Simplifying Policy Management

the CPUC extends the deadline for completing R.20-05-012 to September 30, 2026.

The order is effective May 14, 2026, and is adopted at the CPUC’s San Francisco location. Commissioners signing the decision are President Darcie L. Houck, Karen Douglas, and Christine Harada.

The single actionable directive is that the statutory deadline for this proceeding is officially extended to September 30, 2026.

allocation, and process/timing concerns. Several parties support parts of the Staff Proposal, but there remains substantial disagreement over the appropriate interim GHG value, whether the SCC should function as a cap or floor, and whether the current schedule provides enough transparency for adoption.

GHG valuation and gas-electric alignment

• SoCalGas supports temporarily aligning the gas ACC GHG avoided cost value with the electric ACC GHG value until a gas-specific methodology is developed, arguing the electric-sector value is the more robust interim calculation.
• PG&E supports using a single cross-sector GHG value in the ACC and says the electric-sector value is the most robust available near-term proxy, while noting a longer-term gas-specific approach would be preferable.
• SEIA supports eliminating the GHG Re-Balancing Adjustment and using one consistent GHG value across the electric and gas ACC models based on the electric-sector marginal GHG value.
• CUE opposes applying the electric-sector GHG value to gas-sector emissions reductions and says the electric IRP value does not measure the marginal cost of abating direct gas-sector emissions.
• NRDC, BayREN/3C-REN, and CAL ADVOCATES continue to oppose replacing the gas-sector value with the electric-sector proxy, arguing it would understate gas-sector decarbonization costs and weaken cost-effectiveness for electrification and gas-efficiency measures.

SCC as a cap or floor for GHG avoided costs

• SCE supports using the High SCC as a cap on ACC GHG avoided costs and says the cap should be applied as a post-processing adjustment rather than inside the integrated calculation.
• CUE also supports a High SCC cap, but says it should operate as a real guardrail and not simply re-label capped GHG value as capacity value without independent justification.
• PG&E supports an SCC-based cap on an interim basis, while suggesting the Commission work with CARB on a more durable framework and, longer term, consider a California-based cap tied to state planning.
• SDG&E opposes using the Federal SCC as the cap reference, arguing it measures damages rather than marginal abatement cost and is too volatile for ACC design.
• SoCalGas opposes using the SCC as either a floor or a cap in the ACC, saying SCC values were adopted for an information-only societal cost test and were not intended to drive TRC-based ACC modeling.
• BayREN/3C-REN oppose the proposed SCC cap as applied only to the demand side and argue that if any cap is adopted it should be applied consistently across supply- and demand-side resource valuation.
• CLECA recommends a Base SCC cap rather than the High SCC and says the cap must be implemented as a binding constraint within the integrated calculation, with corresponding output and recalibration shown.

GHG rebalancing adjustment

• SEIA supports removing the GHG Re-Balancing Adjustment, saying it is unnecessary if the same avoided GHG value is used across electric and gas ACC models.
• CUE supports retaining the GHG rebalancing component, arguing it reflects load-shift impacts in the electric sector and is distinct from the cross-sector price question.
• CAL ADVOCATES, BayREN/3C-REN, and SCE also continue to oppose removing rebalancing, saying it can materially affect the cost-effectiveness of electrification and fuel-switching measures.
• PG&E and NRDC support removing the adjustment, with PG&E saying a single GHG value makes the adjustment unnecessary and NRDC questioning whether the adjustment is a true marginal-cost input for the ACC.

Integrated calculation methodology and resource panel

• PG&E supports the simplified integrated calculation approach and says the Commission should consider an additional workshop, advance workpapers, and a formal comment period before adoption.
• SCE supports the Excel-based integrated calculation concept but wants more documentation, including side-by-side comparisons and updated modeling inputs.
• CLECA says the proposed 2x2 integrated calculation is structurally limited, does not optimize most years, and should be replaced with a broader linear-programming or multi-resource approach using the full IRP resource panel.
• SEIA says the integrated calculation should include additional resources beyond solar and storage and proposes an alternative multi-step protocol if a full-panel approach is not feasible this cycle.
• CUE asks for benchmark outputs, sensitivity runs, and validation materials before further methodological changes are adopted.

Hourly generation-capacity allocation

• PG&E supports replacing temperature-based day selection with energy-price-based day assignment, using LOLH instead of EUE, and differentiating weekday and weekend reliability risk.
• SCE supports the same general hourly allocation refinements but says the underlying modeling details should be reviewed before final adoption.
• SDG&E supports the proposed move to LOLH, energy-price-based day selection, and weekday/weekend differentiation.
• CAL ADVOCATES supports the conceptual changes, subject to additional review and disclosure.
• CUE supports the shift to energy-price-based day assignment but asks for more analysis on how the change affects different resource types and asks for implementation workpapers.
• SEIA says the conceptual changes are reasonable but cannot support adoption without the supporting workpapers and year-by-year outputs.
• SBUA agrees reliability risk is shifting beyond the hottest summer days, but asks for deeper analysis and alternative reliability assumptions to be tested.

Process, timing, and transparency

• PG&E and CLECA both support an additional workshop and more complete workpapers before adoption, citing concerns about transparency and the need to review final IRP inputs.
• SEIA, CUE, and CAL ADVOCATES say the current schedule does not allow enough time to review the revised model, workpapers, and supporting data.
• BayREN/3C-REN and SoCalGas argue that the substantive GHG policy questions should be resolved through Track 3 guiding principles before being embedded in the ACC update.
• CLECA and CUE both ask for formal supplemental comment opportunities after updated model runs and supporting documentation are released.