Simplifying Policy Management

nonparticipating-customer-funded adder because external funding sources the Commission had anticipated are no longer available.

Key context and funding changes

• The U.S. Environmental Protection Agency (EPA) terminated California’s Solar for All award in August 2025, eliminating a prospective source of federal grant funding referenced in D.24-05-065.
• Public Law 119-21 accelerates federal tax credit expirations: residential credits end in 2025 and commercial credits in 2027.
• As part of California’s 2025–2026 Budget Bill, $33 million previously appropriated to the Commission for the community renewable energy and storage-backed programs reverted to the General Fund.
• AB 1207 discontinues use of greenhouse gas (GHG) allowance proceeds to fund DAC-GT beginning July 1, 2026.
• The DAC-GT cost containment cap was approved by Resolution E-5367 on July 24, 2025.

Findings of fact (highlights)

• D.24-05-065 created the new community renewable energy program under Pub. Util. Code §769.3(c) but left implementation details for a subsequent decision.
• D.24-05-065 intended to use current PURPA-compliant tariffs (e.g., ReMAT and the PURPA Standard Offer Contract) as the cost foundation.
• ReMAT and the PURPA Standard Offer have differing maximum contract lengths (ReMAT up to 20 years; PURPA Standard Offer up to 12 years for new facilities).
• Providing compensation above PURPA avoided costs would violate Pub. Util. Code §769.3(c).
• Increasing project size caps to 5 MW or raising statewide capacity caps would require legislative action.
• ReMAT already differentiates contract prices by expected energy delivery timing and accommodates storage through different product types.
• The modified GT program is voluntary and participant-funded; SDG&E’s legacy stranded GT cost recovery was handled in its 2023 ERRA compliance proceeding.
• The Commission’s Executive Director extended the deadline for IOUs to submit modified GT implementation advice letters to 90 days after resolution of issues from D.24-05-065.
• D.24-05-065 directed migration of reporting to the California Distributed Generation Statistics website (DGStats), replacing several prior reporting requirements (D.15-01-051, D.16-05-006, D.18-06-027, Resolution E-4999, D.21-12-036, Resolution E-5028).
• CCAs proposing new DAC-GT programs generally submitted straightforward proposals not requiring Tier 3 review; the Commission has already specified main DAC-GT requirements.

Conclusions of law and policy directions

• The Commission adopts a customer Community Renewable Energy tariff per Pub. Util. Code §769.3(c).
• Each investor-owned utility (IOU) must base its Community Renewable Energy tariff on its ReMAT tariff as the cost and generation resource foundation.
• To limit impacts on nonparticipating customers, Community Choice Aggregators (CCAs) participating in the program should align their tariffs to the ReMAT pricing and IOU PPAs in their service territory.
• CCAs and Electric Service Providers (ESPs) that elect to participate (per Pub. Util. Code §769.3(b)) may begin or end participation by notifying the Commission via a Tier 1 advice letter.
• GT procurement oversight through IOU Procurement Review Group (PRG) meetings and cost oversight through ERRA proceedings is sufficient; therefore, certain prior oversight routines may be discontinued.
• Proposed modifications to each IOU’s GT shall be filed via a Tier 2 advice letter within 90 days of this decision’s issue date.
• IOU DAC-GT tariffs should be updated to reflect funding via public purpose program surcharge collections (consistent with Pub. Util. Code §748.5(c)).
• Allow time for programs to mature before initiating the next DAC-GT program evaluation.
• CCAs seeking to offer new DAC-GT programs must use a Tier 2 advice letter.
• Program administrators shall complete transition of required reporting to DGStats (or successor) within 180 days of this decision’s issue date.
• The Commission authorizes recovery of costs to implement D.24-05-065’s reporting requirement and directs a deadline for completing the reporting transition.
• All Administrative Law Judge and assigned Commissioner rulings in this consolidated proceeding are affirmed; unresolved motions are denied; consolidated Applications A.22-05-022, A.22-05-023, and A.22-05-024 are closed.

Specific orders and deadlines (actionable items)

• Within 60 days after this decision’s issue date, Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), and Southern California Edison Company (SCE) must each submit a Tier 2 advice letter proposing a new customer Community Renewable Energy tariff consistent with D.24-05-065 and this decision. Each filing must include a program implementation and marketing plan as described in the decision.
• CCAs and ESPs that told the Commission they will participate in the community renewable energy program must submit a Tier 1 advice letter to notify the Commission when they begin or end participation.
• This decision supersedes D.15-01-051 Ordering Paragraphs 10, 11, 15, and 17 for the IOU programs named (ending certain required monthly/annual reports, annual program forums, and advisory group requirements) as of this decision’s issue date.
• Within 90 days after this decision’s issue date, PG&E, SDG&E, and SCE must each submit a Tier 2 advice letter modifying their Green Tariff per D.24-05-065, including a timeline and transition plan for migrating legacy GT customers to the modified GT if and when approved.
• Within 30 days after the issue date, PG&E, SDG&E, and SCE must each file a Tier 1 advice letter updating their DAC-GT tariffs to specify funding via public purpose program surcharge collections.
• This decision supersedes D.24-05-065 Ordering Paragraph 14 regarding DAC-GT program evaluation; the DAC-GT evaluation will proceed per D.18-06-027 Ordering Paragraph 7, and Energy Division staff will share evaluation results and recommendations with the service list no later than two years from this decision’s issue date.
• This decision supersedes D.18-06-027 Ordering Paragraph 17 for CCAs’ DAC-GT programs; new CCA DAC-GT programs receiving funds per D.18-06-027 must be implemented by Tier 2 advice letter.
• Within 180 days after the issue date, PG&E, SDG&E, SCE, and other Program Administrators in the California Renewable Energy Portfolio must complete transition of DAC-GT, GT, and community renewable energy program reporting to DGStats.
• Within 180 days after the issue date, PG&E, SDG&E, SCE, and Program Administrators must execute co-funding agreements with SCE consistent with Section 5 of the decision for DGStats data integration costs.
• The consolidated applications A.22-05-022, A.22-05-023, and A.22-05-024 are closed; the order is effective immediately.

Effect on prior decisions

• The decision explicitly supersedes limited elements of D.24-05-065 (nonparticipating-customer-funded adder and certain DAC-GT evaluation provisions), parts of D.15-01-051 concerning GT oversight reporting and meetings, and one ordering paragraph of D.18-06-027 related to CCA DAC-GT program implementation procedures.

Proceeding status

The proceeding is closed upon issuance of this decision.

today (PG&E Flex Connect deployments). However, residential and secondary-system BTM devices remain unaddressed, and protocol fragmentation persists (SCE using an Australian CSIP variant). Matter 1.3 (May 2024) added EVSE support but by Oct. 2025 only one Matter-certified EVSE exists; Matter-native batteries and inverters are absent. Matter 1.5 may produce initial products in 2026, but consumer-scale deployment is years away. AMI 2.0 results from EPIC are not expected until late 2026/early 2027, introducing 18–24 month schedule risk.

Structural gaps and platform need

Five gaps: unaddressed installed BTM base; standards on unfinished foundations; fragility to policy change; no realistic manufacturer adoption path; and an aggregator-centric model that raises costs, concentration, and data-ownership risks. Universal Devices argues a platform layer is required for discovery, protocol translation, local resilience, and policy adaptability.

Requests to the Commission

• Recognize the platform layer in High DER strategy and require CBA to account for it.
• Designate NuCore as a reference implementation and support structured IOU pilots demonstrating device integration, protocol translation, and edge execution (no funding or exclusivity sought).
• Require IOU DERMS aggregator interfaces to be open, documented, and non-exclusive on a published timeline.

Practice and Procedure.

Under Rule 16.4, modification requests addressing Commission decisions generally must be filed within one year. BAC filed more than one year after D.20-08-043 became effective and did not adequately justify the delay.

The record also notes related developments:

• AB 843, signed September 23, 2021, authorized community choice aggregators to join BioMAT.
• The Commission previously identified Rulemaking (R.) 18-07-003 as the appropriate forum to consider BioMAT sunset changes, affirmed on April 6, 2023.

Findings and conclusions reflect these points, and the decision orders denial of BAC’s petition and closure of R.18-07-003. The order is effective May ___, 2026, in San Francisco.