Simplifying Policy Management

positions from recent party comments, organized by key topics.

Alignment with State Policy Goals

• CEJA and Sierra Club propose reforms to better align the RA Program with California’s affordability, climate, equity, and air quality objectives, as required by the Public Utilities Code.

Evaluation of the Slice of Day Program

• CEJA and Sierra Club request a staff analysis of the Slice of Day program’s impact on environmental requirements and affordability, noting that no such evaluation has occurred since its 2024 implementation. They express concern that the program may unintentionally encourage gas facility contracting, increasing costs and undermining environmental goals.

Transparency and Procurement Tracking

• CEJA and Sierra Club propose the creation of a procurement tracker dashboard to improve transparency around local procurement activities. This tool would provide data on resource availability and local capacity needs, supporting more effective planning by load-serving entities and communities.

Coordination Between IRP and RA Proceedings

• CEJA and Sierra Club emphasize the need for explicit coordination between the Integrated Resource Planning (IRP) and RA proceedings, particularly regarding local procurement and the retirement of natural gas generators in disadvantaged communities. They urge the Commission to integrate local procurement into the Track 2 scope and establish a clear timeline to ensure progress on clean energy procurement and reduced fossil fuel reliance in impacted areas.

Resource Adequacy Framework and Energy Only (EO) Resources

• California Energy Storage Alliance (CESA) and Joint Parties propose allowing EO resources to contribute to the charging sufficiency of deliverable energy storage resources within the same Transmission Planning Study Area. They argue this change reflects operational realities, supports grid reliability, and helps control costs as the state’s EO and storage resources grow.

Market Participation and Contractual Requirements

• CESA and Joint Parties recommend that EO resources be required to bid into CAISO markets to ensure effective participation in charging sufficiency. They also suggest that EO resources be included in Load Serving Entity (LSE) RA Plans only when supported by contractual agreements.

Implementation and Planning Tools

• CESA and Joint Parties propose updates to the RA Plan Template to allow broader inclusion of EO resources across Study Areas, rather than limiting them to points of interconnection. They also call for clear allocation of charging sufficiency values as pairing rules expand, and highlight the importance of leveraging Study Areas to facilitate local charging and renewable development near storage facilities.

at other than zero dollars and how such valuation should be applied consistent with legal and policy principles.

Background

The California Public Utilities Commission initiated Rulemaking 25-02-005 in February 2025 to update policies related to the Energy Resource Recovery Account (ERRA) and the Power Charge Indifference Adjustment (PCIA). The proceeding is divided into multiple tracks, with Track One addressing reforms to the resource adequacy Market Price Benchmark, resolved by Decision 25-06-049. Track Two focuses on determining the valuation methodology for renewable energy certificates (RECs) generated before January 1, 2019, used for bundled service customer compliance in PCIA calculations. A prehearing conference was held in January 2026 to discuss these issues and establish the procedural schedule. The overall goal is to reform ratemaking processes and ensure accurate valuation of Pre-2019 Banked RECs.

key topics.

Procurement Targets and Timing

• Solar Energy Industries Association (SEIA) supports the recommended Base Case portfolio and advocates for a 6 GW procurement order, urging accelerated procurement to leverage expiring tax credits.
• American Clean Power - California (ACP-California) supports the 6,000 MW target as a step toward addressing reliability gaps and maximizing federal tax credits.
• San Diego Gas & Electric Company (SDG&E) recommends reducing the procurement mandate to 2,000 MW by 2030 and 2,000 MW by 2032, citing outdated forecasts and insufficient evidence for the 6,000 MW requirement.
• Southern California Edison Company (SCE) urges adjustments to procurement targets based on updated load forecasts.
• Pacific Gas and Electric Company (PG&E) recommends reducing the 2032 incremental procurement target from 4,000 MW to 2,000 MW, aligning with updated load forecasts.
• California Independent System Operator Corporation (CAISO) endorses a phased approach for 6 GW procurement (2 GW per year from 2029 to 2031) to prevent reliability gaps.
• Cal Advocates/MILEY/CPUC recommends clarifying storage cap application and allowing compliance flexibility.
• NextEra Energy Resources, LLC finds the 6 GW procurement directive reasonable but seeks more flexibility in compliance.
• REV Renewables supports the 6,000 MW NQC procurement requirement.
• Invenergy California Offshore LLC supports the 6,000 MW procurement target and the proposed allocation between 2030 and 2032.
• Calpine LLC argues the 6 GW procurement is excessive and recommends limiting initial procurement to 2 GW by 2030, deferring further decisions.
• ENGIE North America, Inc. supports the 2,000 MW by 2030 and 4,000 MW by 2032 procurement schedule.
• Form Energy, Inc. supports the 6,000 MW procurement but raises concerns about over-reliance on solar and short-duration storage.
• esVolta, LP endorses the initiation of an additional 6 GW reliability procurement.

Resource Mix and Storage Cap

• SEIA supports a balanced energy mix with a 50% cap on storage procurement, but raises concerns about implementation and calls for clear rules on counting new clean energy.
• ACP-California recommends replacing the storage cap with an energy-minimum procurement requirement, providing LSEs greater flexibility.
• Central Coast Community Energy (3CE) recommends removing the 50% cap on storage resources, arguing it could increase costs and contradict previous Commission directives.
• SDG&E argues the 50% storage cap could increase costs and limit LSEs' ability to optimize portfolios, requesting that hybrid resources be excluded from the cap.
• California Wind Energy Association (CalWEA) supports the 50% cap on new storage capacity to promote a balanced portfolio.
• Western Power Trading Forum (WPTF) urges removal of the 50% storage cap, calling it arbitrary and a hindrance to cost-effective procurement.
• CALIFORNIA ENERGY STORAGE ALLIANCE (CESA) and CAISO strongly oppose the 50% storage cap, arguing it is arbitrary, unsupported by modeling, and could undermine reliability and affordability.
• SCE requests the 50% cap apply only to standalone storage, not co-located resources, and seeks exemptions for early procurement contracts.
• PG&E seeks clarification on the storage cap, particularly for co-located resources, and requests eligibility for CCS projects.
• Cal Advocates/MILEY/CPUC recommends the 50% cap apply only to standalone storage, not storage paired with generation.
• NextEra Energy Resources, LLC criticizes the 50% storage cap, suggesting it be raised to 90% or that co-located storage be exempted.
• REV Renewables opposes the storage cap, arguing it is not substantiated and could negatively impact affordability and reliability.
• ENGIE North America, Inc. opposes the 50% storage cap, stating it is arbitrary and could lead to less reliable and more costly outcomes.
• California Coalition of Large Energy Users (CLEU) opposes the 50% storage cap, arguing ELCC methodology already accounts for diversity and the cap could inflate costs.
• Form Energy, Inc. opposes the 50% storage cap, especially for long-duration storage, and recommends it not apply to such resources.
• esVolta, LP supports a technology-neutral procurement approach without caps on storage resources.

Long-Duration and Clean Energy Resources

• SEIA highlights the urgency of increasing clean energy generation and recommends expedited project development, including distributed solar projects.
• ACP-California urges updating resource eligibility rules to include energy-only resources and repowered projects.
• 3CE advocates for exempting long-duration energy storage (LDES) and hybrid resources from the storage cap, emphasizing their importance for reliability and climate goals.
• CESA and CAISO call for improved ELCC methodologies for LDES and advocate for their procurement.
• Form Energy, Inc. emphasizes the need for long-duration and multi-day storage, calling for a consistent ELCC methodology and specific procurement for long-duration resources.
• Vote Solar supports new ELCC studies for hybrid projects and recommends an additive approach for capacity accreditation.
• Ormat Technologies, Inc. advocates for enhanced busbar mapping to support geothermal resource development and transmission infrastructure.
• Invenergy California Offshore LLC supports offshore wind volumes and online dates in the Base Case portfolio, and emphasizes the importance of transmission deliverability for long lead-time resources.

Transmission Planning and Busbar Mapping

• ACP-California recommends improvements in busbar mapping to optimize geothermal and solar development, and supports modeling energy-only resources as fully deliverable.
• California Wind Energy Association (CalWEA) criticizes the PD for underrepresenting in-state wind potential due to flawed mapping and modeling, and calls for reserving transmission deliverability for in-state wind.
• Sonoma Clean Power Authority (SCPA) and San José Clean Energy recommend remapping geothermal capacity to Northern California substations and request CAISO validation of transmission upgrades for long-lead time resources.
• SCE stresses the importance of clear eligibility rules and cost recovery guidelines for procurement and transmission planning.
• PG&E calls for timely updates and clear standards, including for busbar mapping and resource eligibility.
• CAISO seeks clarifications on deliverability reservations for out-of-state wind and geothermal, and emphasizes consistency in planning cycles.
• Coalition for Community Solar Access (CCSA) recommends including dispatchable front-of-the-meter distributed energy resources in transmission planning and modeling.
• Ormat Technologies, Inc. urges updating busbar mapping to reflect commercial interest in out-of-state geothermal development and recommends mapping additional capacity to support geothermal corridors.

Compliance Flexibility and Good Faith Efforts

• 3CE advocates for extending compliance flexibility and retaining the "good faith efforts" standard, aligning with previous Commission decisions.
• SDG&E highlights the need for compliance flexibility mechanisms and consideration of good faith efforts before imposing penalties.
• SCE recommends alternative compliance mechanisms to avoid penalizing LSEs for delays beyond their control.
• PG&E requests a two-year grace period for the 2030 target and explicit recognition of good faith efforts in compliance assessments.
• Cal Advocates/MILEY/CPUC recommends allowing LSEs to use compliance flexibility mechanisms from previous decisions to address project delays.
• NextEra Energy Resources, LLC urges extending compliance flexibility for LSEs facing project delays.
• Calpine LLC advocates for flexibility in compliance and waiving penalties for LSEs that meet resource adequacy requirements.

Modeling, Forecasts, and Analytical Assumptions

• SDG&E and SCE call for updated modeling and studies, including the acceleration of ELCC studies to align with final decisions.
• PG&E urges alignment with the 2025 Integrated Energy Policy Report (IEPR) and timely publication of ELCC values.
• CAISO supports portfolios that align with the 2024 IEPR and reflect increased resource buildout for higher demand forecasts.
• California Coalition of Large Energy Users (CLEU) emphasizes the need for structured, transparent resource planning, updated modeling, and public workshops, and calls for concurrent release of ELCC studies for procurement tranches.
• Form Energy, Inc. calls for a forward-looking ELCC methodology for all storage durations and inclusion of a range of storage durations in planning.

Distributed and Local Resources

• SEIA recommends including smaller distributed solar projects to enhance local reliability and reduce costs.
• CCSA advocates for the inclusion of dispatchable front-of-the-meter distributed energy resources in planning and procurement frameworks, and for coordination with regulatory bodies to recognize these resources as load modifiers.
• CLEU calls for minimum requirements for distributed energy resources in procurement orders and flexible contract terms for DERs and virtual power plants.
• Vote Solar urges the Commission to reconsider its decision against local capacity procurement requirements and to encourage procurement in areas reliant on gas-fired generation.

Technology Eligibility and Resource Adequacy

• ACP-California urges updating resource eligibility rules to include energy-only resources and repowered projects, and recommends facilitating repowering of existing renewable projects.
• Bloom Energy Corporation urges the inclusion of fuel cells (natural gas and biogas) as eligible resources, citing their reliability and emissions benefits.
• PG&E seeks clarification on eligibility for co-located resources and CCS projects.
• Calpine LLC recommends expanding energy procurement requirements to include CCS projects and prioritizing their modeling in future planning cycles.
• esVolta, LP advocates for using ELCC as the primary measure for resource reliability and supports a technology-neutral, storage-friendly approach.

Cost, Affordability, and Ratepayer Impacts

• SDG&E, SCE, and PG&E emphasize the need to ensure procurement is cost-effective and does not impose unnecessary burdens on ratepayers.
• Calpine LLC warns that excessive procurement could create unnecessary financial burdens and recommends a phased, flexible approach.
• CLEU stresses the importance of robust cost analysis and modeling to avoid inefficiencies and higher costs for ratepayers.
• ENGIE North America, Inc. argues that the storage cap could lead to less reliable and more costly procurement outcomes.