Opponents Say SoCalGas’s Outage Reports Undercut the Case for Higher Aliso Canyon Inventory

Sierra Club and Cal Advocates filed June 1 comments challenging SoCalGas's case for higher Aliso Canyon inventory, responding to external and internal outage reports that ALJ Ormond directed the utility to file in A.26-01-009.

Recall that the outage reports were meant to show whether upstream weather events, pipeline outages, and internal system constraints justify raising Aliso Canyon's maximum inventory level.

CAL ADVOCATES

Cal Advocates says neither report demonstrates that additional Aliso Canyon inventory is necessary. It says the External Outage Report identifies no Emergency Flow Orders over the past decade and only one curtailment, affecting noncore electric-generation customers. Moreover, SoCalGas managed every listed external weather event without gas-customer impacts while Aliso Canyon operated at (or below) its current maximum allowable reservoir pressure.

On the internal side, Cal Advocates says SoCalGas describes pipeline incidents, curtailments in the San Joaquin Valley, North Coastal System, and San Diego County, and other constraints, but never claims or shows that additional Aliso Canyon inventory was necessary to address any of them, nor explains how its preferred 86.2 Bcf level would have prevented them. Cal Advocates concludes the reports suggest that the current inventory level has worked.

SIERRA CLUB

Sierra Club says SoCalGas omitted outage durations despite ALJ Ormond's explicit direction, with appendices listing only the year of each event, and that the reports provide no citations for gas prices, weather descriptions, or infrastructure outage causes. Sierra Club says that's important because some claims conflict with SoCalGas's own ENVOY data.

Sierra Club argues further that SoCalGas framed both reports to deflect responsibility for major events: the six-year Line 235 outage appears as routine maintenance work with no mention of the Safety and Enforcement Division's five specific negligence findings against SoCalGas for that rupture.

On substance, Sierra Club argues a February 2019 curtailment, the only one SoCalGas attributes to external events, also involved an unplanned Aliso Canyon withdrawal-capacity reduction of 420 MMcfd on February 5, the day before the curtailment began. Aliso Canyon was already constrained to 34 Bcf post-blowout, with inventory at 30.4 Bcf, during Los Angeles's coldest February since 1962. Sierra Club says that despite all of it, the CAISO served 100% of electric demand and issued no alert, warning, emergency, or Flex Alert. Sierra Club concludes the event reflects Aliso Canyon's unreliability during peak conditions rather than a need for more inventory.

On Winter Storm Elliott, Sierra Club says SoCalGas's External Outage Report states 1.2 Bcf was withdrawn from storage December 22-25, 2022, while SoCalGas's own ENVOY data shows 1.089 Bcf. Sierra Club says actual withdrawals during those days ran at 21% of available capacity, and demand was still met.

Sierra Club argues Receipt Point Utilization cannot prove gas was unavailable at receipt points, since low RPU equally reflects lower demand or customer scheduling behavior, and that low Operational Flow Order days suggest the latter problem is addressable through stronger scheduling requirements, not more inventory.

On the Internal Outage Report, Sierra Club says SoCalGas never distinguishes which curtailments additional Aliso Canyon withdrawals could have mitigated and which were unavoidable regardless. It identifies Imperial Valley, North Coastal Zone, and San Joaquin Valley as the latter. Sierra Club also says the report omits 400 MMcfd of untapped receipt capacity at Otay Mesa. And it notes that SoCalGas expresses concern about supply to what appears to be a Sempra-owned gas plant in Mexicali while saying nothing about how Sempra's Energia Costa Azul LNG export facility competes with SoCalGas customers for the same supply pool.

Sierra Club argues that Energy Division's 2025 Biennial Assessment found only 30.2 Bcf (44% of authorized capacity) is needed to maintain reliability, and that the result is conservative because it stacks extreme assumptions that have never simultaneously occurred.

INSTANT ANALYSIS

Cal Advocates gives the CPUC the most direct path to rejecting SoCalGas's outage showing: no Emergency Flow Orders, one curtailment in 10 years, no causation shown for internal incidents, no explanation of what 86.2 Bcf fixes.

Sierra Club’s February 2019 argument is strong because it complicates SoCalGas’s attempt to treat the event as external. SoCalGas can still argue that a 60-year cold snap drove the curtailment, but Sierra Club can point to an unplanned Aliso Canyon withdrawal constraint the day before the curtailment began. That makes the event a poor vehicle for proving that more Aliso Canyon inventory is needed.