PACIFIC GAS AND ELECTRIC COMPANY RUBY PIPELINE …

Application: 20-08- (U 39 M) Exhibit No.: (PG&E-1)

Date: August 28, 2020 Witness(es): Gillian Clegg

PACIFIC GAS AND ELECTRIC COMPANY

RUBY PIPELINE CONTRACT AMENDMENTS

PREPARED TESTIMONY

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PACIFIC GAS AND ELECTRIC COMPANY RUBY PIPELINE CONTRACT AMENDMENTS

PREPARED TESTIMONY

TABLE OF CONTENTS

Chapter Title Witness

1 OVERVIEW AND POLICY Gillian Clegg

2 PROPOSED RUBY AMENDMENT Gillian Clegg

3 RUBY STEP-DOWN CAPACITY, RUBY EXTENSION, AND REDWOOD COST RECOVERY REQUESTS

Gillian Clegg

Appendix A AMENDED RUBY CONTRACT (ELECTRIC FUELS

FUNCTION) (CONFIDENTIAL IN ITS ENTIRETY)

Appendix B AMENDED RUBY CONTRACT (CORE GAS

SUPPLY FUNCTION) CONFIDENTIAL (CONFIDENTIAL IN ITS ENTIRETY)

Appendix C REDLINE COMPARISON OF AMENDED RUBY

CONTRACT AND RUBY CONTRACT (ELECTRIC FUELS FUNCTION) CONFIDENTIAL (CONFIDENTIAL IN ITS ENTIRETY)

Appendix D REDLINE COMPARISON OF AMENDED RUBY

CONTRACT AND RUBY CONTRACT (CORE GAS SUPPLY FUNCTION) CONFIDENTIAL (CONFIDENTIAL IN ITS ENTIRETY)

Appendix E STATEMENT OF QUALIFICATIONS Gillian Clegg

Appendix F IDENTIFICATION OF CONFIDENTIAL

INFORMATION


CHAPTER 1

OVERVIEW AND POLICY

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PACIFIC GAS AND ELECTRIC COMPANY CHAPTER 1

OVERVIEW AND POLICY

TABLE OF CONTENTS

A. Introduction ............................................................................................................ 1-1

B. About the Ruby Pipeline ....................................................................................... 1-2

C. Overview of the Original Ruby Proceeding .......................................................... 1-2

1. Application Overview ...................................................................................... 1-2

a. The Ruby Contracts ................................................................................. 1-3

b. Electric Fuels’ Request for Redwood Path ............................................. 1-4

2. Overview of Ruby Decision ............................................................................ 1-4

a. Requirements to Exercise Step-Down Rights ........................................ 1-5

b. Requirements to Exercise Evergreen Rights ......................................... 1-5

c. Management and Cost Recovery for Electric Fuel’s arrangements on the Redwood Path .............................................................................. 1-6

D. Purpose of PG&E’s Application and Compliance with Commission Policy ....... 1-7

1. Commission General Order (GO) 96-B Requires an Application for Amendments to the Ruby Contracts ............................................................. 1-7

2. D.08-11-032 Requires an Application to Establish a Process for Step-Down Rights and Evergreen Rights ..................................................... 1-7

3. PG&E’s BPP Supports the Relief Requested to allow PG&E to

Independently Manage Electric Fuel’s Redwood Path ................................. 1-8

E. Conclusion ............................................................................................................. 1-9

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Chapter 1 provides the background and policy discussion regarding the 1

original Ruby Contract and D.08-11-032 (Ruby Decision). Chapter 2 addresses 2

the amendments made to the Ruby Contracts in greater detail. Chapter 3 3

addresses issues raised by the Ruby Decision regarding capacity step-down, 4

evergreen rights, and cost recovery. 5

B. About the Ruby Pipeline 6

The Ruby Pipeline is owned and operated by Ruby Pipeline, LLC. The 7

Ruby Pipeline extends from Opal, Wyoming to an interconnection with PG&E’s 8

gas transmission system at Malin, Oregon, on the California-Oregon border3. 9

The 42-inch diameter pipeline system spans a distance of 680 miles, has a 10

delivery capacity of 1.5 billion cubic feet per day, and provides natural gas (NG) 11

supplies from the major Rocky Mountain basins to consumers in California, 12

Nevada, and the Pacific Northwest. Once gas arrives to PG&E at Malin, 13

Oregon, it is transported into California via PG&E’s California Gas Transmission 14

Redwood Pipeline (Redwood Path). 15

C. Overview of the Original Ruby Proceeding 16

1. Application Overview 17

PG&E filed Application 07-12-021 on December 21, 2007 seeking 18

CPUC approval of (1) long-term (LT), firm transportation arrangements on 19

the Ruby Pipeline, as set forth in a Precedent Agreement4 (PA) signed by 20

PG&E and Ruby Pipeline, LLC5 for its bundled electric customers and core 21

NG customers; and (2) Electric Fuels entering into transportation 22

arrangements for matching downstream capacity on the Redwood Path. 23

PG&E’s primary justification for acquiring capacity on the Ruby Pipeline 24

was to increase its access to Rocky Mountain gas supplies, thus diversifying 25

and reducing its heavy reliance on plateauing and declining gas production 26

3 The technical receipt and delivery points are Williams Opal Plant and Onyx Hills, but we will use the more familiar industry terms Opal and Malin, along with pricing for those points, in this filing.

4 The PA was the initial contractual commitment between Ruby and PG&E for PG&E to acquire firm transportation capacity. It established the rates, terms and conditions for service. Subsequent to CPUC approval of the PA, PG&E and Ruby executed the FTSAs that were consistent with and restated and superseded the PA.

5 El Paso Corporation was the original developer of the Ruby Pipeline. El Paso was acquired by Kinder Morgan, Inc. in 2012.

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in Canada. Historically, PG&E obtained more than half of its NG from the 1

Western Canadian Sedimentary Basin that experienced LT and significant 2

decline in the 2000s. On the other hand, the Rocky Mountain region has 3

experienced growing gas production over the past 3 decades. 4

a. The Ruby Contracts 5

The Ruby Contracts included two sets of firm transportation service 6

agreements (FTSA): (1) for CGS; and (2) for Electric Fuels. 7

For CGS, PG&E sought to acquire 250 thousand decatherms per 8

day (MDth/d) of firm capacity for the 15-year period of November 1, 9

2011 through October 31, 2026. 10

For Electric Fuels, PG&E sought to acquire 250 MDth/d of firm 11

capacity for a 4-month period beginning July 1, 2011, and 125 MDth/d 12

for the 15-year period of November 1, 2011 through October 31, 2026. 13

Together, CGS and Electric Fuels collectively would hold 14

375 MDth/d6 of firm capacity on the Ruby Pipeline for a 15-year period 15

(i.e., November 1, 2011 through October 31, 2026). PG&E would pay a 16

fixed reservation charge equal to the lower of $0.68 per dekatherm (Dth) 17

or 95 percent of the Initial Recourse Rate. PG&E would also pay a fuel 18

charge equal to approximately 1.1 percent of the volume of shipped gas. 19

The Ruby Contracts also contain three overarching provisions to 20

minimize risk for PG&E’s customers: 21

1) A “most-favored-nation” clause to ensure PG&E receives the best 22

rate available on the Ruby Pipeline. The clause guarantees PG&E 23

will receive any lower rate offered to another similarly situated 24

shipper during the initial 15-year period. Thus, if Ruby offers a rate 25

lower than $0.68/Dth to another similarly situated shipper, PG&E 26

would also receive the lower rate. The rate protection applied to the 27

reservation charge but not the fuel charge; 28

2) Capacity step-down rights in Years 11-15 to provide flexibility to 29

reduce capacity if conditions warrant (Step-Down Rights); and 30

3) At the end of the initial 15-year term, PG&E has the right to annually 31

renew the Ruby Contracts for up to 10 1-year extensions (Evergreen 32

6 CGS 250 MDth/d + Electric Fuels 125 MDth/d.

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Rights). This provision ensures PG&E can maintain prudent 1

diversification for an additional 10-year period at favorable rates 2

($0.68/Dth) if conditions warrant. 3

b. Electric Fuels’ Request for Redwood Path 4

PG&E also sought to acquire matching downstream capacity on the 5

Redwood Path (i.e., 250 MDth/d for an initial four-month period followed 6

by 125 MDth/d for a 15-year period) since Electric Fuels did not hold 7

capacity on the Redwood Path in 2007. Capacity on the Redwood Path 8

is necessary to move the gas from the Malin point south to PG&E 9

Citygate where it is ultimately distributed to serve customers in northern 10

California. CGS already held firm downstream capacity on PG&E’s 11

Redwood Path, thus PG&E did not propose any changes to CGS’s 12

Redwood Path arrangements. 13

2. Overview of Ruby Decision 14

The Commission determined that PG&E’s contract for LT capacity on 15

the Ruby Pipeline advances the Commission’s policy objectives of gas 16

supply security, reliability, and price stability. Notably, in D.08-11-032, the 17

Commission references the following proceedings and how the Ruby 18

Pipeline furthers its regulatory goals: 19

• Per D.04-09-022, gas utilities should hold a diverse portfolio of pipeline 20

capacity across multiple supply basins to ensure adequate supplies for 21

core gas customers. CGS’s Ruby capacity fits within the capacity range 22

established in D.04-09-022; 23

• Per Order Institute Rulemaking 07-11-001, the Commission commits to 24

obtaining more gas from the Rocky Mountains in its effort to diversify 25

supplies. The Ruby Pipeline provides access to gas supplies from the 26

Rocky Mountains; 27

• Per D.06-07-010, CGS must hold sufficient assets to fulfill the 28

1-in-10-year peak day demand. The Ruby capacity increases available 29

supplies, which should lower costs of PG&E Citygate purchases during 30

cold weather events; 31

• Per D.08-11-032, the Commission must ensure California residents 32

have access to adequate supplies of gas; and 33

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• Per D.06-09-039, electric utilities must ensure adequate gas supplies 1

are available for gas-fired generation. The Ruby capacity achieves the 2

Commission’s objective of securing firm interstate pipeline capac ity for 3

electric generation. 4

In approving the LT transportation arrangements with Ruby, the Commission 5

also established process requirements for exercising the Step-Down Rights 6

and Evergreen Rights in the Ruby Contracts, as well as limits for 7

management and cost recovery of Electric Fuel’s contract capacity on 8

Redwood Path. 9

a. Requirements to Exercise Step-Down Rights 10

To minimize risk, PG&E negotiated capacity Step-Down Rights in 11

the Ruby Contracts. Starting on the 11th anniversary (November 1, 12

2022) and each anniversary thereafter until the 15th anniversary, CGS 13

and Electric Fuels each have the option to reduce its capacity as 14

follows: 15

• Down to 80 percent of contracted capacity on the 11th anniversary; 16

• Down to 60 percent on the 12th anniversary; 17

• Down to 40 percent on the 13th anniversary; 18

• Down to 20 percent on the 14th anniversary; and 19

• And down to 0 percent on the 15th anniversary. 20

D.08-11-032 directs that PG&E shall obtain Commission authorization to 21

either keep or release the step-down capacity using procedures the 22

Commission has in place at that time (which may include pre-approval). 23

If no procedures are in place, PG&E is directed to file an application at 24

least 1 year prior to the first step-down to obtain authority to either keep 25

or release the step-down capacity, and that such application would 26

include a proposal for any subsequent decisions for PG&E to retain or 27

release step-down capacity. Chapter 3 of this Testimony describes 28

Electric Fuels’ and CGS’s proposed procedures for exercising Step-29

Down Rights. 30

b. Requirements to Exercise Evergreen Rights 31

At the end of the first 15-years of the contracts (Initial Term), CGS 32

and Electric Fuels will each have an evergreen right to renew its Ruby 33

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Contract for a 1-year term. The evergreen renewal is exercisable each 1

year until October 31, 2035 or 10 years after the expiration of the Initial 2

Term. The rate for evergreen extension periods will be the effective rate 3

at the end of the initial 15-year term or at the end of any subsequent 4

evergreen extension term. 5

D.08-11-032 directs that PG&E shall obtain prior Commission 6

authorization before exercising, or not exercising, its evergreen right to 7

annually renew the Ruby Contracts when these arrangements expire 8

after 15 years. If no procedures are in place, PG&E is directed to file an 9

application at least 1 year prior to the expiration of the Initial Term of the 10

transportation arrangements to obtain authority to either extend the 11

arrangements for 1 year or let them expire. Further, PG&E is directed to 12

include a proposal for Commission review and approval of any 13

subsequent decision(s) by PG&E to annually extend or terminate the 14

transportation arrangements under the Ruby Contracts. Chapter 3 of 15

this Testimony proposes the procedures for Commission approval to 16

exercise Electric Fuel’s and CGS’s Evergreen Rights. 17

c. Management and Cost Recovery for Electric Fuel’s arrangements 18

on the Redwood Path 19

The Commission approved Electric Fuel’s transportation 20

arrangement on the Redwood Path. However, the Commission 21

provided that PG&E may recover costs for Electric Fuels’ Redwood Path 22

arrangements in future years only to the extent the Commission has 23

authorized recovery of Electric Fuels’ upstream arrangements on the 24

Ruby Pipeline.7 However, even if Electric Fuels elects to step-down its 25

Ruby capacity for Years 11-15, retaining the full amount of Redwood 26

Path capacity may offer benefits such as supply location diversity, 27

enhanced reliability, and access to an economic supply source. 28

Chapter 3 of this Testimony also describes PG&E’s request for 29

independent management and cost recovery of capacity on the 30

Redwood Path should Electric Fuels find it beneficial to retain it even if it 31

decides to step-down capacity on the Ruby Pipeline. 32

7 D.08-11-032, OP 3.x.

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either keep or release the step-down capacity and exercise evergreen rights 1

if no procedures are in place. In compliance with that decision, PG&E seeks 2

Commission authorization in this Application for procedures to exercise the 3

Ruby step-down capacity and evergreen rights. Chapter 3 of this Testimony 4

describes the proposed procedures. 5

PG&E’s request should be approved because the proposed procedure 6

is consistent with Commission processes, ensures timely resolution, and is 7

administratively efficient. Additionally, the proposed procedure is 8

appropriate because exercising such contract rights does not incur new or 9

incremental costs to customers but maintains the status quo or reduces 10

PG&E’s commitments per the contract. 11

3. PG&E’s BPP Supports the Relief Requested to allow PG&E to 12

Independently Manage Electric Fuel’s Redwood Path 13

PG&E’s BPP already authorizes Electric Fuels to procure pipeline 14

capacity for terms of 5 years or less. Yet, as discussed in D.08-11-032, 15

during Years 11-15 of the Ruby Contract, PG&E is only authorized to 16

recover the costs of Electric Fuels’ Redwood Path capacity to the extent that 17

the Commission has approved cost recovery of the matching upstream 18

capacity on Ruby Pipeline. The Ruby Decision, in effect, incents Electric 19

Fuels to step-down Redwood capacity by limiting cost recovery to matching 20

capacity on the Ruby Pipeline. However, the BPP authorizes Electric Fuels 21

to recontract for that same capacity on Redwood Path and restore cost 22

recovery. This Application seeks to streamline the authority for Electric 23

Fuels to accomplish what effectively the BPP already permits it to do, 24

without taking the additional actions to step-down Redwood capacity just to 25

immediately recontract for that same capacity, if needed. 26

Chapter 3 of this Testimony also describes PG&E’s request for a 27

proposal to seek future Commission authorization for Redwood Path cost 28

recovery should Electric Fuels find it beneficial to retain the matching 29

Redwood capacity even if it decides to step-down its capacity on the Ruby 30

Pipeline in Years 11-15 of the Ruby Contract. 31

PG&E’s request should be approved because it promotes flexibility to 32

manage costs and portfolio needs for Ruby capacity and Redwood capacity 33

independently and is in the best interest for customers. Furthermore, this 34

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request is prudent because it removes the scenario where Electric Fuels 1

steps down capacity with the intent to recontract as authorized under the 2

BPP but is unable to recontract because the capacity is no longer available. 3

E. Conclusion 4

The requests sought by PG&E in this Application are in the best interest of 5

PG&E’s customers. In alignment with Commission Policy, PG&E submits this 6

Application for amendments to contracts with a duration exceeding 5 years. 7

Additionally, D.08-11-032 requires an application to establish a process for 8

step-down and evergreen rights. The requests outlined in Chapter 1 are 9

reasonable as they support affordability, administrative efficiency, and foster 10

reliability. 11


CHAPTER 2

PROPOSED RUBY AMENDMENT


CHAPTER 3

RUBY STEP-DOWN CAPACITY, RUBY EXTENSION, AND

REDWOOD COST RECOVERY REQUESTS

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PACIFIC GAS AND ELECTRIC COMPANY CHAPTER 3

RUBY STEP-DOWN CAPACITY, RUBY EXTENSION, AND REDWOOD COST RECOVERY REQUESTS

TABLE OF CONTENTS

A. Introduction ............................................................................................................ 3-1

B. Proposal of Procedures for Obtaining Commission Authorization to Retain or Release Step-Down Capacity for Electric Fuels and Core Gas Supply ........ 3-1

1. Description of Proposed Procedure for Electric Fuels.................................. 3-2

2. Description of Proposed Procedure for Core Gas Supply ........................... 3-4

C. Proposal of Procedures for Commission Review and Approval of the Annual Decisions by Electric Fuels and Core Gas Supply, to Exercise or

Not Exercise Its Evergreen Right ......................................................................... 3-5

1. Description of Proposed Procedure for Electric Fuels.................................. 3-6

2. Description of Proposed Procedure for Core Gas Supply ........................... 3-7

D. Proposal of a Procedure for Obtaining Commission Authorization to Retain or Release Matching Capacity on the Redwood Path for Electric Fuels ...................................................................................................................... 3-8

1. Description of Proposed Procedure............................................................. 3-10

E. Conclusion ........................................................................................................... 3-11

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PACIFIC GAS AND ELECTRIC COMPANY 1

CHAPTER 3 2

RUBY STEP-DOWN CAPACITY, RUBY EXTENSION, AND 3

REDWOOD COST RECOVERY REQUESTS 4

A. Introduction 5

The purpose of Chapter 3 is to: 6

1) Seek approval of procedures for California Public Utilities Commission 7

(CPUC or Commission) review and approval of the annual decisions by both 8

the Electric Fuels Department (Electric Fuels) and Core Gas Supply 9

Department (Core Gas Supply or CGS), to retain or release step-down 10

capacity under the Amended Ruby Contracts. 11

2) Seek approval of procedures for Commission review and approval of the 12

annual decisions by both Electric Fuels and CGS, to exercise or not 13

exercise its evergreen right to annually renew the Amended Ruby Contracts 14

after Year 15 of the contract. 15

3) Seek approval of a procedure for Commission review and approval for 16

Electric Fuels to retain or assign the unmatched Redwood Path capacity, if 17

in the future, Electric Fuels elects to step down its capacity under its 18

Amended Ruby Contract to below 125 thousand decatherms per day. 19

B. Proposal of Procedures for Obtaining Commission Authorization to Retain 20

or Release Step-Down Capacity for Electric Fuels and Core Gas Supply 21

In Decision (D.) 08-11-032, the Commission required Pacific Gas and 22

Electric Company (PG&E) to obtain prior Commission authorization before 23

exercising, or not exercising, its contractual right to reduce, or step down, the 24

Ruby contract capacity by 20 percent increments beginning in Year 11 under 25

each of the contracts until 100 percent of the Ruby contract capacity can be 26

reduced at the beginning of Year 15. Specifically, Ordering Paragraph 27

(OP) 3.viii in D.08-11-032 states: 28

PG&E shall obtain prior Commission authorization before exercising, or not 29

exercising, its right under the Precedent Agreement to annually reduce its 30

Ruby capacity by 20% increments beginning in Year 11 of the Agreement. 31

To that end, PG&E’s Core Gas Supply and Electric Fuels Departments shall 32

each use the procedures the Commission has in place at that time to obtain 33

Commission approval (including pre-approval) to either keep or release the 34

step-down capacity. If no procedures are in place, PG&E shall file an 35

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application at least one year prior to the first step down to obtain authority to 1

either keep or release the step-down capacity. The application shall include 2

a proposal for Commission review and approval of any subsequent 3

decisions by PG&E to either retain or release step-down capacity under the 4

Precedent Agreement. 5

At this time, there are no established procedures for obtaining Commission 6

approval (or pre-approval) to keep or release step down capacity under a 7

pipeline capacity contract on behalf of Electric Fuels or Core Gas Supply. As 8

such, this chapter is requesting approval of procedures for both Electric Fuels 9

and Core Gas Supply. This application proposes procedures for Commission 10

approval of exercising step-down rights in compliance with D.08-11-032. 11

1. Description of Proposed Procedure for Electric Fuels 12

PG&E proposes Commission approval of Electric Fuels’ decision to 13

exercise step-down rights so long as the following procedures are followed: 14

1) Each year, in advance of exercising, or not exercising, its right to step 15

down capacity under the Amended Ruby Contract, Electric Fuels will 16

consult the Procurement Review Group1 (PRG) on its proposal of 17

whether to step down; 18

2) The exercise, or not, of the Ruby pipeline step-down capacity will not 19

result in pipeline holdings that exceed the pipeline capacity limits in the 20

Bundled Procurement Plan (BPP);2 and 21

3) Electric Fuels will file an expedited Tier 1 Advice Letter (AL) seeking 22

Commission pre-approval of its decision to exercise or not to exercise its 23

step-down rights under the Amended Ruby Contract. 24

This proposal to authorize Commission pre-approval, subject to the 25

procedure described above, is appropriate because the decision to exercise 26

these contract rights does not result in new or incremental costs to 27

customers, but rather, only provides the option to maintain the status quo or 28

reduce PG&E’s commitments under the contract. Thus, the risk associated 29

with this contract management decision is minimal. Furthermore, the 30

1 The PRG membership consists of representatives from the CPUC, Public Advocates Office at the California Public Utilities Commission (Cal Advocates), The Utility Reform Network (TURN), and other independent parties.

2 2014 BPP Confidential Appendix C Section B.2.

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proposed process is consistent with existing Commission processes, 1

ensures timely resolution, and uses administrative resources efficiently. 2

The proposed step-down procedure is similar to the existing procedure 3

that Electric Fuels follows when executing new pipeline capacity contracts 4

per its authority in the BPP.3 The BPP authorizes Electric Fuels to procure, 5

and let expire, pipeline capacity contracts up to five years in duration, as 6

long as: (1) that procurement is compliant with the pipeline capacity limits 7

laid out in the BPP, (2) the PRG is consulted in advance of the procurement, 8

and (3) the contract is filed with the Commission as part of the Quarterly 9

Compliance Report, which is filed as a Tier 1 AL. 10

While the Amended Ruby Contracts have a duration longer than five 11

years, the decision on the step-down capacity affects only one year of 12

capacity. In addition, the PRG consultation will provide stakeholders and 13

the Commission an opportunity to review PG&E’s analysis and raise 14

concerns, if any, with PG&E’s proposed course of action, consistent with 15

any other pre-approved BPP action. Given the limited customer risk 16

associated with exercising the step-down right, such a PRG-consultation 17

process and expedited Tier 1 AL reporting structure is appropriate. 18

This proposed procedure will facilitate timely resolution. If a Tier 2 or 3 19

AL, or application is required, there is potential that it could take several 20

months or longer to obtain a decision. Given that the step-down rights occur 21

annually, any delay in previous years’ decisions could complicate the 22

analysis of the need to step-down in subsequent years. An approval 23

process, as outlined above, is a reasonable approach to ensure there are no 24

timing issues. 25

Lastly, the proposed procedure is administratively efficient. It utilizes 26

existing, tried-and-true processes for stakeholder feedback and reporting. 27

It is an efficient use of existing resources and processes. 28

3 Section V of the 2014 BPP.

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2. Description of Proposed Procedure for Core Gas Supply 1

The proposed step-down procedure is similar to the existing processes4 2

Core Gas Supply follows when executing new pipeline capacity contracts 3

and gas storage contracts. PG&E proposes the Commission delegate 4

authority to the Director of Energy Division for approval of Core Gas 5

Supply’s decision to exercise step-down rights so long as the following 6

procedures are followed: 7


down capacity under the Amended Ruby Contract, CGS will recommend 9

to the Cal Advocates and TURN5 its proposal of whether to step down. 10

CGS shall also provide Energy Division and Legal Division staff with the 11

opportunity to attend such meetings. 12

2) Upon receiving concurrence or a lack of opposition from the 13

Cal Advocates, and TURN (if it elects to participate), CGS will file an 14

expedited Tier 1 AL with a 10-day protest period and 21-day approval 15

date, seeking Commission approval of its decision to exercise or not to 16

exercise its step-down rights under the Amended Ruby Contract. 17

a. If concurrence is not achieved with the Cal Advocates and TURN, 18

then PG&E can file a Tier 1 AL with standard 20-day protest and 19

approval date no earlier than 30 days after the filing date. 20

This proposal to authorize Commission approval, subject to the 21

procedure described above, is appropriate because the decision to exercise 22

these contract rights does not result in new or incremental costs to 23

customers, but rather, only provides the option to maintain the status quo or 24

reduce PG&E’s commitments under the contract. Thus, the risk associated 25

with this contract management decision is minimal. Furthermore, the 26

4 This procedure is similar to one first established and approved in D.04-09-022 and described in Footnote 43 of D.08-11-032. Additionally, the procedure is also similar to the approval processes of OP 5 and OP 6 of D.06-07-010 and Appendix I of D.19-09-025.

5 TURN’s participation in these procedures is voluntary. For the purposes of this approval procedure, when TURN is referenced, it is understood that the organization’s participation is voluntary.

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proposed process is consistent with existing Commission processes,6 1

ensures timely resolution and uses administrative resources efficiently. 2

This proposed procedure will facilitate timely resolution. If a Tier 2 or 3 3

AL, or application is required, there is potential that it could take several 4

months or longer to obtain a decision. Given that the step-down rights occur 5

annually, any delay in previous years’ decisions could complicate the 6

analysis on whether the step-down in needed in the instant year. An 7

approval process, as outlined above, is a reasonable approach to ensure 8

there are no timing issues. 9

Lastly, the proposed procedure is administratively efficient. The 10

procedure relies on consultation between PG&E, the Cal Advocates, Energy 11

Division, Legal Division, and TURN. It is an efficient use of existing 12

resources and processes while incorporating stakeholder feedback. 13

C. Proposal of Procedures for Commission Review and Approval of the 14

Annual Decisions by Electric Fuels and Core Gas Supply, to Exercise or 15

Not Exercise Its Evergreen Right 16

D.08-11-032 requires Electric Fuels and Core Gas Supply to obtain prior 17

Commission authorization before exercising, or not exercising, its evergreen 18

right to annually renew the Amended Ruby Contract after Year 15 of the 19

contract. Specifically, OP 3.ix reads: 20

PG&E shall obtain prior Commission authorization before exercising, or not 21

exercising, its evergreen right to annually renew the Ruby Pipeline 22

transportation arrangements when these arrangements expire after 23

15 years. To that end, PG&E’s Core Gas Supply and Electric Fuels 24

Departments shall each use the procedures the Commission has in place at 25

that time to obtain Commission approval (including pre-approval) to either 26

extend the transportation arrangements or let them lapse. If no procedures 27

are in place, PG&E shall file an application at least one year prior to the 28

expiration of the initial 15-year term of the transportation arrangements to 29

obtain authority to either extend the arrangements for one year or let them 30

expire. The application shall include a proposal for Commission review and 31

approval of any subsequent decision(s) by PG&E to annually extend or 32

terminate the transportation arrangements under the Precedent Agreement. 33

6 This procedure is similar to one first established and approved in D.04-09-022 and described in Footnote 43 of D.08-11-032. Additionally, the procedure is also similar to the approval processes of OP 5 and OP 6 of D.06-07-010 and Appendix I of D.19-09-025.

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1. Description of Proposed Procedure for Electric Fuels 1

PG&E proposes that the same procedure is followed as that for seeking 2

Commission review and approval of the decision to exercise or not exercise 3

the step-down capacity under the Amended Ruby Contract. 4

PG&E proposes that: 5

1) Each year, in advance of exercising, or not exercising, its evergreen 6

right to renew the Amended Ruby Contract, Electric Fuels will consult 7

the PRG on its proposal; 8

2) The exercise, or not, of the annual evergreen right to renew will not 9

result in pipeline holdings that exceed the pipeline capacity procurement 10

limits in the BPP;7 and 11

3) Electric Fuels will file an expedited Tier 1 AL seeking Commission 12

approval of its decision to exercise or not to exercise its evergreen right 13

to renew under the Amended Ruby Contract. 14

The proposed procedure should be approved for the same reasons as 15

listed above: 16

1) The proposed procedure is in line with the current process that Electric 17

Fuels follows when executing new pipeline capacity contracts per its 18

authority in the BPP; 19

2) The evergreen right to renew is a commitment of only one year of 20

pipeline capacity; 21

3) PRG consultation will provide stakeholders and the Commission an 22

opportunity to review PG&E’s analysis and raise concerns, if any, with 23

PG&E’s proposed course of action, consistent with any other 24

pre-approved BPP action; 25

4) This proposed procedure will facilitate timely resolution of an annual 26

decision; and 27

5) The proposed procedure is administratively efficient. It utilizes existing, 28

tried-and-true processes for stakeholder feedback and reporting. It is an 29

efficient use of existing resources and processes. 30

7 2014 BPP Confidential Appendix C Section B.2.

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2. Description of Proposed Procedure for Core Gas Supply 1

While there is no established procedure for approving the explicit lapse 2

of transportation arrangements for CGS, there was an established 3

Commission procedure for seeking Commission approval of new and 4

extensions of interstate transportation agreements. This procedure was first 5

established and approved in D.04-09-022 and is described in Footnote 43 of 6

D.08-11-032. Similar approval processes were also established for 7

obtaining gas storage contracts in D.06-07-010 and Appendix I of 8

D.19-09-025. 9

PG&E proposes that the same approval procedure be used to satisfy 10

the requirement in OP 3.ix in D.08-11-032. Additionally, PG&E proposes the 11

Commission delegate authority to the Director of Energy Division to 12

approve. Each year, in advance of exercising or not exercising its 13

evergreen right to renew the Amended Ruby Contract: 14

1) Recommend to the Cal Advocates and TURN8 that CGS either exercise 15

or not exercise its evergreen right to extend the Amended Ruby 16

Contract for one year, along with any replacement capacity, if needed. 17

CGS shall also provide Energy Division and Legal Division staff with the 18

opportunity to attend such meetings. 19

2) Upon receiving concurrence or a lack of opposition from the 20

Cal Advocates and TURN (if it elects to participate), file an expedited 21

Tier 1 AL with a 10-day protest period and 21-day approval date, 22

seeking Commission approval of its decision to exercise or not to 23

exercise its evergreen right to renew under the Amended Ruby 24

Contract. 25

a. If concurrence is not achieved with the Cal Advocates and TURN, 26

then PG&E can file a Tier 1 AL with standard 20-day protest and 27

approval date no earlier than 30 days after the filing date. 28

8 TURN’s participation in these procedures is voluntary. For the purposes of this approval procedure, when TURN is referenced, it is understood that the organization’s participation is voluntary.

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D. Proposal of a Procedure for Obtaining Commission Authorization to Retain

or Release Matching Capacity on the Redwood Path for Electric Fuels

As described in Chapter 1, the Ruby Pipeline extends from Opal, Wyoming

to an interconnection with PG&E's gas transmission system at Malin, Oregon, on

the Califorria-Oregon border. Once gas arrives at Malin, Oregon, it is then

transported into California via PG&E's Galifornia Gas Transmission's

Redwood Pipeline (Redwood Path) to the PG&E Citygate receipt point.

D .08-11-032 authorized Electric Fuels to recover in retail rates the costs ct

capacity on the Redwood Path, but only to the extent that the Commission has

authorized recovery of matching upstream capacity for Electric Fuels on the

Ruby Pipeline. OP 3.x reads:

During Years 11 through 25 of the Precedent Agreement, PG&E may recover in retail rates for bundled electric service the costs for Electric Fuels' Redwood Path arrangements only to the extent the Commission has autho rized recovery of matching upstream capacity for Electric Fuels on the Ruby Pipeline.

However, it may be beneficial to customers for Electric Fuels to retain all or

some Redwood Path capacity to serve load, even if it elects to step down its

Ruby capacity in Years 11 through 159 for the following reasons:

1) The Redwood Path enhances supply location diversity, providing access to

the Malin receipt point.

2) The Redwood Path enhances reliability, providing a physical hedge against

supply disruptions and price run ui:s a: the PG&E Citygate receipt point.

3) The Redwood Path has historically been economic, meaning that on

aver age, it has been cheaper for a market participant to buy gas at Malin

than at the PG&E Citygate location even if the full tariff rate is assumed for

the Redwood Path reservation cost.1 O

4) The Redwood path is currently economic on a forward-looking basis.11

9 El ectric Fuels' current 15-yecr Redwood Path transportation arrangements expire October 31, 2026.

10 Since the beginning of 2016, the Redwood Peth has realized an average positive net spread of $0.095/ Million British Thermal Units (MM Btu). even if the full tariff rate is assumed for the Redwood Path reservation cost.

11 FromNo in effect, if the full

even

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3-9

The loss of cost recovery for the Redwood capacity that is in excess of Ruby 1

capacity (Unmatched Redwood Capacity) based on whether the Ruby capacity 2

is stepped down is inconsistent with the Redwood contract (which does not have 3

Step-Down Rights) and Electric Fuels’ procurement authority in the BPP12 4

(which provides cost recovery pre-approval for procurement of pipeline capacity 5

if performed pursuant to the BPP). Given that the Redwood contract does not 6

have Step-Down Rights like the Ruby Contract, the elimination of cost recovery 7

for Unmatched Redwood Capacity will put PG&E in the position of having to sell 8

it to minimize cost recovery risks even though retaining the Unmatched 9

Redwood Capacity may be in the best interest of customers. Effectively, to 10

resolve the cost recovery risk, Electric Fuels would use its authority under the 11

BPP to first offer the Unmatched Redwood Capacity for sale and then 12

immediately re-contract for other capacity on the Redwood Path to secure cost 13

recovery. Yet this approach is risky. Long-term capacity on the Redwood Path 14

is regularly fully subscribed so there is a risk that capacity would not be available 15

to be re-purchased. This could leave customers without needed capacity. 16

Rather than requiring these additional administrative steps and creating the 17

risk of not being able to re-contract for Redwood capacity, PG&E proposes that 18

the Commission adopt a new procedure for obtaining approval for how Electric 19

Fuels’ manages the Unmatched Redwood Capacity. Electric Fuels will make an 20

annual decision to retain or sell (also known as assign13) some or all of the 21

Unmatched Redwood Capacity.14 If PG&E follows the procedure below, PG&E 22

requests that the Commission authorize: 23

• Continued cost recovery of any retained upstream Redwood Path capacity, 24

even if Electric Fuels elects step down the Ruby capacity (i.e., the 25

Unmatched Redwood Capacity); and, 26

• Cost recovery of the difference, if any, between the contract rate under 27

Electric Fuels’ Redwood Path contract and the negotiated rate resulting from 28

12 Section V of the 2014 BPP.

13 When a shipper, such as Electric Fuels, assigns a portion of its capacity to another shipper, it and the assignee sign an assignment form which can be found here: https://www.pge.com/tariffs/assets/pdf/tariffbook/GAS FORMS 79-867.pdf.

14 Per D.08-11-032, Electric Fuels will continue to have cost recovery for Redwood Path capacity that matches the retained Ruby capacity.

3-10

assigning any portion of the Unmatched Redwood Capacity to a 1

replacement shipper,15 should the rate on the assigned capacity be below 2

that of the contract rate on Electric Fuels’ contract. 3

The procedure will enable Electric Fuels to manage its Redwood capacity 4

independently from its pipeline capacity position on Ruby and in the best interest 5

of customers. 6

1. Description of Proposed Procedure 7

PG&E proposes that: 8


down capacity under the Ruby contract, Electric Fuels will consult the 10

PRG on its proposal to retain or assign any portion of its Unmatched 11

Redwood Capacity. 12

a. If the proposal is to assign some or all of the Unmatched Redwood 13

Capacity, Electric Fuels will offer that amount of Redwood capacity 14

to the market for sale using an electronic solicitation, as described in 15

Appendix B, Section B.1.d of the 2014 BPP. At least five calendar 16

days prior to executing the contract assigning the capacity to one or 17

more replacement shippers, Electric Fuels will provide the electronic 18

solicitation results to the PRG. 19

2) The retention or assignment of the Unmatched Redwood Capacity will 20

not result in pipeline holdings that exceed the pipeline capacity 21

procurement limits in the BPP. 22

3) Electric Fuels will file an expedited Tier 1 AL seeking Commission 23

pre-approval of its decision to retain or assign the Unmatched Redwood 24

Capacity. 25

15 When a shipper assigns Redwood capacity to a replacement shipper on a temporary basis, say a portion of the capacity of its original contract, the replacement shipper is then responsible for paying the contract rate under the shipper’s original transportation arrangements directly to PG&E’s California Gas Transmission. So if Electric Fuels assigned capacity to a replacement shipper for a lower rate than the contract rate in its Redwood contract, then Electric Fuels would owe a “make-whole” payment to the replacement shipper. Similarly, if Electric Fuels assigned the capacity to a replacement shipper for a higher rate than that in its Redwood contract, then the replacement shipper would owe an incremental payment to Electric Fuels up to the negotiated rate the replacement shipper agreed to pay.

3-11

a. If the decision includes an assignment of some or all of the 1

Unmatched Redwood Capacity, the AL will include the results of the 2

electronic solicitation and a request to recover the “make whole” 3

costs, if any, of the Unmatched Redwood Capacity that may occur if 4

the capacity is assigned for a rate that is less than the contract rate 5

in the Electric Fuels Redwood contract. 6

This proposal to authorize Commission pre-approval for Unmatched 7

Redwood Capacity and its cost recovery, subject to the procedure described 8

above, is appropriate because the decision does not result in new or 9

incremental costs to customers, but rather, only provides the option to 10

maintain the status quo or reduce PG&E’s cost commitments under the 11

contract. Furthermore, the proposed process is consistent with existing 12

commission processes, ensures timely resolution and uses administrative 13

resources efficiently, consistent with the explanations provided for the 14

proposed Ruby Step-Down and Evergreen processes. Most importantly, 15

authorizing this approval process to receive cost recovery for Unmatched 16

Redwood Capacity enables Electric Fuels to manage its needs for Redwood 17

capacity independently from the Ruby pipeline, and focus solely on the best 18

interest of customers. 19

E. Conclusion 20

PG&E is seeking: (1) approval of procedures for Commission review and 21

approval of the annual decisions by both Electric Fuels and CGS to retain or 22

release step-down capacity under the Amended Ruby Contracts, (2) approval of 23

procedures for Commission review and approval of the annual decisions by both 24

Electric Fuels and CGS to exercise its evergreen right, and (3) approval of 25

procedures for Commission authorization to retain or assign capacity on the 26

Redwood Path for Electric Fuels independently of the upstream capacity on 27

Ruby. 28

PG&E’s request for Commission approval of the above three procedures is 29

reasonable because they mimic existing procedures and thus leverage existing 30

resources and stakeholder feedback processes. In addition, it is reasonable for 31

PG&E to independently decide to retain or assign the Redwood Path capacity, 32

and seek Commission approval to do so, even if it seeks to step-down the 33

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upstream Ruby capacity as the Redwood Path may have stand-alone value to 1

customers in being used to serve the Electric Fuels’ load. 2


APPENDIX A

AMENDED RUBY CONTRACT

(ELECTRIC FUELS FUNCTION)

(CONFIDENTIAL IN ITS ENTIRETY)


APPENDIX B

AMENDED RUBY CONTRACT (CORE GAS SUPPLY FUNCTION)



APPENDIX C

REDLINE COMPARISON OF AMENDED RUBY CONTRACT AND

RUBY CONTRACT (ELECTRIC FUELS FUNCTION)



APPENDIX D

REDLINE COMPARISON OF AMENDED RUBY CONTRACT AND

RUBY CONTRACT (CORE GAS SUPPLY FUNCTION)



APPENDIX E

STATEMENT OF QUALIFICATIONS

GC-1

PACIFIC GAS AND ELECTRIC COMPANY 1

STATEMENT OF QUALIFICATIONS OF GILLIAN CLEGG 2

Q 1 Please state your name and business address. 3

A 1 My name is Gillian Clegg, and my business address is Pacific Gas and 4

Electric Company, 77 Beale Street, San Francisco, California. 5

Q 2 Briefly describe your responsibilities at Pacific Gas and Electric Company 6

(PG&E). 7

A 2 I am the Senior Director of Electric and Gas Acquisition. I currently oversee 8

the natural gas procurement functions provided by the Core Gas Supply and 9

Electric Gas Supply departments of PG&E. I also oversee the short-term 10

electric procurement function. 11

Q 3 Please summarize your educational and professional background. 12

A 3 I received a Bachelor of Science degree in Mathematics from Simon Fraser 13

University in British Columbia, Canada. I also received a Master of Science 14

degree in Mathematical Finance from the University of British Columbia. In 15

2007, I joined PG&E and have since held various positions of increasing 16

responsibility, including as a Senior Risk Analyst, a Real Time Asset 17

Manager, Principal Renewable Transactor, and Director of Core Gas 18

Supply. Prior to joining PG&E in 2007, I held a Quantitative Analyst position 19

at Powerex Corp. 20

Q 4 What is the purpose of your testimony? 21

A 4 I am sponsoring the following testimony in PG&E’s Ruby Pipeline Contract 22

Amendments: 23

• Chapter 1, “Overview and Policy”; 24

• Chapter 2, “Proposed Ruby Amendment”; and 25

• Chapter 3, “Ruby Step-Down Capacity, Ruby Extension, and Redwood 26

Cost Recovery Requests.” 27

The purpose of my testimony is to substantiate why the Amended Ruby 28

Contracts and the proposals are in the best interest of PG&E’s customers. 29

Q 5 Does this conclude your statement of qualifications? 30

A 5 Yes, it does. 31


APPENDIX F

IDENTIFICATION OF CONFIDENTIAL INFORMATION

PG&E Confidentiality Declaration (Rev 01/02/2018) 1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

DECLARATION SUPPORTING CONFIDENTIAL DESIGNATION ON BEHALF OF

PACIFIC GAS AND ELECTRIC COMPANY (U 39 E)

1. I, Gillian Clegg, am the Senior Director of Electric & Gas Acquisition of Pacific Gas and

Electric Company (“PG&E”), a California corporation. Fong Wan, the Senior Vice President

of Energy Policy and Procurement of PG&E, delegated authority to me to sign this

declaration. My business office is located at:

Pacific Gas and Electric Company 77 Beale Street, Mail Code B5A

San Francisco, CA 94105

2. PG&E will produce the information identified in paragraph 3 of this Declaration to the

California Public Utilities Commission (“CPUC”) or departments within or contractors

retained by the CPUC in response to a CPUC audit, data request, proceeding, or other CPUC

request.

Name or Docket No. of CPUC Proceeding (if applicable): 2020-08-___ Ruby Pipeline

Contract Amendments Application

3. Title and description of document(s): Ruby Pipeline Contract Amendments—Prepared

Testimony, Confidential Appendices A through D

4. These documents contain confidential information that, based on my information and belief,

has not been publicly disclosed. These documents have been marked as confidential, and the

basis for confidential treatment and where the confidential information is located on the

documents are identified on the following chart:


Check Basis for Confidential Treatment Where Confidential Information is located on

the documents Customer-specific data, which may include demand, loads,

names, addresses, and billing data

(Protected under PUC § 8380; Civ. Code §§ 1798 et seq.; Govt. Code § 6254; Public Util. Code § 8380; Decisions (D.) 14-05-016, 04-08-055, 06-12-029)

Personal information that identifies or describes an individual (including employees), which may include home address or phone number; SSN, driver’s license, or passport numbers; education; financial matters; medical or employment history (not including PG&E job titles); and statements attributed to the individual

(Protected under Civ. Code §§ 1798 et seq.; Govt. Code § 6254; 42 U.S.C. § 1320d-6; and General Order (G.O.) 77-M)

Physical facility, cyber-security sensitive, or critical energy infrastructure data, including without limitation critical energy infrastructure information (CEII) as defined by the regulations of the Federal Energy Regulatory Commission at 18 C.F.R. § 388.113

(Protected under Govt. Code § 6254(k), (ab); 6 U.S.C. § 131; 6 CFR § 29.2)

Proprietary and trade secret information or other intellectual property and protected market sensitive/competitive data

(Protected under Civ. Code §§3426 et seq.; Govt. Code §§ 6254, et seq., e.g., 6254(e), 6254(k), 6254.15; Govt. Code § 6276.44; Evid. Code §1060; D.11-01-036)

See table below

Corporate financial records

(Protected under Govt. Code §§ 6254(k), 6254.15)


Third-Party information subject to non-disclosure or confidentiality agreements or obligations

(Protected under Govt. Code § 6254(k); see, e.g., CPUC D.11-01-036)

Other categories where disclosure would be against the

public interest (Govt. Code § 6255(a)):

______________________________________

_________________________________________________

_________________________________________________

5. The importance of maintaining the confidentiality of this information outweighs any public

interest in disclosure of this information. This information should be exempt from the public

disclosure requirements under the Public Records Act and should be withheld from

disclosure.

6. I declare under penalty of perjury that the foregoing is true, correct, and complete to the best

of my knowledge.

7. Executed on this August 28, 2020 at San Francisco, California.

___________________________ Gillian Clegg Senior Director Pacific Gas and Electric Company


RUBY PIPELINE CONTRACT AMENDMENTS APPLICATION ATTACHMENT TO DECLARATION

AUGUST 28, 2020


ATTACHMENT NAME

DOCUMENT NAME CATEGORY OF

CONFIDENTIALITY LOCATION

Prepared Testimony

Chapter 1


Page 1-1 (Lines 9-10); Page 1-7

(Lines 24-29)

Prepared Testimony

Chapter 2 Proprietary and trade secret information or other intellectual property and protected market sensitive/competitive data

Page 2-I (Table of Contents Titles for

Sub-sections C1, C2, D2, E2); Page 2-1

(Lines 12-13, 23-33); Page 2-2 (Lines 1-

4, 7-22, 29); Page 2-3 (Lines 1-8, 14-21,

26-31); Page 2-4 (Lines 5-8, 14-19, 20,

23-30); Page 2-5 (Lines 1-2, 4-16); Page

2-6 (Lines 1-14); Page 2-8 (Lines 1-13,

15-23); Page 2-9 (Lines 16-29); Page 2-

10 (Lines 4-24, 27-30); Page 2-11 (Lines


ATTACHMENT NAME DOCUMENT NAME

CATEGORY OF CONFIDENTIALITY LOCATION

1-9, 11-19, 32-33); Page 2-12 (Lines 1, 6-

10)

Prepared Testimony

Chapter 3 Proprietary and trade secret information or other intellectual property and protected market sensitive/competitive data

Page 3-8 (Footnote 11)

Appendix A: Amended

Ruby Contract (Electric

Fuels Function)

Appendix A: Amended Ruby Contract (Electric Fuels Function)


The entire contract amendment is

confidential.

Appendix B: Amended

Ruby Contract (Core Gas

Function)

Appendix B: Amended Ruby Contract (Core Gas Function)



confidential.


ATTACHMENT NAME DOCUMENT NAME

CATEGORY OF CONFIDENTIALITY LOCATION

Appendix C: Redline

Comparison of Amended

Ruby Contract and Ruby

Contract (Electric Fuels

Function)

Appendix C: Redline Comparison of Amended Ruby Contract and Ruby Contract (Electric Fuels Function)



confidential.

Appendix D: Redline


Ruby Contract and Ruby

Contract (Core Gas

Function)

Appendix D: Redline Comparison of Amended Ruby Contract and Ruby Contract (Core Gas Function)



confidential.

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA


RUBY PIPELINE CONTRACTS AMENDMENTS

DECLARATION OF GILLIAN CLEGG SEEKING CONFIDENTIAL TREATMENT

FOR CERTAIN DATA AND INFORMATION CONTAINED IN PREPARED TESTIMONY

I, Gillian Clegg, declare:

1. I am the Senior Director of Electric & Gas Acquisition within the Energy Policy

and Procurement organization at Pacific Gas and Electric Company (PG&E). In this position,

my responsibilities include overseeing the natural gas procurement functions provided by the

Core Gas Supply and Electric Gas Supply departments of PG&E. I also oversee the short-term

electric procurement function. This declaration is based on my personal knowledge of PG&E’s

practices and my understanding of the Commission’s decisions protecting the confidentiality of

market-sensitive procurement information.

2. Based on my knowledge and experience, and in accordance with the Decisions

06-06-066, 08-04-023, and relevant Commission rules, I make this declaration seeking

confidential treatment for certain procurement data and information contained in the Ruby

Pipeline Contracts Amendments Prepared Testimony.

3. Attached to this declaration is a matrix identifying the data and information for

which PG&E is seeking confidential treatment. The matrix specifies that the material PG&E is

seeking to protect constitutes confidential market sensitive procurement data and information

covered by D.06-06-066 and Public Utilities Code Section 454.5(g). The matrix also specifies

why confidential protection is justified. Further, the data and information: (1) is not already

public; and (2) cannot be aggregated, redacted, summarized or otherwise protected in a way that

allows partial disclosure. By this reference, I am incorporating into this declaration all of the

explanatory text that is pertinent to my testimony in the attached matrix.

I declare under penalty of perjury, under the laws of the State of California, that the

foregoing is true and correct. Executed on August 28, 2020 at San Francisco, California.

Gillian Clegg


Application for Approval of Amendments to Long-Term Natural Gas Transportation Contracts with Ruby Pipeline […] PREPARED TESTIMONY

August 28, 2020


Redaction Reference

Category from D.06-06-066, Appendix 1, or

Separate Confidentiality Statute or Order That Data Corresponds To

Justification for Confidential Treatment Length of Time Data To Be Kept Confidential

Prepared Testimony Chapter 1: Overview and Policy Page 1-1

(Lines 9-10)

Page 1-7 (Lines 24-29)

VII) B: Contracts and PPAs between utilities and non-

affiliated third parties

These sentences disclose a market-sensitive negotiated contract term, if disclosed, would put PG&E and Ruby Pipeline at a competitive disadvantage. Disclosing this information would give other shippers, competitors, or market participant insight into the negotiating positions of PG&E and the pipeline. The disclosure of information may result in higher costs to ratepayers.

Not to exceed three years into the future

Prepared Testimony Chapter 2: Proposed Ruby Amendment Page 2-i

(Table of Contents Titles for

Sub-sections C1, C2, D2,

E2)

Page 2-1 (Lines 12-13,

23-33)

Page 2-2 (Lines 1-4, 7-

22, 29)


14-21, 26-31)







August 28, 2020


Redaction Reference





14-19, 20, 23-30)

Page 2-5

(Lines 1-2, 4-16)

Page 2-6

(Lines 1-14)






Page 2-7

(Figure 2-2, Lines 1-10)

I) B: Utility Gas Price Forecasts

Utility gas price forecast. Release of this market sensitive information could put PG&E at a competitive disadvantage with regards to other market participants and could detrimentally impact PG&E customers.



15-23)


affiliated third parties And


These sentences disclose a market-sensitive negotiated contract term, if disclosed, would put PG&E and Ruby Pipeline at a competitive disadvantage. Disclosing this information would give other shippers, competitors, or market participant insight into the negotiating positions of PG&E and the pipeline. The disclosure of information may result in higher costs to ratepayers. These sentences also rely on utility gas price forecast. Release of this market sensitive information could put PG&E at a competitive disadvantage with regards to other market participants and could detrimentally impact PG&E customers.




August 28, 2020


Redaction Reference





Page 2-10

(Lines 4-24, 27-30)


11-19, 32-33)

Page 2-12 (Lines 1, 6-

10)





Prepared Testimony Chapter 3: Ruby Step-Down Capacity, Ruby Extension, and Redwood Cost Recovery Requests

Page 3-8 (Footnote 11)


Utility gas price forecast. Release of this market sensitive information could put PG&E at a competitive disadvantage with regards to other market participants and could detrimentally impact PG&E customers.


Confidential Appendices



August 28, 2020


Redaction Reference




Appendix A Amended

Ruby Contract with

Electric Fuels, in its

entirety





Appendix C Redline


Ruby Contract with

Electric Fuels, in its

entirety





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