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Weekly Digest
Application of PACIFIC GAS AND ELECTRIC COMPANY (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff and Green Tariff Shared Renewables Programs.
Renewable Energy Programs Update
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Overview of Renewable Energy Programs
- The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
- Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.
Comments on Proposed Decision
- The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
- Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).
FERC Orders and Cases
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
Treatment of Credits
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
Solar for All Program and National Community Solar Partnership
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Potential Modifications to the NVBT
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
Recommendations for the NVBT Program
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Use of Funding Sources
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Targeting Low-Income Households
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Challenges with PURPA Prices
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
Stakeholder Comments
- Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
- Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.
Concusion
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045
Renewable Energy Programs Update
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Overview of Renewable Energy Programs
- The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
- Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.
Comments on Proposed Decision
- The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
- Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).
FERC Orders and Cases
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
Treatment of Credits
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
Solar for All Program and National Community Solar Partnership
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Potential Modifications to the NVBT
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
Recommendations for the NVBT Program
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Use of Funding Sources
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Targeting Low-Income Households
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Challenges with PURPA Prices
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
Stakeholder Comments
- Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
- Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.
Concusion
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency
Renewable Energy Programs Update
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Overview of Renewable Energy Programs
- The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
- Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.
Comments on Proposed Decision
- The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
- Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).
FERC Orders and Cases
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
Treatment of Credits
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
Solar for All Program and National Community Solar Partnership
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Potential Modifications to the NVBT
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
Recommendations for the NVBT Program
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Use of Funding Sources
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Targeting Low-Income Households
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Challenges with PURPA Prices
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
Stakeholder Comments
- Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
- Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.
Concusion
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Application of PACIFIC GAS AND ELECTRIC COMPANY (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff and Green Tariff Shared Renewables Programs.
Renewable Energy Programs Update
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Overview of Renewable Energy Programs
- The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
- Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.
Comments on Proposed Decision
- The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
- Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).
FERC Orders and Cases
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
Treatment of Credits
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
Solar for All Program and National Community Solar Partnership
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Potential Modifications to the NVBT
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
Recommendations for the NVBT Program
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Use of Funding Sources
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Targeting Low-Income Households
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Challenges with PURPA Prices
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
Stakeholder Comments
- Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
- Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.
Concusion
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045
Renewable Energy Programs Update
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Overview of Renewable Energy Programs
- The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
- Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.
Comments on Proposed Decision
- The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
- Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).
FERC Orders and Cases
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
Treatment of Credits
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
Solar for All Program and National Community Solar Partnership
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Potential Modifications to the NVBT
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
Recommendations for the NVBT Program
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Use of Funding Sources
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Targeting Low-Income Households
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Challenges with PURPA Prices
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
Stakeholder Comments
- Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
- Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.
Concusion
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency
Renewable Energy Programs Update
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Overview of Renewable Energy Programs
- The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
- Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.
Comments on Proposed Decision
- The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
- Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).
FERC Orders and Cases
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
Treatment of Credits
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
Solar for All Program and National Community Solar Partnership
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Potential Modifications to the NVBT
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
Recommendations for the NVBT Program
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Use of Funding Sources
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Targeting Low-Income Households
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Challenges with PURPA Prices
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
Stakeholder Comments
- Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
- Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.
Concusion
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Order Instituting Rulemaking to Continue Implementation and Administration, and Consider Further Development, of California Renewables Portfolio Standard Program.
Last Week's New Comments +4
This update provides a high-level summary of recent reply comments filed on December 9, 2025, in the California Public Utilities Commission (CPUC) proceeding R24-01-017 regarding the 2025 Renewables Portfolio Standard (RPS) Procurement Plans. The following is a sampling of parties' positions on key topics addressed in the comments.
Scope of the Proceeding and Proposed Decision Modifications
- Joint Community Choice Aggregators (Joint CCAs) urge that any...
- authorization for
- PG&E
- to procure additional short-term RPS products should not preempt ongoing Commission proceedings and that the Proposed Decision should not prejudge issues under review elsewhere.
- San Diego Gas & Electric Company (SDG&E) argues that requests from San Diego Community Power and Clean Energy Alliance (SD CCAs) and Ava Community Energy (Ava) for modifications to the Proposed Decision are outside the scope of the current proceeding and should be addressed in other forums.
- Southern California Edison Company (SCE) contends that the SD CCAs’ proposed findings are unnecessary and outside the scope, and that Ava’s comments do not demonstrate errors in the Proposed Decision.
- Pacific Gas and Electric Company (PG&E) asserts that SD CCAs’ and Ava’s requests extend beyond the scope of the proceeding, particularly regarding the valuation of pre-2019 Renewable Energy Certificates (RECs) and the Voluntary Allocation and Market Offer (VAMO) program.
- Joint CCAs emphasize that the valuation of PG&E’s pre-2019 RPS bank is still under review in separate proceedings and that the Commission should not prejudge these matters in the current decision.
- SDG&E maintains that the Proposed Decision already addresses cost-effectiveness and that further changes are unnecessary.
- SCE states that the SD CCAs’ proposals to address the valuation of pre-2019 banked RECs are outside the scope and could be interpreted as supporting the CCAs’ litigation position.
- PG&E argues that imposing new costs on bundled service customers for pre-2019 RECs would violate statutory protections and that the Commission should not make legal conclusions on customer indifference obligations without a proper record.
- Joint CCAs support the SD CCAs’ position that any cost reductions for bundled customers using banked RECs must align with the Commission’s Indifference Framework, ensuring compensation for customers who originally paid for those RECs.
- Joint CCAs caution against framing PG&E’s affordability proposal as beneficial for bundled customers if it results in cost shifts to unbundled customers, and argue that such issues should be resolved in the appropriate Energy Resource Recovery Account (ERRA) and Power Charge Indifference Adjustment (PCIA) proceedings.
- PG&E maintains that the SD CCAs’ comments on customer indifference obligations are beyond the scope of the current proceeding and should not be addressed without a proper record.
- PG&E contends that Ava’s proposed modifications to the VAMO program lack a legal basis and would require significant changes to the program and existing contractual rights. PG&E urges the Commission to reject these proposals.
- SCE critiques Ava’s assertion that the Commission must consider “cross-LSE” impacts from voluntary allocations, stating that Ava’s comments contradict existing Commission decisions.
- SDG&E argues that Ava’s requests for cross-LSE impact analysis and clarification of discretionary sales are procedurally inappropriate and should be addressed through a petition for modification of an earlier decision.
- SCE supports PG&E’s suggestion to clarify that the 2025 RPS Plans will take effect ten days after filing unless suspended, aligning with recent Commission decisions.
Order Instituting Rulemaking to Implement Senate Bill 520 and Address Other Matters Related to Provider of Last Resort.
Last Week's New Proposed Decision +1
Proposed Decision
Overview
On December 12, 2025, the California Public Utilities Commission (CPUC) issued a proposed decision to implement Senate Bill 520, which was enacted on September 16, 2021. This legislation establishes a clear process for non-Investor Owned Utilities (non-IOUs) to apply for Provider of Last Resort (POLR) status. The decision is part of a multi-phase rulemaking that began on March 18, 2021, with Phase 2 specifically addressing non-IOU...
POLR designations. The earlier Phase 1 Decision, issued on April 18, 2024, updated the framework for IOUs as POLRs.
Key Provisions
- Non-IOUs are required to serve all customer classes within their designated territories and to meet the criteria set forth in SB 520.
- The application process for non-IOUs is streamlined but rigorous. Non-IOUs must submit comprehensive applications, which should be jointly filed with the relevant IOU. These applications must detail their services, regulatory compliance, and plans to prevent cost-shifting.
- While IOUs may oppose applications, they do not have the authority to veto them.
- The Commission will assess each application individually, focusing on:
- Technical and financial capacity
- Compliance with procurement and disconnection rules
- Cost recovery mechanisms equivalent to those for IOUs
- Minimum requirements for insurance and financial stability will be established for non-IOU POLRs.
Geographic and Customer Class Division
The decision clarifies that the geographic division of POLR responsibilities is permitted; however, division by customer class is not allowed. Non-IOUs must file a Petition for Rulemaking at least 12 months before applying for POLR status. The Commission’s authority over non-IOU POLRs, particularly regarding rates and terms, remains under review, and legal briefs may be required to clarify the scope under SB 520.
Current Status
As of now, no non-IOU entities have indicated their intent to serve as POLRs for all customers in any region, which renders some Phase 2 questions moot. The proposed decision will be considered at the CPUC’s Business Meeting on January 15, 2026. There will be opportunities for parties to file comments under Rule 14.3. The order affirms previous rulings, closes the rulemaking, and mandates comprehensive information from non-IOU applicants to ensure compliance with SB 520.
Order Instituting Rulemaking to Modernize the Electric Grid for a High Distributed Energy Resources Future.
Last Week's New Comment +1
Company Overview
Pacific Gas and Electric Company (PG&E) has submitted a supplemental response to the California Public Utilities Commission.
Context
This response addresses inquiries from the November 3, 2025, Assigned Commissioner’s Ruling regarding flexible connections for single-phase customers.
Proposed Solutions
- Conventional service upgrades
- A new initiative funded by EPIC, which allows electrification without panel upgrades by integrating electric vehicle...
- (EV) chargers with advanced metering infrastructure (
- AMI 2.0
- )
- Power control systems
- Smart inverters to optimize load capacity
Order Instituting Rulemaking to Oversee the Resource Adequacy Program, Consider Program Reforms and Refinements, and Establish Forward Resource Adequacy Procurement Obligations.
Last Week's New Scoping +1
Overview
The main purpose of this proceeding is to oversee and refine the Resource Adequacy (RA) program for the 2027 and 2028 compliance years, including establishing forward procurement obligations for load-serving entities. It aims to continue implementing the Slice-of-Day RA program, adopt local and flexible capacity requirements, and address key issues such as accreditation methodologies and transactability. Additionally, the proceeding seeks to coordinate with...
related resource planning efforts and consider program reforms to ensure reliability and alignment with state energy policies.
Background
The California Public Utilities Commission initiated this Order Instituting Rulemaking on October 9, 2025, to address forward procurement obligations for load-serving entities beginning with the 2027 Resource Adequacy compliance year and to consider improvements to the RA program. This proceeding builds on previous rulemakings that established RA requirements for 2025 and 2026. The OIR identified key issues and solicited comments on its scope, schedule, and administration. Numerous stakeholders submitted input, and a prehearing conference was held to discuss these topics. The Commission subsequently set the scope and schedule based on the feedback received.
Order Instituting Rulemaking to Establish a Framework and Processes for Assessing the Affordability of Utility Service.
Last Week's New Comments +11
CPUC R18-07-006: December 8, 2025 Comments on Proposed Decision Updating Affordability Framework
The California Public Utilities Commission (CPUC) received a range of reply comments on Commissioner Houck’s Proposed Decision (PD) to update the affordability framework and close the proceeding. This update summarizes a sampling of parties’ positions on key topics addressed in the latest filings.
Scope and Procedural Issues
- Independent Small Local Exchange...
- Carriers (LECs)
- argue the PD improperly modifies the essential service level for broadband, which is outside the scope of Phase 3, and that related statements should be removed to comply with procedural rules and due process.
- CTIA contends that broadband issues in the PD are outside the current phase’s scope, which is limited to energy, and recommends removing Section 6 to avoid legal errors.
- Pacific Gas and Electric Company (PG&E) opposes expanding affordability metrics reporting to all rate increase proceedings, stating this exceeds the PD’s scope and lacks evidentiary support.
- Bear Valley Electric Service, Inc. (BVES) raises concerns about the introduction of contextual graph requirements at the closing stage of the proceeding, arguing this undermines meaningful participation and should be removed.
- California Community Choice Association (CalCCA) supports robust affordability metrics and opposes proposals from Joint Utilities and Southern California Edison (SCE) to eliminate contextual information, arguing this would reduce transparency and usefulness.
- PG&E supports limiting affordability metrics to General Rate Cases (GRCs) for administrative efficiency and opposes CalCCA’s proposal to expand reporting.
- California Water Association (CWA) finds it impractical to develop affordability metrics for non-residential water customers and recommends sunsetting ongoing reporting requirements for Class A water utilities unless deemed necessary.
- Small Business Utility Advocates (SBUA) supports establishing affordability metrics for small commercial customers and urges the Commission to adopt or initiate a process for these metrics.
- California Large Energy Consumers Association and coalition (Joint Ratepayers) advocate for comprehensive affordability metrics that track cumulative rate changes and impacts on all customer classes, not just residential.
- BVES argues that requiring utilities to present graphs comparing revenue and rate changes to inflation is misleading and could result in underfunding necessary capital investments.
- PG&E supports SCE’s recommendation to remove tables comparing capital revenue requirements to inflation, stating these can mislead decision-makers.
- UCAN supports the PD’s requirement for graphical comparisons to the Consumer Price Index (CPI) using actual residential rates, arguing this enhances clarity and transparency for customers and the Commission.
- Joint Utilities (SDG&E and SoCalGas) express concern that contextual graphs lack evidentiary support and may be misleading, supporting their elimination from the PD.
- CWA critiques the requirement for energy utilities to compare water revenue and rate changes to inflation, suggesting it could mislead and underfund essential infrastructure.
- CalCCA supports including contextual information such as CPI comparisons, arguing it improves transparency and understanding of affordability metrics.
- Independent Small LECs support Cal Broadband’s assertion that pricing obligations for public funding represent a form of rate regulation and that the PD’s conclusion is legally flawed.
- CTIA cautions that the PD’s assertion that pricing constraints tied to public funding do not equate to rate regulation could jeopardize access to federal funds, and recommends factual accuracy if broadband issues are retained.
- SBUA urges the Commission to develop affordability metrics for small commercial customers and supports UCAN’s call for a new proceeding to address these issues.
- PG&E acknowledges concerns about the lack of metrics for small commercial customers but notes the Commission found it infeasible due to the framework’s residential focus.
- CWA emphasizes the impracticality of extending metrics to non-residential water customers due to diverse usage patterns.
- Joint Ratepayers advocate for metrics that capture impacts on all customer classes, including non-residential and agricultural customers.
- UCAN calls for a follow-up proceeding to refine affordability metrics and ensure ongoing monitoring, emphasizing transparency in how utility rates affect residential customers.
- PG&E argues that the PD already ensures affordability remains a priority in major revenue proceedings and introduces mechanisms for enhanced transparency, such as website postings and public cost trackers.
- CWA recommends reviewing and potentially sunsetting ongoing reporting requirements for water utilities to ensure relevance and usefulness.
- BVES contends that the inclusion of graph requirements represents a legal error and requests removal of Section 3.3.1 from the PD.
- Joint Utilities request elimination of certain PD sections and modifications to correct legal and factual errors, particularly regarding contextual graphs and comparisons.
- UCAN finds that neither Sempra nor SCE has demonstrated legal or factual errors in the PD’s requirements for graphical context and supports continued review.
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