Simplifying Policy Management

This includes considerations regarding cost allocation between bundled and departed customers.

Key Issues

• Valuation of Pre-2019 RECs: There is debate over whether assigning a zero-dollar value to pre-2019 RECs aligns with statutory requirements to prevent cost shifts and maintain fairness among customer groups.
• Legal and Policy Questions: The Joint Investor-Owned Utilities (IOUs) emphasize the need for the Commission to address both legal and policy questions.
• Valuation Methodologies: Other parties, such as CalCCA and Cal Advocates, call for clearer valuation methodologies and consideration of both legal and factual matters.
• Credits for Departed Customers: Ongoing discussions revolve around whether departed customers should receive credits for RECs used by current bundled customers, and whether a second valuation of these RECs could violate statutory protections.

Stakeholder Positions

• Procedural Schedule: Stakeholders generally support the proposed procedural schedule but recommend additional case management steps and flexibility for evidentiary hearings if needed.
• IOUs' Preference: The IOUs prefer resolving issues through legal and policy briefings.
• Other Parties' Openness: Other parties are open to hearings or settlement discussions depending on the development of the record.
• Data Access Concerns: Concerns have been raised about data access and confidentiality regarding SCE’s pre-2019 REC holdings, with calls for clearer protocols.

Conclusion

Further discussions are set for the prehearing conference on January 23, 2026.

offering, with potential expansion to other utilities. This update provides a sampling of positions from utilities, technology providers, trade groups, and advocacy organizations on key topics addressed in recent filings.

Necessity and Structure of the Standard Offer FSC

• PG&E opposes the PD, arguing that a standardized FSC is unnecessary, could be costly and inflexible, and would limit utility discretion needed for safety and reliability. PG&E recommends using a Standard Form Agreement instead of a tariff and urges caution in standardizing FSC offerings.
• Emerald AI supports the Standard Offer FSC, viewing it as a way to expedite customer energization and reduce peak system stress, while advocating for a scalable, enforceable, and technology-neutral framework.
• EDF supports the development of a standard offer for FSCs, stating that current processes are limited and a standardized approach would broaden participation and provide customer certainty.

Inclusion of Utilities and Customer Types

• EDF recommends that the PD apply to all utilities, not just SCE and PG&E, to address upstream capacity constraints. If not immediately extended to SDG&E, EDF suggests requiring implementation after any capacity-driven delays.
• CALSTART recommends that the Standard Offer be applied to SDG&E upon Commission approval, citing existing capacity constraints.
• EDF emphasizes the importance of including single-phase customers in FSC participation to maximize program effectiveness and grid reliability.

Performance-Based Pathways and Technology Neutrality

• Emerald AI advocates for a performance-based pathway allowing customers to operate within defined Limited Load Profiles (LLPs), and calls for clarifications to ensure the Standard Offer remains technology-neutral with optional enhanced offerings.

Advanced Metering and Compliance Verification

• Emerald AI highlights the importance of using Advanced Metering Infrastructure (AMI) for compliance verification and suggests optional telemetry for faster confirmation and improved data collection.

Preliminary Capacity Assessments (PCAs)

• PG&E opposes the PCA process, arguing it duplicates existing efforts, could lead to inaccurate estimates, and would require significant system upgrades that cannot be completed by the proposed deadline.
• CALSTART supports PCAs, stating they are essential for informing customer investment decisions and provide timely, reliable power availability estimates. CALSTART argues that PCAs serve a distinct purpose from the Intake process and help streamline project deployment.
• EDF supports retaining the Step 0 PCA, stating it provides valuable early assessments for customers and improves interconnection efficiency.

Emergency Ratings and Power Control Systems

• IREC expresses concern that the proposed framework could restrict additional capacity for customers using non-certified power control systems (PCS) due to the high costs of UL 3141-certified devices. IREC urges the CPUC to provide a pathway for customers relying on uncertified devices and to collect more data on emergency capacity ratings’ impact on LLPs.
• EDF supports further investigation into how utilities' emergency ratings policies interact with FSCs, but urges the Commission not to delay a final decision. EDF recommends using a customer's load shape for emergency rating limitations rather than cumulative nameplate capacity.

Transparency, Data Collection, and Reporting

• Emerald AI recommends robust data collection by PG&E and SCE, including additional data fields to evaluate the Standard Offer’s effectiveness and quantify benefits over time. Emerald AI also calls for clear, plain-language information on constraints, LLP duration, revision processes, and exceedance consequences.
• IREC recommends that utilities disclose their normal and emergency rating standards and clarify how they assess load impacts during engineering evaluations to improve transparency.
• PG&E urges the elimination of duplicative data fields in reporting requirements and advocates for a separate reporting structure for PCA and Standard Offer processes, with a practical implementation plan before enforcement.

Implementation Timelines and Advice Letter Process

• PG&E recommends deferring implementation timelines until a thorough cost analysis is completed and highlights the need for technology upgrades to support expanded FSC participation.
• EDF opposes requests from SCE and PG&E to extend timelines for FSC deliverables, arguing that delays would undermine progress and that strict adherence to the PD's schedule is necessary.
• Emerald AI suggests providing clear, accessible information on the Implementation Advice Letter process and recommends standardized provisions for alternative control methods and transparent exceedance management.

Engineering Evaluations and Load Control Methods

• IREC urges the Commission to require utilities to explain how on-site photovoltaics will be considered in engineering evaluations and to enforce a strict 30-day timeline for initial load limit discussions after a complete application. IREC also recommends clarifying provisions for uncertified controls and their impact on connected load calculations.
• PG&E outlines requirements for verifying customer interest and capability before engineering studies, collecting and retaining curtailment data, and allowing customers to select preferred load control methods, with liability for exceedances assigned to customers.

Standardization and Program Refinement

• Emerald AI proposes clarifying edits to improve consistency and enforceability of the Standard Offer, including standardized LLP templates and transparent exceedance management for large load participation.
• PG&E supports refining the Standard Offer by tracking certain data fields but suggests deleting some proposed items to streamline the process.
• IREC supports the inclusion of uncertified controls in the framework and advocates for clear guidance to resolve ambiguities, streamline processes, and ensure non-discriminatory access to FSCs.

extensive information required and the holiday season contributed to their difficulties.

Opposition to Extension

The Center for Accessible Technology opposed the extension, arguing that it could hinder outreach efforts to vulnerable populations.

Commission's Emphasis

The Commission highlighted the importance of the utilities fully addressing the requirements from previous rulings to enhance their outreach effectiveness.