Simplifying Policy Management

he Energy Division is also considering a second workshop and will provide updates to the service list.

Filing Information

This ruling will be formally filed by the Docket Office.

perspectives on pilot design, customer eligibility, cost recovery, and alignment with state policy goals. The following is a sampling of parties' positions on key topics addressed in the latest round of comments.

Status and Design of TOB Pilots

• Silicon Valley Clean Energy Authority (SVCE) supports the approval of at least one investor-owned utility (IOU) TOB pilot, especially for gas-to-electric fuel-switching, and continues to seek cost recovery for its own pilot expenses.
• San Diego Gas & Electric Company (SDG&E) requests that the CPUC not move forward with its pilot at this time, in line with the Joint Tariff On-Bill Proposal Assessment, and supports learning from other pilots before proceeding further.
• Southern California Gas Company (SoCalGas) supports the Dunsky Report’s recommendation to approve its TOB pilot, with some openness to modifications but opposition to changes that could delay implementation.
• Southern California Edison Company (SCE) recommends that the Commission not approve its pilot at this time due to concerns about affordability and scalability, and emphasizes the need for strict consumer protections.
• Public Advocates Office (Cal Advocates) advises against approving any TOB pilots in their current form, but suggests a modified SCE pilot could be considered if it better mitigates risks and expands eligibility.

Customer Eligibility and Equity

• Small Business Utility Advocates (SBUA) expresses concern that small businesses are excluded from TOB funding opportunities and urges modifications to include them, citing the need for equitable access and alignment with CPUC goals.
• Cal Advocates criticizes the current pilots for limited eligibility, particularly the exclusion of renters and multifamily buildings, and argues this undermines equity and decarbonization objectives.
• SCE notes that excluding income-qualified customers from the initial pilot could increase costs for vulnerable groups and stresses the importance of maintaining bill neutrality for customer protection.
• SoCalGas raises concerns about including rental properties and CARE customers in the pilot, citing potential cost and disconnection risks.

Cost Recovery and Ratepayer Impact

• SVCE seeks authorization for cost recovery related to its field trial and pilot expenses, emphasizing that only participants should bear costs in a full-scale program.
• SDG&E highlights concerns about the affordability impact of using additional Public Purpose Program (PPP) funds for pilot costs and the need for billing system upgrades.
• SCE projects that its pilot would require approximately $7 million in ratepayer funding and opposes changes that would undermine consumer protections or increase cost shifting to non-participants.
• Cal Advocates argues that the current proposals impose high and unreasonable costs on ratepayers and recommends reallocating uncommitted PPP funds to reduce ratepayer impact if any pilot is approved.
• SoCalGas clarifies that its pilot would use internal and possibly unspent PPP funds, but should not rely solely on PPP underspending.

Alignment with State Policy Goals

• SVCE asserts that TOB pilots support California’s equity, affordability, and decarbonization goals, but expresses concern that some recommendations could threaten bill neutrality and customer protections.
• Cal Advocates contends that the current pilots do not align with California’s decarbonization and equity goals and could worsen the state’s rate affordability crisis.
• SBUA emphasizes that including small businesses in TOB programs is essential for achieving equity and decarbonization objectives.

Consumer Protections and Program Safeguards

• SCE stresses the necessity of strict consumer protections, including bill neutrality, to mitigate financial risks and maintain program integrity, warning that relaxing these could reclassify TOB charges as loans.
• SVCE highlights the importance of robust customer protections and evaluation metrics such as savings verification, customer acceptance, and equitable adoption.
• SoCalGas expresses concern about the risk of disconnection for non-payment if certain customer groups are included and supports maintaining the current billing schedule for clarity.

Implementation and Collaboration

• SVCE urges PG&E to develop a plan for TOB billing functionality to enable future pilot collaboration and effective program delivery.
• SCE identifies significant IT and implementation challenges, including the need for further billing system modifications and the exclusion of certain technologies until the model is validated.
• SDG&E notes the need for billing system upgrades and extended equipment warranties to ensure program viability.

Pilot Duration and Evaluation

• SoCalGas advocates for extending the pilot duration to at least three years to adequately assess viability and outcomes.
• SVCE views pilot programs as essential for assessing feasibility, reducing per-participant costs, and informing broader rollout strategies.

Integrated Resource Plan (IRP) and ACC Process

• Southern California Gas Company (SoCalGas) supports aligning the ACC with the IRP to improve accuracy and efficiency.
• Southern California Edison Company (SCE) supports using direct outputs from the IRP for avoided generation capacity and greenhouse gas prices to simplify and reduce costs.
• Solar Energy Industries Association (SEIA) emphasizes the need for the ACC to align with the IRP and for technology neutrality and comprehensive cost accounting.
• California Large Energy Consumers Association (CLECA) recommends that the ACC be technology-agnostic and aligned with the IRP process.

ACC Update Schedule and Timeline

• SoCalGas expresses concern about the compressed timeline for the biennial ACC update, recommending that key dates be solidified to ensure timely delivery and adequate stakeholder involvement.
• Marin Clean Energy (MCE) emphasizes the importance of coordinating the ACC update schedule with energy efficiency (EE) portfolio planning and recommends aligning EE filing timelines with the ACC schedule or providing guidance when updated ACC values are unavailable.
• SCE recommends adjusting the schedule to use the 2025-26 Transmission Planning Process if the final Preferred System Plan is not available in time for the 2026 ACC, and proposes splitting the review into separate tracks for generation and transmission/distribution.
• Vote Solar supports delaying the 2026 ACC update until the final Preferred System Plan is released in February 2026 to allow recalibration of demand-side resource values.
• SEIA raises concerns about the proposed schedule, particularly the timing of the Staff Proposal’s release and the absence of a workshop and discovery period, and recommends publishing the Staff Proposal earlier and adding a workshop.
• CAL ADVOCATES/DUTTA/CPUC recommends modifying the ACC update schedule to include time for evidentiary hearings and suggests moving all schedule items up by one month to provide a buffer before the final resolution.
• Pacific Gas and Electric Company (PG&E) advocates for a streamlined ACC update process, focusing on comments rather than testimony, and recommends eliminating the briefing phase from the schedule.
• CLECA opposes eliminating evidentiary hearings and compressing the schedule, arguing these changes would limit stakeholder input and transparency, and recommends two workshops before the proposal release and extended comment periods.

Stakeholder Engagement and Transparency

• SEIA calls for a more inclusive, transparent, and timely ACC update process, including earlier publication of proposals, workshops, and data requests.
• CLECA advocates for transparency and stakeholder engagement, recommending workshops, written testimony, and extended comment periods.
• Clean Coalition supports transparency guidelines and greater geographic transparency to assist local governments.

Equity and Societal Cost Considerations

• Vote Solar supports the adoption of the Societal Cost Test (SCT) with a high Social Cost of Carbon to capture long-term avoided greenhouse gas emissions.
• SEIA acknowledges the importance of distributional equity analysis and advocates for integrating it with existing cost-effectiveness tests for a holistic evaluation of distributed energy resources.
• Clean Coalition emphasizes that equity should be a key factor in the ACC, supporting the use of the SCT and advocating for its application across all DER proceedings.
• Western Riverside Council of Governments (I-REN) emphasizes the need to include non-energy benefits and address equity in the ACC framework, supporting funding increases contingent on equity and inclusivity improvements.

Scope of ACC and Resource Inclusion

• SCE recommends against expanding the ACC to in-front-of-meter (IFOM) distributed energy resources, suggesting a separate track for these issues.
• SEIA advocates for expanding the ACC to include localized benefits and a thorough assessment against guiding principles.
• Clean Coalition supports including front-of-meter (FOM) resources in the ACC, noting their value in reducing reliance on transmission infrastructure and enhancing reliability.
• CLECA advocates for broader resource inclusion in the ACC to accurately reflect avoided costs and cautions against artificial constraints tied to specific technologies.

Budget and Cost Recovery

• SoCalGas questions the justification for increasing the ACC budget from $350,000 to $1.2 million without clear deliverables and recommends that budget increases be based on specific model needs, not inflation alone. SoCalGas also requests a revision of the cost recovery mechanism, suggesting annual amortization through a Tier 2 Advice Letter process.
• SCE agrees with increasing ACC funding to $1.2 million, with some funds allocated to update cost-effectiveness tools for DER and Demand Response portfolios.
• CAL ADVOCATES/DUTTA/CPUC calls for clarification on the proposed budget increase, seeking a clearer rationale for the specific figure of $1.2 million.
• PG&E supports increasing funding for ACC modeling work to $1.2 million annually, citing the growing complexity of the model and the need for a buffer to prevent delays.
• I-REN supports the proposed funding increase to $1.2 million, contingent on future improvements to the ACC that incorporate equity and inclusivity recommendations.
• CLECA reserves judgment on the proposed budget increase for future comments.

Process Streamlining and Legal Procedures

• SCE suggests streamlining the process by limiting the comment period to one round of comments and one round of replies, and eliminating legal briefs in favor of comments.
• PG&E recommends eliminating the briefing phase from the schedule, arguing it is unnecessary without an evidentiary record.