Simplifying Policy Management

event-specific actions are not suitable for this quasi-legislative proceeding.

Procedural history and filings

• March 27, 2026: CCSF filed its motion under Rule 11.1.
• April 13, 2026: PG&E opposed the motion, arguing the rulemaking addresses statewide electric distribution objectives, noting SED is reviewing the Mission Substation event under the existing enforcement framework, and warning that adding an investigation would derail systemwide considerations.
• July 1, 2026: Assigned Commissioner Matthew Baker issued the Ruling denying CCSF’s motion.

Legal and procedural basis

The Ruling cites Rule 11.1 and the Order Instituting Rulemaking (pages 9–10) to explain why CCSF’s requested actions do not fit this quasi-legislative proceeding, while reiterating that the Commission’s enforcement and investigative authority is not limited by the denial.

Questions for parties

The Ruling asks whether event-specific investigations should proceed via enforcement channels or separate formal investigations, how to balance statewide objectives with event-specific review, and whether procedural mechanisms (e.g., coordination with SED) can avoid prejudging or duplicating active enforcement reviews.

Decision

The March 27, 2026 CCSF Motion is DENIED. The Ruling is dated July 1, 2026 and signed by Assigned Commissioner Matthew Baker.

LCR is set at 23,618 MW for 2027, 24,545 MW for 2028, and 25,480 MW for 2029. FCR for 2027 ranges from 23,824 MW to 29,063 MW.

Resource Accreditation and Storage

Effective for the 2027 RA year, the Commission clarified storage QC calculations as (MAX_CONT_ENERGY_LIMIT - MIN_CONT_ENERGY_LIMIT) / 4. For non-dispatchable resources, transmission-related outages will use proxy data starting in 2027. While EO resources remain ineligible for RA capacity, co-located EO resources may contribute to charging sufficiency starting in 2027. LDES is defined as resources with 8+ hours of discharge, utilizing an FCP multiplier framework (2x to 8x) for the SOD framework.

Framework Transitions and Market Rules

A UCAP framework will be implemented for the 2028 RA year, utilizing EFORd and the best three of the last four years of outage data. Regarding CAISO’s EDAM and DAME, RA resources are prohibited from retaining capacity-related IR or RC revenue. For DR, an interim accreditation solution involving three specific values sent to CAISO applies to the 2027 RA year.

Program Refinements and Penalties

The Commission rejected hourly load obligation trading but established an interim reporting process for large loads. Effective for the 2027 RA year, a new penalty structure for charging sufficiency deficiencies converts MWh shortfalls into a 24-hour flat-profile MW equivalent to determine penalties. The proceeding remains open for Track 2.

Last Week's New Comments +15

Overview

This is a sampling of parties’ positions in CPUC Rulemaking R.25-10-003 on the June 1, 2026 Proposed Decision. This week’s filings continue last week’s discussion, with parties largely focusing on energy-only charging sufficiency, long-duration storage accreditation, UCAP/storage treatment, and whether Imbalance Reserve and Reliability Capacity products should face zero-dollar bidding or revenue-allocation rules. Several parties also addressed implementation timing, contract treatment, and related reporting issues.

Energy-only resources and charging sufficiency

• CAISO says broader energy-only eligibility for charging sufficiency should wait for its planned analysis, and that the Commission should use CAISO’s forthcoming reliability assessment before allowing standalone EO resources to count.
• PG&E supports an Energy Division study of qualifying capacity treatment for solar and wind EO resources, but wants EO charging sufficiency eligibility to remain narrow for now.
• SCE supports allowing co-located EO resources to count toward charging sufficiency up to the point-of-interconnection limit, but says the accounting should track the EO resource rather than the paired storage.
• CalCCA supports broader EO charging sufficiency treatment and argues the Commission should not rely only on the proposed deferment approach.
• American Clean Power – California says the record already supports allowing EO resources to contribute to charging sufficiency, at least in a limited geographic framework, and urges near-term study rather than delay.
• NextEra Energy Resources, LLC supports counting co-located EO generation toward charging sufficiency, but recommends a different formula that subtracts paired-storage needs before applying deliverability caps.
• CESA supports broader EO eligibility and says the existing record is enough to move forward now rather than wait for more study.
• SANTA CLARITA VALLEY WATER AGENCY supports broader EO eligibility and urges the Commission to rely on the existing record instead of waiting for additional TPP results.
• Sierra Club supports an interim approach that would credit EO resources for charging sufficiency in a more limited, locational way while the record is further developed.
• Vistra opposes broad standalone EO eligibility and says charging sufficiency should depend on deliverable EO capacity available to the withdrawal point when storage needs to charge.
• SDG&E agrees EO charging sufficiency questions should not be expanded before additional analysis, and supports removing related reporting references tied to EO/IR issues.
• ACP-California supports an Energy Division EO qualifying-capacity study and asks the Commission to clarify how co-located EO and storage arrangements can be counted without double counting.

Long-duration storage, state of charge, and worst-day charging assumptions

• Hydrostor, Inc. says the Proposed Decision is too conservative on long-duration storage and should recognize both an initial state of charge and energy available in the days leading up to a peak event.
• CESA argues the LDES framework should not use a zero initial state of charge or a worst-day-only charging proxy, and instead should reflect charging opportunity before the worst day.
• American Clean Power – California says a zero state of charge assumption and worst-day-only approach are inappropriate for LDES and should not be used as the sole charging sufficiency basis.
• Vistra supports retaining a zero initial state of charge assumption for the near term and says a conservative framework is appropriate for Track 1.
• Cal Advocates/M.Miley/CPUC supports the Proposed Decision’s blended LDES charging methodology, including zero initial state of charge and a worst-day forward charging period basis, as a reasonable compromise.
• Sierra Club says the zero initial state of charge assumption likely understates LDES contributions and urges a higher interim assumption or a commitment to revisit the issue with operating data.
• GreenGenStorage, LLC objects to using a worst-day charging basis combined with a zero initial state of charge, saying the record does not support that conservative combination for LDES and that it would overstate charging needs.

Storage qualifying capacity, foldback, and UCAP

• CAISO supports the proposed storage accreditation clarifications but says implementation details for storage nonlinearity and foldback still need coordination.
• PG&E supports treating foldback in storage qualifying capacity but wants any related implementation to begin with the 2027 compliance year rather than immediately.
• SCE supports the foldback-related QC changes and likewise wants them to take effect starting with the 2027 RA year.
• CalCCA says storage nonlinearity should be reflected in qualifying capacity, not penalized again through UCAP.
• ACP-California supports accounting for foldback in a way that avoids double-counting the same physical limitation in both QC and UCAP.
• CESA says foldback should be handled in QC, not as a forced outage in UCAP, and warns against double counting.
• Vistra wants the Commission to avoid double counting storage limitations and argues UCAP should not be applied in a way that over-derates storage.
• Hydrostor, Inc. says the storage accreditation framework should better reflect how LDES operates and should not rely on overly conservative assumptions that reduce accredited value.

UCAP implementation timing and outage definitions

• CAISO supports implementing UCAP in 2028 and says the unresolved details can be worked out in parallel or in Track 2.
• SCE supports the 2028 UCAP start date and wants the Energy Division’s forced outage definition adopted to align UCAP with CAISO outage classifications.
• SDG&E supports a 2028 UCAP test year but says binding compliance should not begin until 2029 at the earliest.
• PG&E recommends delaying binding UCAP implementation further, and seeks a later transition period before compliance becomes mandatory.
• Vistra supports 2028 UCAP implementation but says the program should be limited and refined before broader obligations are imposed.
• Cal Advocates/M.Miley/CPUC supports the Proposed Decision’s UCAP-related framework and argues parties seeking changes have not shown a legal, factual, or technical error.
• WPTF asks for a structured Track 2 process to resolve UCAP implementation details.
• CESA argues outage treatment should not capture known design limitations such as foldback and should avoid double-counting storage constraints.

Imbalance Reserve and Reliability Capacity products: zero-dollar bids, revenue allocation, and contract treatment

• CAISO opposes the Proposed Decision’s zero-dollar bid requirement for IR and RC and says resources should be allowed to bid economically under the CAISO tariff.
• PG&E opposes zero-dollar bidding for IR and says LSEs should not be forced to pursue IR revenues at any cost under existing contracts.
• SCE says IR and RC are distinct products, supports limiting new rules to prospective application, and opposes retroactive application to existing contracts.
• SDG&E also opposes retroactive treatment and says existing contracts should be excluded from any IR or RC allocation approach.
• CalCCA opposes the zero-dollar bid and revenue-flow requirements, or at minimum wants existing contracts excluded from them.
• WPTF says IR should not be treated as a capacity product and warns that applying zero-dollar bidding and revenue-allocation rules would distort prices and create competitive asymmetry.
• American Clean Power – California says the Commission should reject broad zero-dollar bidding and mandatory revenue diversion for IR and RC, especially where existing contracts are involved.
• CESA opposes zero-dollar bids for IR and RC and says the market and contracting harms outweigh any claimed benefit.
• Vistra opposes hourly load obligation trading, says IR is not a CPUC RA product, and argues the Commission should not impose contract or bidding rules that conflict with CAISO’s market design.
• Hydrostor, Inc. says the zero-dollar bid requirement is unsupported and could drive up procurement costs without improving reliability.
• GreenGenStorage, LLC does not address IR or RC in its filing.

Existing contracts and prospective-only application

• Multiple parties, including PG&E, SCE, SDG&E, Vistra, CalCCA, ACP-California, and WPTF, say any new DAME or revenue-allocation rules should apply prospectively and should not reopen existing contracts.
• Cal Advocates/M.Miley/CPUC does not focus on contract retroactivity in the same way, and instead emphasizes its view that the Proposed Decision’s blended approach is reasonable.

Hourly load obligation trading and large-load issues

• CalCCA supports hourly load obligation trading and argues it can reduce unnecessary procurement and improve affordability.
• SDG&E opposes hourly load obligation trading and asks that it be rejected with prejudice.
• Vistra also opposes adopting financial hourly load obligation trading now and says the record does not show clear customer savings.
• CalCCA says the meet-and-confer approach for large loads is not enough on its own and wants a more durable allocation process.
• PG&E supports a meet-and-confer process for large loads as a practical interim step, though CalCCA disagrees with that characterization.

Other reporting and implementation issues

• PG&E supports clarifying reporting requirements and says the Commission should avoid administrative complexity in the ordering paragraphs.
• SDG&E supports removing Quarterly Compliance Report references for IR and RC because that process is not a good fit for those products.
• Cal Advocates/M.Miley/CPUC asks for gross-cost reporting for IR and RC and for correction of the ordering paragraph covering DAME metrics.
• NextEra Energy Resources, LLC urges the Commission to align must-offer obligations for co-located EO charging sufficiency with system charging sufficiency requirements.
• CAISO says EO resources that count toward charging sufficiency should submit bids consistent with their availability, and it will provide additional reliability analysis through the 2026-2027 TPP process.