Simplifying Policy Management

and the next Preferred System Plan, with parties differing over planning assumptions, resource technologies, procurement mechanisms, and the pace of decarbonization. This is a sampling of parties' positions.

Load forecasts, affordability, and planning assumptions

• ALLIANCE FOR RETAIL ENERGY MARKETS Recommends replacing the 2024 IEPR forecast with the 2025 IEPR forecast, which it considers more current and less likely to overstate load growth. It also favors scenario-based or percentage clean-energy targets that scale with load.
• Golden State Clean Energy, LLC Supports retaining the 2024 IEPR forecast to preserve continuity with the agreed forecast framework and long-term transmission planning. It argues that changing forecasts would not resolve underlying uncertainty.
• San Diego Gas & Electric Company Supports using the 2025 IEPR forecast where the Single Forecast Set Agreement does not require the 2024 forecast, along with updated CAISO transmission-capability estimates. This continues its earlier emphasis on forecast accuracy, feasibility screens, and affordability.
• Western Power Trading Forum Requests reconciliation of transmission-capability data, resource baselines, minimum-build assumptions, and the representation of the 6,000 MW NQC order in the reliability reserve margin. It also asks for transparent reliability validation and correction of an inconsistency in peaker ELCC values.
• Shell Energy North America (U.S.), LP Supports updating commercial and transmission assumptions but requests explicit information on transmission pathways, in-service dates, deliverability status, resource-adequacy value, and import-allocation rights for major out-of-state resource blocks.
• Middle River Power LLC Supports revised assumptions that recognize development constraints and higher interim GHG targets, while recommending additional review of solar build rates that remain above historical levels.
• Pattern Energy Group, LP Urges the Commission to account for project-specific federal permitting status, existing and planned transmission, complementary use of existing transmission capacity, and additional transmission-service rights rather than applying broad reductions to out-of-state wind availability.

GHG targets, portfolio pace, and the recommended Base Case

• San Diego Gas & Electric Company Supports the 38 MMT by 2030, 30 MMT by 2035, and 8 MMT by 2045 trajectory, arguing that more stringent interim targets would produce infeasible build rates, higher costs, and reliance on most queued solar projects being built.
• CALPINE LLC Supports the Staff-recommended Base Case and the 38/30/8 MMT trajectory as a more achievable near-term path that limits the risk of premature resource and transmission investment while maintaining long-term emissions progress.
• Middle River Power LLC Supports the 38 MMT and 30 MMT interim targets and opposes reverting to lower targets, citing affordability, reliability, legal compliance, and resource-development constraints.
• Shell Energy North America (U.S.), LP Supports 38 MMT in 2030 and 30 MMT in 2035, while retaining 8 MMT in 2045 for analysis and evaluating at least one alternative endpoint. It recommends testing slower out-of-state wind growth and slower enhanced-geothermal commercialization.
• Western Power Trading Forum Supports a modified 38/30 MMT Base Case subject to input reconciliation and reliability validation, but recommends comparing it with the more stringent trajectory using emissions, costs, build rates, deliverability, and post-2035 construction requirements.
• Golden State Clean Energy, LLC Opposes softening the GHG standard and argues that proactive transmission planning, rather than lower targets, should address resource-development constraints. It supports the limited-out-of-state-resource sensitivity.
• ALLIANCE FOR RETAIL ENERGY MARKETS Prefers the 2025 IEPR-based 38 MMT case if the Commission limits its choice to the modeled cases, and favors percentage clean-energy targets over mass-based constraints. It does not support the recommended limited-out-of-state sensitivity.

Resource availability, out-of-state resources, and transmission deliverability

• Pattern Energy Group, LP Recommends making incremental out-of-state wind available earlier than assumed, based on permitting developments, projects such as Silver Rock and Bolo, additional transmission-service requests, and available capacity on existing lines. It also asks the Commission to align RESOLVE and CAISO deliverability assumptions.
• Ormat Technologies, Inc Generally supports the Base Case's out-of-state geothermal quantities but requests clarification about RESOLVE's selection of Beatty and Eldorado rather than the lower-cost Control 115 kV connection. It recommends prioritizing Control and Hilltop upgrades and improving the Maximum Import Capability expansion and retention processes.
• Zanskar Geothermal & Minerals, Inc. Recommends expanding northern geothermal availability, studying a direct westward tie from Northern Nevada, evaluating whether Humboldt transmission could serve northern geothermal, and planning deliverability alongside development rather than waiting for fully developed projects.
• Golden State Clean Energy, LLC Supports reducing out-of-state wind over the study horizon but recommends limits on generic interstate transmission additions and greater recognition of in-state backbone upgrades that can support multiple resources and reduce congestion.
• Shell Energy North America (U.S.), LP Supports the general portfolio direction but warns that the projected increase in out-of-state wind depends on uncertain interregional transmission, deliverability arrangements, and import rights. It recommends distinguishing resources supported by identified transmission from those dependent on generic future transmission.
• ALLIANCE FOR RETAIL ENERGY MARKETS Supports allowing in-state and out-of-state resources to compete with accurate interconnection costs and recommends realistic geothermal deliverability assumptions, central procurement, or adequate time for LSEs to meet procurement requirements.
• Ormat Technologies, Inc Supports the in-state-resource sensitivity as a comparison of decarbonization costs, transmission needs, and feasibility with and without out-of-state resources.

Geothermal development and northern transmission

• Ormat Technologies, Inc Reports that Control-area constraints caused approximately 140,000 MWh of geothermal curtailment in 2025 and recommends transmission work at Control 115 kV and Hilltop 345 kV to support geothermal delivery.
• Zanskar Geothermal & Minerals, Inc. Argues that the portfolio concentrates imported geothermal in southern California and may require costly south-to-north transfers. It proposes a northern corridor sensitivity comparing northern geothermal supply and transmission with moving southern supply north.
• Pattern Energy Group, LP Supports expanding access to diverse high-capacity-factor resources through regional transmission and recommends reserving CAISO deliverability for location-constrained resources while avoiding assumptions that new resources require entirely new transmission.

Distributed energy resources and community solar

• Coalition for Community Solar Access Recommends establishing a CEC-CAISO-Commission load-modifier pathway for front-of-the-meter distributed energy resources, updating RESOLVE to capture their value, studying an FTM DER sensitivity, allowing distribution-connected resources to participate in West LA Basin procurement, and including LSE-planned FTM DERs in the 2027 PSP.
• Coalition for Community Solar Access Proposes a 5 MWac distribution-connected solar-plus-storage candidate resource in local reliability areas, with a separate build limit from utility-scale solar, transmission adders for remote resources, distribution and transmission credits for well-sited resources, and cost inputs reflecting 1-5 MW systems.
• Coalition for Community Solar Access Cites distributed-resource potential to supplement declining behind-the-meter solar growth, reduce CAISO queue and transmission bottlenecks, and provide local reliability and transmission-deferral benefits.
• Small Business Utility Advocates Last week's comments support screening demand-side alternatives before supply-side procurement and fuller valuation of efficiency, demand response, distributed resources, behind-the-meter storage, and flexible load.
• The Protect Our Communities Foundation Last week's comments request sensitivity analysis that optimizes behind-the-meter solar-plus-storage, assigns it resource-adequacy value, and accounts for Rule 21 changes that could reduce transmission needs and local costs.

Carbon capture, gas retention, hybrid resources, and Diablo Canyon

• CALPINE LLC Supports retaining natural-gas capacity needed for reliability, completing carbon-capture-and-sequestration candidate-resource modeling, and evaluating continued Diablo Canyon operation beyond 2030 as a sensitivity.
• Middle River Power LLC Recommends modeling CCS as a candidate resource now, making it expressly eligible in procurement programs, and recognizing hybrid gas-and-storage configurations, including gas peakers with one-hour batteries and combined-cycle facilities with eight-hour batteries.
• Western Power Trading Forum Requests analysis of retention dependencies and resource unavailability, an all-resource forward procurement or retention mechanism, and candidate-resource treatment for CCS, repowers, efficiency improvements, hybrid configurations, and storage additions.
• CALPINE LLC Supports Staff's updated gas-retention assumptions, including protection for units with CCS retrofit potential, and recommends technology-neutral evaluation of CCS in future IRP cycles.
• Pacific Gas and Electric Company Last week's comments support extending Diablo Canyon operations through 2045 as a least-regrets option that could reduce new procurement, costs, and emissions.
• Sierra Club and California Environmental Justice Alliance Last week's comments oppose treating CCS as a zero-carbon resource, citing fossil-fuel dependence, uncertain capture performance, energy penalties, and cost concerns.

Western Los Angeles Basin geographically targeted procurement

• Shell Energy North America (U.S.), LP Opposes issuing a procurement order on the current record and requests a transparent comparison of wires and non-wires alternatives, including the fourth Mesa transformer, HVDC, and storage. It also seeks validation of the need, quantity, timing, procurement responsibility, cost allocation, and market-power protections.
• San Diego Gas & Electric Company Opposes geographically targeted procurement to replace the Serrano-Del Amo-Mesa project absent a statewide cost-recovery mechanism. It argues that storage lacks a CAISO tariff pathway as a transmission asset and should instead be evaluated through regular CAISO planning.
• Western Power Trading Forum Supports a competitive resource alternative only after CAISO verifies the need and defines the required local service, including power, usable energy, location, discharge profile, charging capability, and contingency conditions. It identifies inconsistencies between the stated 4,400 MW or 12,428 MWh need, the proposed 2,900 MW or 2,336 MWh procurement, and another cited 2,366 MWh figure.
• Coalition for Community Solar Access Supports geographically targeted procurement downstream of the Mesa constraint, with eligibility based on electrical location rather than interconnection voltage or queue status. It recommends allowing WDAT and Rule 21 projects, competitive solicitations, and a joint CAISO-Commission framework.
• ALLIANCE FOR RETAIL ENERGY MARKETS Opposes adding geographically targeted procurement without adjusting the existing 6,000 MW order to prevent over-procurement. It supports SCE as the procurement entity, cost allocation through the CAM subject to safeguards, and clarification of capacity, duration, NQC, nameplate, UCAP, and foldback treatment.
• CALPINE LLC Recommends that any procurement be narrowly tailored to the identified transmission need, avoid duplication, remain technology-neutral, and consider whether retaining or modifying existing resources could address the constraint more efficiently.
• WPTF Recommends SCE administer a single competitively neutral solicitation for any verified residual need, with independent evaluation, bid and market-power protections, a transmission alternative retained as a benchmark, and cost responsibility tied to demonstrated benefits.
• Pattern Energy Group, LP Requests that any future non-wires alternative avoid disrupting CAISO-approved transmission projects where the CAISO has already identified a need, because changing those decisions could undermine investment certainty.

Procurement governance, cost allocation, and transparency

• Shell Energy North America (U.S.), LP Recommends defining the service and beneficiaries before assigning procurement responsibility or using the CAM. Any mechanism should allocate net costs according to benefits, credit market revenues, prevent duplicative recovery, and include transparent true-ups.
• Western Power Trading Forum Supports a joint Commission-CAISO framework addressing need identification, alternatives analysis, procurement authority, operating obligations, solicitation rules, development milestones, cost allocation, market protections, and continuing-need review.
• ALLIANCE FOR RETAIL ENERGY MARKETS Supports competitive procurement and market-power safeguards, requires Commission approval for utility-owned generation, and opposes perpetual cost recovery through PCIA or CAM. It favors stakeholder review of any change to load-ratio-share allocation.
• American Clean Power–California Last week's comments recommend faster coordination among transmission planning, interconnection, permitting, and procurement, along with improved busbar mapping, standardized machine-readable filings, consistent redactions, and accessible planning-tool data.
• Western Power Trading Forum Requests publication of draft busbar-mapping results, comparisons with the prior cycle, a focused workshop, written corrections, and revised mapping before transmittal to CAISO.