Simplifying Policy Management

Industrial Process Heat Recovery (IPHR) technology customer exemption from certain nonbypassable charges.

The Commission must set a cap on eligible customers and minimize cost impacts to non-participating customers.

On December 12, 2025, Energy Division held a technical workshop on AB 2109 requirements.

On April 9, 2026, the Commission opened Rulemaking 26-04-009 on California Advanced Electric Rate Design.

At the prehearing conference on June 18, 2026, the three utilities generally supported the proposed schedule.

Joint IOU Proposal Requirements

The proposal must include: a list of nonbypassable charges IPHR customers should and should not be exempt from, with justification;

technology eligibility requirements complying with Public Utilities Code Sections 451.7(a) and (b);

a participation cap based on methodology such as total aggregate megawatt or customer count, including estimated rate and bill impacts to non-participants by customer class and a proposed cap share for each utility (e.g., 40% for SCE, 20% for PG&E, 20% for SDG&E);

compliance requirements such as metering and technology reporting; and

additional strategies to minimize cost impacts on non-participating customers.

Supplemental Questions for Party Comments

Parties must address whether the Joint IOU Proposal comprehensively addresses AB 2109 requirements, whether additional non-participating customer protections should be considered, and whether alternatives to the proposal exist that satisfy AB 2109 requirements.

The ruling is dated September 3, 2026, at San Francisco, California, and signed by Administrative Law Judge Joanna Perez-Green.

and renewable-energy stakeholders support additional disclosure or production. This is a sampling of parties' positions.

Scope and relevance of the requested 8760 load data

• SCE Opposes Clean Coalition’s motion to compel production of 24 months of hourly, machine-readable 8760 load data for specified substations and a feeder. SCE argues the request exceeds the defined scope of Tracks 1 and 2, is not reasonably calculated to lead to admissible evidence under Rule 10.1, and would improperly create new data-reporting obligations through discovery.
• PG&E and SDG&E Support denial of the motion, arguing that the August 2023 scoping ruling does not require or contemplate 8760 data and that the Commission has adopted 576 representative load profiles as the relevant data granularity for this proceeding.
• Joint Supporting Parties Support Clean Coalition’s motion and argue that hourly data is directly relevant to Track 1 transparency and Track 2 issues, including DER orchestration, open distribution-system access, and evaluation of location-specific grid needs.
• SBUA Opposes accepting SCE’s relevance objection. SBUA argues Rule 10.1 does not require a prior Commission order specifically authorizing discovery and that raw data could help parties assess whether existing planning frameworks are practical or need improvement.

Value of 8760 data compared with 576 representative profiles

• SCE Maintains that the Commission-approved ICA validation framework requires publication of 576 representative profiles derived from full-year data and does not require disclosure of the underlying 8760 data. SCE argues Clean Coalition has not shown that the representative profiles are inadequate or that the requested data would produce evidence on issues within the proceeding’s scope.
• PG&E and SDG&E Argue that Clean Coalition has not identified an analysis it could not perform with the existing 576-profile data or demonstrated that the adopted data is deficient. They contend the narrowed request for two substations and one feeder is either too limited to be probative or could become a basis for substantially broader requests.
• Joint Supporting Parties Argue that 576 representative hours cannot show the continuity, duration, frequency, recurrence, or seasonal clustering of local load conditions. They maintain that full hourly data is needed to evaluate storage dispatch, flexible load, DER orchestration, and non-wires alternatives.

Track 2 timing and data-governance issues

• SCE Argues that Track 2 remains under development and that no Commission decision has established an orchestration framework or related data-sharing requirements. SCE characterizes the request as premature and as an attempt to accelerate Commission timelines, noting that broader orchestration activities may not begin until at least 2029.
• PG&E and SDG&E Maintain that the request is premature because the Commission has not yet adopted a DER orchestration framework. They also argue that the motion could prejudge data-access issues being considered in Track 2 of the Customer DER proceeding, Rulemaking 22-11-013.
• Joint Supporting Parties Respond that the Commission need not resolve the entire Track 2 data-access framework to order bounded discovery. They argue that current hourly data is relevant to developing the factual record on priority locations, DER valuation, operational constraints, forecasting, and third-party access.

Burden, confidentiality, and protective measures

• SCE Argues that producing facility-specific 8760 data would impose burdens beyond Commission-directed reporting obligations and could affect data-governance issues addressed in other proceedings and working groups. SCE offered alternative generic profiles but states that Clean Coalition insisted on specific facilities.
• PG&E and SDG&E Emphasize that producing hourly interval data would require dedicated engineering and data-management resources. They contend that a ruling for Clean Coalition could establish a precedent allowing similar requests for any utility or facility and effectively replace the Commission’s adopted data-granularity process.
• Joint Supporting Parties Argue that generalized burden, confidentiality, cybersecurity, and precedent concerns should not justify withholding an entire relevant dataset. They support targeted protections such as confidentiality treatment, aggregation, anonymization, masking, use restrictions, nondisclosure obligations, or partial production.

ICA transparency and stakeholder access

• Joint Supporting Parties Maintain that location- and time-specific information is necessary for meaningful participation by DER developers, community choice aggregators, local governments, and public-interest organizations. They cite the need to identify locations where DERs can provide value, evaluate community resilience and non-wires alternatives, and independently test utility planning data, including data affected by SCE’s April 2026 correction of substation load values.
• SBUA Emphasizes that broad intervenor participation supports development of an effective regulatory framework. SBUA argues that Track 1’s broad scope permits parties to develop independent analyses rather than limiting them to utility-produced planning outputs.

Distribution-equipment ratings information

• IREC Argues that PG&E and SCE have not fully provided the normal and emergency ratings required under Decision 26-02-025 and the related implementation advice letter. IREC states that the missing information includes ratings for equipment such as substation transformers, medium-voltage conductors, circuit breakers, regulators, reclosers, switches, and other distribution facilities, which can determine available capacity for flexible service connections.
• PG&E Filed a motion for leave to submit its response confidentially, according to IREC’s description of the procedural filings. The information provided was described as including ratings for certain overhead and underground conductors and distribution-transformer capability, but not the full range of equipment identified in the implementation materials.
• SCE Provided a response and certain rating materials, including secondary-transformer loading information and underground and overhead construction standards. IREC states that SCE supplied emergency-loading information for only one type and size of overhead conductor and did not provide transformer overloading information.

Confidentiality of PG&E ratings materials

• IREC Requests denial of PG&E’s motion to file its ratings information under seal. IREC argues that PG&E has not demonstrated trade-secret or other applicable grounds for confidentiality, that the information concerns standard engineering limits for commercially available equipment, and that any specific sensitivity should be addressed with narrowly tailored protections rather than withholding the materials categorically.

resources, and compliance flexibility. This is a sampling of parties' positions.

Overall RCPPP framework and planning-to-procurement linkage

• California Independent System Operator Corporation Supports Option 3 as the strongest foundation for aligning the Preferred System Plan, transmission planning, and LSE procurement. It favors recurring, attribute-based and locational procurement requirements.
• California Unions for Reliable Energy Supports Option 3 because it would convert the adopted IRP portfolio into procurement obligations and replace the current ad hoc process.
• GreenGenStorage, LLC Supports Option 3 with modifications, arguing that the adopted PSP should directly inform procurement because ratepayers fund transmission built for the planned portfolio.
• American Clean Power - California Conditionally supports Option 3 as a relatively simple and predictable framework that can build on existing regulatory processes.
• Southern California Edison Company Opposes adopting Option 3 as proposed and favors separate reliability and mass-based GHG procurement frameworks, with flexibility rather than direct conversion of modeled portfolios into binding obligations.
• Alliance for Retail Energy Markets Prefers its multi-year RA proposal and cautions that binding requirements based on long-term planning assumptions may pursue resources that are unavailable or commercially infeasible.
• California Large Energy Consumers Association Supports a programmatic framework but recommends a multi-year Slice-of-Day construct within Option 1 because Option 3 would create overlapping compliance regimes and focus too narrowly on new resources.
• Sonoma Clean Power Authority Opposes the additional proposal as insufficiently adaptive, particularly because it may reduce resource diversity, overlook winter reliability, and lock in obligations based on uncertain assumptions.
• Middle River Power LLC Supports Option 1 because it would address total new and existing resource needs rather than relying on an assumed existing fleet.
• Redwood Coast Energy Authority Supports implementing RCPPP reforms while retaining a non-binding PSP and avoiding a prescriptive allocation of PSP resources to individual LSEs.

Clean-energy and GHG requirements

• UCS and NRDC Continue to recommend pairing Option 3 with a Clean Energy Standard covering new and existing resources, with REC retirement and safeguards against resource shuffling.
• Sierra Club Supports Option 3 but opposes a separate CES, favoring the CSP Calculator as a mass-based GHG true-up tied to actual portfolio emissions.
• American Clean Power - California Supports retaining strong GHG targets and establishing a front-end and backstop compliance process, including consideration of the CSP Calculator. It opposes proposals to weaken adopted targets.
• Environmental Defense Fund Warns that capacity requirements alone may not achieve state GHG goals and supports safeguards such as full procurement of identified long-lead-time resources and protections against divergence from modeled portfolios.
• California Wind Energy Association Recommends separating reliability and clean-energy requirements, with a clean-energy obligation focused on system-critical reliability hours rather than prescribed technologies.
• Pacific Gas and Electric Company Supports a forward-looking mass-based GHG framework and distinguishes emissions-reduction needs from reliability needs.
• Cal Advocates/M.Miley/CPUC Supports reviewing GHG feasibility and recommends targets of 38 MMT in 2030 and 30 MMT in 2035, while balancing environmental objectives with ratepayer impacts.
• GreenGenStorage, LLC Favors an emissions verification and true-up within Option 3 using mass-based and hourly accounting rather than a separate CES.
• The Protect Our Communities Foundation Opposes relaxing GHG commitments and urges prioritization of behind-the-meter solar-plus-storage and virtual power plants as lower-cost zero-emitting resources.

Existing resources, retention, repowering, and retrofits

• Clearway Energy Group LLC Urges the Commission to address existing-resource retention and repowering in the initial RCPPP decision rather than treating existing resources as a planning assumption.
• California Independent System Operator Corporation Recommends a retention compliance mechanism requiring LSEs to demonstrate that an adequate combination of existing and new resources remains available to meet the reliability standard.
• CALIFORNIA ENERGY STORAGE ALLIANCE Supports a contract-status baseline that removes retiring or inadequately contracted resources and allows existing resources to satisfy resulting needs, while preserving strong new-resource procurement signals.
• Nextpower Supports an objective contract-status baseline and credit only for verified incremental attributes from repowering or expansion, including added storage duration, charging energy, or hourly performance.
• Mainspring Energy, Inc. Recommends addressing existing thermal retirements and creating early market signals for repowering and fuel-switchable or transition-ready firm resources.
• Pacific Gas and Electric Company Supports recognizing existing resources and alternative compliance mechanisms but opposes a generic procurement buffer and separate contracting requirements.
• Middle River Power LLC Supports including existing resources, repowers, and co-located thermal-storage facilities in a framework that credits both reliability and emissions-reduction benefits.
• California Resources Corporation Urges eligibility for CCS retrofits as clean firm repowers, citing their potential to preserve existing interconnection and deliverability while reducing emissions.
• Sierra Club Opposes gas repowering and CCS in all RCPPP options, arguing that they prolong fossil combustion and may increase pollution, cost, and reliance on unproven technologies.
• Ava Community Energy Supports retention and repowering reforms, including incremental credit for storage added at existing thermal sites, but opposes using Option 3 to implement those reforms.

Need allocation, load growth, and load migration

• Redwood Coast Energy Authority Supports assigning procurement need based on each LSE’s share of forecasted incremental load growth rather than current load share applied to systemwide growth. It also supports tranches, periodic reassessment, and final assignments at least three years before delivery.
• Ava Community Energy Supports obligations that track each LSE’s changing share of system load and peak demand, including treatment of new entrants and customer migration.
• Alliance for Retail Energy Markets Recommends a dynamic load-obligation framework in which long-term contract responsibilities remain stable while transferable compliance credits follow changing load.
• Western Power Trading Forum Supports a dynamic compliance layer with regular load updates, symmetric treatment of load increases and decreases, new-entrant obligations, and a credit registry.
• California Unions for Reliable Energy Supports allocating aggregate incremental need by LSE load and critical-hour demand, while allowing transferable obligations only when they represent qualifying resources actually delivering energy.
• Pacific Gas and Electric Company Opposes allocating total need solely by pro-rata load share and favors accounting for each LSE’s existing portfolio and individual IRP position.
• San Diego Gas & Electric Company Supports an approach that begins with LSE individual IRPs and allocates remaining system need on a load-share basis.
• Sonoma Clean Power Authority Argues that Section 397 requires consideration of each LSE’s load and resource portfolio and supports critical-hour or residual-need allocation methods.
• California Wind Energy Association Proposes allocating needs based on LSE-specific causation, including each LSE’s share of gas-fired generation during system-critical hours.
• California Coalition of Large Energy Users Supports addressing load migration prospectively and recommends pairing Option 3 with multi-year RA to close the gap between short-term RA and the five-year procurement horizon.

Resource attributes, accreditation, and procurement categories

• Southern California Edison Company Supports technology-neutral, attribute-based requirements and a hybrid framework using marginal ELCC for planning and Slice-of-Day accreditation for near-term compliance.
• California Large Energy Consumers Association Favors broad resource attributes rather than technology mandates and supports Slice-of-Day accreditation to avoid applying inconsistent standards to the same resources.
• Nextpower Supports using SOD, marginal ELCC, and hourly physical-performance measures together, with incremental performance assessed against documented facility baselines.
• Form Energy, Inc Supports distinct multi-day storage categories, complementary reliability metrics including EUE, LOLH, and LOLE, and clean-firm definitions based on performance during extended grid stress rather than annual capacity factor.
• Long Duration Energy Storage Council (LDES Council) Supports technology-agnostic procurement differentiated primarily by storage duration and opposes additional attributes that could narrow competition.
• Mainspring Energy, Inc. Recommends minimum procurement floors for dispatchable resources and duration-based tranches for long-duration storage, informed by SERVM and RESOLVE.
• San Diego Gas & Electric Company Supports broad categories for generic capacity, generation, long-lead-time resources, and demand-side management, with feasibility screens and compliance flexibility.
• California Unions for Reliable Energy Supports attribute-based need expression but recommends eligibility require PCC 1 resources that deliver energy to California customers rather than relying on unbundled RECs.
• Santa Clarita Valley Water Agency Supports separate FCDS and EODS need determinations so energy-only resources can contribute to clean-energy objectives without being treated as reliability capacity.
• California Wind Energy Association Recommends separate reliability and clean-energy metrics and flexible compliance using resources capable of delivering during system-critical hours.

Long-lead-time resources, contracting, and commercial operation dates

• California Independent System Operator Corporation Supports retaining a three-year contracting milestone, extending the standard commercial-operation deadline to seven years, allowing qualifying long-lead resources up to ten years, and providing indicative forecasts through later procurement cycles.
• Green Hydrogen Coalition Recommends a differentiated framework with a binding ten-year long-lead-time track: need at T-10, full contracting at T-7, and operation at T, with technology-neutral eligibility.
• Ormat Technologies, Inc. Supports contract-specific COD compliance for long-lead resources, recognizing geothermal development timelines and the need to coordinate procurement with transmission deliverability and import capability.
• CALIFORNIA ENERGY STORAGE ALLIANCE Supports approximately seven-year procurement cycles and COD-extension flexibility for long-duration and other long-lead resources.
• American Clean Power - California Supports extending contracting and online deadlines to approximately T+5 and T+7, with additional accommodations for long-lead resources.
• Environmental Defense Fund Considers five years insufficient for long-lead resources and supports procurement requirements at least ten years in advance.
• California Unions for Reliable Energy Supports applying the five-year horizon to contracting rather than online delivery for long-lead resources, with enforceable interim contracting milestones.
• Western Power Trading Forum Recommends resolving feasible timelines and retention rules before binding implementation and using the 2028 cycle as an indicative test.
• GreenGenStorage, LLC Supports five years for standard resources and eight years for long-lead categories, with staged contracting and contracted CODs extending up to ten years.
• California Coalition of Large Energy Users Supports a three-year forward RA requirement alongside Option 3 and recommends addressing years T+2 through T+5.

Transmission, deliverability, and geographic procurement

• California Independent System Operator Corporation Supports explicit locational requirements aligned with busbar mapping and transmission planning to avoid disconnects between procurement and deliverability.
• Santa Clarita Valley Water Agency Supports geographically specific FCDS and EODS procurement requirements tied to busbar mapping and the Transmission Planning Process.
• Ormat Technologies, Inc. Urges coordination among RCPPP procurement, Transmission Plan Deliverability, Maximum Import Capability, and CAISO allocation processes for out-of-state geothermal resources.
• California Wind Energy Association Recommends planning transmission for PSP resources at the outset, reserving firm transmission where needed, and accounting for upgrade timing.
• Environmental Defense Fund Supports incorporating transmission availability and upgrade status into procurement determinations and deadlines.
• Cal Advocates/M.Miley/CPUC Opposes locational procurement requirements because they could narrow competition, increase seller market power, and raise customer costs.
• American Clean Power - California Supports improving transmission planning and busbar mapping to reflect commercial feasibility and avoid penalizing procurement delayed by transmission constraints.
• GreenGenStorage, LLC Supports a durable PSP-to-procurement-to-transmission link and regular reporting comparing executed procurement with adopted resource categories and busbar zones.

Compliance flexibility, transferability, buffers, and penalties

• Redwood Coast Energy Authority Supports retaining transferable procurement obligations so smaller LSEs can adjust obligations to match available resources and avoid over-procurement.
• CALIFORNIA ENERGY STORAGE ALLIANCE Supports transferable RCPPP compliance attributes with clear trading rules and a load-migration mechanism.
• Western Power Trading Forum Supports proportionate penalties, good-faith recognition, safe harbors for uncontrollable delays, and a transparent credit registry rather than punitive category enforcement.
• California Large Energy Consumers Association Opposes a rigid 100 percent contracting requirement and significant contracting penalties, and supports SOD alignment, safe harbors, and contemporaneous publication of accreditation inputs.
• San Diego Gas & Electric Company Supports eliminating the procurement buffer, extending alternative compliance provisions, relaxing deadlines, and using moderate penalty pricing.
• Pacific Gas and Electric Company Opposes a generic procurement buffer and supports alternative compliance mechanisms and a good-faith efforts standard.
• Cal Advocates/M.Miley/CPUC Supports an adaptive retirement allowance that adjusts need as resources exit, while opposing proposals that guarantee contracts for uneconomic existing resources or narrow competition through location-specific mandates.
• Environmental Defense Fund Finds insufficient support for a one-percent buffer and would require additional evidence before adopting one.
• California Unions for Reliable Energy Supports credit for early action and over-procurement, but limits transferable compliance value to resources that actually deliver energy to California customers.
• GreenGenStorage, LLC Supports procurement bands, good-faith alternative compliance, and penalties tied to the deficient resource category rather than a generic highest-cost resource.

Local reliability and distributed resources

• Sierra Club Supports including local reliability analysis, energy-based metrics, air-quality and disadvantaged-community considerations, and a pathway for distributed energy resources and virtual power plants.
• Environmental Defense Fund Supports local procurement modeling and a process to identify locations where clean generation, storage, or transmission could enable fossil-fuel retirement.
• Form Energy, Inc Supports integrating local and systemwide capacity requirements and evaluating reliability with multiple complementary metrics.
• The Protect Our Communities Foundation Urges prioritizing behind-the-meter solar plus storage and virtual power plants, arguing these resources can reduce emissions, land impacts, and costs.
• Sonoma Clean Power Authority Supports Slice-of-Day accounting and stronger attention to winter reliability as electrification, data-center load, and solar-storage penetration change seasonal risks.
• California Coalition of Large Energy Users Supports using SERVM alongside RESOLVE to evaluate reliability in a multi-year RA framework.

Energy-only resources and clean firm technologies

• Santa Clarita Valley Water Agency Supports recognizing the modeled need for energy-only solar separately from deliverable reliability capacity.
• American Clean Power - California Supports allowing energy-only resources to receive IRP and RA credit when they contribute to emissions reduction, including solar paired with storage.
• California Wind Energy Association Supports technology-neutral clean-energy procurement focused on delivery during system-critical hours rather than prescribing particular technologies.
• California Resources Corporation Supports qualifying CCS retrofits as clean firm resources and emphasizes their potential air-quality, deliverability, and development-time benefits.
• Sierra Club Opposes CCS and gas repowering, arguing that clean firm eligibility should not extend to technologies that continue fossil combustion.
• Middle River Power LLC Supports recognition of co-located natural-gas and battery facilities where added storage reduces emissions while preserving reliability and local capacity.
• Mainspring Energy, Inc. Supports clean-firm and dispatchable procurement floors that could include fuel-flexible generators using RPS-compliant fuels or committed pathways to those fuels.
• Long Duration Energy Storage Council (LDES Council) Supports duration-differentiated storage procurement and opposes technology-specific requirements beyond duration.