Simplifying Policy Management

of parties' positions on key topics addressed in the latest round of comments.

Transparency and Data Access

• CalCCA recommends that investor-owned utilities (IOUs) provide unredacted data sheets in Excel format, including detailed customer load and feeder information, to enhance transparency and support planning.
• EDF calls for PG&E to refile its response with comprehensive, unredacted data to enable a better assessment of FSC effectiveness and customer needs.
• PG&E reports that it has provided an amended, unredacted Excel file with updated data fields and definitions, following discussions with CPUC Energy Division staff.
• CALSTART urges utilities to publicly disclose standardized unit cost information for Rule 15 and Rule 16 projects to help customers estimate costs and plan projects.

Standardization and Process Improvements

• CALSTART highlights the need to standardize and streamline the preliminary power check process, recommending completion within 30 business days and application responses within 5–10 business days, as well as the ability for customers to reserve power capacity for 90 days.
• CalCCA calls for standardized procedures and consistent standards for buffer levels and load limit buffers, along with clear guidelines for using emergency ratings in FSCs.
• IREC recommends that utilities clearly document customer access to load limit procedures in tariffs or Commission-approved documents and supports the establishment of a working group to define the energization process for new services.
• Cal Advocates urges IOUs to adopt proactive strategies for FSC deployment, including early identification of opportunities in the interconnection process and extending FSC durations in low-impact cases to defer upgrades.
• SDG&E recommends that FSCs be offered through bilateral contracts rather than a stand-alone tariff, with clear operational requirements established upfront.

Technical Standards and Buffer Levels

• Cal Advocates recommends minimizing or eliminating equipment buffers in FSC load limits unless justified by data, noting that PG&E operates with no buffer while SCE applies a 5% buffer.
• IREC urges SCE to adopt a 0% buffer on load limits, arguing that existing thermal capacities already provide a conservative margin, and recommends annual reviews of established limits.
• VGIC notes that SCE limits load to 95% of equipment ratings and requires Power Control Systems, while PG&E allows full capacity usage with fewer restrictions.
• CALSTART calls for consistent technical standards across utilities, particularly for Power Control Systems and load buffer calculations, and suggests focusing FSC improvements on constrained circuits.

Notification and Customer Engagement

• CalCCA recommends establishing clear notification procedures to inform Community Choice Aggregators (CCAs) about FSC candidates, supporting better planning and cost avoidance.
• EDF advocates for utilities to allow customers to express interest in FSCs during the application process and to proactively evaluate FSC options during pre-application power checks.
• SDG&E does not support adding an FSC checkbox to energization request forms, preferring to discuss the option directly with customers when relevant.

Cost and Compensation Models

• VGIC advocates for a durable FSC framework that fairly compensates customers who voluntarily manage their load to defer upgrades, suggesting a shared savings model that benefits both customers and utilities.
• SDG&E states that customers opting for FSCs should not receive compensation, as the service provides early access to partial energization rather than a demand response benefit.

Implementation Approaches and Utility Practices

• IREC recommends that PG&E and SCE expand their Load Limit Letter and Load Control Management Systems programs to all customers, and that SDG&E develop a similar offering.
• SDG&E emphasizes that detailed engineering reviews, rather than Load Integration Capacity Analysis, should determine import limits for FSCs to ensure alignment with system capabilities.
• EDF highlights the disparity between PG&E’s more flexible load limit letters and SCE’s more restrictive load control management systems, urging broader eligibility and participation.

Collaboration and Ongoing Engagement

• CalCCA seeks ongoing collaboration with the Commission and stakeholders to develop standardized FSC agreements and improve the energization process.

from the 2023 SGIP Impact Evaluation report, indicating that systems enrolled in DR programs achieve higher load reductions.

Community Choice Aggregators and Investor-Owned Utilities

The ruling notes that various Community Choice Aggregators (CCAs) and investor-owned utilities (IOUs) have proposed DR programs, which are currently under review.

Access to SGIP Funds

It confirms that all residential customers can access SGIP funds and outlines the process for customers to reserve funds, including extensions until they can access a qualified DR program.

Key Question for Input

A key question posed for party input is whether the Commission should exempt low-income residential customers from the DR requirement when applying to the Residential Solar and Storage Equity budget. Responses are due by July 15, 2025.