Simplifying Policy Management

O in opposing ED’s proposal to require zero-dollar bids for DAME products. CAISO’s DAME products (RCU, RCD, and IR) are procured in the day-ahead market and voluntary; generators will bid flexible capacity to earn market prices, negating forced zero-dollar bids. IEP warns that zero-dollar bid requirements risk letting other balancing areas in EDAM/neighboring areas access California-based generation at no cost and urges the Commission to adopt CAISO’s proposal rejecting zero-dollar bid mandates.

Revisions to ED Staff UCAP methodology

IEP urges removing NOW outage categories deemed outside generator control—“ambient not due to temperature,” “ambient fuel insufficiency,” “metering/telemetry,” “remote terminal unit RTU/RIG,” and “transitional limitation”—because they penalize generators for third-party/system issues. IEP supports REV’s request (aligned with CESA) to clarify “forced outage” for energy storage to avoid inappropriate capacity discounts. IEP also backs MRP and Calpine proposals to treat geothermal and co-located/hybrid natural gas + storage resources with facility-level UCAP and unit-level flexibility to reflect operational and reliability realities.

Conclusion

IEP supports removing market restrictions and refining UCAP rules as described, and requests the Commission consider these reply comments in ongoing RA program reform deliberations.

non-profit-governed smart home and energy platform (source on GitHub) that provides device-level intelligence, protocol translation, and policy execution. Universal Devices holds OpenADR 2.0a/2.0b/3.0 certification, has active projects with PG&E and SCE, and participated in CEC grant programs including CalFUSE. NuCore accepts OpenADR and IEEE 2030.5 and translates to Matter, Z-Wave, Zigbee, Wi‑Fi, Modbus, SunSpec, and proprietary APIs.

Scope, objectives, and constraints

Universal Devices urges the Commission to explicitly include residential and secondary BTM in DER orchestration. Primary objectives for IOU DSO-led orchestration: enable verifiable residential and small commercial BTM demand flexibility; reduce grid constraint costs via device-level operating envelopes; and establish a protocol-neutral BTM execution layer. Targeted constraints include thermal overloads at secondary transformers/service laterals, voltage deviations from residential solar export, and coincident EV charging peaks.

Guiding principles and interoperability

Supports proposed principles and requests adding “Local resilience and edge operability” and extending technology-neutral, performance-based to the communications protocol layer. IOU applications must present interoperability strategies, maintain protocol neutrality (OpenADR, IEEE 2030.5, others), distinguish DSO-to-aggregator and aggregator-to-device interfaces, and address the BTM platform layer explicitly.

Costs, aggregators, and ownership

Benefit-cost analyses must include aggregator transaction costs, customer-premises hardware, software fees, aggregator margins, DERMS/ADMS integration, and edge resilience costs. Aggregators should be optional competitive providers; direct DSO-to-BTM participation must be enabled. The BTM execution layer should be customer-owned to preserve data rights and edge resilience and avoid IOU stranded cost risk.

Requests and next steps

Requests to the Commission: explicitly include residential/secondary BTM; add local resilience principle; require IOU applications to address BTM execution layer and protocol neutrality; publish open DSO aggregator interfaces on a timeline; and include aggregator costs in benefit-cost analyses. Universal Devices offers NuCore pilots and will present at the May 21, 2026 workshop.

third-party findings with SED and CCSF. PG&E requests denial of CCSF’s Motion.

Primary grounds for denial

PG&E advances three critical reasons: (1) SED is already reviewing the December 2025 outages under the Commission’s enforcement framework (Res. M-4846 and the 2020 Enforcement Policy), has visited the Mission Substation, issued data requests, and obtained substantial information; (2) R.24-05-023 was opened (OIR issued June 6, 2024) as a systemwide Rulemaking to update distribution safety, reliability, and resiliency, with the Assigned Commissioner’s Scoping Memo (Oct. 16, 2024) directing Track 1 standardization of reliability reporting—not adjudication of individual events; and (3) converting the Rulemaking to an event-specific proceeding would duplicate SED’s review, risk inconsistent enforcement, require recategorization and new procedures, delay Track 1 outputs, and risk violating timing expectations (Pub. Util. Code, Section 1701.5).

Conclusion and requested disposition

PG&E urges the Commission to deny CCSF’s Motion and rely on SED’s ongoing review and PG&E’s third-party investigation to inform any enforcement or remedial actions, preserving the Rulemaking’s systemwide Track 1 objectives.

particularly for medium- and heavy-duty transportation electrification.

Energization timeline targets and performance benchmarks

• CTIA said the Commission’s existing energization timeline targets, adopted in 2024, allow utilities too much time and have not led to noticeable improvements in utility energization performance. CTIA renewed its request for size-differentiated targets focused on utility-controlled steps, with a 2 MW threshold separating small and large projects.
• CTIA proposed 60 business days for application and design approval for small projects and 90 business days for large projects, plus 30 business days for construction inspection and site energization for both, resulting in total targets of 90 business days for small projects and 120 business days for large projects.
• PACT supported energization timelines that account for the maturity of utility systems and data capabilities, arguing that compliance expectations should be phased and aligned with utilities’ ability to measure phase-level performance accurately.

Application review and rejection/re-filing practices

• CTIA recommended shortening the utility application review period to 30 business days and making that period cumulative across initial filings and any re-filed applications returned for correction, so utilities cannot restart the clock through late rejections.
• CTIA said this approach would reduce the ability to game metrics and would better reflect actual energization timelines.

Remedial actions, enforcement, and corrective action plans

• PACT urged the Commission to use a structured, graduated compliance framework that begins with supportive remedial actions, then moves to required corrective action plans and scoped penalties only as utility data quality and performance maturity improve.
• PACT said low-maturity utilities should receive capacity-building remedies, such as consultant support and process improvements; medium-maturity utilities should face specific staffing, timeline, and best-practice requirements; and high-maturity utilities could be subject to stronger financial penalties for sustained underperformance or failure to implement corrective measures.
• PACT recommended standardized corrective action plans with measurable milestones, responsible parties, and attention to utility, customer, and third-party dependencies, along with ongoing monitoring through existing reporting channels.

Dispute resolution and other process improvements

• CTIA asked the Commission to create an expedited dispute-resolution process for electric service connection issues, citing models used in other regulatory contexts as examples of faster, tailored relief.
• PACT urged the creation of a joint Energization Working Group for the large investor-owned utilities to standardize processes, improve data collection, identify best practices, and develop customer-facing tools.
• PACT also recommended that utilities use Flexible Service Connection programs to generate lessons learned, and that they provide more actionable pre-application grid information to help customers plan projects and coordinate upgrades.

Priority for transportation electrification

• PACT said the rulemaking should continue to prioritize transportation electrification, especially medium- and heavy-duty charging deployment, to support state climate and electrification goals.