Simplifying Policy Management

workshop.

The modification also reschedules comments on those studies and Planning Reserve Margin (PRM) proposals.

Track 2 Schedule

Workshop on LOLE studies: September 15, 2026 (Hybrid) – unchanged.

Parties file and serve Final 2028 LOLE studies and PRM proposals: November 2, 2026 (previously October 13, 2026).

Opening comments on LOLE studies and PRM proposals: November 20, 2026 (previously November 12, 2026).

Reply comments on LOLE studies and PRM proposals: December 11, 2026 (previously December 3, 2026).

Other Track 2 Dates

• All other Track 2 dates remain unchanged, including Track 2 proposals (January 15, 2027), workshop (early February 2027), opening comments (February 26, 2027), reply comments (March 12, 2027), and Proposed Decision (June 2027).
• Energy Division May submit a proposal before or concurrently with party proposals.

Ruling

The ruling was signed by Administrative Law Judge Debbie Chiv in San Francisco, California.

issues and extended the deadline to March 31, 2025.

An Amended Scoping Memo (August 11, 2023) extended it to December 31, 2025.

D.25-12-012 (December 4, 2025) extended it to October 30, 2026.

Basis and Actions

• Due to proceeding complexity and limited staff resources, the October 30, 2026 deadline cannot be met.
• The extension allows time for remaining issues.
• The comment period is waived under Rule 14.6(c)(4).
• Darcie L. Houck remains assigned Commissioner.
• Jack Chang and Justin Regnier remain assigned Administrative Law Judges.

Order

• The deadline is extended to December 31, 2026, effective September 17, 2026.
• Issued in San Marcos, California.
• President John Reynolds and Commissioners Houck, Karen Douglas, and Christine Harada concurred.
• Commissioner Matthew Baker recused himself.

Last Week's New Ruling +1

On September 24, 2026, Administrative Law Judge Justin Regnier issued an email ruling in Rulemaking 21-06-017, granting the Interstate Renewable Energy Council (IREC) leave to file a reply to Pacific Gas and Electric Company’s (PG&E) September 22, 2026 reply.

Ruling and Procedural History

• On September 24, 2026, Administrative Law Judge Justin Regnier issued an email ruling in Rulemaking 21-06-017, granting the Interstate Renewable Energy Council (IREC) leave to file a reply to Pacific Gas and Electric Company’s (PG&E) September 22, 2026 reply.
• The procedural sequence began August 24, 2026, when PG&E moved for leave to file a confidential response to the ALJ’s August 13, 2026 email ruling.
• IREC Opposed on September 3, 2026.
• PG&E Requested to reply on September 14, 2026, and sought an extension of the Rule 11(f) timeline, granted September 17, 2026.
• PG&E Filed its reply on September 22, 2026.

IREC’s Request and Grounds

• IREC Requested leave to file a limited reply of no more than five pages, due within five days of the ruling.
• IREC Argued Section III of PG&E’s September 22 reply introduced entirely new arguments for confidential treatment of the capability sheets that PG&E could have raised in its original August 24 motion, and IREC had no prior opportunity to respond.
• IREC Requested the Commission disregard the new arguments or grant leave for a limited reply addressing only those newly raised confidentiality arguments.

Ruling and Filing Requirements

• The ALJ granted IREC’s request.
• IREC May file a reply to PG&E’s September 22, 2026 reply no later than noon on Tuesday, September 29, 2026.
• IREC The reply shall be no more than five pages and must address only the newly raised confidentiality arguments in Section III of PG&E’s September 22, 2026 reply.
• The ruling was issued at San Francisco, California, and states "IT IS SO RULED."

Last Week's New Comment +1

On September 22, 2026, Pacific Gas and Electric Company (PG&E) filed a reply to the September 3, 2026 Opposition by the Interstate Renewable Energy Council (IREC) regarding PG&E’s Motion to File Under Seal.

Procedural Background

The dispute follows an August 13, 2026 Email Ruling by Administrative Law Judge Regnier directing PG&E and Southern California Edison Company (SCE) to file capability sheets and engineering standards.

PG&E received permission to reply on September 17, 2026.

Procedural Objections

• PG&E Argues IREC’s Opposition is procedurally improper.
• PG&E Half of IREC’s filing constitutes a motion to compel under Rule 11.3, exceeding the scope of a Rule 11.4(b) response.
• PG&E IREC also failed to meet the mandatory meet-and-confer requirement under Rule 11.3(a), never contacting PG&E or SCE informally.

Trade Secret and Confidentiality

• PG&E Maintains its Capacity Sheets qualify as trade secrets under California Civil Code section 3426.1(d), combining third-party manufacturer data with PG&E’s proprietary system configurations.
• PG&E Public release could create safety and liability risks.
• PG&E Has required Non-Disclosure Agreements and filed documents under seal on August 24, 2026.
• PG&E The documents are also commercially sensitive under Public Utilities Code section 583 and General Order 66-C, citing D.18-09-008.

Compliance and Conclusion

• PG&E Asserts both utilities fully complied with the August 13, 2026 Ruling; IREC’s additional data requests exceed the ruling’s scope.
• PG&E Requests the Commission deny and reject IREC’s Opposition in its entirety.

greenhouse-gas targets, procurement pace, technology eligibility, and the role of centralized versus distributed resources. This is a sampling of parties' positions.

Load forecasts, affordability, and large-load risk

• Small Business Utility Advocates Requests transparent large-load forecasts identifying magnitude, timing, and certainty; representative small-business bill analyses based on applicable tariffs; no-large-load counterfactuals; cost-causation analysis; and financial protections so small businesses do not bear costs from speculative data-center growth.
• Southern California Edison Company Supports using the 2025 IEPR forecast rather than the 2024 forecast, citing materially lower projected resource additions and costs, and recommends procurement guidance account for affordability and realistic resource availability.
• Pacific Gas and Electric Company Warns that the 2024 forecast can produce over-procurement and recommends current forecasts, scenario-based planning, and realistic assumptions about load and resource development.
• San Diego Gas & Electric Company Urges adoption of the 2025 IEPR forecast for the Preferred System Plan and procurement obligations, rejects true-up approaches for long-term contracts based on inflated need, and emphasizes ratepayer affordability.
• The Protect Our Communities Foundation Argues that applying higher statewide or pro rata data-center assumptions to San Diego could cause over-procurement and shift costs to San Diego ratepayers despite limited projected local data-center growth.

Procurement guidance, feasibility, and cost controls

• Southern California Edison Company Recommends a Procurement Guidance Portfolio that translates long-term planning into actionable but flexible procurement direction, with safeguards for interconnection, transmission, permitting, supply chains, resource availability, and customer costs.
• Pacific Gas and Electric Company Supports limiting near-term procurement to resources in the CAISO interconnection queue or supported by existing or developing transmission, while retaining flexibility for longer-term clean firm technologies.
• San Diego Gas & Electric Company Supports feasibility guardrails at both individual-plan and aggregate-system levels, including review of queue status, development pipelines, transmission readiness, import capability, historical build rates, and affordability.
• American Clean Power–California Supports faster transmission, interconnection, permitting, and resource development, while recommending improved busbar mapping, longer planning horizons, better coordination between transmission planning and interconnection, and timely resolution of the RCPPP framework.
• Cal Advocates Recommends that Liberty Utilities amend its IRP to provide a long-term procurement framework and assess cost-effective in-house capabilities, rather than relying on repeated future advice-letter requests.

Aggregate portfolios, procurement obligations, and interim targets

• Pacific Gas and Electric Company Urges caution in aggregating LSE portfolios because inconsistent assumptions and infeasible resource selections could turn one LSE’s preferences into procurement obligations for others.
• San Diego Gas & Electric Company Recommends that aggregate planning rely on adopted system benchmarks rather than voluntary targets, use a bottom-up and top-down allocation process, and reject additional ad hoc procurement orders absent demonstrated need.
• Southern California Edison Company Supports a more gradual interim GHG trajectory of 38 MMT in 2030 and 30 MMT in 2035, asserting that the existing 30/25 MMT trajectory could require historically unrealistic build rates and higher costs.
• Sierra Club and California Environmental Justice Alliance Support retaining the 30 MMT by 2030 and 8 MMT by 2045 benchmarks referenced in their comments, and oppose lowering GHG targets based on feasibility or cost concerns.

Reliability planning and Slice of Day

• Pacific Gas and Electric Company Supports adopting the Slice of Day framework for IRP reliability planning to better reflect variable and energy-limited resources and improve alignment with resource adequacy proceedings.
• Southern California Edison Company Reports that Slice of Day analysis can identify whether resources are available when needed and satisfy reliability requirements at lower cost than planning based solely on annual accreditation metrics.
• Sierra Club and California Environmental Justice Alliance Identify discrepancies between ELCC-based IRP planning and Slice of Day compliance, and recommend procurement requirements expressed through generation and energy quantities rather than fluctuating ELCC metrics alone.

Distributed energy resources, demand response, and community solar

• Small Business Utility Advocates Requests a demand-side alternatives screen before supply-side procurement and fuller valuation of efficiency, demand response, distributed resources, behind-the-meter storage, and flexible data-center load, with program participation reported by customer class.
• The Protect Our Communities Foundation Requests sensitivity analysis that optimizes behind-the-meter solar-plus-storage, assigns it resource adequacy value, and accounts for removal of Rule 21 barriers, arguing that distributed resources can reduce transmission needs and local costs.
• Coalition for Community Solar Access Recommends a regulatory pathway recognizing front-of-the-meter distributed resources as load modifiers, inclusion of LSE-planned capacity in system and transmission planning, and tools that capture localized reliability and transmission-deferral value.
• Sierra Club and California Environmental Justice Alliance State that demand-side resources are not adequately optimized or credited in IRP modeling and request clearer valuation methods, modeling tools, and coordination with CAISO.

Disadvantaged communities, air quality, and emissions transparency

• Sierra Club and California Environmental Justice Alliance Argue that several LSEs inadequately address disadvantaged communities and air quality requirements, and recommend withholding approval of noncompliant plans, requiring measurable emissions-reduction criteria, stronger community outreach, and procurement preferences for disadvantaged communities.
• Sierra Club and California Environmental Justice Alliance Request public disclosure of GHG, air-pollutant, disadvantaged-community, and reliability information that they contend has been improperly withheld as confidential.

Clean firm resources, geothermal, and carbon capture

• Pacific Gas and Electric Company Supports extending Diablo Canyon operations through 2045 as a least-regrets option that could reduce new procurement, costs, and emissions, while favoring feasible clean firm resources over unsupported near-term assumptions.
• American Clean Power–California Supports transmission and procurement pathways for geothermal and other geographically diverse clean firm resources, including least-regrets transmission for resources outside California.
• XGS Energy, Inc. Contends that next-generation geothermal is being developed in California despite limited representation in the current interconnection queue, and recommends using development evidence, resource maps, and commercial agreements in planning rather than relying only on queue filings.
• Sierra Club and California Environmental Justice Alliance Oppose including carbon capture and sequestration as a zero-carbon resource, citing continued fossil-fuel dependence, uncertain capture performance, energy penalties, and high costs.
• Southern California Edison Company Requests clear rules for evaluating carbon capture and sequestration, including lifecycle emissions, capture and storage verification, residual emissions, reliability value, and eligibility toward GHG targets.
• San Diego Gas & Electric Company Reports that aggregated plans contain substantial geothermal and wind claims beyond demonstrated development or transmission capability and recommends treating unsupported selections as preferences rather than established system need.

Filing transparency and planning data

• American Clean Power–California Recommends standardized, machine-readable public IRP filings, consistent redaction practices, accessible Excel versions of planning tools, and an integrated dataset review before using individual plans to develop the Preferred System Plan.
• Small Business Utility Advocates Requests standardized disclosure of large-load forecasts, development stages, financial protections, cost-recovery mechanisms, customer-class bill impacts, and demand-side program results in future IRP cycles.