority level. (Continued) Issued by Date Filed February 17, 1998 Advice Ltr. No G William L. Reed Effective February 17, 1998 Vice President Decision No Regulatory Affairs Resolution No.

17 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE F. Restoration of Service (Continued) Sheet 2 Where curtailment takes place on a partial basis for a given priority block, the utility will attempt, at the earliest time practical, to balance the amount of curtailment for customers in any given curtailment block. G. Operating Emergency In the event a customer declares an operating emergency, service may be made available out of the normal curtailment pattern, if in the judgment of the utility it is possible to do so. Out of pattern deliveries will be provided to Critical Customers whenever they declare an operating emergency. Subsequent out of pattern curtailment will be imposed on such customers in order to balance the amount of curtailment with other customers served at the same priority. H. Electric Generation Service T Subject to the capability of the utility's physical facilities, and the requirements of higher priority customers, dispatching arrangements will be made based on requirements to minimize particularly adverse air pollution impacts. I. Gas Transportation Service Levels The utility shall offer the following levels of gas transportation service, and the service levels listed below shall serve as a basis for gas curtailment: 1. Core Service Firm Inter- & Intrastate Transportation Service. Gas Purchased from the utility. Optional Intrastate Transportation-Only Service. Curtailment based on end-use priorities. Includes all P-1 and P-2A end-use priorities. 2. Core Subscription Service Firm Inter- & Intrastate Transportation Service. Gas Purchased from the Utility (minimum one-year term). Two-Year transport Contract Term. D T T 3. Firm Noncore Service 1/ Firm Intrastate Transportation Service. Two-Year Contract Term. Optional Utility Gas Purchases. Use-or-Pay Obligations & Penalties. 1/ Customers electing noncore service must have Automatic Meter Reading (AMR) equipment installed at customer s expense as a condition of noncore service. (Continued) Issued by Date Filed May 19, 2000 Advice Ltr. No G William L. Reed Effective June 1, 2000 Vice President Decision No Chief Regulatory Officer Resolution No.

18 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE I. Gas Transportation Service Levels (Continued) Sheet 3 4. Interruptible Noncore Service 1/ Interruptible Intrastate Transportation Service. Minimum One-Month Contract Term. Optional Utility Gas Purchases. No Use-or-Pay Obligations or Penalties. Gas curtailment among the service levels shall be made in reverse order with interruptible noncore transportation volumes curtailed first followed by firm noncore transportation volumes, including core subscription, with core service volumes curtailed last. Gas curtailment within each service level is described in Section N. hereunder. D D In order to notify noncore customers of gas curtailments, the customer must provide and maintain accurate primary and alternate day/night contact phone numbers and contact names who will be responsible for responding to the utility's notice to curtail gas services. The inability of the utility to notify a noncore gas customer of curtailment due to having out-dated and/or incorrect phone numbers and contact names, will result in the customer being changed to core status for the next 12- month period. J. End-Use Priority Classification In the event of a curtailment within the core service, the utility will curtail gas supplies in the reverse order of the assigned end-use priorities described below: Priority Description P-1 All residential use regardless of size. All non-residential use through a single meter that is equal to or less than 20,800 therms. P-2A Non-residential use through a single meter that is greater than an annual monthly average of 20,800 therms, where the customer has made a minimum two-year election to receive core reliability service. Electric generation start-up and igniter fuel. Fuel for Natural Gas Vehicles. T 1/ See footnote sheet 2 (Continued) Issued by Date Filed April 6, 2000 Advice Ltr. No G-A William L. Reed Effective April 8, 2000 Vice President Decision No. Chief Regulatory Officer Resolution No.

19 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE K. Delivery Point Curtailment Sheet 4 Delivery of natural gas may be interrupted in the event of projected or actual capacity constraints or projected or actual supply shortages at system delivery points. 1. Local System Constraint In the event of a localized curtailment, customers in the unconstrained areas may continue to receive service while customers that are equal or higher in the curtailment order are curtailed in the constrained area. 2. SDG&E System Constraint In the event projected or actual system wide operating constraints exist, SDG&E will schedule deliveries, to the extent feasible in accordance with the curtailment order listed under Section N. L. Receipt Point Constraint The provisions in this section apply to all end use customers in SDG&E's service territory and their designated agents. 1. Curtailment Because of Incompatibility of Gas SDG&E has the right to maintain the gas in its system at the necessary level of quality. SDG&E has the right to refuse in part or in total the delivery of gas into its system that is not of the quality required for service to SDG&E's customers. SDG&E shall be the sole judge of the ability of its system to accept any gas and of the need for allocation of service because of incompatibility. (See Rule 20). 2. Receipt Point Constraints (other than SoCal Gas Storage Facilities) If the quantity of gas received by SDG&E from an interstate pipeline or other interconnecting gas service is less than the confirmed nominations from that interstate pipeline or other service, the gas actually received by SDG&E will be deemed to have been allocated on that day in accordance with the allocation provisions in Section N. To the extent that subsequent interstate pipeline records are determined to differ from this allocation, then that deviation will be credited to the customer's account. 3. Option to Purchase SDG&E Gas To the extent practicable, the utility may offer standby service at the appropriate charges. If standby service is not available during a curtailment period and the customer continues to use gas, that usage will be subject to the corresponding penalty rates. (See Rule 20). (Continued) Issued by Date Filed February 17, 1998 Advice Ltr. No G William L. Reed Effective February 17, 1998 Vice President Decision No Regulatory Affairs Resolution No.

20 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company Revised 6781-G San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE M. Gas Storage Constraint Sheet 5 1. SoCal Storage Injection Constraint If the storage injection capacity available to the utility or its customers is constrained at the point of storage injection, the utility will allocate injections into storage in the order specified in Section N. 2. SoCal Storage Withdrawal Constraint If the operating conditions require the allocation of gas supplies at the point of storage withdrawal, the utility will schedule deliveries, to the extent feasible, in accordance with the allocation order listed under Section N. N. Gas Curtailment and Constraints Gas curtailment or constraints occur whenever the utility declares a gas shortage. A gas shortage exists when, in the utility's judgment: (a) (b) There is a deficiency of gas supplies available to meet customer requirements; or There is a restriction or limitation on transmission or distribution pipelines necessary for the acceptance, transmission, or subsequent redelivery of gas. 1. Delivery Point Curtailments When in the judgment of the utility, based upon expected gas requirements compared with available system supply and capacity, operating conditions require the curtailment of service, curtailment shall be made as necessary: a. Local System Constraint (1) All standby procurement service, or portions thereof, serving: i. Interruptible noncore transportation customers; ii. Followed by firm noncore transportation customers. (2) Interruptible Noncore Transportation Service i. Curtail gas according to the percent of the default transportation rate paid for interruptible intrastate services, with customers paying the lowest percentage to be curtailed first and customers paying the highest percentage to be curtailed last. (Continued) Issued by Date Filed February 17, 1998 Advice Ltr. No G William L. Reed Effective February 17, 1998 Vice President Decision No Regulatory Affairs Resolution No.

21 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE N. Gas Curtailment and Constraints (Continued) Sheet 6 1. Delivery Point Curtailments (Continued) a. Local System Constraint (Continued) (2) Interruptible Noncore Transportation Service (Continued) ii. For customers who are paying the same percentage of default transportation rate, curtail gas on a pro rata basis (equal percentage), with actual curtailments to EG to be curtailed before cogeneration volumes in each curtailment episode. T (3) Firm Intrastate Noncore Transportation Service Curtail gas on a pro rata basis (equal percentage) with EG volumes curtailed before cogeneration volumes in each curtailment episode. T (4) Upon declaration of a supply emergency by the CPUC, curtail all gas volumes serving core customers in the following manner: i. All core standby procurement service; ii. P-2A gas volumes, or portions thereof; iii. P-1 gas volumes, or portions thereof. b. SDG&E System Constraints (1) All standby procurement service, or portions thereof, serving: I. Interruptible noncore transportation customers; ii. Followed by firm noncore transportation customers. (2) Interruptible Noncore Transportation Service i. Curtail gas according to the percent of the default transportation rate paid for interruptible intrastate services, with customers paying the lowest percentage to be curtailed first and customers paying the highest percentage to be curtailed last. ii. For customers who are paying the same percentage of default transportation rate, curtail gas on a pro rata basis (equal percentage), with EG curtailed before cogeneration volumes in each curtailment episode. T (Continued) Issued by Date Filed May 19, 2000 Advice Ltr. No G William L. Reed Effective June 1, 2000 Vice President Decision No Chief Regulatory Officer Resolution No.

22 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE N. Gas Curtailment and Constraints (Continued) Sheet 7 1. Delivery Point Curtailments (Continued) b. SDG&E System Constraints (Continued) (3) Firm Noncore Transportation Service i. Interruption of service shall be done on a rotating block basis. For determining the order of customer rotations, customers shall be divided into two curtailment lists: - The first list shall consist of EG customers. T - The second list shall consist of all other firm service noncore customers. ii. iii. iv. Each curtailment list shall be ordered by individual customer with the order of customers for each list established by lottery or other non-discriminatory means. New customers to firm service shall be randomly assigned a position on the appropriate list. Once the order of customers is established for each list, the utility may aggregate the listed customers into blocks where operationally feasible. In the event firm service customers are added or deleted from the curtailment lists, the utility shall adjust the aggregation of the customer blocks as necessary. In the event of a firm service curtailment, the utility shall curtail, in unison, that number of customer blocks, or a portion thereof, necessary to maintain service to higher priority customers. The customer blocks curtailed shall be established by: - Selecting the first customer block from one curtailment list; then - Selecting the first customer block from the other curtailment list. - Continuing such alternating selections down the two curtailment lists until the required level of curtailment is reached. (Continued) Issued by Date Filed May 19, 2000 Advice Ltr. No G William L. Reed Effective June 1, 2000 Vice President Decision No Chief Regulatory Officer Resolution No.

23 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE N. Gas Curtailment and Constraints (Continued) Sheet 8 1. Delivery Point Curtailments (Continued) b. SDG&E System Constraints (Continued) (3) Firm Noncore Transportation Service (Continued) iv. (Continued) For subsequent curtailment episodes, once customers on both lists have been selected for curtailment, the alternating rotations process shall continue at the beginning of the curtailment lists. v. In the event the curtailment of the last customer block selected would result in exceeding the necessary level of curtailment, then the customers within that block shall be selected for curtailment based on the customer order within the block. vi. vii. Those customers not selected for curtailment shall be treated as a separate block in succeeding curtailment rotations. If the curtailment of an individual customer would result in exceeding the level of curtailment necessary, then such customer shall be curtailed only to the level of curtailment which is necessary. For the curtailment list containing EG customers, EG customers shall be listed before cogeneration customers. The utility will make every endeavor to curtail firm service to noncore customers in the manner specified above. T T (4) Upon declaration of a supply emergency by the CPUC, curtail all gas volumes serving core customers in the following manner: i. All core standby procurement service; ii. P-2A gas volumes, or portions thereof; iii. P-1 gas volumes, or portions thereof. (Continued) Issued by Date Filed April 6, 2000 Advice Ltr. No G-A William L. Reed Effective April 8, 2000 Vice President Decision No. Chief Regulatory Officer Resolution No.

24 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE N. Gas Curtailment and Constraints (Continued) Sheet 9 2. Receipt Point Constraint Allocations When in the judgment of the utility, based upon expected gas requirements compared with available supplies from all sources, other than SoCal storage fields, conditions require the allocation of service, allocation shall be made in the following order as necessary: a. Allocate all gas volumes serving core customers in the following manner: i. P-1 gas volumes, or portions thereof. ii. P-2A gas volumes, or portions thereof; iii. All core standby procurement service; b. Firm Noncore Transportation Service Allocate gas on a pro rata basis (equal percentage). c. Interruptible Noncore Transportation Service i. Allocate gas according to the percent of the default transportation rate paid for interruptible intrastate services, with customers paying the highest percentage to be allocated gas first and customers paying the lowest percentage to be allocated gas last. ii. For customers who are paying the same percentage of default transportation rate, allocate gas on a pro rata basis (equal percentage). d. All standby procurement service, or portions thereof, serving: i. Firm noncore transportation customers; ii. Followed by interruptible noncore transportation customers. 3. Storage Constraint Allocations When in the judgment of the utility, based upon expected gas requirements compared with available supplies from all sources, conditions require the allocation of service, allocation shall be made in the following order as necessary: a. SoCal Storage injection Constraint (1) Firm Storage Injection Service i. Core transportation customers; ii. Followed by firm noncore transportation customers; iii. Followed by Interruptible noncore transportation customers. (Continued) Issued by Date Filed February 17, 1998 Advice Ltr. No G William L. Reed Effective February 17, 1998 Vice President Decision No Regulatory Affairs Resolution No.

25 Revised Cal. P.U.C. Sheet No G San Diego Gas & Electric Company San Diego, California Canceling Revised Cal. P.U.C. Sheet No G RULE 14 SHORTAGE OF GAS SUPPLY, INTERRUPTION OF DELIVERY, AND PRIORITY OF SERVICE N. Gas Curtailment and Constraints (Continued) Sheet Storage Constraint Allocations (Continued) a. SoCal Storage injection Constraint (Continued) (2) As-available Storage Injection Service i. Core transportation customers; ii. Followed by firm noncore transportation customers; iii. Followed by Interruptible noncore transportation customers. (3) All standby procurement injection service, or portions thereof, serving: i. Core transportation customers; ii. Followed by firm noncore transportation customers; iii. Followed by Interruptible noncore transportation customers. b. SoCal Storage Withdrawal Constraint (1) Core Storage Withdrawal Service. i. Firm core customers; ii. Followed by As-available core customers; iii. Followed by core standby procurement service. (2) Firm Storage Withdrawal Service. i. Firm noncore transportation customers; ii. Followed by Interruptible noncore transportation ustomers. (3) As-available Storage Withdrawal Service. i. Firm noncore transportation customers; ii. Followed by Interruptible noncore transportation customers. (4) All standby procurement procurement injection service, or portions thereof, serving: i. Firm noncore transportation customers; ii. Followed by Interruptible noncore transportation customers. (Continued) Issued by Date Filed February 17, 1998 Advice Ltr. No G William L. Reed Effective February 17, 1998 Vice President Decision No Regulatory Affairs Resolution No.

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