Simplifying Policy Management

multiple tracks and workshops.

Recent Developments

Decision 23-08-026, issued on August 10, 2023, expanded on-bill financing programs. The CAEATFA decision in D.23-08-026 required Investor-Owned Utilities (IOUs) to file a Joint Tariff On-Bill (TOB) Proposal. This proposal was submitted along with a viability report by Dunsky Energy + Climate Advisors.

Comment Submission Details

Parties must address specific questions about the proposals, focusing on customer protection, equity, and cost-effectiveness. The timeline for comments is as follows:

• Opening comments are due by May 14, 2025.
• Reply comments are due by May 30, 2025.
• Requests for evidentiary hearings must be submitted by June 6, 2025.

efficiency. This aligns with California's goals of achieving 60% renewable energy by 2030 and 100% by 2045, as outlined in Senate Bill (SB) 100.

Compliance Requirements

• Retail sellers must demonstrate compliance with Decision (D.) 17-06-026, which requires that 65% of RPS resources be procured through long-term contracts of 10 years or more.
• Plans must adhere to a consistent numbering convention and include an officer-verified checklist.

Specific Guidelines for Utilities

• Small and Multi-Jurisdictional Utilities (SMJUs) have specific guidelines.
• New CCAs and ESPs must file RPS Plans either at registration or 90 days before commercial operation.
• The CPUC will review and decide on the proposed RPS Plans by the end of 2025.

Assessment and Analysis Requirements

• Retail sellers are required to assess their RPS portfolio supply and demand through 2035.
• Plans must detail procurement strategies, market price management, and trends in transportation electrification.
• Quantitative analyses, risk assessments, and mitigation strategies must be included, such as a Minimum Margin of Procurement (MMoP) to address potential project delays or underperformance.
• Plans must also include bid solicitation protocols, safety considerations, and price adjustment mechanisms.

Procedural Schedule

• Draft RPS Plans must be submitted by June 30, 2025.
• Comments on these drafts are due by July 28, 2025, with reply comments due by August 11, 2025.
• The Commission will vote on the Proposed Decision in the fourth quarter of 2025.
• Final RPS Plans must be filed within 30 days of the Decision's effective date.

resources, and the prioritization of clean energy in local capacity areas. The following is a sampling of parties’ positions on key topics.

Statutory Compliance and Commission Process

• Protect Our Communities Foundation (PCF) contends that the CPUC did not comply with Public Utilities Code section 454.57, particularly subdivisions (e)(4)(A) and (e)(4)(B), by failing to adequately consider cost-effective alternatives and provide required findings or conclusions. PCF supports granting the AfR to ensure lawful and thorough planning.

• Vote Solar argues that the Commission’s decision does not meet the requirements of SB 887, SB 350, and SB 1020, particularly regarding greenhouse gas reduction targets and prioritization of emissions reductions in disadvantaged communities.

Consideration of Distributed Energy Resources (DERs) and Alternatives

• Protect Our Communities Foundation (PCF) emphasizes the need to incorporate behind-the-meter (BTM) solar plus storage and virtual power plants (VPPs) into resource projections, arguing that their exclusion contradicts legislative directives and could lead to unnecessary ratepayer costs.

• Vote Solar criticizes the Commission’s rationale for excluding DERs, particularly BTM solar, from planning models, and supports the inclusion of these resources to reduce reliance on non-preferred resources in local capacity areas.

Resource Planning and Local Capacity Needs

• Protect Our Communities Foundation (PCF) advocates for the inclusion of BTM solar, storage, and VPPs in resource planning to minimize the need for new transmission capacity and reduce dependence on non-preferred resources by 2035. PCF highlights significant potential for rooftop and parking lot solar, especially in SDG&E territory.

• Vote Solar urges the Commission to prioritize the development of clean renewable resources in local capacity areas, warning that failure to do so may prolong the operation of fossil gas plants and necessitate new fossil gas procurement, particularly as electrification increases demand.

Modeling and Forecasting Approaches

• Protect Our Communities Foundation (PCF) criticizes the reliance on the RESOLVE model for not accounting for BTM solar resources, arguing that this limits the ability to achieve greenhouse gas reductions and realize additional system benefits.

• Vote Solar expresses concern that the use of system averages without considering local transmission constraints undermines efforts to reduce nonpreferred resources and meet statutory requirements.

Impacts on Disadvantaged Communities

• Vote Solar asserts that the current decision does not adequately address the needs of disadvantaged communities and fails to prioritize emissions reductions in these areas, as required by state law.

Certification of Service

• Vote Solar confirms that it has served its response to the Application for Rehearing to all parties on the service list for this proceeding, in accordance with Commission rules.

Enhancement

• The California Forestry Association (Calforests) supports the Bioenergy Association of California's (BAC) petition to extend and enhance the BioMAT program, citing direct ratepayer benefits, public health improvements, and economic development, especially through the use of forest waste for wildfire mitigation.
• BAC supports an expedited interim extension of the BioMAT program, emphasizing its necessity under state law and broad support from sectors such as water, wastewater, forestry, dairy, and agriculture.

Wildfire Mitigation and Forest Management

• Calforests highlights the role of small-scale biomass facilities in forest health and wildfire resilience, noting the importance of effective forest management and the need for viable biomass markets to address disposal challenges from fuel reduction activities.
• BAC underscores the wildfire mitigation benefits of BioMAT projects, referencing state policies and CPUC decisions that recognize the program’s role in addressing wildfire hazards linked to tree mortality and forest health.

Economic and Environmental Impacts

• Calforests points to the creation of quality jobs in rural communities, support for local economies, and improved water quality and supply as key benefits of bioenergy facilities, linking these outcomes to broader environmental sustainability and community prosperity.
• BAC notes that BioMAT projects provide firm, renewable power that is essential for electricity reliability, particularly for water and wastewater agencies during emergencies such as wildfires. BAC also highlights the protection of water resources as a significant benefit for ratepayers and agricultural productivity.

Program Design and Participation Barriers

• Calforests identifies significant unsubscribed capacity under the current BioMAT pricing structure, indicating barriers to participation for small-scale biomass facilities. Calforests supports lifting price caps and adjusting queue prioritization to incentivize investment in new projects.
• BAC concurs with the need for an interim extension of the program and a subsequent review of additional proposed changes, noting increasing interest in BioMAT as evidenced by multiple parties expressing intentions to develop new projects.

Cost Considerations

• BAC disputes cost arguments against the BioMAT program, emphasizing that the program is mandated by state law without cost caps or offramps. BAC criticizes comparisons of BioMAT costs to those of the Renewable Portfolio Standard (RPS), arguing that BioMAT provides firm power and that past cost references are misleading as they primarily reflect BioRAM projects.

Water and Wastewater Agency Benefits

• Calforests emphasizes that extending the BioMAT program is crucial for water and wastewater agencies, as it enhances energy reliability, supports public health and safety, and provides additional benefits such as biochar for water filtration and alternatives to costly biosolid disposal methods.
• BAC highlights stakeholder responses, including from the Association of California Water Agencies, that stress the importance of BioMAT projects in mitigating wildfire risks, protecting water supplies, and ensuring service continuity during extreme events.

State Policy and Resource Conservation

• BAC references state climate plans and policies, such as the California Forest Carbon Plan and the Short-Lived Climate Pollutant Reduction Strategy, which call for full implementation of BioMAT and identify it as essential for meeting pollution reduction and carbon neutrality goals. BAC also critiques opposing views that dispute the connection between bioenergy and wildfire mitigation, emphasizing the necessity of forest thinning and biomass removal for resilience and emissions reduction.

This summary reflects a sampling of positions from trade associations and advocacy groups. Additional comments from utilities, developers, and other stakeholders may provide further perspectives on these topics.