The 2019 Gas Transmission and Storage (GT&S) Rate Case Final Decision (D.) 19-09-025, issued on September 23, 2019, adopted the Natural Gas Storage Strategy (NGSS) that substantially changed PG&E’s gas storage asset holdings, its operational functions and CGT’s role in the market. As part of the NGSS, the Commission adopted PG&E’s proposal to reclassify 51,098 MMcf of PG&E owned gas from working gas to cushion gas (or base gas). Under the NGSS, PG&E’s working gas capacity is approximately 52,460 MMcf. PG&E is changing the reporting of the storage inventory level to be consistent with this change in working gas capacity. Beginning with the actual data for June 11, 2021, PG&E Total Gas in Storage inventory numbers will reflect the reduction in current inventory of the reclassified 51,098 MMcf to cushion gas. The current inventory of PG&E Total Gas in Storage and Storage Activity Archives will be adjusted going forward and can be found on the Pipe Ranger Operations page.

Q. Why is PG&E making the change now?

As PG&E continues to implement the changes authorized in the 2019 GT&S Rate Case Decision, PG&E recently changed its accounting records to reflect the reclassification. As a result of the recent change to PG&E’s accounting record, PG&E is updating the way it reports the amount of gas in storage and its reporting to U.S. Energy Information Administration (EIA). Specifically, for the EIA’s Weekly Natural Gas Storage Report for week ending June 11, 2021, the first weekly report to reflect the updated working gas after this reclassification.

Q. How will this reclassification impact PG&E’s storage operations or products?

This reclassification will not further alter how Gas Operations operate PG&E’s storage facilities nor CGT storage and market center products beyond the changes adopted by the Commission associated with the NGSS.

Q. What is cushion gas or base gas?

Cushion gas is the minimum amount of gas needed in the field in order to provide the services adopted in the 2019 GT&S Rate Case Decision. According to EIA, base gas (or cushion gas) is defined as the volume of natural gas intended as permanent inventory in a storage reservoir to maintain adequate pressure and deliverability rates throughout the withdrawal season. Measures of base gas, working gas, and working gas capacity also can also change from time to time. These changes occur, for example, when a storage operator reclassifies one category of natural gas to the other, often as a result of new wells, equipment, or operating practices (such a change generally requires approval by the appropriate regulatory authority). Finally, storage facilities can withdraw base gas for supply to market during times of particularly heavy demand, although by definition, this gas is not intended for that use.

If you have any questions on the above, please contact a CGT Sales Representative or Account Manager.