Very good analysis Cedar Dave!
At the time, it was natual gas prices that went crazy. I now that the Sumas border price skyrocketed and seemed strange. I do think that there was some strange things happening in terms of natural gas capacity, the basic gas price was pretty high. If El Paso points a finger to the gasoline pipeline in Bellingham that blew up and killed 3, I suspect they can raise a good issue of going to max pressure on equipment they didn't trust.
However, this is politics and not science! El Paso will need to fight this on a political/public relations basis rather than filling the equivalent to a request for a reversal.
I suspect that Wagner, if he acts as I suspect, is tossing a bone to California with this and is planning on a swift kick to California's collective groin on some electric issues.
This should be interesting to watch.
On the capacity issue:
Since the average flow during the relevant period was only 2,594 MMcf/d, there was a withholding of 696 MMcf/d of capacity to the California delivery points.
The record is clear that El Paso Pipeline could have operated at or near MAOP without violating the Department of Transportation’s regulations and could have made available an additional 210 MMcf/d of capacity to its California delivery points. Not doing so was a violation of El Paso Pipeline’s certificate obligation to transport 3,290 MMcf/d to the California border.
Why the 696 MMcf/din one place and 210 MMcf/d in another?
If the Pipeline represents half of the total capacity into California then the per centage of total gas witheld would be %3.2 and %10.5. Certainly the gas price would go up and perhaps there wasn't enough gas to transport at the prices in the period previous to the period in question. I.E. Just the witholding of capacity would not seem to account for the large increase in prices .