Find in one place the latest developments in the California Public Utlities Commission's long-term gas planning proceeding (R.20.01.007) as well as all the practical info you'll need to participate successfully in the discussion.
Key Links
The CPUC has opened a proceeding to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and perform Long-Term Gas System Planning. This proceeding was launched in the context of local government actions to limit gas expansion and anticipated impacts on gas demand in the future.
Presiding Commissioner: Clifford Rechtschaffen
Presiding Administrative Law Judge: Karl J. Bemesderfer
Proceeding Timeline: Phase 1 and Phase 2
- All Proceeding Documents are on the Docket Card.
- To be added to the Service List (as information only), you need to fill out and submit this form.
- To make a motion to be added as a Party, follow the Rules, Policies, and Procedures. Refer to page 2.
The CPUC has opened a proceeding to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and perform Long-Term Gas System Planning. This proceeding was launched in the context of local government actions to limit gas expansion and anticipated impacts on gas demand in the future.
Presiding Commissioner: Clifford Rechtschaffen
Presiding Administrative Law Judge: Karl J. Bemesderfer
Proceeding Timeline: Phase 1 and Phase 2
California’s Building Transition: Recommendations for Gas Transition Regulatory Proceedings at the California Public Utilities Commission
This report, completed by Kiki Velez, student at Stanford University, provides an overview of the regulatory and policy issues concerning the long-term reduction of gas demand and infrastructure needs. The report provides analysis of various options and some initial recommendations for Coalition members to consider.
Summary of the Latest Proceeding Developments:
[4/22/22] Final Decision Issued
On April 22, the Commission issued a Final Decision extending Southern California Gas Company’s Rule 30 Operational Flow Order winter noncompliance penalty structure year-round. The final decision makes this rule applicable to Southern California Gas Company, San Diego Gas & Electric Company, and Pacific Gas and Electric Company service territories. This final decision is based on the Proposed Decision of 3/18/22, with only clarifying changes made. Between the Proposed Decision of 3/18/22 and this Final Decision, EDF submitted a proposal that was denied by the commission. This proposal would have required the IOUs to perform a root cause analysis of each Operational Flow Order and submit the analysis before the Commission, which the Commission deemed unnecessary.
The rulemaking, despite this Final Decision, remains open. Decisions around Rule 30 Operational Flow Order summer noncompliance penalty structure have not been made.
[3/18/22] Proposed Decision Issued
On March 18, the ALJ issued a Proposed Decision (for vote no sooner than April 21, 2022) that extends the SoCalGas Rule 30 Operational Flow Order (OFO) winter noncompliance penalty structure to apply year-round to SoCalGas, SDG&E, and PG&E. The penalty structure was originally adopted to apply to SoCalGas only in Decision 19-05-030 and was extended in Decision 21-11-021.
An OFO is a mechanism to protect the operational integrity of a pipeline (see more detail here). OFOs require that gas supply and demand volumes are within a specified range within the pipeline. Most parties agree to retaining the winter schedule (currently only applicable to SoCalGas) and expanding it to the other gas IOUs (i.e., PG&E and SDG&E). The structure provides a relatively smooth transition between OFO non-compliance stages and adopting the structure for all gas IOUs creates clearer and more consistent price signals across the state.
This report, completed by Kiki Velez, student at Stanford University, provides an overview of the regulatory and policy issues concerning the long-term reduction of gas demand and infrastructure needs. The report provides analysis of various options and some initial recommendations for Coalition members to consider.
Summary of the Latest Proceeding Developments:
[4/22/22] Final Decision Issued
On April 22, the Commission issued a Final Decision extending Southern California Gas Company’s Rule 30 Operational Flow Order winter noncompliance penalty structure year-round. The final decision makes this rule applicable to Southern California Gas Company, San Diego Gas & Electric Company, and Pacific Gas and Electric Company service territories. This final decision is based on the Proposed Decision of 3/18/22, with only clarifying changes made. Between the Proposed Decision of 3/18/22 and this Final Decision, EDF submitted a proposal that was denied by the commission. This proposal would have required the IOUs to perform a root cause analysis of each Operational Flow Order and submit the analysis before the Commission, which the Commission deemed unnecessary.
The rulemaking, despite this Final Decision, remains open. Decisions around Rule 30 Operational Flow Order summer noncompliance penalty structure have not been made.
[3/18/22] Proposed Decision Issued
On March 18, the ALJ issued a Proposed Decision (for vote no sooner than April 21, 2022) that extends the SoCalGas Rule 30 Operational Flow Order (OFO) winter noncompliance penalty structure to apply year-round to SoCalGas, SDG&E, and PG&E. The penalty structure was originally adopted to apply to SoCalGas only in Decision 19-05-030 and was extended in Decision 21-11-021.
An OFO is a mechanism to protect the operational integrity of a pipeline (see more detail here). OFOs require that gas supply and demand volumes are within a specified range within the pipeline. Most parties agree to retaining the winter schedule (currently only applicable to SoCalGas) and expanding it to the other gas IOUs (i.e., PG&E and SDG&E). The structure provides a relatively smooth transition between OFO non-compliance stages and adopting the structure for all gas IOUs creates clearer and more consistent price signals across the state.
In response to comments from TURN, the Proposed Decision includes a process to allow for temporary relief from the OFO penalty in limited circumstances when there is an extreme price spike. Gas IOUs may file an expedited Tier 2 Advice Letter to request a temporary change.
[3/1/2022] Amended Ruling and a New Ruling Issue
On March 1, the ALJ issued a superseding Ruling to the February 9 Ruling that includes a revised list of data to be provided by utilities. The Ruling also names SDG&E as an additional respondent and encourages responses from the municipal gas utilities owned by the cities of Long Beach, Palo Alto, and Vernon. The deadline for response is still April 22, 2022. Requested gas system data includes items such as number of large volume customers served, daily and hourly consumption, miles of high and medium pressure pipelines, miles of Adyl-A pipeline, miles of pipeline exposed to certain safety incidents, and other gas system data. These data will be used to determine priorities for increasing, maintaining, or retiring parts of the current gas infrastructure, as part of a long-term gas planning strategy.
Also on March 1, the ALJ issued a new Ruling accomplishing a number of items. First, the Ruling releases Energy Division's Workshop Report for Track 2a and invites party comment. Second, the Ruling orders PG&E, SoCalGas, and Southwest Gas to propose safety parameters and regulatory processes to derate pipelines on their system from transmission to distribution. Third, the Ruling asks parties what the regulatory process to derate a transmission pipeline to a distribution pipeline should be. Responses for all three issues are due on March 15, 2022.
[2/9/2022] Seeking Data from Gas Utilities Ruling Issued
The ruling released on February 9 directs Gas IOUs to provide specified information about their gas systems by April 22, 2022 and encourages Gas MOUs to do the same.
[2/4/2022] Ruling Setting Briefing Dates for Track 2a, Scoping Question A
This February 4 ruling adopts the date of Monday February 28, 2022 for Opening Briefs and Friday April 1, 2022 for Reply Briefs.
[1/5/2022] Amended Scoping Memo and Ruling Issued
Commissioner Rechtschaffen issued an amended scoping memo on January 5th for Phase 2 of the Proceeding. In the revised version, the Commission doubles down on issues of equity and affordability, and adds additional detail on workforce and targeted decommissioning opportunities. Specifically, the Commission states that “addressing the unique challenges faced by low-income and disadvantaged communities in the context of the transition away from gas is a priority in this proceeding”.
The Phase 2 timeline and scope remains largely the same. The first workshop for Track 2a on Gas Infrastructure will be held on January 10th, with a second scheduled for January 24th. The Commission’s Track 2a Workshop Report is expected to be published on February 14, with reply comments due February 28th. Opening briefs will be due in March (exact date TBD), the deadline to file a motion to serve testimony due March 14, and a proposed decision expected in June/July (exact date TBD). The full schedule can be found on page 15 of the amended scoping memo.
In Track 2a of the proceeding, the Commission added text acknowledging and adding minimizing stranded assets as a likely goal to consider when evaluating gas pipeline infra for decommissioning. The Commission also added two additional questions as part of Track 2a - one on identifying efforts to evaluate what infrastructure will be needed specifically for industrial customers, and another question on if there should be a streamlined approval process at the Commission for cost-effective zonal electrification (i.e. targeted geographic electrification).
Track 2b was retitled to include an explicit focus on equity issues, changing it to “Track 2b: Equity, Rate Design, Gas Revenues, Safety, and Workforce Issues”. The Commission added more detailed questions to the proceeding scope regarding considering gas rate design and cost allocation strategies to address affordability, as well as around workforce development, including retraining for low-income and disadvantaged communities.
[10/14/2021] Scoping Memo and Ruling Issued
Commissioner Rechtschaffen issued a scoping memo and ruling that kicks off Phase 2 of the Proceeding. The memo lays out the scope and guiding questions related to three main tracks for Phase 2 of the proceeding -
Up first, Track 2a will aim to determine the appropriate gas infrastructure portfolio for the state’s gas utilities, aligned with state GHG reduction goals. Guiding questions cover:
Track 2c will be focused on both rate design and workforce challenges. On rate design, guiding questions include defining the suite of affordability and other economic concerns for low-income customers and disadvantaged communities, mitigation strategies for rate affordability, and additional financial mechanisms such as accelerated depreciation and securitization to balance costs. Related to workforce, Track 2c will address long-term utility workforce planning, mitigation strategies for a declining gas workforce, and opportunities to set requirements around retraining, job quality, and job access.
[9/23/2021] Ruling Granting Motion for the Filing of Briefs on all Track 1 Issues
After receiving reply comments from parties related mainly to issues of size and type of penalty to be imposed by the Commission in the event of a utility’s prolonged failure to meet design standards, the ALJ issued a ruling denying motions for testimony and evidentiary hearings, citing a relative lack of new disagreement or conflict. The ALJ granted motions for the filing of briefs on all Track 1 issues. Briefs are due October 15, 2021, and reply briefs are due on October 29, 2021.
[7/31/2020] ALJ’s Ruling Seeking Comments from Parties
ALJ Ava Tran sought comments from consumer advocates, utilities and other parties regarding a range of proceeding issues.
[7/21/2020] Gas Proceeding Webinar 2
The second part of the CPUC gas team-led webinar covers Track 1B of the proceeding.
Passcode: Gasplanning123
[7/7/2020] Gas Proceeding Webinar 1
This webinar led by the CPUC’s gas team covers Track 1a of the proceeding.
Password: Gasplanning123
[4/23/2020] Scoping Memo and Ruling Issued
Commissioner Randolph issued a memo defining the questions to be addressed during the proceeding and the process for answering them.
[3/24/2020] Preconference Hearing
ALJ Ava Tran principally discussed requests for party status and other procedural issues. No final rulings were made on scope, schedule or the need for hearings. The transcript is here.
[1/16/2020] Order Instituting a Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and perform Long-Term Gas System Planning
This Order Instituting a Rulemaking (OIR) opens up and kicks-off a new proceeding, and includes a scope of the issues that will be included in the proceeding, as well as a schedule (we suggest you treat this as tentative), and how to participate.
Specifically, this OIR laid out the following:
There will be two phases to this proceeding.
Phase 1 seeks to define reliability requirements for gas service. Phase 1a will cover the parameters of existing reliability standards and consider whether updated and new requirements are necessary. Phase 1b will examine how to mitigate the risks that gas supply shortages pose to electric reliability and market prices.
Phase 2 is focused on long-term gas system planning. This Phase is of greater relevance to BDC objectives and looks at whether the projected reduction in gas demand will require regulatory changes. This phase also includes topics such as demand scenarios from greenhouse gas-related laws at the local and state levels.
[3/1/2022] Amended Ruling and a New Ruling Issue
On March 1, the ALJ issued a superseding Ruling to the February 9 Ruling that includes a revised list of data to be provided by utilities. The Ruling also names SDG&E as an additional respondent and encourages responses from the municipal gas utilities owned by the cities of Long Beach, Palo Alto, and Vernon. The deadline for response is still April 22, 2022. Requested gas system data includes items such as number of large volume customers served, daily and hourly consumption, miles of high and medium pressure pipelines, miles of Adyl-A pipeline, miles of pipeline exposed to certain safety incidents, and other gas system data. These data will be used to determine priorities for increasing, maintaining, or retiring parts of the current gas infrastructure, as part of a long-term gas planning strategy.
Also on March 1, the ALJ issued a new Ruling accomplishing a number of items. First, the Ruling releases Energy Division's Workshop Report for Track 2a and invites party comment. Second, the Ruling orders PG&E, SoCalGas, and Southwest Gas to propose safety parameters and regulatory processes to derate pipelines on their system from transmission to distribution. Third, the Ruling asks parties what the regulatory process to derate a transmission pipeline to a distribution pipeline should be. Responses for all three issues are due on March 15, 2022.
[2/9/2022] Seeking Data from Gas Utilities Ruling Issued
The ruling released on February 9 directs Gas IOUs to provide specified information about their gas systems by April 22, 2022 and encourages Gas MOUs to do the same.
[2/4/2022] Ruling Setting Briefing Dates for Track 2a, Scoping Question A
This February 4 ruling adopts the date of Monday February 28, 2022 for Opening Briefs and Friday April 1, 2022 for Reply Briefs.
[1/5/2022] Amended Scoping Memo and Ruling Issued
Commissioner Rechtschaffen issued an amended scoping memo on January 5th for Phase 2 of the Proceeding. In the revised version, the Commission doubles down on issues of equity and affordability, and adds additional detail on workforce and targeted decommissioning opportunities. Specifically, the Commission states that “addressing the unique challenges faced by low-income and disadvantaged communities in the context of the transition away from gas is a priority in this proceeding”.
The Phase 2 timeline and scope remains largely the same. The first workshop for Track 2a on Gas Infrastructure will be held on January 10th, with a second scheduled for January 24th. The Commission’s Track 2a Workshop Report is expected to be published on February 14, with reply comments due February 28th. Opening briefs will be due in March (exact date TBD), the deadline to file a motion to serve testimony due March 14, and a proposed decision expected in June/July (exact date TBD). The full schedule can be found on page 15 of the amended scoping memo.
In Track 2a of the proceeding, the Commission added text acknowledging and adding minimizing stranded assets as a likely goal to consider when evaluating gas pipeline infra for decommissioning. The Commission also added two additional questions as part of Track 2a - one on identifying efforts to evaluate what infrastructure will be needed specifically for industrial customers, and another question on if there should be a streamlined approval process at the Commission for cost-effective zonal electrification (i.e. targeted geographic electrification).
Track 2b was retitled to include an explicit focus on equity issues, changing it to “Track 2b: Equity, Rate Design, Gas Revenues, Safety, and Workforce Issues”. The Commission added more detailed questions to the proceeding scope regarding considering gas rate design and cost allocation strategies to address affordability, as well as around workforce development, including retraining for low-income and disadvantaged communities.
[10/14/2021] Scoping Memo and Ruling Issued
Commissioner Rechtschaffen issued a scoping memo and ruling that kicks off Phase 2 of the Proceeding. The memo lays out the scope and guiding questions related to three main tracks for Phase 2 of the proceeding -
- Track 2a: Gas Infrastructure;
- Track 2b: Safety, Data, Process; and
- Track 2c: Gas Revenues and Rate Design, Workforce Issues.
Up first, Track 2a will aim to determine the appropriate gas infrastructure portfolio for the state’s gas utilities, aligned with state GHG reduction goals. Guiding questions cover:
- Considerations around size and cost thresholds for considering gas infrastructure projects;
- Criteria for determining the repair or replacement of aging transmission infrastructure;
- Criteria for assessing de-rating opportunities in line with declining demand;
- Criteria for assessing pipelines for proactive decommissioning, including safety, customer class, community characteristics such as disadvantaged communities (DAC), and non-pipeline alternatives;
- Planning and procedural processes for local electric capacity standards;
- and more.
Track 2c will be focused on both rate design and workforce challenges. On rate design, guiding questions include defining the suite of affordability and other economic concerns for low-income customers and disadvantaged communities, mitigation strategies for rate affordability, and additional financial mechanisms such as accelerated depreciation and securitization to balance costs. Related to workforce, Track 2c will address long-term utility workforce planning, mitigation strategies for a declining gas workforce, and opportunities to set requirements around retraining, job quality, and job access.
[9/23/2021] Ruling Granting Motion for the Filing of Briefs on all Track 1 Issues
After receiving reply comments from parties related mainly to issues of size and type of penalty to be imposed by the Commission in the event of a utility’s prolonged failure to meet design standards, the ALJ issued a ruling denying motions for testimony and evidentiary hearings, citing a relative lack of new disagreement or conflict. The ALJ granted motions for the filing of briefs on all Track 1 issues. Briefs are due October 15, 2021, and reply briefs are due on October 29, 2021.
[7/31/2020] ALJ’s Ruling Seeking Comments from Parties
ALJ Ava Tran sought comments from consumer advocates, utilities and other parties regarding a range of proceeding issues.
[7/21/2020] Gas Proceeding Webinar 2
The second part of the CPUC gas team-led webinar covers Track 1B of the proceeding.
Passcode: Gasplanning123
[7/7/2020] Gas Proceeding Webinar 1
This webinar led by the CPUC’s gas team covers Track 1a of the proceeding.
Password: Gasplanning123
[4/23/2020] Scoping Memo and Ruling Issued
Commissioner Randolph issued a memo defining the questions to be addressed during the proceeding and the process for answering them.
[3/24/2020] Preconference Hearing
ALJ Ava Tran principally discussed requests for party status and other procedural issues. No final rulings were made on scope, schedule or the need for hearings. The transcript is here.
[1/16/2020] Order Instituting a Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and perform Long-Term Gas System Planning
This Order Instituting a Rulemaking (OIR) opens up and kicks-off a new proceeding, and includes a scope of the issues that will be included in the proceeding, as well as a schedule (we suggest you treat this as tentative), and how to participate.
Specifically, this OIR laid out the following:
There will be two phases to this proceeding.
Phase 1 seeks to define reliability requirements for gas service. Phase 1a will cover the parameters of existing reliability standards and consider whether updated and new requirements are necessary. Phase 1b will examine how to mitigate the risks that gas supply shortages pose to electric reliability and market prices.
Phase 2 is focused on long-term gas system planning. This Phase is of greater relevance to BDC objectives and looks at whether the projected reduction in gas demand will require regulatory changes. This phase also includes topics such as demand scenarios from greenhouse gas-related laws at the local and state levels.