CPUC PIPELINE SAFETY ENHANCEMENT PLAN (PSEP) LIKELY TO IMPACT GAS SUPPLIES TO FOOD PROCESSORS

As the result of last year’s San Bruno pipeline rupture and fire, and pursuant to a National Transportation Safety Board investigation, California state legislators and state regulators are demanding that gas utilities provide better-validated proof of critical operating information from their pipeline operations.

On January 23, 2011, the California Public Utilities Commission (CPUC) ordered Pacific Gas & Electric (PG&E), Southern California Gas (SoCalGas), San Diego Gas & Electric Company (SDG&E), and Southwest Gas to perform comprehensive records review of their transmission pipelines and identify those that have not had their maximum allowable operating pressures (MAOP) established by pressure testing.

On June 9, 2011, the CPUC issued its decision ordering "all California natural gas transmission operators to develop and file with the Commission a Natural Gas Transmission Pipeline Comprehensive Pressure Testing Implementation Plan (Implementation Plan) detailing the utilities’ actions in replacing or testing all natural gas transmission pipelines that have not been pressure tested." The companies filed their Natural Gas Transmission Pipeline Comprehensive Pressure Testing Implementation Plans on August 26, 2011.

Links to utility Implementation Plans:

PG&E: http://www.pge.com/includes/docs/pdfs/shared/edusafety/systemworks/gas/latestupdates/PGE_Implementation_Plan.pdf

SDG&E and SoCalGas:
http://sdge.com/sites/default/files/regulatory/Pipeline_Safety_Enhancement_Plan%20Filing.pdf

As testing involves shutting down gas flows in order to test and possibly replace pipeline, all food processors in these utility service areas should contact their utility account representative in order to minimize potential interruptions of service or to ensure that any interruptions don’t coincide with seasonal processing. Currently, the implementation schedules for testing are ranked in priority based upon risk assessment and maintaining reliability.

In general, the Implementation Plans reflect:

1. A timeline for completion
2. Listing of proposed interim safety enhancement measures
3. Any other measures that will enhance public safety during the implementation period
4. Set forth criteria on which pipeline segments were identified for replacement instead of pressure testing
5. Include rate proposals with the following:
  a. For PG&E only, proposed cost allocation between shareholders and ratepayers; 
  b. Specific rate base and expense amounts for each year proposed to be included in regulated revenue requirement; 
  c. Proposed rate impacts for each year and each customer class

Article written by John Larrea, Government Affairs Director

California League Of Food Producers