Simplifying Policy Management

projects progressing timely.

Effective Dates

The stay is retroactively effective from February 1, 2025, and will remain in place until the Commission makes a final decision on SCTCA's motion.

Program Requirements

The SGIP requires projects to be operational within 18 months of receiving a Conditional Reservation Letter, with extensions permitted under D.15-06-002.

Support for the Motion

• The SCTCA's motion is supported by 24 letters from affected project customers.
• These letters highlight delays due to uncontrollable circumstances.

Ruling Directives

• The ruling directs SGIP program administrators to halt terminations of these projects.
• Projects under a stay cannot receive SGIP incentives.

transparency.

Energization Cost Caps and Funding Levels

• PG&E states that the PD appropriately increases cost caps based on updated forecasts and energization timelines, balancing affordability and timely service. PG&E argues that the PD aligns with legislative intent and prior Commission decisions.
• The Utility Reform Network (TURN) supports the PD’s downward adjustment of capital cost caps, arguing that PG&E’s forecasts do not realistically account for project timelines and that the adjustment reflects likely spending based on past performance.
• The Coalition of California Utility Employees (CUE) contends that cost caps should not hinder PG&E’s ability to perform necessary energization work and calls for a balance between protecting ratepayers and ensuring timely funding, as required by SB 410.
• The Clean Coalition urges rejection of the PD, arguing that it grants PG&E additional funding without sufficient assessment of historical performance or process effectiveness, and that it could set a precedent for maintaining unnecessary backlogs.

Labor Practices and Workforce Planning

• PG&E refutes claims that reliance on external labor is problematic, stating that increased demand—not a lack of internal resources—caused the backlog, and that contract labor is necessary to meet anticipated work surges.
• TURN criticizes PG&E’s reliance on costly external labor, arguing that the PD underestimates the true costs and impact on ratepayers.
• CUE supports TURN’s recommendation for PG&E to provide detailed information on its internal-to-external labor ratio in the next General Rate Case, and calls for workforce planning to ensure compliance with Public Utilities Code section 935.

Project Timelines and Application Processing

• TURN supports the PD’s conclusion that applications not deemed complete by August 1, 2026, are unlikely to be operational by year-end, and that it is reasonable to adjust cost caps accordingly. TURN also notes that PG&E’s historical data shows very few projects are completed within 30 days, with average timelines much longer.

Accountability, Transparency, and Data-Driven Planning

• The Clean Coalition emphasizes the need for accountability and transparency, arguing that the PD lacks a data-driven foundation and does not require PG&E to provide a plan to address its backlog or justify its ability to double its work pace.

Ratepayer Impacts and Interim Cost Recovery

• CUE calls for the Commission to ensure that interim cost recovery is sufficient to fund energization work, subject to later review for reasonableness, and for PG&E to report on how new loads impact rates.
• The Clean Coalition and TURN both raise concerns that the PD’s approach could misrepresent the financial implications for ratepayers, particularly if it relies on speculative future customer loads or incentivizes repeated rate increases.

Association (CalCCA) and is deemed reasonable to ensure timely finalization of forecasts before individual integrated resource plan filings.

Next Steps

Further details regarding the schedule and requirements will be provided during an upcoming prehearing conference.

Last Week's New Comments +8

Overview

The California Public Utilities Commission (CPUC) is conducting a new rulemaking (R25-06-019) on electric Integrated Resource Planning (IRP) and procurement. This update provides a sampling of positions from utilities, community choice aggregators, renewable energy developers, and advocacy groups based on comments filed on August 18, 2025. Key topics include the IRP filing timeline, procurement orders, load forecasting, resource planning, affordability, and the integration of distributed energy resources.

Timeline for Filing IRP Plans

• CalCCA supports allowing Load Serving Entities (LSEs) at least six months to file IRP plans after requirements are issued, citing the need for adequate preparation and internal approvals.
• PG&E recommends extending the IRP filing deadline to at least six months after final requirements are published, due to recent updates in load forecasts and potential delays.
• CleanPowerSF emphasizes that LSEs need a minimum of six months to prepare IRPs, proposing a March 2, 2026, deadline to ensure comprehensive planning and public review.
• SCE supports a six-month window for LSEs to file IRPs after the release of final inputs and assumptions, to allow for thorough analysis.

Scope and Coordination with Other Proceedings

• PG&E urges the CPUC to avoid duplicating issues already under review in Rulemaking 20-05-003, recommending that parties be directed to that proceeding for expedited procurement and emergency order topics.

Procurement Orders and Near-Term Needs

• CalCCA opposes near-term procurement orders proposed by other parties, arguing they lack demonstrated need, could distort the market, and may not be cost-effective given current investment and tax credit constraints.
• IEP supports a near-term needs assessment and procurement order by December 2025, highlighting a procurement gap between 2028 and 2032 and the urgency of addressing reliability and emissions reductions.
• SCE recommends adopting a Reliable and Clean Power Procurement Program (RCPPP) framework instead of an interim procurement order, emphasizing the need for comprehensive analysis before new mandates.

Load Forecasting and Demand Growth

• CalCCA stresses the importance of accurate load forecasting, especially with the growth of data centers, and recommends a collaborative approach to improve forecasting accuracy and transparency.
• Center for Biological Diversity raises concerns about exponential electricity demand growth from data centers, urging the IRP process to implement guardrails to protect ratepayers and environmental objectives.

Affordability and Cost-Effectiveness

• CalCCA emphasizes prioritizing affordability in greenhouse gas (GHG) emission reduction requirements and supports continued evaluation of cost comparisons in IRP analyses.
• PG&E and SCE advocate for customer affordability to remain central in the IRP process and oppose technology carveouts, recommending system-wide modeling to determine resource needs.
• CalWEA recommends a Reference System Plan as a benchmark for cost-effectiveness.
• SBUA supports workshops to clarify affordability and recommends incorporating small-business affordability metrics in the Commission's proceedings.

Distributed Energy Resources and Local Resource Planning

• Center for Biological Diversity urges maximizing distribution-connected solar+storage and accelerating deployment of front-of-the-meter distributed energy resources (FTM DER), highlighting their value for local ownership and resilience.
• SBUA supports enhancing local reliability through DERs and increasing small business participation in these programs, recommending analysis of DER benefits for local reliability and cost reduction.
• CalWEA supports evaluating renewable energy curtailments and advocates for effective modeling to address curtailment issues, as well as comprehensive evaluation of local emissions and resource solutions.

Alignment and Flexibility in Procurement Programs

• CalCCA supports aligning the RCPPP with existing Resource Adequacy (RA) and Renewable Portfolio Standard (RPS) programs, and urges the Commission to reject technology-specific procurement orders to allow LSEs flexibility in resource selection.
• SCE and PG&E recommend a technology-neutral approach and reliance on system-wide modeling.
• IEP advocates for a technology-neutral approach in the needs assessment to ensure a diverse and reliable energy portfolio.

Central Procurement and Local Control

• CalCCA opposes proposals for Investor-Owned Utilities (IOUs) to conduct central procurement in coordination with the Department of Water Resources, citing current law and a lack of evidence that IOUs achieve better results than Community Choice Aggregators.

Long-Lead Time Resources and System Reliability

• PG&E highlights the need for contingency planning for long-lead time resources, such as offshore wind and enhanced geothermal, due to significant lead times for transmission build-out.
• SCE recommends a comprehensive analysis of reliability and clean energy needs before new procurement mandates.

Gas-Fired Resources and Aliso Canyon

• PG&E calls for a deeper examination of the interconnectedness of electric and gas systems, particularly the role of natural gas facilities like Aliso Canyon in supporting the grid.
• SCE and PG&E caution against premature analysis or retirement of gas-fired resources and the Aliso Canyon facility, emphasizing that such decisions should follow thorough assessments of impacts on reliability and affordability.

Support for Collaborative and Transparent Planning

• CalCCA advocates for careful, collaborative, and cost-effective planning in the IRP process, with a focus on flexibility, affordability, and accurate forecasting, and endorses ongoing support for the Tracking Energy Development (TED) task force.
• CalWEA supports collaborative efforts such as a busbar mapping workshop to improve wind resource development and transmission planning.

Design and Implementation

• San Diego Gas & Electric Company (SDG&E) expressed concern about the prescriptive nature of the PD’s guidelines for large IOUs and the lack of sufficient record on costs and feasibility. SDG&E opposed defaulting non-residential customers to dynamic rates, citing insufficient evidence of their ability to respond.
• PACIFIC GAS AND ELECTRIC COMPANY (PG&E) advocated for demand flexibility rates to be opt-in only, rejecting proposals to default commercial and industrial customers onto these rates. PG&E supported a comprehensive review of dual participation in dynamic rates and demand response programs in future proceedings.
• Southern California Edison Company (SCE) opposed defaulting commercial and industrial customers to dynamic rates, citing potential bill volatility and unique customer needs. SCE supported keeping dynamic rates opt-in.
• CAL ADVOCATES/DELAPORTA/CPUC recommended rejecting the Sierra Club’s proposal to automatically place commercial and industrial customers on DF rates, citing lack of supporting evidence and operational analysis. Cal Advocates supported a phased approach to implementation based on pilot findings.
• Center for Accessible Technology (CforAT) agreed that residential customers should not be defaulted to demand flexibility rates and emphasized the need for direct support for low-income customers.

Export Compensation in Rate Proposals

• SDG&E opposed mandatory export compensation rates in DF Rate Proposals, arguing that existing rates are sufficient and that symmetric pricing would shift costs to non-participating customers.
• Solar Energy Industries Association (SEIA) supported the PD’s adoption of statewide MGCC values for export compensation but called for clarification to ensure only settled values are used. SEIA advocated for timely compliance with filing requirements.
• Vehicle-Grid Integration Council (VGIC) urged the Commission to require IOUs to include export compensation in DF rate proposals, aligning with previously adopted DF principles.
• Clean Coalition recommended that DF rate proposals incorporate export compensation to enhance grid reliability and value alignment.
• SCE supported the PD’s flexible approach to export compensation, favoring optional and asymmetric export rates that exclude non-marginal costs to prevent cost shifts.

Marginal Generation Capacity Cost (MGCC) and Avoided Cost Calculator (ACC)

• SDG&E supported Cal Advocates’ position that MGCC values should be determined in General Rate Case (GRC) Phase 2 proceedings and criticized the PD’s reliance on the ACC for MGCC values.
• PG&E agreed that ACC values are inappropriate for ratemaking and advocated for long-run MGCC values to ensure stability. PG&E called for clarification in the PD to allow for both settled and litigated values from GRC Phase II.
• SEIA defended the ACC’s relevance for MGCC, but criticized the PD’s inclusion of non-settled MGCC values, urging clarification to use only settled values.
• CAL ADVOCATES/DELAPORTA/CPUC opposed PG&E’s proposal to update MGCC values via a Tier 1 Advice Letter, advocating for a Tier 2 process to ensure thorough review.

Marginal Distribution Capacity Costs (MDCCs) and Locational Pricing

• SEIA supported the PD’s requirement for IOUs to take initial steps toward locational MDCC pricing and suggested a simpler implementation using existing data at the planning region or baseline territory level.
• Clean Coalition supported the PD’s adoption of locational MDCC, recognizing the importance of time- and location-varying grid costs.

Timeline and Procedural Issues

• SDG&E found CalCCA’s request for additional details on CCA-IOU system interactions premature, given the current PD’s lack of necessary systems and processes.
• PG&E requested adequate time for IOUs to prepare updated DF rate proposals, ideally by November 2026, warning that failure to allow sufficient time could undermine customer adoption.
• SEIA urged the CPUC to reject IOU requests for extended timelines, emphasizing the need for timely compliance with filing requirements.
• VGIC argued against SDG&E’s request for a late 2026 proposal, supporting a 90-day timeline for SDG&E and stressing the need for continuity in dynamic rates for PG&E.
• CalCCA supported keeping the proceeding open to facilitate collaboration between IOUs and CCAs and backed PG&E’s suggestion to extend the timeline for IOUs to create DF Rate Proposals.
• CforAT emphasized the need to keep the proceeding open to address unresolved issues and ensure stakeholder engagement.
• Clean Coalition supported extending the proceeding to address unresolved data access issues for CCAs.

Customer Protection and Support for Low-Income Customers

• PG&E expressed concerns about the PD’s premature conclusions on customer protection methods and called for cost assessments for proposed measures.
• CforAT stressed the need for clarity on residential customer issues and criticized vague recommendations for low-income customer support, emphasizing health and safety implications.

Collaboration and Data Access for Community Choice Aggregators (CCAs)

• CalCCA advocated for continued collaboration between IOUs and CCAs in developing DF rates and highlighted the need to address systems and processes for CCAs to implement DF rates.
• Clean Coalition emphasized the necessity for CCAs to have access to high-quality, granular data to effectively manage DF rates.

Clarification of Terminology

• Clean Coalition recommended that the term "Distribution Load Aggregation Point" (DLAP) be clearly defined to prevent confusion with similar terms used by the California Independent System Operator.