Simplifying Policy Management

necessary and set the proceeding to stand submitted upon close of oral argument on August 31, 2026.

Oral Argument Logistics and Rulings

Oral argument: 12:00 p.m., August 31, 2026, in-person at CPUC Auditorium, 505 Van Ness Avenue, San Francisco, CA 94102. A quorum of Commissioners will attend; no decisions will be made at the event. Parties must attend in person to present; public may attend in person or virtually (video/listen-only). Written documents and visual aids will not be accepted. Principal rulings: hold oral argument as scheduled and quorum in attendance.

Deadlines, Requests, and Public Access

Deadline to request to speak: close of business, July 29, 2026. Requests must be emailed to the assigned ALJ and the service list, naming representative(s) and estimated speaking time. Joint IOUs (Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas & Electric Company) shall receive collective time equal to other individual parties. The ALJ will allocate and may adjust speaking times and will circulate an agenda before August 31, 2026. WebEx link and access codes provided for public listen-only participation.

granted the extension. The ruling also reminds GPI to include the entire service list on any procedural communication with an ALJ.

Guidance for Future Requests

Any future requests for deadline extensions must indicate whether GPI has attempted to contact other parties to obtain their agreement to the extension.

Questions/Items for Parties to Address

• Did GPI contact other parties to seek agreement to an extension? If so, identify which parties and the results.
• When filing comments, confirm in the opening paragraph that the ALJs granted the extension per Rule 11.6.
• Ensure all procedural communications to an ALJ include the entire service list.

consider extending Risk Spending Accountability Report requirements to small gas utilities such as Alpine and West Coast Gas.

Background

This proceeding continues the California Public Utilities Commission’s review of the Risk-Based Decision-Making Framework (RDF) for electric and gas utilities to ensure safety spending effectively mitigates risks. It follows the closure of R.20-07-013 in August 2025 and was initiated by an Order Instituting Rulemaking (OIR) to address issues such as incorporating risk tolerance, modifying the RAMP schedule and SPD evaluation timing, refining Benefit-Cost Ratio methodology, and expanding Risk Spending Accountability Report requirements to small gas utilities. Stakeholders and respondents submitted comments in June 2026, and a Prehearing Conference was held on June 17, 2026. The Assigned Commissioner issued a scoping memo to establish the issues, schedule, and processes for the proceeding.

or operationally burdensome requirements.

Data sufficiency, verification, and auditability

• Southern California Tribal Chairmen’s Association (SCTCA) argues the Guidehouse review shows IOU self-reported energization data is not reliable enough for compliance determinations without independent verification. SCTCA asks the Commission to require complete, verifiable data, customer access to recorded step dates and delay-cause codes, a customer dispute process, and report-level summaries of disputes and resolutions.
• Interstate Renewable Energy Council, Inc. (IREC) supports an auditable framework and says the Commission should not delay enforcement by treating incomplete or immature reporting systems as a substitute for compliance. IREC also supports clearer step triggers, consistent treatment of overlapping time, and remediation plans if data sufficiency thresholds are not met.
• Cal Advocates supports using the Guidehouse review to keep pressure on data quality, but emphasizes the Commission should retain reporting requirements and require more specific, useful disclosures rather than relaxing oversight.
• Pacific Gas and Electric Company (PG&E) and Southern California Edison Company (SCE) both argue the proceeding should not convert Guidehouse’s data-quality framework into a new enforcement regime. PG&E says the existing timeline data are sufficient for performance assessment, while SCE says compliance should be measured by progress toward adopted timeline targets rather than by data completeness alone.
• California Community Choice Association (CalCCA) supports Guidehouse-style sufficiency standards and says the IOUs still have not fully complied with the reporting requirements needed for regulatory decision-making.

Concurrent time, step definitions, and reporting methodology

• IREC and CalBroadband both support more transparent reporting of how overlapping utility and customer activities are counted, with IREC seeking an auditable framework and CalBroadband warning against methodologies that understate customer wait times.
• Cal Advocates rejects SCE’s proposed within-step allocation method, saying it would reduce transparency and conflict with D.24-09-020’s assignment of specific energization steps to IOUs.
• PG&E defends its own concurrent-time methodology and says excluding overlapping time is reasonable when done consistently and transparently. PG&E warns that broader changes could distort the metrics and create perverse incentives.
• SCE also opposes reclassifying customer-controlled fields as compliance data, saying that would blur the Commission’s distinction between IOU-controlled and customer-controlled work.

Upstream capacity and related reporting

• SCTCA argues upstream capacity constraints are a major source of delay in Tribal, rural, and remote areas and wants separate reporting for projects on Tribal lands and in rural/remote communities, including delay causes and pauses tied to upstream constraints.
• IREC supports revising the template to capture all projects dependent on upstream work, the date a project was placed on hold, and the expected completion date for the upstream upgrade.
• Cal Advocates wants the Commission to keep both upstream capacity and project cost reporting in the biannual reports, saying the data are necessary for oversight and reasonableness review.
• SCE and SDG&E both argue upstream capacity planning belongs in the separate distribution planning framework, not as a new compliance target in this proceeding. SDG&E specifically urges the Commission to reject attempts to apply energization timeline targets to upstream distribution upgrades.
• PG&E supports clarifying upstream capacity fields, but says they should remain informational rather than become compliance metrics tied to individual project timelines.

In-progress projects and outliers

• IREC, EDF, and CalBroadband support reporting on in-progress projects that are already delayed, even if those projects are not used directly in compliance calculations. They say excluding them would hide bottlenecks and give an incomplete picture of performance.
• CalCCA agrees that delayed in-progress projects should be included and separately accounted for, while CalBroadband says stalled projects should be tracked with causes of delay and remediation efforts.
• PG&E and SDG&E oppose using in-progress projects in compliance calculations, arguing that final durations and responsibility allocations are not yet fixed.
• IREC and CalCCA also want outlier projects included in submissions and separately identified, while PG&E opposes rigid outlier caps and SCE says clearly bad-data projects may need to be flagged as outliers.

Tribal, disadvantaged, and broadband-specific reporting

• SCTCA seeks separate reporting on how delay information and delay-reporting processes are communicated to Tribal and disadvantaged communities, including contact verification, channels used, and coordination with Tribal governments.
• EDF supports SCTCA’s call for disaggregated and project-level data so stakeholders can assess whether energization improvements are reaching Tribal and historically disadvantaged communities.
• CalBroadband asks for a broadband-specific energization category and a 90-day timeline for broadband deployment projects, saying broadband work is distinct from ordinary commercial projects and needs separate treatment.

Pre-Decision projects, staffing, and compliance scope

• IREC argues pre-Decision projects should not be excluded from compliance review and says limiting the targets to post-Decision projects would weaken the Legislature’s intent.
• SCE and SDG&E oppose retroactive application of compliance expectations to pre-Decision projects, saying the reporting systems and operational assumptions changed after D.24-09-020.
• Cal Advocates says staffing reports remain directly relevant to energization performance and wants more robust annual workforce reporting, including historic staffing and apprentice allocation data.
• CalCCA similarly argues staffing levels are directly tied to the ability to meet energization timelines and should remain part of the Commission’s oversight framework.
• PG&E says staffing reports should not be treated as a direct compliance measure for energization targets.