San Diego Gas & Electric Company s2

SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA GAS COMPANY NORTH-SOUTH PROJECT REVENUE REQUIREMENT (A.13-12-013) (1ST DATA REQUEST FROM TURN) ______

QUESTION 1:

Please provide all cost benefit analyses of the North-South project and the River Route from a total customer class perspective and core and noncore customers in particular in machine readable form (Excel spreadsheet).

RESPONSE 1:

No such analysis has been performed.

1 SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA GAS COMPANY NORTH-SOUTH PROJECT REVENUE REQUIREMENT (A.13-12-013) (1ST DATA REQUEST FROM TURN) ______

QUESTION 2:

Please provide 10 years of historical data (2013-2004) showing the MMcfd and MMbtu curtailed on the Southern System due to the inability of SCG to move gas from the Northern System to the Southern System. Please provide the data on a daily basis for each year in machine readable form (Excel spreadsheet).

RESPONSE 2:

The Southern system minimum shows how much gas would be curtailed each day if there were no supplies flowing on Southern receipt points. See attached.

Southern System Min(2004 to 2013).xlsx

QUESTION 3:

Please provide a projection of estimated curtailed volumes for the next 20 years (2014- 2023) based on the "2014 California Gas Report" demand forecasts for core and noncore customers, with noncore segregated into EG and other noncore, in machine readable form (Excel spreadsheet) if the North-South pipeline is not build.

RESPONSE 3:

SoCalGas/SDG&E have no such projection.

QUESTION 4:

Please provide all analyses in machine readable form (Excel spreadsheet) that show curtailment of supplies, for core and noncore customers and core and noncore EG customers, on the Southern System if the North-South project is not built, is delayed by 5 years or delayed by 10 years.

RESPONSE 4:

See Response 3.

QUESTION 5:

Please provide all correspondence; i.e., emails, letters, phone conversations, etc. SCG/SDG&E has had with FERC-regulated pipeline companies, such as, Kinder Morgan/El Paso, etc. regarding alternatives to the North-South pipeline project.

RESPONSE 5:

SoCalGas and SDG&E object to this question on the grounds that it requests confidential and proprietary information. Without waiving these objections, and subject thereto, SoCalGas and SDG&E respond as follow:

TW.pdf

QUESTION 6:

Please provide any analysis that SCG/SDG&E has done to build a pipeline from Cadiz on El Paso Line 1903 to the Cactus City or the Desert Center compressor stations.

RESPONSE 6:

No such analysis has been performed.

QUESTION 7:

Please provide any analysis SCG/SDG&E has done on how a conversion of El Paso Lines 2000 and 1903 from gas delivery to oil delivery would affect SCG's Southern System gas supply delivery capabilities.

RESPONSE 7:

SoCalGas/SDG&E have no such analysis.

QUESTION 8:

In Figure 1 of SCG's application, pg. 14, it shows in the legend "FOREIGN PIPELINE". Please provide a map showing these foreign pipelines and indicate which foreign country owns these pipelines.

RESPONSE 8:

The term “FOREIGN PIPELINE” in Figure 1 of Mr. Bisi’s Prepared Direct Testimony does not indicate ownership by a foreign country. Rather, the term indicates pipelines which neither SoCalGas nor SDG&E own or operate. Those foreign pipelines shown in Figure 1 are: the Mojave Pipeline; the Kern River Pipeline; the Kern/Mojave common pipeline; the North Baja Pipeline; and the PG&E Baja Path transmission pipelines. Maps of these pipelines are equally available to TURN.

QUESTION 9:

Please provide 2 hard copies and a copy in machine readable form of the 2014 California Gas Report and all associated work papers.

RESPONSE 9:

Please refer to the separate response to Question 9 provided on July 14, 2014.

QUESTION 10:

Please provide the California Gas Report based historical data for the Southern System for core, noncore firm and noncore interruptible load and separate EG from other noncore.

RESPONSE 10:

SoCalGas and SDG&E object to this question on the grounds that it requests confidential customer-specific information.

QUESTION 11:

Please provide data in machine readable form showing the curtailment of noncore customers on the Southern System by firm and interruptible and EG and non-EG firm and nonfarm customers if the River Route alternative is chosen instead of the proposed route.

RESPONSE 11:

There is no such data.

QUESTION 12:

If SoCalGas/SDG&E were to impose a minimum flow obligation as an alternative method of meeting Southern System minimum flow requirements, please explain what level of flow (for example, as a percentage of deliveries from different customer classes) would be required and how often would such a minimum flow obligation be required based on existing forecasts for 5 and10 years in the future.

RESPONSE 12:

SoCalGas/SDG&E cannot answer this question because the answer would depend on future flows that we are not able to model. However, given that sometimes there is sufficient supply at Blythe and other times there is a Southern System minimum of 800 MMcfd with no market-supplies at Blythe, one can assume the percentage would range from zero to 35 percent (800 divided by a low sendout of 2300 MMcf/d).

QUESTION 13:

Re Musich p. 20 – Please identify which intervenors opposed the minimum flow proposal in the last BCAP.

RESPONSE 13:

The December 23, 2008 testimony of Southern California Edison Company, the Indicated Producers, and the Southern California Generation Coalition expressed opposition to the Southern System Minimum Flow Order proposed by SoCalGas and SDG&E in A.08-02-001.

QUESTION 14:

Re Morrow, p. 2:4-7: Please provide any studies or analyses concerning the impact of imposing tighter monthly balancing rules on the Southern System minimum flow requirements.

RESPONSE 14:

There are no such studies.

QUESTION 15:

Re Musich, p. 2:11 – Why is it not “in the economic interest” of shippers to deliver into the Southern System? Please provide any historical price data or future price forecasts that explain this behavior.

RESPONSE 15:

The table below compares the average ICE day-ahead price at Ehrenberg with the average prices at SoCalGas’ other receipt points on the days in which the other receipt points traded. (Unlike Ehrenberg, the other points do not trade every day). The table shows a significant and growing price disadvantage at Ehrenberg vis-à-vis all the other points. This means that on most days of the year, Ehrenberg is the last point that suppliers want to use to meet their Southern California customers’ needs. This explains why customers’ supplies at Ehrenberg keep declining each year.

Avg. Ehrenberg Premium Over Other Border Points SoCal SoCal SoCal Ehrenberg - SoCal Ehrenberg - Ehrenberg - SoCal SoCal Ehrenberg - SoCal SoCal Ehrenberg - Kramer SoCal KRS Needles TopockEP SoCal WR 2008 (0.062) NaN 0.076 NaN (0.001) 2009 0.034 0.015 0.011 NaN (0.027) 2010 0.016 0.032 0.015 NaN 0.013 2011 0.031 0.059 0.032 NaN 0.024 2012 0.043 0.042 0.046 0.052 0.045 2013 0.079 0.074 0.079 0.089 0.075 2014 0.066 0.106 0.111 0.064 0.028

QUESTION 16:

Re. Musich, p. 5, Figure 1 – Please explain the causes of the increase in the minimum requirements since 2008, identifying all relevant factors that contribute to the increase. Please quantify the impact(s) of any factor(s) if possible.

RESPONSE 16:

Southern System electric generation has increased since the SONGS outage. See slide 4 from the May 8, 2014 Customer Forum (provided below for convenience). In addition, pipeline maintenance over the last several years has occasionally reduced SoCalGas’ normal ability to flow 150-300 MMcfd of Northern supplies to the Southern system.

2014_Forum_Presen tation_final.pdf

QUESTION 17:

Re Musich, p. 17:14-20 – Does Ms. Musich contend that if SCG/SDG&E contracted for firm supply and capacity, the situation for Southern System minimum flow would be unchanged? Is it possible to solve the minimum flow requirement by holding capacity and supply to Blythe, aside from any operational problems along the relevant El Paso pipeline and associated supply basins?

RESPONSE 17:

No, Ms. Musich contends that the minimum flow requirement itself would be unchanged. No, the minimum flow requirement is not a function of interstate capacity holdings.