Simplifying Policy Management

2026.

Standard Offer Structure and Implementation

• PG&E supports a Standard Form Agreement over a full tariff, citing greater flexibility and reduced administrative burden, and recommends further cost-benefit analysis before implementation.
• Enphase Energy supports the inclusion of the Standard Offer FSC in a tariff, emphasizing standardization and transparency.
• Emerald AI advocates for a standardized Standard Offer to ensure predictable energization outcomes and supports Limited Load Profiles (LLPs) as a compliance baseline.
• TURN recommends limiting the Standard Offer to agreements that do not negatively impact non-participating ratepayers and calls for annual reporting on cost-efficiency.
• SDG&E opposes immediate implementation of the FSC Standard Offer upon encountering a constraint, arguing that a single instance does not indicate a systemic issue.

Definition and Scope of Upstream Capacity

• SDG&E argues that expanding the definition of "upstream capacity" to include secondary distribution facilities is overly broad and recommends retaining the current interpretation focused on primary-side constraints.
• PG&E maintains that "upstream capacity" should focus on primary-side constraints, warning that extending it to secondary systems could undermine the purpose of FSCs.
• Clean Coalition recommends expanding the definition to include both primary and secondary distribution grids to enhance customer access to FSCs.

Technical Requirements and Safety

• IREC argues that SCE should not mandate telemetry unless its necessity for safety and reliability is demonstrated, and highlights the lack of evidence comparing telemetry and AMI costs and benefits.
• Emerald AI contends that telemetry and communication features should be optional, not prerequisites for the Standard Offer, to avoid delays in implementation.
• PG&E emphasizes the importance of maintaining current processes and expresses concern about the cost-prohibitive nature of UL 3141-certified devices.
• Tesla opposes requiring UL 3141 certification for load-only FSCs, citing potential barriers to deployment.
• Enphase Energy refutes PG&E's concerns about PCS accelerating equipment aging and supports the relevance of the PNNL report indicating negligible thermal impacts on service transformers.
• IREC opposes the requirement for two-second response times for Power Control Systems (PCS), citing a lack of supporting evidence and referencing studies that suggest longer response times are adequate for safety.

Load Limiting Profiles and Customer Access

• PG&E supports customizing Load Limiting Profiles (LLPs) based on location rather than applying a uniform standard, and insists that LLPs should remain power-based to avoid unnecessary complexity.
• Emerald AI supports LLPs as a baseline for compliance and advocates for a performance-based, technology-neutral approach to safety and compliance verification.
• Clean Coalition urges IOUs to clarify how customers can access LLPs before application submission to promote efficiency and resource conservation.

Response Timelines and Application Processes

• Clean Coalition supports establishing a 5-day average and a 10-day maximum response timeline for customer applications, along with a Unit Cost Guide for Rule 15/16 to provide cost certainty.
• SCE argues against a proposed 10-day maximum timeline for load limit conversations, stating that such compliance timelines were not included in the current proceeding's scope.
• Emerald AI urges the Commission to maintain aggressive implementation targets to capitalize on the economic benefits of flexible loads, while streamlining reporting requirements.

Cost-Benefit Evaluation and Ratepayer Impact

• IREC argues against requiring utilities to evaluate costs and benefits on a project-by-project basis, advocating for a comprehensive assessment of the FSC program's overall impact on ratepayers.
• TURN supports Cal Advocates’ suggestion for utilities to outline their ratepayer cost-benefit analysis criteria in the Implementation Advice Letter and emphasizes that ratepayer benefits should be a requirement for FSC agreements.
• SDG&E emphasizes that eligibility for the FSC Standard Offer should not depend on net benefits to all ratepayers, advocating for clarification that utilities must serve customers regardless of ratepayer benefit assessments.
• Clean Coalition emphasizes that FSCs should prioritize customer benefits over ratepayer benefits, as the primary goal is to facilitate faster energization and alleviate delays caused by traditional upgrades.

Treatment of On-Site Generation and Solar

• SCE clarifies that modifications to secondary infrastructure and on-site generation/storage do not impact FSCs and should not be included in the standard offer, focusing instead on grid import for customer load.
• Clean Coalition agrees with the need for IOUs to clarify how on-site solar will be treated in engineering reviews, given the prevalence of solar projects in California.

Complexity and Scalability of FSCs

• IREC concurs with SCE's concerns about the complexity of creating FSCs that optimize for energy usage, suggesting such requirements could lead to increased costs and delays.
• Emerald AI supports a simple, scalable offering to demonstrate the value of FSCs and believes safety and implementation concerns can be addressed without compromising the PD's goal.

Stakeholder Collaboration and Future Proceedings

• TURN recommends that SDG&E collaborate with SCE and PG&E to create an FSC Standard Offer for timely energization requests and directs the development of long-term FSC use cases in future proceedings.
• Tesla supports the continuation of PG&E's Load Limit Letters and the extension of SCE's Load Control Management Study (LCMS) pilot, which is vital for medium-heavy duty electrification efforts.
• SDG&E supports the view that discussions on using FSCs for non-bridging solutions should occur in the High DER Proceeding, as these comments are outside the scope of the current decision.

discussion and input.

Last Week's New Comments +12

The California Public Utilities Commission (CPUC) has received a range of proposals and comments from stakeholders in the ongoing Resource Adequacy (RA) proceeding. The following is a high-level, fact-based summary of key positions from a sampling of parties, organized by major topics addressed in recent filings.

Resource Adequacy Requirements and Planning Reserve Margins

• California Independent System Operator Corporation (CAISO) urges the CPUC to set RA requirements based on a 0.1 Loss of Load Expectation (LOLE) standard and to publish Planning Reserve Margins (PRMs) for 2028 and 2029, considering multiple PRMs to address varying conditions throughout the year.

Energy-Only (EO) Resources and Deliverability

• Sonoma Clean Power Authority (SCPA) proposes greater flexibility in accrediting EO resources, especially long-lead time (LLT) resources, including reducing RA obligations for contracted EO LLT resources, removing deliverability requirements for EO resources during non-summer months, and implementing a "connect and manage" model to expedite deployment.
• American Clean Power – California (ACP-California) recommends including EO resources in the Master Resource Database and supply plans, modifying accreditation rules for wind and solar by replacing the exceedance methodology with a worst-day average analysis, and removing barriers to EO resource investment caused by current deliverability requirements.
• Pacific Gas and Electric Company (PG&E) supports allowing EO resources to contribute to Slice of Day (SOD) charging sufficiency requirements on an interim basis, with separate qualifying capacity values and geographic constraints, and proposes a three-year evaluation period.
• CALIFORNIA COMMUNITY CHOICE ASSOCIATION (CalCCA) calls for recognition of EO resources’ reliability contributions, allowing EO resources co-located with deliverable resources to count toward RA or storage charging sufficiency (within POI limits), and proposes a must-offer obligation for EO resources.

Charging Sufficiency and Storage Resource Integration

• Cal Advocates/MILEY/CPUC proposes the Multi-Day Energy Sufficiency Requirement (MDESR), introducing a slice-of-day energy sufficiency accounting method for multi-day storage resources, with a four-day forward charging period and collective energy accounting for LSEs.
• ACP-California supports revising charging sufficiency requirements to allow EO resources to be included in storage charging sufficiency tests, and highlights the need for accurate assessment of charging sufficiency to avoid underestimating transmission and deliverability needs.
• Southern California Edison Company (SCE) proposes allowing excess energy from paired EO storage resources to count toward LSEs’ charging sufficiency needs and extending off-peak import counting rules year-round.
• CALIFORNIA ENERGY STORAGE ALLIANCE (CESA), along with Form Energy, Hydrostor, and Fourth Power, recommends a new methodology for integrating Long-Duration Energy Storage (LDES) into the RA program, including a three-category energy accounting approach and a conservative initial state of charge assumption.

Qualifying Capacity and Accreditation Methodologies

• ACP-California proposes modifying qualifying capacity accreditation rules for wind and solar, advocating for a worst-day average analysis and supporting the use of Effective Load Carrying Capacity (ELCC) methods.
• Calpine LLC recommends maintaining current non-UCAP net qualifying capacities for individual geothermal units while capping facility-wide capacity showings at the total reliable capacity, to better reflect the operational flexibility of interdependent units.
• PG&E proposes applying the existing qualifying capacity methodology to EO resources, with a separate set of QC values for interim use.

Unforced Capacity (UCAP) Framework and Data Quality

• CALIFORNIA ENERGY STORAGE ALLIANCE (CESA) calls for clear outage selection criteria, transparent data validation, and resource-specific assessments in the UCAP methodology, emphasizing that storage resources operating within design limits should not be penalized.
• AES Corporation recommends stringent data quality standards, independent oversight, and a delay in UCAP implementation for technology classes with unresolved data issues. AES also proposes a UCAP refresh mechanism and a transition to Python-based calculation tools for transparency.

Market Integration, Bidding, and Revenue Allocation

• SCE proposes distinct bidding and revenue rules for Reliability Capacity and Imbalance Reserve products, and supports unrestricted IR bidding and zero-dollar RC bids.
• Alliance for Retail Energy Markets (AReM) proposes that payments from the Residual Unit Commitment (RUC) process for RA resources be allocated to LSEs after EDAM implementation, supports the existing framework for revenue allocation, and urges the CPUC not to dictate contract terms for ESPs.
• CAISO argues against restrictions on RA resources for bidding and revenue eligibility in new Day Ahead Market Enhancements (DAME) products, warning that such restrictions could undermine regionalization benefits and increase costs for ratepayers.

Integration of Data Center Loads and Load Forecasting

• CalCCA recommends that RA requirements be based on actual data center load interconnection information, rather than forecasts, and suggests separating data center loads from overall demand forecasts to enhance reliability and reduce costs.

Local Capacity Requirements and Administrative Mechanisms

• PG&E proposes eliminating the Local Capacity Requirement - Reduction Compensation Mechanism (LCR-RCM) due to low participation, administrative complexity, and potential for increased customer costs, while allowing existing contracts to expire naturally.

Coordination, Transparency, and Data Management

• CalCCA calls for improved coordination between the CPUC and CAISO, clarification on the use of local RA data by Central Procurement Entities, and publication of aggregated data to enhance transparency.
• AES Corporation recommends dedicated office hours for stakeholders to discuss UCAP methodology and data validation, and emphasizes the need for transparent, version-controlled calculation tools.

the U.S. EPA regarding the termination of California’s Solar for All award.

Response Timeline and Limitations

• Parties have ten days to file a response.
• Responses are limited to five pages.

Clarification on Official Notice

The ruling clarifies that the official notice pertains only to the documents' contents and publication, not the truth of their assertions.

Issuing Authority and Date

The ruling was issued by Administrative Law Judge Valerie U. Kao on January 27, 2026.

comment deadline to February 6, 2026, and the reply comments deadline to February 11, 2026.

Purpose of the Decision

This decision aims to ensure timely preparation for a vote on the proposed decision scheduled for February 26, 2026, and to align with the California Independent System Operator’s Transmission Planning Process.

Reminder to Parties

• Parties are reminded to submit their comments by the new deadlines to facilitate ongoing proceedings.