Simplifying Policy Management

Choice Aggregators (CCAs).

Adequacy of Evidentiary Record and Procedural Rigor

• PG&E supports SDG&E’s concerns about the lack of sufficient evidence and procedural rigor behind the CPUC’s decision, particularly regarding the costs and cost-effectiveness of implementing complex RTP rates.
• SBUA criticizes the final decision for lacking a comprehensive record, especially on costs and affordability impacts for ratepayers, with a focus on small businesses.

Cost-Effectiveness and Affordability

• PG&E warns that prescriptive requirements for RTP rates could result in high implementation costs and low customer participation, threatening electric rate affordability.
• SBUA emphasizes the need for further analysis of affordability and costs associated with demand flexibility guidelines, noting that small businesses may face high energy costs and implementation barriers.

Prescriptive Nature of CPUC Decision and Advocacy for Rehearing

• PG&E advocates for a rehearing to revise the decision, urging less prescriptive language and utility-specific cost assessments before mandating RTP rate designs. PG&E highlights the need for a robust evidentiary record to support findings on cost-effectiveness, as required by California law.
• SBUA requests that the Commission grant SDG&E’s application for rehearing to address unresolved issues, including the need for just and reasonable rate design elements for all ratepayers under Public Utilities Code section 451.

Jurisdiction and Deference to CEC Standards

• PG&E critiques the CPUC’s deference to the California Energy Commission (CEC)’s Load Management Standards, arguing that the CPUC retains exclusive jurisdiction over retail electric rates and should not delegate this authority. PG&E points to recent CEC actions, such as the approval of SMUD’s Load Management Standards Plan, which excluded dynamic rates due to cost concerns, as evidence for reassessing CPUC requirements.

Community Choice Aggregators (CCAs) and Program Participation

• PG&E notes that by 2026, twelve CCAs will serve about 53% of its service territory’s load, with most meeting CEC policy criteria. PG&E observes that CCA participation in RTP pilots has been limited and that the complexity of new rate designs may further deter involvement, impacting overall program success. PG&E plans to propose strategies to enhance CCA participation.

Impacts on Small Businesses and Track B Issues

• SBUA argues that Track B issues were not fully adjudicated, leaving critical questions unresolved, such as access to dynamic rates and implications for large commercial hydrogen generation. SBUA contends that incomplete adjudication hinders small business participation in demand flexibility rates, as they may incur implementation costs without the ability to engage effectively due to complex rate designs.

Request for Revised Schedule

• PG&E emphasizes that the CPUC’s imposed 60-day deadline for submitting Supplemental Testimony is insufficient for thorough analysis and proposal development. PG&E requests a revised schedule to allow for updated testimony and urges the CPUC to reconsider the evidentiary basis and operational feasibility of its decision.

capacity requirements, planning reserve margins, and accreditation methodologies for energy storage and renewable resources. Additionally, the proceeding may result in modifications to prior Commission decisions and coordination with related resource planning efforts.

Background

The California Public Utilities Commission established the Resource Adequacy (RA) program in 2005 to ensure reliable electricity supply, introducing system RA requirements in 2006 and local RA obligations in 2007. The program has evolved through annual proceedings and rulemakings to set local and flexible capacity requirements and refine compliance mechanisms. Key developments include the adoption of interim flexible capacity requirements and the 24-hour Slice-of-Day (SOD) framework. The current proceeding continues oversight for the 2027 and 2028 compliance years, extends local RA obligations through 2030, and further refines the SOD program. It follows the previous rulemaking R.23-10-011, which addressed the 2025-2026 compliance years.

update process was lengthy and complex, involving multiple procedural steps such as workshops, testimony, and hearings. To streamline updates and improve efficiency, the Commission will now utilize the most recently adopted Integrated Resource Plan (IRP) Base Case portfolio for ACC updates and has adopted a new schedule for these updates.

Rulemaking 22-11-013

Initiated in November 2022, Rulemaking 22-11-013 remains open and is divided into two phases:

• Phase One: Focuses on cost-effectiveness and data access.
• Phase Two: Addresses equipment performance standards.

The Commission has received stakeholder input through workshops and testimonies. Key parties involved include:

• CLECA
• Vote Solar
• SEIA
• SCE
• MCE
• Cal Advocates
• PG&E
• SoCalGas
• CCR REN

Stakeholders raised concerns regarding the timeline, the need for adequate stakeholder engagement, and alignment with other proceedings. In response, the Commission agreed to modify the schedule to allow for workshops and potential evidentiary hearings. Additionally, it decided to use the IRP TPP portfolio for the 2026 ACC update if the PSP is unavailable.

Budget Increase for ACC

The Commission approved an increase in the ACC budget from $350,000 to $1,200,000 annually to address rising costs and the growing complexity of the update process. SoCalGas questioned the basis for the budget increase and called for annual evaluations, while Cal Advocates requested clarification on the necessity of the increase. PG&E and SCE supported the higher funding, citing the need for enhanced modeling and resources.

The Commission found the budget adjustment reasonable, recognizing the ACC’s critical role in evaluating DER-related avoided costs and the need for improved modeling capabilities. This decision is effective immediately.

sampling of parties’ positions organized by key topics.

Program Termination and Public Interest

• SCE, PG&E, and SDG&E (Joint IOUs) support the PD’s conclusion that ending BioMAT is in the public interest, citing high costs and limited participation.
• Cal Advocates/CPUC agrees with the PD, emphasizing that BioMAT is underutilized, costly, and less effective than other procurement options.
• BAC and CASA oppose the PD, arguing that terminating BioMAT would cause irreparable harm to stakeholders and the state, and that the record does not justify ending the program.
• AECA and Dairy Cares contest the PD, advocating for the extension of BioMAT due to its climate and societal benefits.

Cost and Benefit Analysis

• Cal Advocates/CPUC supports the PD’s cost analysis, noting that BioMAT is more expensive than other RPS resources and has not delivered intended benefits.
• BAC and CASA challenge the IOUs’ cost claims, arguing that the Commission’s calculations are flawed and do not adequately assess BioMAT’s societal and ratepayer benefits.
• AECA and Dairy Cares align with BAC, contending that IOU cost claims are exaggerated and unsupported, and that BioMAT’s impact on rates is minimal while its climate benefits are significant.

Legal Authority and Statutory Mandates

• SCE, PG&E, and SDG&E assert that the PD correctly identifies CPUC’s authority to terminate BioMAT, countering claims that the program must remain open until all capacity mandated by SB 1122 is procured.
• BAC and CASA argue that executive orders cannot override state law without a state of emergency, and that BioMAT is legally required under SB 1122.

Alternative Procurement Options

• SCE, PG&E, and SDG&E maintain that Assembly Bill 843 allows Community Choice Aggregators (CCAs) to procure bioenergy independently after BioMAT ends, and that other procurement programs are available.
• AECA and Dairy Cares counter that there are no adequate alternative procurement options for bioenergy resources, citing IOU procurement plans that focus on solar and wind.
• BAC and CASA emphasize that other programs do not substitute for BioMAT, which specifically supports small-scale bioenergy projects.

Process and Record Adequacy

• BAC and CASA assert that the record in the current rulemaking is insufficient to justify ending BioMAT, noting a lack of public comment opportunities and workshops on costs and benefits.

Requests for Stay or Modification

• BAC and CASA request a stay of the PD, arguing that it violates existing laws and would lead to significant harm, and express support for alternative changes proposed by other parties.