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Weekly Digest

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A22-05-022

+21

New comments

Application of PACIFIC GAS AND ELECTRIC COMPANY (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff and Green Tariff Shared Renewables Programs.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.

Recommendations for the NVBT Program

The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.

AB-2083

+21

New comments

Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.

Recommendations for the NVBT Program

The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

AB-3246

+21

New comments

Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.

Recommendations for the NVBT Program

The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

A22-05-022

+21

New comments

Application of PACIFIC GAS AND ELECTRIC COMPANY (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff and Green Tariff Shared Renewables Programs.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.

Recommendations for the NVBT Program

The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

AB-2083

+21

New comments

Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.

Recommendations for the NVBT Program

The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

AB-3246

+21

New comments

Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.

Recommendations for the NVBT Program

The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

R23-12-008

3 Comments

Order Instituting Rulemaking Regarding Transportation Electrification Policy and Infrastructure.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Last Week's New Comments +3

CPUC R23-12-008: Recent Party Comments on Transportation Electrification Data and Program Requirements

The California Public Utilities Commission (CPUC) received reply comments from several parties regarding the proposed decision on revised data gathering and reporting requirements for transportation electrification programs. This update provides a sampling of parties' positions on key topics addressed in the latest filings.

Annual TE Programs and Initiatives...

Compliance (ATEPIC) Report and Data Reporting

PG&E supports consolidating reporting into the ATEPIC Report and calls for a collaborative stakeholder process to develop a useful data template.
SDG&E advocates for streamlined data reporting processes to improve efficiency and supports establishing an end date for the annual compliance report to reduce administrative burden.
SCE recommends making the consolidated TE Programs and Initiatives Report publicly accessible, with confidential information redacted, and requests at least 120 days’ notice for template changes, with six months for new data collection requirements.

Technical Assistance (TA) Programs and Budget Structure

PG&E endorses recommendations for TA program structure, suggesting utilities manage their own TA budgets without a central administrator or administrative cap.
SDG&E supports removing the three-year cap on TA budgets, citing that aggressive timelines can disrupt program implementation, and emphasizes the need for a grace period for Funding Cycle Zero (FC0) to overlap with TA services.
SCE supports a streamlined approach for Transportation Advisory Services (TAS) implementation and opposes lengthy handbook development processes.

Funding Allocations and Program Sunset Dates

SCE urges retention of the California Energy Commission’s 2021 Integrated Energy Policy Report for funding allocations and argues for extending sunset dates for Charge Ready programs through December 31, 2029, citing market barriers and program complexity as reasons for low participation.
SDG&E supports retaining FC0 funding until fully utilized to avoid gaps that could impact medium- and heavy-duty electrification, especially in underserved communities.

Vehicle Procurement Requirements

PG&E backs removal of the vehicle procurement requirement for charging depot providers, recommending the change apply prospectively to avoid retroactive complications.
SCE supports retroactive elimination of vehicle purchase requirements for program participants and recommends using a vehicle-to-port ratio for performance evaluation.

Response to UCAN Claims and VGI Stocktake

PG&E contests UCAN’s assertion that the VGI stocktake is essential for accountability, arguing its limitations hinder oversight.
SDG&E counters UCAN’s claim that TA programs overlook behind-the-meter and vehicle-grid integration options, clarifying these are included in the program scope, and argues the VGI Stocktake is not essential for accountability.
SCE opposes UCAN’s claims regarding Transportation Advisory Services and maintains that legislative mandates for VGI integration are met through individual program reporting.

Report Deadlines and Clarifications

PG&E agrees with extending the deadline for the first ATEPIC report to allow adequate preparation and supports clarifications regarding report content and filing process.

Order Instituting Rulemaking Regarding Transportation Electrification Policy and Infrastructure.

R20-08-022

4 Comments

Order Instituting Rulemaking to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Last Week's New Comments +4

Overview

Recent reply comments in CPUC proceeding R20-08-022 address the Administrative Law Judge’s Proposed Decision on Tariff On-Bill (TOB) Pilot Proposals. This update summarizes a sampling of parties’ positions on key topics, including consumer protections, program implementation, regulatory oversight, and pilot design.

Consumer Protections and Program Nature

The Center for Accessible Technology, National Consumer Law Center, and National Housing Law Project...

(Consumer Advocates

Southern California Edison Company (SCE) supports removing consumer debt terminology from the TOB Pilot description, advocating for language that reflects the charge as a tariff rather than a loan.
Southern California Gas Company (SoCalGas) asserts that the TOB program is not a loan or debt, but a utility investment recouped through decarbonization charges, and supports clarifying this distinction.

Department of Financial Protection and Innovation (DFPI) Oversight

SCE supports obtaining a DFPI determination on whether the TOB Decarbonization Charge constitutes lending before pilot implementation and agrees with Consumer Advocates on the need for this regulatory review.
SoCalGas supports CPUC consultation with DFPI to ensure the TOB program does not trigger lending regulations.
Pacific Gas and Electric Company (PG&E) supports SCE’s suggestion to require a DFPI exemption as a prerequisite for implementing any TOB pilot or program, citing potential costs and complexities of compliance.

Pilot Design and Implementation Flexibility

SCE emphasizes the need for implementation flexibility and opposes late-stage modifications to the pilot’s core features, such as extending the cost-recovery period or including low-income customers before testing the model.
SoCalGas recommends deferring the inclusion of customers with discounted rates until more information is available about their financial implications.
PG&E opposes recommendations from other parties to mandate a research plan on scaling TOB and incorporating TOB billing functionality, arguing these actions are premature and unnecessary without insights from ongoing pilots.

Eligibility, Technology, and Performance Evaluation

SoCalGas agrees on the importance of clarifying the eligibility of technologies under the TOB proposal and highlights the need to address budget adjustments due to the extended pilot term.
SCE supports incorporating gas bill savings into performance evaluations and requests that gas utilities provide necessary data for accurate measurement.

Utility Roles and Acknowledgment

SoCalGas requests acknowledgment of its role in the Joint TOB Pilot Proposal, noting it was inadvertently excluded from certain Findings of Fact in the Proposed Decision.
SCE clarifies that only it, as Program Administrator, will collect the Decarbonization Charge, and third-party contractors will not act as lenders.

Order Instituting Rulemaking to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers.

R21-06-017

5 Comments

Order Instituting Rulemaking to Modernize the Electric Grid for a High Distributed Energy Resources Future.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Last Week's New Comments +5

Overview

Recent filings in CPUC proceeding R21-06-017 reflect ongoing efforts to modernize California’s electric grid, improve distribution planning, and enable flexible connections for distributed energy resources (DERs). This update summarizes a sampling of parties’ positions on key topics, including scenario planning, grid modernization, load forecasting, and regulatory changes.

Scenario Planning and Electrification Goals

NRDC supports the establishment of a...

statewide scenario planning framework for the Distribution Planning and Evaluation Process (DPEP), endorsing the use of a High Scenario for investment planning that aligns with aggressive electrification and state policies. NRDC

recommends extending the planning horizon to ten years and ultimately to 2045, developing a policy compliance scenario, and forming a technical working group to improve scenario development and identify future transportation electrification (TE) hot spots.Grid Modernization and Flexible Connections

SCE supports grid modernization for a future with high DER penetration, emphasizing the operationalization of smart inverters to unlock non-firm capacity and improve grid operations during abnormal conditions. SCE is preparing to deploy Advanced Distribution Management Systems (ADMS) and Distributed Energy Resource Management Systems (DERMS) by 2027-28, with a focus on dynamic controls and improved forecasting.
PG&E is expanding its ADMS and DERMS capabilities, currently providing short-term load and generation forecasts for polyphase customers and planning to increase feeder coverage. PG&E highlights the need for improved forecasting and dispatching at the secondary transformer level and robust communication infrastructure for signaling variable operating envelopes.
SDG&E notes that there are currently no existing programs, tariffs, or incentives for customers to comply with utility-initiated import and export limits. SDG&E is focused on foundational activities and infrastructure readiness, with incremental improvements in forecasting and data integration expected through the late 2020s.

Load Forecasting and Data Integration

NRDC recommends technical refinements to load forecasting, including adopting a 10-year planning horizon for substations and refining the definition of “hot spot” to better capture TE demand. NRDC also calls for annual reporting on demand flexibility, such as managed charging and vehicle-to-grid capabilities, to improve transparency and accuracy.
SCE is enhancing load and generation forecasting for single-phase feeder customers, with plans to improve service infrastructure modeling by 2027-28. SCE’s DERMS is designed to scale up to 5 million DERs, and the company is considering interim measures while advanced systems are developed.
PG&E’s DERMS currently generates forecasts for 37 modeled feeders, with plans to expand to 250 feeders by 2027, pending funding. PG&E is exploring cost-effective communication solutions, including AMI 2.0 meters and edge computing for single-phase customers.
SDG&E highlights limitations in real-time data acquisition and modeling, noting the absence of customer-level operational data and the need for significant investments to enable accurate forecasting and compliance with operating envelopes.

Regulatory and Rule Modifications

NRDC emphasizes the importance of classifying certain studies as Category B2 to ensure utilities account for TE loads in planning, in line with statutory requirements. NRDC recommends a more flexible, tiered approach to Category B2 classification to avoid “cliff effects” and better reflect gradual TE adoption.
SCE identifies the need for modifications to rules such as Rule 21, Rule 16, and Rule 29 to support dynamic operational envelopes, and requests further Commission guidance on signaling maximum import values during abnormal operations.
PG&E advocates for updates to Rules and Tariffs to enable operator-signaled maximum capacity limits for flexible customer classes.
SDG&E notes the potential need for rule and tariff modifications to implement variable operational envelopes and stresses the importance of coordinated frameworks and regulatory compliance.

Stakeholder Engagement and Reporting

SCE seeks stakeholder input on implementing dynamic rates and operational envelopes, with responses due by December 10, 2025. SCE also highlights the role of aggregators in data translation and program coordination, considering agreements to reduce costs for customers.
NRDC recommends that utilities report on how state policies are integrated into their studies and supports the use of Transportation Electrification Proactive Planning (TEPP) data to improve transparency and regulatory compliance.
SDG&E provides ongoing billing operations data and customer usage information via Electronic Data Interchange (EDI), distinguishing between free and fee-based data available to large customers.

Order Instituting Rulemaking to Modernize the Electric Grid for a High Distributed Energy Resources Future.

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