PG&E Files 2023 GT&S Cost Allocation and Rate Design Application

Date: September 30, 2021

PG&E filed its 2023 Gas Transmission & Storage (GT&S) Cost Allocation and Rate Design (CARD) application on September 30, 2021. The Rate Case Plan Decision (D. 20-01-002) moved determination of PG&E’s GT&S functional revenue requirements from the GT&S Rate Case into PG&E’s GRC Phase 1. PG&E’s CARD filing includes the ratemaking proposals for PG&E’s GT&S services to recover the revenue requirement that will be adopted in the 2023 GRC Ph 1 for the period 2023-2026. The CARD application addresses the non-revenue-requirement related aspects of the backbone and storage ratemaking. PG&E has proposed that the 2023 GRC and 2023 GT&S CARD decisions be implemented simultaneously.


On June 30, 2021, the 2023 GRC filing included the illustrative backbone rates using the currently approved 2019 GT&S final decision (D.19-09-025) rate design methodology, backbone and storage capacities, load forecast, backbone load factor, and the current (2021) rate differentials between the Baja and Redwood backbone paths. In this 2023 CARD filing, PG&E proposes the rates for GT&S services to recover the revenue requirement that will be adopted in the 2023 GRC. The final rates adopted by the California Public Utilities Commission (CPUC) could be higher or lower than the proposed rates filed by PG&E depending on the outcomes of the two proceedings and the final decision implementation date if beyond January 1, 2023.


The following are some key drivers impacting the proposed backbone rates:

  • Revenue requirements filed in the 2023 GRC Phase 1, for 2023 through 2026
  • Decrease in total throughput, resulting primarily from a forecasted decline in noncore demand
  • Decrease in allocation of storage costs included in backbone rates
    • The revenue requirement for Inventory Management is proposed to be collected in end‑use transportation rates with differentiation by customer class instead of being recovered on an equal cents per therm basis in backbone rates.
    • There are no proposed operational changes to Pipeline Balancing services related to Inventory Management and Reserve Capacity.
  • New Baja-Redwood path rate differentials: $0.137, $0.161, $0.164, and $0.176 per Dth in 2023-2026.

PG&E’s proposed CARD backbone rates are as follows:


PathPresent Rates2023 CARD Proposed Rates
202120222023% Change from 20212024% Change2025% Change2026% Change
Noncore Redwood Annual$0.73$0.75$0.57-21.80%$0.6616.20%$0.694.80%$0.747.20%
Noncore Baja Annual$0.90$0.93$0.71-21.30%$0.8216.50%$0.864.20%$0.927.20%
Core Redwood Annual$0.69$0.72$0.55-20.20%$0.6416.80%$0.685.40%$0.737.50%
Core Redwood - Seasonal$0.83$0.86$0.66-20.20%$0.7716.80%$0.815.40%$0.877.50%
Core Baja - Seasonal$1.03$1.08$0.82-20.10%$0.9617.00%$1.014.70%$1.087.50%
Silverado/Mission Annual$0.57$0.59$0.40-29.60%$0.4818.30%$0.504.30%$0.537.40%



($/Dth @ Full Contract)
- backbone transmission rate per Dth incurred by a firm shipper that uses its full contract quantity at a 100 percent load factor.


To read the filing, go here and in the "Case" dropdown select GTS Cost Allocation and Rate Design (CARD) 2023 case [A. 21-09-XXX], click "Search."


Further details of an Open Season for firm Redwood and Baja capacities will follow the week of October 4th. Please stay tuned to Pipe Ranger for updates as the 2023 General Rate Case and 2023 CARD case continue to move forward. Please contact Allen DeBrum at (925) 244-3498 with questions.

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