Simplifying Policy Management

Lewam Tesfai, Executive Director.

topics have sufficient net benefits for inclusion in Track 3 and provide one- to two-sentence directions. Topics include: targeted solutions for uneconomic legacy resources; revisiting allocation, including potential mandatory allocations; mechanisms to reduce volatility and stabilize rates; and other structural frameworks for achieving indifference and promoting competition among LSEs. Parties must also identify mutually exclusive topics and timing considerations, including whether proposals should be concurrent, before, or after other issues, and estimate the time needed to develop proposals.

Day 2 — Refinements to PCIA and ERRA

Parties must identify their two to three highest-priority issues and, for each, state the anticipated complexity in record development and the required analyses.

Day 3 — Data Access and Template

Part 2 provides a template for a joint case management statement listing desired data from CCAs and utilities with columns for type of data desired, why the data is necessary or relevant, the providing party’s concerns, and joint options to address concerns. Parties should suggest template changes, identify motivations if opposing proposals, and state how much time is needed between the Track 3 Scoping Memo and the meet-and-confer/file deadline.

Filing rules and deadlines

Comments are due July 9, 2026, with a maximum length of 15 pages, and the attachment should be named “[Party name] Workshop Comments.” Reply comments are due July 16, 2026, with a maximum length of 7 pages, and the attachment should be named “[Party name] Workshop Reply Comments.” Dated June 19, 2026; signed /s/ MARIA SOTERO, Administrative Law Judge.

Last Week's New Comments +2

R25-02-005 — Sampling of Parties’ Positions on the June 16, 2026 Comments

This is a sampling of parties’ positions on how the Commission should value and allocate Pre-2019 Banked RECs used for bundled RPS compliance. The filings largely focus on whether those RECs should remain valued at zero or receive a non-zero compliance value, and on how any value should be assigned for PCIA and related rate-setting purposes.

Core dispute over valuation and customer indifference

• CalCCA says Pre-2019 Banked RECs have compliance value that should be recognized when IOUs use them for bundled RPS compliance, and that doing so is necessary to preserve customer indifference for departed customers who helped fund those RECs.
• The Joint IOUs say Pre-2019 Banked RECs should continue to be valued at zero for indifference purposes, arguing that a non-zero valuation would shift costs to bundled customers and be inconsistent with Commission precedent.

Legal theory and burden of proof

• CalCCA argues California law and the PCIA framework require departed customers to receive the compliance value of RECs paid for on their behalf, and it says the Commission can implement that through existing vintaging tools.
• The Joint IOUs argue CalCCA has not met its burden to show that its proposals would produce just and reasonable rates, and they contend the existing PCIA methodology does not support a separate credit outside the PCIA rate structure.

Proposed valuation methods

• CalCCA proposes valuing Pre-2019 Banked RECs at the compliance-year RPS MPB when they are used for bundled compliance, with the resulting benefit credited back to the RECs’ generation vintage.
• As a fallback, CalCCA supports a composite valuation that would combine the RPS MPB and PCC-3 market price.
• The Joint IOUs reject CalCCA’s valuation approaches and support keeping the value at zero; if the Commission adopts a non-zero value, they favor a modified Staff Proposal 4 and say any unbundled share should be benchmarked to PCC-3.

Allocation mechanics and treatment of customer cohorts

• CalCCA says the benefits from banked RECs should be allocated by vintage so that later-departing customers receive a fair share of the value they helped fund.
• CalCCA also offers an alternative approach that would proportionally decrement LSE RPS procurement needs rather than transfer REC ownership.
• The Joint IOUs oppose reallocating already-retired RECs to other retail sellers and say the Commission should not require mandatory reassignment through RNS templates or other compliance tools.

Concerns about market and affordability effects

• The Joint IOUs say a non-zero valuation would create downstream harms, including higher RPS procurement costs, possible stranded resources, and reduced affordability for bundled customers.
• CalCCA disputes those concerns, arguing that the near-term rate effects appear limited and that the market evidence does not show a material affordability risk from valuing the banked RECs.

Implementation and timing

• The Joint IOUs say that if the Commission adopts a non-zero approach, it should use a narrowly tailored version of Staff Proposal 4, with one-time allocation mechanics, exclusions for RECs already used, separate accounting treatment, and advice-letter implementation steps targeted for updated valuation work in October 2026 and new rates in January 2027.
• CalCCA says implementation can be handled through existing PCIA, ERRA, and reporting processes with limited operational changes.

the proceeding should be.

Proceeding scope, sequencing, and process

• Cal Advocates/EINHORN/CPUC supports a phased approach, with Phase I covering Risk Tolerance, BCR modifications, RAMP schedule/process, and SMJU reporting, and later phases addressing additional issues such as transmission wildfire risk and time value of risk.
• PG&E supports a bifurcated process, with a hearing track for Risk Tolerance and a workshop-based track for BCR methodology and SMJU reporting.
• SCE supports a sequenced process and prefers that foundational framework elements be clarified before final requirements are adopted.
• SoCalGas and SDG&E support keeping the proceeding focused and administrable, with sequencing that stabilizes methodology before broader policy changes.
• TURN argues the proceeding should not pursue an abstract Risk Tolerance metric and instead should shift focus to budget-constrained portfolio optimization and related Rate Case Plan issues.
• EPUC/IS supports a flexible framework, workshops for technical issues, and a separate evidentiary track only if the Commission pursues a formal Risk Tolerance standard.
• MGRA supports Commission-led guidance, workshops, and a staged process, with hearings only if needed to resolve disputed facts.

Risk tolerance and affordability

• Cal Advocates/EINHORN/CPUC argues that affordability should be part of the Risk Tolerance discussion and linked to portfolio optimization under budget scenarios.
• EPUC/IS also supports incorporating affordability and says risk tolerance should reflect realistic residual risk in light of rate impacts and utility spending levels.
• MGRA supports including affordability in the framework and says risk tolerance must account for ratepayer ability to bear mitigation costs.
• TURN is skeptical of a stand-alone abstract Risk Tolerance standard unless it is tied to affordability and budget constraints, especially for vulnerable customers.
• PG&E supports adopting a Risk Tolerance standard and says affordability should not define safety risk, though it should be addressed in ratemaking proceedings.
• SCE opposes embedding affordability directly in risk tolerance at this stage and says affordability is better addressed in GRCs.
• SoCalGas and SDG&E similarly oppose conflating affordability with safety risk, arguing that affordability belongs in ratesetting processes rather than as the threshold for acceptable residual risk.

Risk tolerance framework design and record development

• SCE supports a flexible, utility-informed Risk Tolerance framework rather than a rigid standard, and asks Staff to develop a clear proposal with common definitions and methodology first.
• SoCalGas and SDG&E also prefer a safety-based standard or framework that is clearly separated from affordability and developed through a practical, sequential process.
• PG&E supports a formal risk tolerance track and says evidentiary hearings are appropriate to build a complete record.
• MGRA supports SPD drafting initial guidelines and a proposal, followed by workshops and party alternatives, so the Commission can compare options with a fuller record.
• TURN argues that if Risk Tolerance is retained at all, the process should start with a comprehensive SPD proposal and only later consider hearings if necessary.
• EPUC/IS opposes a rigid statewide standard and supports a flexible framework that can inform RAMP and GRC workstreams.

RAMP schedule, review process, and SB 254/WMP coordination

• Cal Advocates/EINHORN/CPUC says the current RAMP timeline is too compressed and supports later due dates, more time for informal comments, and coordination with WMP review requirements.
• EPUC/IS supports lengthening the schedule, formalizing informal comments, and adding workshops so stakeholders can meaningfully review and respond to RAMP filings.
• MGRA says the current schedule should be restored to a more workable format and formalized so early intervenor input can be incorporated into SPD reports.
• TURN recommends renaming the issue to include the Rate Case Plan and SB 254 implementation, with added attention to WMP timing and intervenor participation.
• PG&E prefers to preserve the adopted schedule or manage changes case-by-case, and emphasizes the need to align RAMP timing with GRC preparation.
• SCE is open to schedule adjustments but warns that excessive delay could disrupt GRC timing and preparation.
• SoCalGas and SDG&E support a practical schedule review, but caution that any extension must account for downstream GRC needs.

BCR methodology, avoided O&M, and PVRR

• Cal Advocates/EINHORN/CPUC says the Commission should standardize BCR methodology and place avoided O&M in the numerator as a benefit, rather than treating it as a denominator offset.
• EPUC/IS supports unscaled, risk-neutral BCRs, putting avoided O&M savings in the numerator, and adopting standardized PVRR-based cost inputs for capital projects.
• TURN supports standardizing O&M treatment, using unscaled BCRs as the default, and considering PVRR to better reflect lifetime costs.
• MGRA supports examining historical O&M treatment and favors a standardized PVRR approach that captures lifetime costs more accurately.
• SCE and PG&E support preserving the analytical role of BCRs and caution that moving costs or savings into the numerator could distort the metric.
• SoCalGas and SDG&E support targeted methodological refinements but oppose mandatory PVRR calculations in RAMP and prefer BCRs remain a decision-support tool rather than a substitute for risk tolerance.

SMJU and small utility reporting

• Cal Advocates/EINHORN/CPUC supports extending RSAR reporting to Alpine and West Coast Gas, with a reasonable transition period.
• EPUC/IS reserves comment on expanding RSAR requirements to Alpine and West Coast Gas pending further opportunity.
• PG&E, SCE, and SoCalGas/SDG&E take no position in the summaries provided on extending RSAR reporting to those utilities.

New or expanded topics raised in this week’s comments

• TURN adds a specific proposal to shift emphasis from Risk Tolerance to improvements in budget-constrained portfolio optimization, including tighter limits on how utilities set starting budget assumptions and broader inclusion of CPUC-jurisdictional spending.
• TURN also raises SB 254 implementation as a reason to broaden the RAMP process to include Rate Case Plan scheduling and WMP coordination.
• MGRA emphasizes preserving meaningful intervenor participation in WMP-related CPUC processes after SB 254 and recommends a dedicated Phase I track on that issue.
• Cal Advocates continues to push for more granular risk analysis, standardized cost inputs, and a workshop process to develop a Commission-approved PVRR approach.