Citadel Energy and Tourmaline Oil Request Evidentiary Hearings in PG&E Rate Case

Strategic Insights -

A dispute is unfolding between Citadel Energy Marketing, LLC, Tourmaline Oil Marketing Corp., and Pacific Gas and Electric Company (PG&E) over the proposed rate design for PG&E's 2023 Gas Transmission and Storage Cost Allocation and Rate Design (GT&S CARD). Citadel and Tourmaline have filed a motion requesting evidentiary hearings to address material contested issues of fact and support their claim that PG&E's proposed rate design is inequitable and unjustified.

Key Takeaways:

  • Citadel and Tourmaline dispute PG&E's assertion that shippers have the right to deliver gas to any point on the backbone system, which would justify shifting 50% of the natural rate differential from Baja shippers to Redwood shippers.
  • The two companies believe that PG&E has failed to substantiate its assertions and rebut critical points, including the fact that shippers can only deliver gas to specific points on the system.
  • A disagreement remains between the parties on the issue of whether PG&E's proposed shifting of 50% of the natural rate differential to Redwood shippers results in the allocation of some Baja costs to Redwood shippers and some Redwood costs to Baja shippers.
  • Citadel and Tourmaline believe that evidentiary hearings are necessary to address these material contested issues of fact and ensure the adequate development of a fulsome record for the Commission.
  • The two companies have served data requests on PG&E and have filed prepared answering testimony to support their claims.
  • The dispute has been ongoing since January 2022, with multiple exchanges of testimony and data requests.

Statistics:

  • 50%: The percentage of the natural rate differential that PG&E proposes to shift from Baja shippers to Redwood shippers.
  • 3: The number of delivery points that on-system shippers can deliver gas to, including the PG&E Citygate and two storage points.
  • 2: The number of delivery points that off-system shippers can deliver gas to on a firm basis, including two specific points.
  • 1: The number of transportation contract required to access additional delivery points via PG&E's local transmission and distribution systems.
  • 2022: The year in which the dispute began with the issuance of the Scoping Memo by Commissioner Darcie L. Houck on January 5th.

Sources:

  • A. 21-09-018, Assigned Commissioner's Scoping Memo and Ruling (January 5, 2022), p. 6.
  • D.06-04-075, issued May 9, 2006, at p. 49-50 (Order Denying Rehearing of Decision D.05-11-029), available at https://docs.cpuc.ca.gov/PublishedDocs/WORD_PDF/FINAL_DECISION/56198.PDF
  • Exhibit No. CT-0001 at 8:5-16 (Crowe Answering Testimony).
  • PG&E Prepared Testimony at 3-21.