Simplifying Policy Management

range of perspectives from utilities, community choice aggregators, renewable energy developers, storage advocates, and environmental organizations.

Procurement Targets and Load Forecasts

• Pacific Gas and Electric Company (PG&E) recommends basing procurement orders on the 2025 Integrated Energy Policy Report (IEPR) load forecast and opposes revisiting the order later, citing the need for market stability.
• Southern California Edison Company (SCE) supports reassessing procurement targets using the 2025 IEPR, noting lower peak demand forecasts and advocating for limiting the second tranche to 2,000 MW and deferring 2032 procurement.
• San Diego Gas & Electric Company (SDG&E) argues the 2032 procurement tranche is unsupported by the latest IEPR and should be revisited in 2027, with a reduction to 2,000 MW if retained.
• Peninsula Clean Energy (PCE) raises concerns about the feasibility of doubling solar capacity and questions the evidence supporting the storage cap, urging delay or adjustment of the cap and consideration of Diablo Canyon’s potential extension.
• Redwood Coast Energy Authority (RCEA) calls for reassessment of procurement needs after the first tranche, citing declining local load and uncertainty in data center forecasts.
• California Independent System Operator Corporation (CAISO) supports maintaining the 6 GW procurement order, arguing the 2025 IEPR may underestimate demand and that the 2024 IEPR should guide planning.
• Solar Energy Industries Association (SEIA) opposes reducing the procurement target based on the 2025 IEPR, warning that excluding "Known Loads" understates system needs.
• American Clean Power - California (ACP-CA) supports the 6 GW order, contending that proposals to reduce it misinterpret IEPR forecasts and that the 2024 IEPR should be used.
• ENGIE North America, Inc. (ENGIE NA) opposes reducing the procurement order based on the 2025 IEPR, emphasizing the need for a robust trajectory to replace retiring fossil generation.
• ALLIANCE FOR RETAIL ENERGY MARKETS (AReM) recommends limiting the procurement order to the 2030 tranche and delaying the 2032 decision, citing uncertainty in data center load forecasts.
• Environmental Defense Fund (EDF) argues against reducing the interim procurement order and supports the full 6,000 MW by 2032 due to anticipated delays in resource development.

Energy Storage Cap and Resource Mix

• PG&E calls for updated Effective Load Carrying Capacity (ELCC) values and supports flexibility in compliance, but does not explicitly address the storage cap.
• SCE supports applying the proposed 50% storage cap only to standalone storage, not all storage, to avoid hindering procurement.
• SDG&E criticizes the 50% storage cap as arbitrary and calls for clarification to exclude hybrid and co-located resources.
• PCE finds the 50% storage cap unworkable and calls for alternatives such as a nameplate capacity cap or independent sufficiency assessments.
• SEIA and the Joint Solar Parties (JSP) argue that paired renewable and storage resources should be exempt from the 50% cap, which they view as impractical.
• ENGIE NA criticizes the 50% storage cap as arbitrary and supports exemptions for co-located storage.
• GreenGenStorage, LLC supports a storage procurement limitation but argues the 50% cap should only apply to standalone short-duration storage, exempting long-duration energy storage (LDES).
• Hydrostor, Inc. contends that lifting the storage cap alone is insufficient and proposes a 1,500 MW NQC mandate for new storage with a minimum 8-hour duration, while opposing reductions to the 2032 tranche.
• Long Duration Energy Storage Council (LDES Council) supports removing the storage cap, warning that a rigid cap could distort procurement and hinder cost-effective portfolios.
• California Wind Energy Association (CalWEA) urges reconsideration of the storage cap in favor of a minimum energy requirement based on a sufficiency gap study.
• Vote Solar recommends removing the 50% storage cap or exempting hybrid resources to promote innovation and reduce costs.
• EDF supports the 50% storage cap, advocating for its application to each tranche and exemptions for co-located and LDES projects.
• Sierra Club supports the storage cap but calls for clarifications and exemptions for LDES and hybrid resources.
• AReM urges elimination of the 50% storage cap, arguing it will hinder procurement and increase costs.
• Independent Energy Producers Association (IEP) opposes the 50% storage cap, stating it could delay necessary storage projects and limit options for load-serving entities.
• Mainspring Energy, Inc. supports a specific tranche for long-duration storage to meet at least 25% of the 6,000 MW NQC requirement.

Resource Eligibility and Technology Neutrality

• PG&E advocates for updated ELCC values and supports a technology-neutral approach to resource eligibility.
• SCE opposes technology carve-outs and supports a technology-neutral procurement order, including eligibility for carbon capture and sequestration (CCS) technologies.
• SEIA/JSP recommend exempting paired renewable + storage resources from the storage cap and support timely ELCC studies.
• ACP-CA advocates for expanding eligibility to include energy-only solar resources and suggests a minimum energy requirement instead of a storage cap.
• IEP calls for removal of exceptions for utility-owned generation and a return to competitive market policies, as well as expedited geothermal procurement.
• Bloom Energy Corporation urges recognition of fuel cells and natural gas with CCS as eligible resources, highlighting their reliability and emissions benefits.
• Sierra Club rejects inclusion of CCS and fossil resources, citing inconsistency with state clean energy goals.
• GreenGenStorage, LLC calls for technology-neutral eligibility and refinement of ELCC accreditation for LDES.
• LDES Council advocates for technology-neutral eligibility rules, allowing energy-only resources to contribute to procurement if they meet reliability objectives.
• Sonoma Clean Power Authority (SCPA) supports inclusion of energy-only resources in procurement requirements.
• XGS Energy, Inc. supports allowing energy-only long lead-time resources, particularly next-generation geothermal, to count toward procurement obligations.

Transmission Planning and Deliverability

• Fervo Energy Company urges updates to Enhanced Geothermal Systems (EGS) mapping, identification of necessary transmission upgrades for out-of-state clean firm resources, and reassessment of deliverability reservations to include out-of-state EGS.
• CAISO opposes allowing energy-only long lead-time resources to qualify for procurement without deliverability assessments, warning of reliability risks.
• CalWEA highlights the need to study transmission options for accessing wind and geothermal resources in Northeastern California and restoring previously modeled wind capacity.
• SCPA supports planning transmission capacity to Northeastern California for wind and geothermal resources and access to out-of-state resources.
• RCEA stresses the need for updated busbar mapping to reflect Transmission Plan Deliverability (TPD) requirements on the North Coast, especially for offshore wind.
• XGS Energy, Inc. supports reserving transmission deliverability for mapped geothermal projects to advance development in areas of commercial interest.
• Fervo Energy Company also calls for a regional transmission assessment to facilitate EGS delivery from Utah and Nevada.

Local Procurement and Distributed Energy Resources

• Sierra Club advocates for prioritizing local procurement, facilitating DER crediting, and holding workshops to address DER integration barriers.
• Environmental Defense Fund (EDF) supports a local procurement framework to enhance local capacity planning.

Long-Duration Energy Storage (LDES) and Reliability

• Hydrostor, Inc. advocates for a 1,500 MW NQC procurement mandate for LDES with a minimum 8-hour duration and opposes reducing the 2032 procurement tranche.
• GreenGenStorage, LLC emphasizes that LDES should be exempt from the storage cap and calls for refined ELCC accreditation for LDES.
• LDES Council supports a clear procurement signal for LDES and removal of the storage cap to meet evolving grid needs.
• Mainspring Energy, Inc. supports a specific LDES tranche to meet at least 25% of the 6,000 MW NQC requirement and prioritizes multi-day storage duration procurements.
• CAISO supports incorporating LDES requirements and updating ELCC values for LDES in the procurement order.

Out-of-State and Offshore Resources

• Fervo Energy Company requests updated EGS mapping to reflect viable development in Utah and Nevada and supports transmission upgrades for out-of-state clean firm resources.
• ACP-CA opposes reductions in out-of-state resources in transmission planning portfolios, citing the need for resource diversity and reliability.
• ENGIE NA supports inclusion of out-of-state solar resources in the transmission planning portfolio for resource diversity.
• CalWEA recommends restoring previously modeled wind capacity and exploring connections to projects like NV Energy’s Greenlink.
• RCEA urges the CPUC not to delay offshore wind resource development and to maintain timelines for offshore wind projects.

Compliance Flexibility and Good Faith Efforts

• PG&E emphasizes the need for compliance flexibility, advocating for alternative compliance mechanisms and recognition of good faith efforts in procurement.
• SCE supports applying the alternative compliance mechanism from prior decisions and considering LSEs' good faith efforts to avoid unnecessary costs.
• SDG&E calls for compliance flexibility due to systemic interconnection delays and supports extending flexibility mechanisms from previous decisions.
• AReM stresses the importance of retaining compliance flexibility from the current midterm reliability program and urges elimination of the storage cap.
• GreenGenStorage, LLC advocates for a good-faith standard in compliance assessments, rather than a binary regime.

Cost Allocation and Ratepayer Impacts

• SCE raises affordability concerns, recommending reassessment of procurement targets to avoid overstating reliability needs and increasing costs.
• SDG&E highlights consensus that the procurement volume is excessively high and economically unjustified, with broad support for reducing the 2032 mandate.
• Sierra Club urges the Commission to develop a large load tariff to align data center costs with causation and address cost allocation concerns.
• AReM warns that changes in data center load forecasts could lead to significant cost shifts and recommends deferring allocation decisions until further studies are completed.
• Small Business Utility Advocates (SBUA) emphasizes the need for clarity and accuracy in modeling assumptions to protect ratepayers from potential risks.

Busbar Mapping and Resource Mapping Methodologies

• IEP supports inclusion of PG&E Fresno area solar resources and calls for proactive mapping to facilitate timely resource buildout and tax credit eligibility.
• Fervo Energy Company advocates for incorporating market and commercial data into busbar mapping and improved data collection to better reflect commercial interests.
• RCEA stresses the need for updated busbar mapping to reflect TPD requirements, especially for offshore wind projects.
• SCPA opposes remapping geothermal capacity away from the Geysers region, citing ongoing development potential.

Greenhouse Gas (GHG) Targets and Decarbonization

• AReM highlights inaccuracies in the PD’s references to GHG targets and requests corrections to reflect that these were set by the CPUC, not CARB.
• EDF argues for a scenario that prioritizes the retirement of gas plants to meet long-term decarbonization goals.
• Vote Solar recommends using surplus procurement to retire aging gas generation and opposes inclusion of CCS projects as eligible resources.
• Bloom Energy Corporation supports the inclusion of fuel cells and natural gas with CCS to help maintain reliability while reducing GHG emissions.

are authorized to modify the agreement through Tier 2 Advice Letters. Additionally, they must update Tariff Rules 2 and 3, enhance customer guidance on their websites, and formalize preliminary capacity assessments to aid customers in evaluating grid availability.

Key Directives

• Ongoing data collection
• Biannual reporting starting March 31, 2026
• Comprehensive cost-efficiency report due by January 15, 2029
• SCE must report on its FSC pilot by March 1, 2026

The decision emphasizes the importance of customer engagement, requiring utilities to assess customer interest prior to conducting engineering studies and to provide transparent information regarding capacity allocation.

Standard Offer Features

• Annual and ad-hoc capacity reviews
• Consideration of on-site generation and photovoltaic outputs
• Options for customers to select load control methods

• Track curtailment incidents
• Maintain records of load determination
• Utilize advanced metering for compliance monitoring

Findings and Support

Findings indicate broad support for Standard Offer FSCs to expedite service during capacity constraints. PG&E and SCE have previously offered FSCs as alternatives. Since July 2023, PG&E has provided non-tariffed FSCs to over 100 customers, with most upgrades anticipated by 2029. SCE’s pilot program has enrolled eight customers. The decision points out that limiting the Standard Offer to customers requiring full capacity year-round is overly restrictive and acknowledges the effectiveness of PG&E’s customer education efforts. The use of UL 3141 certified equipment is encouraged to facilitate compliance.

Overall Goals

The order aims to enhance the efficiency, transparency, and accessibility of energy services for customers facing capacity constraints, while ensuring regulatory compliance and ongoing evaluation. The proceeding remains open for further issues, and the order is effective immediately as of February 5, 2026.

Filing Timeline

ENGIE’s petition was filed more than one year after the effective date of Decision 21-06-005 and did not comply with Rule 16.4(d) guidelines.

Commission's Rationale

The Commission finds it reasonable to deny the petition.

Ongoing Proceedings

Rulemaking 20-05-012 remains open.

Effective Date

This order is effective as of March __, 2026, in Sacramento, California.

Standard (RPS) Procurement Plans.

Arguments Presented

• The decision inadequately assessed SDG&E's RPS Plan.
• The decision failed to require SCE to provide necessary load analysis.

Opposition to Rehearing

Both SDG&E and SCE opposed the rehearing on February 7, 2025.

Commission's Conclusion

The Commission concluded that SBUA did not present sufficient grounds for rehearing.

Effective Date

The order is effective immediately as of February 5, 2026, with Rulemaking 24-01-017 remaining open.

Utilities (IOUs), requested an extension of the deadline for parties to submit materials for the workshop. The original deadline, set by a previous ruling, was February 13, 2026. PG&E proposed moving the deadline to noon on February 17, 2026, citing the President’s Day holiday as a reason for the change.

Support and Process

• PG&E conducted outreach to other parties on February 10, 2026, in accordance with CPUC Rule 11.6, to gauge support for the extension.
• All responding parties supported the request, including the Public Advocates Office, Utility Consumers’ Action Network, California Community Choice Association, and MCE Community Choice Energy.
• The IOUs indicated that the extension would not prejudice any party and requested expedited approval due to the proximity of the original deadline.

Ruling Details

• The CPUC issued a ruling granting the extension, finding good cause based on the joint request and broad support.
• Parties not included in PG&E’s extension request were permitted to submit their responses by the end of the day on February 11, 2026.
• The Docket Office was assigned responsibility for formal filing of the ruling.

Last Week's New Comments +4

Overview of Recent Filings in CPUC Proceeding R21-06-017

Recent reply comments in CPUC proceeding R21-06-017 address the Public Advocates Office’s 2025 Distribution Grid Electrification Model (DGEM) Study and Report, focusing on its role in grid planning, cost estimation, and electrification strategies. This update summarizes a sampling of parties’ positions on key topics, including the use of DGEM as a benchmark, cost estimation methodologies, data transparency, and electrification flexibility.

Use of DGEM 2025 as a Benchmark for Cost Reasonableness

• UCAN urges the Commission to adopt DGEM 2025 as a benchmark for evaluating the reasonableness of utility cost estimates and to reject attempts by utilities to inflate costs.
• SCE opposes using DGEM 2025 as a baseline for utility Electrification Impact Studies (EIS), arguing that the studies have different methodologies and objectives and should not be directly compared.
• Cal Advocates advises against formally adopting DGEM 2025 as a benchmark for distribution planning or rate case cost estimation, citing simplifications and uncertainties in the study.

Cost Estimation and Methodology Disputes

• UCAN disagrees with PG&E’s proposal to inflate DGEM cost estimates by including “stand-alone” line section upgrades, recommending that such costs be justified in General Rate Cases rather than adjusting the DGEM baseline.
• SCE contends that DGEM 2025 and EIS Part 2 are not directly comparable due to their differing approaches, with DGEM providing top-down economic insights and EIS focusing on bottom-up engineering analysis.
• Cal Advocates agrees with PG&E on the limitations of DGEM 2025, particularly regarding feeder overloads and EV load tracking, and emphasizes caution in interpreting the study’s results.
• SBUA highlights uncertainties in IOU grid upgrade forecasts and suggests regulatory streamlining and improved internal planning to facilitate more responsive grid upgrades.

Data Transparency and Planning Assumptions

• SBUA supports calls for IOUs to provide more detailed service request data to Cal Advocates to improve future DGEM iterations and expresses concern about speculative substation upgrades potentially becoming stranded assets.
• UCAN stresses the need for standardized planning assumptions and rigorous oversight to ensure affordability in the electrification transition.

Flexibility in Electrification Strategies

• UCAN supports VGIC and EDF’s emphasis on flexibility, advocating for managed charging scenarios and recommending that future DGEM studies incorporate bidirectional charging (V2G) impacts to enhance ratepayer savings.
• SBUA notes that load growth and flexibility could lower costs but warns of potential unnecessary expenses for ratepayers if demand from data centers is uncertain, recommending that data centers commit to power purchases to mitigate overbuilding risks.

Distribution Planning Process

• SCE emphasizes that the annual Distribution Planning Process (DPP), supported by stakeholder engagement, is the appropriate mechanism for identifying grid needs and mitigation projects, and that DGEM 2025 and EIS Part 2 methodologies should not replace this process.

Comparisons Between DGEM and Utility Studies

• UCAN asserts that significant discrepancies in cost estimates between DGEM and utility EIS results warrant direct comparisons for effective regulation.
• SCE maintains that direct comparisons are inappropriate due to methodological differences.
• Cal Advocates refutes SCE’s claim, stating that comparisons between DGEM 2025 and EIS Part 2 can provide valuable insights for stakeholders.