Simplifying Policy Management

process changes) should be deferred until the Commission adopts clear compliance metrics and reporting standards in Phase 1.

Penalties and Compliance Metrics

Opposes financial penalties in Phase 1. Penalties require finalized, measurable compliance requirements and reporting that distinguish utility-controlled delays from external factors, consistent with R.24-01-018.

Screen Q and Screen R

Opposes raising Screen Q from 1 MVA to 5 MVA or categorical exemptions. It proposes requiring both DFAX > 5% and >1% material flow impact on a constrained facility to fail Screen Q. Opposes eliminating mandatory withdrawal after failing Screen Q. Supports retaining Screen R now and deferring major changes.

Interconnection Timelines and Processes

D.20-09-035 timelines are generally reasonable but must account for project mix and external delays. Recommends excluding FERC-jurisdictional WDT requests from expanded reporting for now, creating a transmission-level pathway for Rule 21 transmission interconnections, and combining design and construction into a single 120-day period.

Fees and Non-Export Proposals

Supports reviewing Rule 21 fees to reflect actual costs and cost-causation but rejects $0 notification fees pending data; it warns non-export notification-only pathways are premature given safety, equipment, and aggregation risks (citing lack of uptake under D.21-06-002).

Conclusion

Adopt measured Phase 1 reforms: finalize compliance metrics/reporting, implement targeted Screen Q refinement, retain Screen R and withdrawal, refine timelines, review fees with data, and require robust safeguards before any notification-only process.

incorporates both last week’s and this week’s comments and reflects a sampling of parties’ positions.

Proceeding structure, sequencing, and scope

• SDG&E says the Commission should prioritize near-term residential Base Services Charge refinements, use guidance-based approaches for large-load and general rate design issues, and exclude topics already being addressed in other proceedings or recently decided.
• Enchanted Rock supports a dedicated large-load track focused on rate design, cost allocation, planning impacts, and customer-provided resources, with enough flexibility to build an adequate technical record.
• Bloom Energy supports customer-sited distributed energy resources as part of the large-load discussion and urges rate structures that recognize on-site power’s reliability and resilience value.
• CEJA supports two concurrent tracks, one for data center issues and one for residential rate design, to better address the different affordability and equity concerns involved.
• Farm Bureau supports phasing and narrower scopes, and endorses SDG&E’s three-track approach for Base Service Charge, large load, and general rate design issues.
• CLECA says the proceeding should be split into focused tracks, including an expedited AB 2109 implementation track, while deferring broader marginal-cost and GRC Phase 2 issues.
• Last week’s comments from multiple parties also generally favored a phased approach, with differing views on which issues should move first and which should be deferred.

Residential Base Services Charge and low-income protections

• SDG&E urges the Commission to preserve and expand the residential Base Services Charge, including removing the cap on BSC tiers and allowing additional fixed cost categories to improve cost recovery and rate stability.
• SDG&E says the Commission should not wait for the one-year evaluation report before making BSC changes and argues that the current CARE safeguard and reported customer outcomes support the existing framework.
• SDG&E cautions against further income graduation of the BSC without more accurate income verification and says the existing three-tier structure satisfies AB 205’s minimum threshold requirement.
• CEJA opposes immediate expansion of the BSC to include additional costs before the required evaluation period is complete and says any BSC review should protect low- and moderate-income customers.
• CEJA also supports exploring middle-income tiers and broader affordability protections so lower bills for low-income customers are maintained.
• Farm Bureau does not take a position on BSC adjustments in this filing, but argues generally against rate changes that would shift costs onto bundled customers without alternatives.
• Last week, multiple parties supported more caution, stronger income verification, or a fuller implementation record before revisiting the BSC, while SCE and some others supported further work in a separate track.

Large loads, data centers, and SB 57 implementation

• Enchanted Rock says the Commission should create a dedicated procedural track for large loads, including data centers, and use performance-based, technology-neutral principles that distinguish passive load growth from responsive load growth.
• Enchanted Rock also recommends that the Commission explicitly include co-located generation, storage, export capability, and customer-provided resources in the large-load track because these affect system value, infrastructure needs, and net-load contribution.
• Bloom Energy supports customer-sited dispatchable resources as a near-term solution for large loads and says rate design should encourage bring-your-own-capacity models, grid services, and resilience.
• Bloom Energy argues that on-site power can reduce transmission and distribution investment needs and help avoid stranded assets while serving large customers more quickly than traditional grid buildout.
• CEJA supports a distinct data center rate class and says data center procurement should follow California clean energy requirements and pay for incremental generation and T&D upgrades.
• CEJA opposes reintroducing fossil-fueled resources in the name of large-load service and says data center tariff design should reflect affordability, pollution, and reliability risks.
• Farm Bureau urges careful scrutiny of data center impacts, including water use and location-specific resource concerns, before any incentive structure is adopted.
• CLECA says any data center tariff should be narrowly tailored to the cost drivers and reliability risks of computational loads, not applied broadly to traditional industrial customers.
• Last week, multiple parties supported some form of focused large-load treatment, though they differed on class design, timing, and the treatment of onsite resources.

Industrial electrification, AB 2109, and nonbypassable charges

• CLECA says AB 2109 implementation should move on an expedited parallel track because the statute creates a narrow exemption from nonbypassable and departing load charges and has already been delayed too long.
• CLECA argues that existing industrial rates and nonbypassable charges can discourage electrification and contribute to emissions leakage and EITE retention risks, and it supports rate reforms that improve industrial decarbonization economics.
• Farm Bureau says the Commission should scrutinize burdensome nonbypassable charges more broadly and consider whether they should be reduced or eliminated to protect affordability.
• SDG&E says AB 2109 and dynamic pricing topics should be handled in other proceedings or utility-specific settings, not relitigated broadly in this OIR.
• Last week, multiple parties supported reforms that better support industrial electrification, while PG&E and SCE generally urged a narrower treatment of AB 2109 and related issues.

Marginal costs, TOU design, dynamic rates, and baseline allowances

• SDG&E says marginal cost studies and TOU period changes belong in GRC Phase 2 proceedings, where IOU-specific load shapes and costs are normally addressed.
• SDG&E also says dynamic pricing is already being addressed in other dockets and should not be relitigated here.
• Farm Bureau likewise opposes revising TOU periods now and supports handling dynamic rates in separate IOU proceedings or GRC Phase 2 cases.
• CLECA says marginal-cost and cost-of-service issues should be deferred to later proceedings, with this rulemaking focusing instead on prospective guidance and implementation priorities.
• CEJA supports reviewing TOU, baseline, and fixed-charge interactions as part of a broader residential equity and electrification review, rather than isolating one element from the others.
• Last week, multiple parties supported more active TOU and rate-form reform, while PG&E, SCE, and TURN generally urged more caution or later-stage treatment.

Customer-sited resources, exports, and technology-specific rates

• Enchanted Rock wants the Commission to recognize customer-provided resources, export capability, and dispatchable co-located generation as part of large-load rate design, with performance-based credits tied to measurable grid value.
• Bloom Energy similarly argues that distributed, on-site resources should be valued for reliability, resilience, avoided infrastructure, and flexibility, not treated only as emergency backup.
• CEJA opposes fossil-fueled distributed resources and says any distributed energy discussion should remain aligned with California’s clean energy procurement framework.
• CLECA says rate design for large industrial customers should remain voluntary and compatible with demand response, while avoiding overbroad technology labels that do not reflect actual cost causation.
• Last week, multiple parties supported export compensation and customer-sited flexibility, while SCE and PG&E generally preferred separate venues for those issues.

Topics parties want deferred or handled elsewhere

• SDG&E says technology-specific rate design, DER pilots, software standardization requirements, baseline reconsideration, and several other issues are either out of scope or better addressed in separate proceedings.
• Enchanted Rock says the large-load track should avoid duplicating IRP, RA, RPS, permitting, or siting processes.
• Bloom Energy says the Commission should focus on rate design and market structure rather than broader siting or technology-permissibility questions.
• Farm Bureau says the proceeding risks becoming unmanageable if it tries to resolve too many cross-cutting issues at once.
• CLECA says GRC Phase 2 and broader marginal-cost issues should be addressed in later proceedings, not in parallel with the current OIR’s more targeted tracks.
• Last week, multiple parties urged the Commission to keep topics like export compensation, submetering, emissions leakage, and broader marginal-cost questions in other venues or later phases.

questions; Attachment B is the September 2025 Biannual Energization Report Review (Guidehouse); Attachment C is a data dictionary. The Ruling requires IOU responses only to questions labeled “Question for IOUs,” but authorizes all parties, including the IOUs, to answer any of the questions.

Deadlines and Comment Procedure

IOU responses and any party responses are due three weeks after issuance of the Ruling (i.e., three weeks after May 28, 2026). Replies to those responses are due two weeks after the initial responses are filed.

Questions and Guidance for Parties

Parties should address the specific questions in Attachment A concerning Guidehouse’s September 2025 Report and the data definitions in Attachment C. The Ruling instructs IOUs to answer questions labeled for them while permitting all parties to submit answers to any questions, subject to the above response and reply deadlines.

Last Week's New Comments +9

Overview

This is a sampling of parties’ positions in CPUC Rulemaking 24-01-018, focused on reply comments filed around the May 28, 2026 deadline. Across the filings, parties generally address how to improve energization timelines, what level of reporting and staffing detail the Commission should require, how enforcement and remediation should work, and whether the Commission should expand or standardize reporting, audit, and planning tools.

Energization timelines and customer-facing delays

• Southern California Tribal Chairmen’s Association (SCTCA) supports faster, enforceable energization timelines and backs a 90-day maximum energization goal as a minimum standard, including for Tribal and local government projects.
• California Broadband & Video Association (CalBroadband) says large utility delays continue to impede broadband deployment and recommends a sector-specific 90-day energization timeline for broadband projects, measured from a complete application through final energization.
• CTIA supports shorter energization timelines generally and says CalBroadband’s 90-day proposal is consistent with shorter timelines CTIA supported for small projects, while cautioning against industry-specific targets.
• CALSTART recommends early access to limited load profile information or an equivalent tool before full application submission, plus a 90-day power reservation mechanism to help projects proceed without losing queue position.

Enforcement, remedial actions, and penalties

• Southern California Tribal Chairmen’s Association (SCTCA) supports enforceable timelines and automatic accountability mechanisms, and rejects the idea that customers should have to police utility performance. It also questions penalty approaches that rely on an “average customer” harm model.
• TURN supports using average energization timelines and reporting failures as triggers for remedial action, and argues remedial actions should be shareholder-funded rather than ratepayer-funded.
• EDF supports tailored remedial actions when performance problems are repeated or significant, opposes delaying enforcement until utilities finish multi-year IT upgrades, and argues shareholder-funded remedial action and penalties are appropriate for egregious noncompliance.
• SCE favors a sequenced, data-driven compliance approach with progressive enforcement and says penalties or prescriptive remedies should not be imposed before the utilities’ systems and data mature.
• CalSSA reports that the Commission rejected several utility proposals in this area, including efforts to ignore average timeline measures, lengthen timeline requirements, and argue against penalties.

Reporting requirements, staffing analyses, and tracking transparency

• CUE urges the Commission to require detailed Section 935 staffing reports that include historical and current staffing, contractor use, forecasts, apprenticeship pipelines, attrition, and assumptions, arguing the current filings are incomplete.
• SCE opposes expanding Section 935 workforce reporting beyond the statute’s current scope and says many of the requested historical and forecasted details would be burdensome and duplicative.
• TURN supports clearer, standardized reporting fields, a central dashboard or webpage, and additional data elements that better distinguish delay causes and future load implications.
• CalBroadband calls for start-to-end reporting in the biannual energization reports, including original request date, rejections or resubmissions, and final energization date, so reported compliance better reflects customer experience.
• EDF argues annual workforce reporting should show how projected staffing aligns with energization targets and future load growth, while also supporting baseline audit requirements for smaller utility territories.
• SCTCA supports improved tracking and transparency, including automated ticketing and standardized portals, so Tribal and local government customers are not forced to monitor utility progress on their own.

Audits, auditor role, and cost recovery

• CUE argues the Commission should require more specific staffing analyses as part of Section 935 implementation, while also relying on the SB 254 auditor process to assess whether utilities have adequate qualified staffing.
• TURN wants higher standards for auditor independence and completeness, plus a clearer pathway for auditor findings to inform enforcement and planning decisions.
• SCE opposes mandating a single joint auditor across utilities and argues SB 254 audit costs should be recoverable in rates, while SB 410-related audit costs are a different issue.
• EDF supports extending SB 254 audit requirements to small and medium-sized utilities to ensure baseline visibility into energization performance.
• CalBroadband recommends auditors play an active role in tracking, escalating, and publicly reporting customer-identified energization delays, with corrective action recommended where delay patterns recur.

Working groups, planning, and system-wide coordination

• SCTCA supports establishing a formal working group with Tribal and local government representation to develop practical energization processes, timelines, and tracking tools.
• EDF supports a joint industry-utility Energization Working Group to help align energization practices with California’s 2045 carbon neutrality goal and improve data collection and transparency.
• SCE supports targeted, incremental improvements in Phase 2 and says the proceeding should not expand into broader issues outside the existing energization framework.
• TURN supports standardization where it improves accountability and customer outcomes, but cautions against unnecessary complexity or added ratepayer costs.

Planning, forecasting, and load growth integration

• SCTCA urges that energization applications be integrated into distribution planning and load forecasts, especially for EV charging and transportation electrification.
• IREC, as discussed in SCTCA’s filing, is cited for the view that current timelines were not evaluated against the pace of new load needed for climate goals.
• SCE says broader integration of future load fields into energization applications would require major system changes and is beyond the limited scope it sees for Phase 2.
• PG&E, as referenced in TURN’s filing, supports some reporting improvements but argues its existing planning process already accounts for future load growth.

Distributed energy resources, non-wires alternatives, and flexible service options

• SCTCA strongly supports expanding Rules 15 and 16 to recognize cost-effective technologies such as at-the-meter power control systems as eligible service upgrades, which it says could reduce delays and help Tribal projects manage limited budgets.
• CALSTART supports continued access to flexible service connections and early-stage utility information that would help customers assess project feasibility and cost.
• TURN supports retaining and clarifying reporting fields related to flexible service options and upstream capacity costs so the Commission can better understand how these tools affect energization outcomes.