of an Additional Achievable Energy Efficiency (AAEE) forecast consistent with SB 350. Club questions the extent to which electrical demand of SDG&E’s customers exceeds SDG&E’s import capability for electricity. This translates to how many customers would lose electric service without gasfired electric generation in San Diego. Sierra Club opines that California’s decarbonization laws are the reason that Line 3602 is not needed. SCGC is sympathetic to Sierra Club’s point of view and suggests that the Commission take official notice of recent updated forecasts such as the most recent IEPR report. POC endorses Sierra Club’s detailed, fact based determination that California’s decarbonization efforts are a reason that this project is not needed and why Line 3602 will become a stranded asset if it is built. “Missing” Rule 3.1 Information Based on a Joint Commissioner/ALJ ruling dated January 22, 2016, the original Application was deemed deficient because the Applicants failed to comply with basic provisions of Rule 3.1 pertaining to CPCN “Construction or Extension of Facilities Requirements,” which require Applicants to provide the following basic information. This information would augment information provided by actual historical and forecasted demands based on actual numbers and/or other factors: Tenyear forecasted (maximum daily and annual daily average daily) volumes in the area to be served by the proposed Line; including information of the quality of gas and broken down by customer type (e.g. core, noncore commercial and industrial, and noncore electric generation; Tenyear historic monthly volumes through Line 1600; and Tenyear historic daily and annual maximum volumes through Line 1600.
Option 2) Assume maintaining Line 1600 at 512 psig (65 MMcfd) and plan available supply pursuant to the Applicants’ forecast and nothing more. No replacement volumes would be needed for the foreseeable future. Based on the Applicants’ most recent demand forecast (Ex. SDGE12 at 85 and 159), peak demand 590 MMcfd by winter 2020/21, and their capacity is 595 MMcfd with Line 1600 at 512 psig. It will take up to four years to pressure test Line 1600 (i.e., conclude by winter 2021/2022 if they initiate hydrotesting in 2018). Therefore, Line 1600 could run at 512 psig until it can be pressure tested. Then, based on results of the hydrotest and/or potential RFO, pressure would then be reduced permanently to 320 psig (or roughly equivalent) and their peak winter capacity reduced to 570 MMcfd. In 2022/23 the Utilities’ forecast anticipates a 1in10 cold day peak of up to 572 MMCfd. Hence, the Applicants would need only 2 MMcfd to ensure reliability for winter 2022/23. Under the above assumptions, at least two options are available to meet the 2 MMcfd deficit. scenario is that 2 MMcfd could be replaced by four years of firm supply from Otay Mesa receipt point (e.g., Costa Azul LNG or El Paso supply or both) he remaining 2 MMcfd be replaced by battery storage. The Applicants’ forecast is for a 563 MMcfd coldday peak in 2023/24, and this drops to 546 MMcfd by 2035/36. Line 3010 can provide 570 MMcfd as a standalone pipeline without Line 1600 in service. Therefore, with the battery storage that SDG&E is already required to procure in large quantity (up to 331 MW procured by 2020 with 96.65 MW procured as of February 2017; D.1704039), we believe that the capacity reduction from derating Line 1600 to 320 psig could, , be accounted for by SDG&E’s battery storage procurements. Either of the two options presented or similar options, would ensure reliability and this could be explored via the results of a RFO as discussed in the following section.
reputable industry studies, new pipelines also pose risks. The hook cracks are resident anomalies of the manufacturing process of electric flash welded longitudinal seams utilized by a single pipe manufacturer A.O. Smith. These stable manufacturing defects do not present an immediate threat unless they interact with other known risks such as corrosion or other integrity threats. Therefore, it is impractical to predict the remaining life of an old buried pipeline or rely on arbitrary time horizons (e.g., 50 years or 20 years) without knowing the actual threats from an integrity assessment and calculate the life based on the extent of threats and other factors. Even with additional information, engineering estimates should not be exclusively relied on to make professional judgments. For example, thirdparty excavations and earth movements are serious time independent threats that are very difficult to predict. In the original application, Applicants stated that hydrotesting was not practical or feasible. Later in the proceeding, they state that it is possible but costly at approximately $million, with a portion of testing to occur in high consequences areas. The results of pressure testing is one major factor to consider when ascertaining how long Line 1600 should remain in service. Therefore, as discussed in the following Section, Applicants must submit a hydrostatic pressure test or replacement plan consistent with Pub. Util. Code § 958. However, as stated earlier, it is impractical to predict the duration of fitness for safe operation solely from pressure test data and pressure testing will never remove or cure the known stable hook crack defects on Line 1600.