Simplifying Policy Management

reporting framework.

Adequacy and Scope of the Proposed Template

• Marin Clean Energy (MCE) states that the Joint IOUs’ proposal is a minimal outline that may not include all necessary data or provide useful analysis, making it difficult for stakeholders to extract relevant insights from the raw data provided.
• Cal Advocates criticizes the proposed report for misclassifying Public Safety Power Shutoff (PSPS) events as unplanned outages and conflating customer and meter data, which could obscure utility decision-making and lead to inaccuracies, especially for vulnerable groups.

Definitions, Metrics, and Data Standards

• MCE notes that while the template uses established definitions and industry standards, there is a need for greater clarity, particularly regarding the definition of "Essential Customers" and the thresholds for reliability metrics, which may not accurately reflect customer experiences.
• Cal Advocates recommends distinct categorization of PSPS events and accurate tracking of outage timing, duration, and customer status to ensure the report aligns with existing data sources and provides a consistent view of utility performance.

Frequency and Timeliness of Reporting

• MCE recommends that reporting frequency should be increased from annual to quarterly or monthly, especially given concerns about deteriorating electric system reliability, to provide more timely insights.

Transparency, Confidentiality, and Data Use

• City and County of San Francisco (San Francisco) emphasizes the importance of transparency in IOU data submissions and urges that any confidential data be clearly identified, with non-disclosure agreements used as needed to balance transparency and privacy.
• San Francisco calls for clarity on how the Commission will use the reported information, stressing that reports should inform decisions and drive actions related to safety, reliability, and resiliency, rather than serve as a formality.
• Cal Advocates urges that the notification process for PSPS events be clearly defined and that detailed records be maintained to support analysis related to environmental factors.

Outage Notification and Communication

• San Francisco expresses concern that the proposed aggregated format for outage notifications may hinder effective evaluation of IOU communication strategies. The City advocates for disaggregated data reflecting geographic and demographic factors to better assess notification effectiveness.
• San Francisco highlights that current notification methods often provide inaccurate information about outage durations, which is critical for essential services, and recommends that the Commission require metrics to measure the accuracy of restoration time notifications.

Data for Vulnerable and Impacted Communities

• MCE emphasizes the need for clear, un-averaged data presentation focused on specific circuits and affected communities, particularly to assess impacts on vulnerable populations.
• San Francisco suggests that reports should include historical data to allow for trend analysis over time, which would help in understanding the impact of outages on different communities.
• Cal Advocates notes the risk of inaccuracies for vulnerable groups if customer and meter data are conflated and recommends proper tracking of customer status, including those with Access and Functional Needs (AFN) or Medical Baseline (MBL) status.

• Extended Completion Date: January 25, 2028

Order Details

• Order Issued On: January 15, 2026
• Location: San Francisco, California
• Effectiveness: Immediate

This extension ensures sufficient time for the proceeding’s completion.

Decision D.24-04-009 from April 18, 2024.

Guidelines for Non-IOUs

Under the new guidelines, non-IOUs, such as Community Choice Aggregators (CCAs) and Direct Access (DA) Providers, must submit detailed implementation plans. These plans must demonstrate their ability to provide universal, equitable service to all customer classes, in accordance with SB 520’s prohibition on class-specific service.

• Existing Commission-regulated services
• Potential conflicts of interest
• Mechanisms to prevent cost-shifting between POLR and current customers

The CPUC will assess each application individually, focusing on the applicant’s technical, financial, and legal qualifications, as well as insurance and financial safeguards.

Application Process

The order requires non-IOUs to include major IOUs as respondents in their applications; however, IOUs cannot block applications. Joint applications are encouraged, and the Commission will resolve threshold issues such as regulatory scope and cost recovery.

Non-IOUs must file a Petition for Rulemaking at least 12 months prior to applying for POLR status, allowing the CPUC to establish requirements for similar entities.

Current Status

As of now, no non-IOU has applied to serve as POLR for all customers in a region, although some have expressed interest under specific conditions. The proceeding is now closed, and the CPUC's focus has shifted to implementing these guidelines for future applicants, ensuring robust evaluation and tailored criteria for each case.

technology providers—submitted comments on the PD. The following is a sampling of parties' positions, organized by key topics addressed in the comments.

Scope and Applicability of the Standard Offer FSC

• EDF recommends extending FSC requirements to San Diego Gas & Electric (SDG&E), in addition to Pacific Gas & Electric (PG&E) and Southern California Edison (SCE).
• Clean Coalition urges the Commission to require all investor-owned utilities (IOUs), including SDG&E, to develop a standard offer FSC, arguing that the need for such agreements is statewide.
• TURN recommends that SDG&E develop an FSC Standard Offer alongside PG&E and SCE.

Definition of Upstream Capacity and Eligibility

• Advanced Energy United argues that the PD’s definition of "Upstream Capacity" is too narrow, as it limits eligibility to polyphase primary distribution networks and excludes many projects on single-phase circuits. United recommends revising the definition to include both polyphase and single-phase systems.
• Enphase Energy calls for a revision to the definition of "Upstream Capacity" to include single-phase secondary distribution networks, noting that the current definition could exclude many residential customers from FSC eligibility.

Customer Access, Data Transparency, and Application Process

• CalCCA recommends that IOUs be required to make information about available shared capacity easily accessible to applicants and to upgrade online application portals to facilitate communication about capacity sharing opportunities. CalCCA also urges the integration of accurate Integration Capacity Analysis (ICA) data into the energization process.
• CALSTART recommends that utilities clarify how customers can access Limited Load Profiles (LLPs) and formalize a pre-application LLP access process to assist with planning.
• SDG&E asserts that its current customer load intake process is effective and opposes adding a formal preliminary capacity evaluation step, which it views as unnecessary and burdensome.

Cost, Ratepayer Protections, and Reporting

• TURN urges clarification that the Standard Offer should not impose extra costs on non-participating ratepayers and recommends annual cost-efficiency reports from IOUs.
• Cal Advocates calls for greater clarity and transparency, including specifying criteria for demonstrating customer and ratepayer benefits, and adding tracking fields to evaluate LLP implementation and capacity utilization.
• SDG&E emphasizes that expanded data tracking should consider affordability and customer benefits, and proposes removing certain data fields it views as duplicative or of limited value.

Load Control, Compliance, and Safety

• SCE urges modifications to the PD’s “trust-and-verify” approach for load control devices, advocating for telemetry options and a faster response time for power control systems (reducing from 30 seconds to 2 seconds).
• SDG&E expresses concerns about the "trust-and-verify" compliance model, stating it could limit utilities’ ability to ensure adherence to load limitations and system reliability. SDG&E advocates for utility discretion in verifying compliance with LLPs.
• EDF recommends clarifying “safe harbor” language for UL 3141 Power Control Systems and requiring utilities to offer single-value FSCs to simplify participation.

Inclusion of Distributed Energy Resources (DERs) and Storage

• Enphase Energy requests explicit inclusion of solar paired with storage and standalone storage in engineering evaluations for FSCs, and supports directing utilities to consider both load and generation outputs in their evaluations.

Implementation Timelines and Process

• SCE calls for extended compliance timelines, arguing that the PD’s deadlines are overly aggressive and could burden utilities and customers. SCE also opposes the immediate rollout of a non-tariffed interim FSC program, preferring to continue its existing Load Control Management Systems (LCMS) process until a new tariff is approved.
• CALSTART urges the Commission to set strict timelines for utilities’ administrative reviews of service applications (5-day average, 10-day maximum) to reduce delays, and recommends that the PD take effect for SDG&E and PacifiCorp when upstream capacity constraints arise.

Data Collection and Performance Tracking

• Clean Coalition recommends including tracking fields to evaluate LLP implementation and capacity utilization.
• Cal Advocates calls for biannual reporting on the performance of the Standard Offer, including cost and performance tracking, to ensure effective use of existing capacity.
• SCE recommends biannual reporting on Standard Offer data and assessment of learnings from the Load Control Management Study pilot.

Design of FSC Offerings and Load Profiles

• Clean Coalition recommends that the standard FSC include at least three daily signals, or a third daily value when it aligns with grid conditions or decarbonization goals, to better support state decarbonization objectives.
• EDF urges utilities to offer single-value FSCs to simplify participation and recommends tracking customer energization timelines and collecting comprehensive data on load limits.