Simplifying Policy Management

supports adopting Guidehouse’s data sufficiency threshold methodology and aligns with CalCCA’s recommendation that utilities complete required process and system upgrades by March 31, 2027. PACT urges a graduated compliance and enforcement approach: use data sufficiency metrics first to trigger corrective reporting, targeted process/technology improvements, and Commission oversight, with stronger enforcement phased in as utilities mature data and processes. When thresholds are missed, utilities should:

• Identify deficient fields
• Explain causes
• State whether fixes require process or technology changes
• Provide implementation timelines
• Describe interim reporting

PACT emphasizes minimizing administrative burden and focusing on fields that inform timely electric service.

Overlapping utility and customer time

PACT opposes erasing overlap visibility by assigning concurrent activity wholly to one party. It recommends reporting which steps occurred concurrently, who controlled them (utility, customer, third party, or shared), and whether overlap delayed, had no effect, or accelerated end-to-end timelines to preserve customer-facing timelines and enable Commission diagnosis.

Upstream dependency reporting and capacity bands

PACT urges a standardized, updateable framework for upstream capacity dependencies without requiring perfect one-to-one attribution. Minimum elements include whether a project depends on upstream upgrades, upgrade types, dependency status (preliminary/confirmed/resolved), and expected versus actual completion dates. For large EV projects, PACT recommends refining Capacity Request Categories above 2 MW into bands (2–5 MW, 5–10 MW, >10 MW) to better analyze bottlenecks affecting MHD charging deployments.

Next steps

PACT supports continued engagement to implement these measures to improve energization reporting consistency, completeness, and utility readiness for MHD electrification.

reliability and outage-mitigation issues beyond the template itself.

Whether the proceeding should remain open

• SCE and SDG&E support adopting the annual reporting requirement and closing R.24-05-023, saying the new reporting framework provides an ongoing compliance vehicle and that any later issues can be addressed through future clarification or a successor proceeding if needed.
• PG&E also supports closing the rulemaking after the template and schema are adopted, arguing the new data will show whether additional Commission action is warranted and that it is premature to keep the docket open before the data are collected and analyzed.
• CforAT opposes closing the proceeding and says the reporting framework should be followed by a second phase or successor docket to address unresolved issues such as corrective actions, outage classification, and broader reliability problems.
• County of Napa, together with the other Joint Local Governments and Joint CCAs, opposes closure and says the proceeding should remain open to address reliability issues beyond the reporting template, or else a successor docket should be opened.
• Center for Biological Diversity likewise asks the Commission to remove language closing the proceeding and instead keep it open for a Phase 2 focused on broader resilience and equity solutions.

Reporting frequency, timing, and interim review

• SCE and SDG&E support annual reporting beginning in 2027 and say the cadence is a reasonable balance that provides consistency, transparency, and a predictable compliance cycle.
• PG&E opposes reporting more frequently than annually, saying the reporting process is resource-intensive and that annual reporting is sufficient because seasonal and event-specific trends can be analyzed from the underlying dataset.
• CforAT argues that annual reporting is too delayed and supports twice-yearly reporting, saying a six-month cadence would better capture reliability trends and reduce the lag between outage events and public reporting.
• County of Napa and the other Joint Local Governments/Joint CCAs support more frequent review of the template and back interim reporting, including a December 2026 interim report, to help inform later Commission action.
• County of Napa and the Joint Local Governments/Joint CCAs also support utilities’ suggestion for annual opportunities to propose template changes rather than waiting on a three-year cycle.
• Center for Biological Diversity does not focus on cadence, but supports keeping the proceeding open so later phases can address broader reliability issues informed by the reporting.

Definitions, outage classification, and narrative content

• CforAT says the template should define “customer with medical needs” and reiterates that PSPS events should be treated differently from routine planned maintenance outages; it also seeks clearer distinctions among outage types and continued attention to PSPS, EPSS, and Fast-Trip impacts.
• SCE and SDG&E support the PD’s reporting structure but ask the Commission to adopt the specific clarifications and technical revisions raised in the Joint IOU opening comments, including shared definitions and outage classification issues for PSPS, Fast-Trip, and EPSS events.
• County of Napa and the other Joint Local Governments/Joint CCAs support a defined “customers with medical needs” category, clearer narrative categorization of outages, and continued inclusion of PG&E fast-trip reporting rather than allowing the annual report to replace more timely information.
• County of Napa and the Joint Local Governments/Joint CCAs also support the utilities’ idea of allowing annual feedback on template changes so definitions and categories can be refined over time.
• PG&E supports a consistent framework and says alternative approaches should be considered through workshops if the proceeding remains open, including event classification and the data dictionary.

Repetitive outages, corrective actions, and reliability trend analysis

• County of Napa and the Joint Local Governments/Joint CCAs support recommendations that would require more information on frequent-outage circuits, corrective actions, fast-trip setting changes, long-term performance trends, and a centralized public posting of reports.
• CforAT supports RCRC’s view that utilities should identify corrective actions for repeat-outage circuits, but says those proposals are better addressed in a second phase rather than being folded into the current reporting-only decision.
• PG&E opposes a requirement to link repetitive outage circuits to future wildfire mitigation or grid-hardening projects, arguing that such a linkage could be misleading and that much of the relevant information is already available in other reporting.
• Center for Biological Diversity supports moving into a later phase to address non-wires alternatives and other resilience measures that could mitigate repeated outage impacts in disadvantaged communities.

Implementation, governance, and stakeholder input

• SCE and SDG&E support the annual reporting framework and ask for limited technical revisions from the Joint IOU opening comments, while maintaining that the core annual reporting requirement should remain unchanged.
• PG&E says the reporting framework will require substantial internal coordination and system work, and opposes interim reporting before utilities have had time to build and test the new process.
• CforAT wants a mechanism for non-IOU parties to request template updates and supports a workshop or forum after the first reports are filed so parties can propose improvements.
• County of Napa and the Joint Local Governments/Joint CCAs support annual opportunities for template feedback and say that regular updates would reduce the need for larger future revisions.