Advocacy at the California Public Utilities Commission (CPUC)

CEERT’s Regulatory Counsel Sara Steck Myers and Associate Regulatory Attorney Megan Myers act as advocates and intervenors before the CPUC and other regulatory agencies to ensure fairly pricing for clean power, improve renewable energy procurement planning, and strengthen implementation of the state’s Renewable Portfolio Standard (RPS). CEERT is helping lead the fight for innovative policies that reflect the true value, costs, and benefits of clean, renewable energy.

Recent Developments:

Summary of CEERT’s Advocacy at the California Public Utilities Commission
From January to May, 2021, CEERT has been active in the following proceedings: Extreme Weather (R.20-11-003), Transmission Planning/Reporting (I.00-11-001), Electric Rates and Costs, Integrated Resource Planning (IRP) (R.20-05-003), Resource Adequacy (RA) (R.19-11-009), Oakland Clean Energy Initiative (OCEI) (A.20-04-013), Gas Reliability (R.20-01-007), Microgrids (R.19-09-009), Aliso Canyon (I.17-02-002), Self-Generation Incentive Program (SGIP) (R.20-05-012), and Integrated Distributed Energy Resources (IDER) (R.14-10-003).

Extreme Weather (R.20-11-003)
On January 8, Administrative Law Judge (ALJ) Stevens issued a Proposed Decision (PD) Directing Pacific Gas and Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDG&E) to Seek Contracts for Additional Power Capacity for Summer 2021 Reliability.  This PD directs and authorizes the three investor-owned utilities (IOUs) to contract for capacity that is available to serve peak and net peak demand this summer and seek approval for cost recovery in rates.  CEERT submitted Opening Comments and Reply Comments arguing against the PD’s exclusive focus on natural-gas-based resource procurement.  The Final Decision D.21-02-028 was issued on February 17.

Subsequently, PG&E, SCE and SDG&E submitted Advice Letters that seek approval of contracts procured pursuant to D.21-02-028.  Parties, including CEERT, then filed Protests/Responses to these Advice Letters on February 26, with CEERT urging the CPUC to direct the IOUs to provide more information about the contracts identified in their Advice Letters.

In January, CEERT submitted Opening Prepared Testimony and Rebuttal Testimony, which recommended that: (1) the CPUC should focus on least-regrets solutions to maintain reliability in Summer 2021, (2) the CPUC should ensure the mitigation measures taken to increase reliability in Summer 2021 are equivalent solutions to the causes of the August 2020 outages, and (3) the CPUC should recognize that there is equal or greater urgency to procure clean resources that can be on-line for the Fall 2021 and Summer 2022.  CEERT opposed procurement of gas resources or expansion of gas-fired generation, but if the CPUC does decide to approve them, these contracts should be short-term.

We also recommended that the CPUC adopt the recommendations made by demand-side resource providers to modify programs so that solar + storage hybrids, demand response (DR), and behind-the-meter (BTM) distributed energy resources (DERs) can compete.

In February, CEERT submitted an Opening Brief and a Reply Brief, arguing that any expansion or new investment in gas-fired generation must be either avoided entirely or, if used in a last resort, be limited to short-term contracts.  We urged the CPUC to accept the program recommendations made by demand-side resource providers, and also made a Motion for Oral Argument.

On March 5, ALJ Stevens issued a Ruling Noticing Final Oral Argument in response to Motions for Oral Argument made by CEERT and CPower/Enel and scheduled it for March 19.  On the same date, he issued a Proposed Decision Directing PG&E, SCE, and SDG&E to Take Actions to Prepare for Potential Extreme Weather in the summers of 2021 and 2022.  In response to the PD, CEERT submitted Opening Comments and Reply Comments, arguing that the CPUC’s continued reliance on gas raises serious environmental justice, environmental, and health concerns, and that the PD fails to adequately address DERs and leaves them with no pathway forward.

On March 19, V. John White appeared on behalf of CEERT at the oral argument.  (See the Transcript.)  John stated that while the proceeding had committed to the advancement of DR and DERs as priority resources, the PD presents a crippling response to DR and DERs by failing to consider proposals by industry leaders and even the utilities, which are needed to increase these resources, and in turn increase demand.  Worse, the PD shuts down the proceeding from any further consideration of these demand-side proposals.  John urged the CPUC to keep this proceeding open and argued that it called for a continuing overreliance on gas.

On March 26, the CPUC issued D.21-03-056, a Decision Directing PG&E, SCE, and SDG&E to Take Actions to Prepare for Potential Extreme Weather in the Summers of 2021 and 2022.  Notably, the Final Decision makes two important changes from the PD in response to comments by CEERT and other parties.  First, it revises the language to state that contracts for fossil-fuel development at new sites or for redevelopment or full repowering at existing or mothballed electric generation sites will not be considered, which is an improvement over the previous text.  Second, the CPUC is keeping the proceeding open in an additional phase to potentially evaluate and consider party proposals, or elements of party proposals.

In March, California Environmental Justice Alliance, Union of Concerned Scientists, and Sierra Club filed an Application for Rehearing and Protect Our Communities Foundation filed an Application for Rehearing of D.21-02-028.  On April 5, CEERT submitted a Response supporting these Applications for Rehearing and the concerns raised about D.21-02-028’s allowed additional procurement of new fossil-fuel capacity, which is inconsistent with numerous important state mandates.

On April 27, Assigned Commissioner Batjer and ALJ Stevens issued a Joint Ruling Discussing Potential Modification of D.21-03-056 Regarding Day-Of Trigger in the Emergency Load Reduction Program (ELRP).  This Ruling identifies a potential inconsistency in D.21-03-056, which implies that ELRP should utilize both day-ahead and day-of triggers.  On April 28, OhmConnect, Inc. requested leave to file Comments on the April 27 Ruling, a request that was supported by the California Efficiency + Demand Management Council.  However, on May 3, ALJ Stevens denied this request and stated that it was likely that a proposed order would be issued shortly that parties can comment on.

CEERT remains optimistic that the CPUC will initiate a second phase of this proceeding to evaluate the numerous meaningful proposals that the CPUC’s March Decision did not have time to address.

CPUC Energy Planning and Procurement and Resource Adequacy
Transmission Reporting (I.00-11-001)
In 2000, the CPUC launched its Investigation I.00-11-001 to implement Assembly Bill (AB) 970 “regarding the identification of electric transmission and distribution constraints, actions to resolve those constraints, and related matters affecting the reliability of electric supply.”  In implementing AB 970, the CPUC from the outset required the IOUs to report specified information on the status of transmission and generation interconnection projects, first monthly (D.01-03-077), then quarterly (D.06-09-003).

The CPUC’s commitment to these “AB 970 Reports,” which contained clear, transparent information about the projects, continued until late Fall 2020.  At that time, the IOUs, starting with PG&E, began filing Petitions for Modification (PFMs) of Decision (D.) 06-09-003 to be exempted from or relieved of the AB 970 Reporting requirement.  In each case, the request was based on claims that settlements in the IOUs’ separate transmission owner (TO) rate cases before the Federal Energy Regulatory Commission (FERC) had resulted in a Stakeholder Transmission Asset Review Process for PG&E, Stakeholder Review Process for SCE, and TO5 Transmission Reporting Process for SDG&E—processes that, according to the IOUs,  afford “more comprehensive” information or are “broader in scope” than the AB 970 quarterly reports and render the AB 97 reports “redundant and unnecessary.”

In two decisions to date, first granting PG&E its exemption request (D.20-11-027 ) and then granting the same relief for SCE (D.21-03-010 ), the Commission concluded that “stakeholders” that are parties to the CPUC proceeding (I.00-11-001) will not be disadvantaged by no longer receiving the AB 970 Reports if the CPUC directs PG&E and SCE to serve the “service list in this proceeding with the public version of the electric transmission projects information” that the utilities are required to provide to “stakeholders” pursuant to their STAR and SRP processes.

CEERT, however, discovered that these processes and the information they provide are not the same as the AB 970 Reports:  they are more difficult to navigate or understand, they restrict access to information previously made publicly available, and they are generally inaccessible, especially for parties that are not involved in the FERC TO rate proceedings.

The last in line to make this exemption request was SDG&E, which filed its PFM on February 24.  On March 26, CEERT filed a response opposing this request, based on multiple facts illustrating that the information claimed to be provided through the FERC settlement processes was not the equivalent to the AB 970 Reports in providing information or accessibility and, where that law is still in effect, did not comply with the statute.  (See CEERT’s Response at: CEERT Response to SDG&E PFM of
D.06-09-003.) The CPUC’s Public Advocates Office also filed a Response in opposition to SDG&E’s PFM.

Both SDG&E and SCE filed replies to these responses.  While neither wished to give up their “exemption” positions, they appeared to recognize that the IOUs could do more to educate CPUC parties on their FERC transmission reporting processes.  To that end, SCE followed up with CEERT to hold a conference call on April 22 to explain its SRP process.  In that conference call, with multiple SCE representatives, the utility walked through its process, discussed confidential versus publicly available information, but, ultimately, conceded that accessibility was still an issue that they hoped to have resolved by June.

On April 28, in a meeting with CPUC Energy Division Chief Ed Randolph, CEERT brought up this issue.  Mr. Randolph asked us to send him a letter he could use to start to educate parties on the IOUs’ processes and ensure that needed transmission information was accessible.

Electric Rates and Costs
On February 24 the CPUC held an Electric Costs and Rates En Banc Hearing with a panel of experts from academia, industry, environmental justice, and consumer advocacy discussing the CPUC’s white paper on utility costs and rate trends, and how those trends might impact California’s decarbonization goals.

On March 19 CEERT filed informal comments on the En Banc Hearing and related white paper, asking for a more robust analysis of transmission costs and recommending a comprehensive evaluation on transmission ownership opportunities. We called for more transparency and analysis on gas price volatility and its effects on ratepayer costs, and the relationship to investment in clean energy and electrification.

Integrated Resource Planning (IRP)( R20-05-003) and Procurement-Related Activities
On January 7, ALJ Fitch issued a Proposed Decision Transferring Electric Resource Portfolios to the CAISO for its 2021-2022 Transmission Planning Process.  CEERT submitted Opening Comments and Reply Comments on the PD, arguing that clean energy procurement presents favorable solutions to current issues in California.  We also argued that there should be increased transparency in the operations of the RESOLVE and SERVM models, that the PD fails to implement the long-term planning objective of the IRP process, and that the CPUC should take proactive steps to improve the IRP process.  The Final Decision D.21-02-008 was issued on February 17.

On February 22, ALJ Fitch issued a Ruling Seeking Feedback on Mid-Term Reliability Analysis and Proposed Procurement Requirements.  CEERT submitted Opening Comments and Reply Comments urging the CPUC to implement near-term RA reform that will more accurately reflect the benefits that clean energy resources bring to the grid, and allow these resources to compete fairly with conventional generation.

CEERT held that transmission analysis, planning, and, perhaps most importantly, actual construction, must account for confounding variables that are not readily discernible in the analysis or available for public viewing.  The CPUC should utilize a least-cost/best-fit levelized cost of energy metric for resource selection, as opposed to the net qualifying capacity RA metric.  We expressed concern about the lack of consideration of GHG emissions, the exclusive focus on capacity procurement with no consideration of energy need, and the inexplicable failure to address critical transmission and interconnection issues, and we concluded that the CPUC’s modeling in the IRP process must be completely overhauled.

Resource Adequacy (RA) (R.19-11-009)
On January 28, CEERT submitted our Track 3B.1 Proposal, which proposed a change to the current net qualifying capacity (NQC) counting methodology for today’s dominant form of hybrid:  in-front-of-the-meter, “utility scale” DC solar + storage.  On the same date, CEERT joined Sunrun, CESA, CALSSA, Tesla, Vote Solar and Enel X North America and submitted a Track 4 Proposal that focused primarily on establishing a qualifying capacity (QC) value and dispatch requirements for behind-the-meter (BTM) hybrid and standalone storage resources.  This Track 4 Proposal also presents two pathways for supply-side RA participation in BTM resources.

A Workshop on February 8-10 covered Track 3.B.2 Proposals, and a second Workshop on February 25 covered Tracks 3.B.1 and 4 Proposals.  CEERT presented at the second Workshop on the hybrid QC.  Workshop materials can be found HERE.

On March 11, ALJ Chiv issued a Ruling granting CEERT’s Motion for Official Notice of Advice Letter (AL) 5868-E, et al., which contain the “2020 Joint IOU ELCC Study – Report 1,” and AL 6041-E, et al., which contain the “2020 Joint IOU ELCC Study – Report 2.”

On March 15, CEERT submitted Opening Comments on RA Tracks 3.B.1, 3.B.2, and 4 Proposals, submitted our revised Track 3.B.1 proposal, and provided comments on other revised Tracks 3.B.1, 3.B.2, and 4 proposals.   On March 23, we submitted Reply Comments on Second Revised Track 3.B.2 Proposals and agreed with numerous parties which recommend that the Standardized Fixed-Price Forward Contract proposal that Energy Division adapted as a basis for moving forward on broad RA reform be dropped from further development in Track 3.B.2.  CEERT also agreed that the SCE/CalCCA Joint Proposal to incorporate energy sufficiency should be carried over for further development.  On March 26, we submitted Reply Comments on Tracks 3.B.1 and 4 Proposals and urged the CPUC to adopt its hybrid counting rules Track 3.B.1 proposal in this RA cycle.  However, there are no viable Track 4 proposals with enough of a record and broad support for adoption at this stage.

On April 2, CAISO submitted a Draft 2022 Local Capacity Technical Analysis and Update Regarding Draft 2022 Flexible Capacity Needs Assessment, and on April 21, CAISO submitted its Draft 2022 Flexible Capacity Needs Assessment.

On April 19, ALJ Fitch issued a Ruling on Energy Division’s Demand Response Proposal and Seeking Comments.  The Proposal pertains to issues relating to Proposed Revision Request (PRR) 1280 and DR in a supply-side context.  Opening Comments were submitted on April 29 and Reply Comments on May 4.

Renewable Portfolio Standard (RPS) Program (R.18-07-003)
On January 20, the CPUC issued D.21-01-005, the Decision on 2020 RPS Plans.  On March 30, Assigned Commissioner Rechtschaffen and Assigned ALJs Lakhanpal and Sisto issued a Ruling Identifying Issues and Schedule of Review for 2021 RPS Procurement Plans.  The Ruling identifies the 2021 RPS Procurement Plan filing requirements for all retail sellers of electricity and sets a schedule for the Commission’s review of the 2021 RPS Procurement Plans.

On April 22, ALJs Lakhanpal and Sisto issued a Ruling Seeking Updated Information Regarding the Renewable Market Adjusting Tariff (ReMAT) Program.  Opening Comments were due on June 9 and Reply Comments are due on June 23.

Oakland Clean Energy Initiative (OCEI) (A.20-04-013)
On January 8, ALJ Fogel issued a Proposed Decision Approving Oakland Clean Energy Initiative Preferred Portfolio Procurement Costs and Cost Recovery.  However, on January 15, PG&E submitted a Motion asking to suspend the comment period on the PD, and submitted new information which was not known at the time the PD was issued.  On January 22, CEERT joined AMP, AReM/DACC, CLECA, NCPA and Shell Energy (the Joint Parties) in a Response stating that the CPUC should not just suspend the comment period, but withdraw it, set aside submission, stay the proceeding pending the resolution of the ongoing negotiations between PG&E, Vistra and esVolta, and then re-open the record.

On January 26, ALJ Fogel issued a Ruling that suspended the comment period for the PD, set aside submission, suspended the procedural schedule and directed additional filings.  Ultimately, on April 5, PG&E submitted an Additional Filing stating that both the PG&E-esVolta Local Area Reliability Service Agreement (LARS Agreement) and the PG&E-Vistra LARS Agreement will be terminated.

On April 26, CEERT joined numerous other parties to submit a Response to PG&E’s Additional Filing, arguing that while sanctions may not be merited, PG&E should be chastised by the CPUC for bringing before it an application that was half-formed and clearly not ready for CPUC and parties’ review and engagement.  The Joint Parties requested that the CPUC direct PG&E to make a formal filing withdrawing its application within the 10 days the ALJ had provided for PG&E to respond to party responses to its recent filing.  On May 4, ALJ Fogel ordered PG&E to file a Response to the Joint Parties’ filing.

CPUC Gas System and Grid Initiatives
Gas Reliability and System Planning (R.20-01-007)
On February 26, ALJ Tran issued a Ruling Seeking Comments on questions related to the scope of issues outlined in Phase 1 (Track 1A and Track 1B).  On March 19, CEERT submitted Opening Comments , agreeing that the CPUC should require electric generators to provide projections of hourly gas usage information on a day-ahead basis, but emphasizing that these projections should be based on results from the CAISO Day-Ahead Unit Commitment Process that designates which generators will receive Day Of dispatch orders and what hourly quantities are expected to be dispatched the next day.

On March 30, Calpine, Southern California Generation Coalition, Indicated Shippers, and The Utility Reform Network (TURN) submitted a Motion to suspend the procedural schedule.  On April 2, several parties, including PG&E, Southern California Gas Company, SDG&E, and SCE submitted motions requesting to serve testimony.  However, the ALJ has not yet ruled on these Motions, and the current procedural schedule, including testimony and briefs, is unknown.

Microgrids (R.19-09-009)

On January 21, the CPUC issued D.21-01-018, a Decision Adopting Rates, Tariffs, and Rules Facilitating the Commercialization of Microgrids Pursuant to Senate Bill 1339 and Resiliency Strategies.

On February 9, Assigned Commissioner Shiroma issued an Amended Scoping Memo and Ruling for Track 3.  The main issue in Track 3 is whether the CPUC should require PG&E, SCE, and SDG&E to waive standby charges for a customer operating a microgrid, regardless of fuel source, so long as: (1) waiving a standby charge will enable the microgrid customer to provide an incremental benefit to other customers, that is (2) commensurate with the magnitude of the otherwise applicable standby charges.

In March, CEERT submitted Opening Comments and Reply Comments on the Track 3 Scoping Memo,  arguing that standby charge waivers should incentivize clean microgrid development.  Thus, we encouraged the CPUC to carefully examine standby charge waivers in Track 3 and ensure that its actions allow for incentivizing progress toward meeting California’s climate goals and facilitating its clean-energy transition.  The CPUC must ensure the activities in Track 3 account for necessary resiliency valuation work in Track 4 and are aligned with other relevant proceedings.

On April 16, the CPUC issued D.21-04-021, which addresses the application for rehearing of D.21-01-018 filed by the City of Long Beach.  The CPUC modified D.21-01-018 to clarify the CPUC’s obligations pursuant to Section 8371 and specify that there are limited exceptions to the over-the-fence rule.  Rehearing of D.21- 01-018, as modified, is denied.

Aliso Canyon (I.17-02-002)
On February 3, ALJ Zhang issued a Ruling on Confidentiality Claims by Southern California Gas Company (SoCalGas) Regarding Information in the Energy Division’s Modeling Report, Entering into the Record the Energy Division’s Modeling Report, and Requesting Prehearing Conference Statements.  A Prehearing Conference was held on February 22, which CEERT attended.  On March 8, ALJ Zhang issued a Ruling on Confidentiality Claims by SoCalGas Regarding Information in the Energy Division’s Modeling Report, and Requesting Comments on that Report.  Parties submitted Opening Comments on March 19 and Reply Comments on April 5.

On March 29, ALJ Zhang issued a Ruling Regarding March 30 Phase 3 Workshop and Request for Comments.  A Workshop was held on March 30, when FTI Consulting and Gas Supply Consulting led an introductory workshop to discuss their baseline analysis, and proposed scenarios for Phase 3.

On April 20 CEERT submitted Opening Comments on the March 29 Ruling.  We expressed our appreciation for the clarity and conciseness of the Workstream # 1 results, but believe that significant additional documentation is required before these results can be entered into the record and serve as the basis for any modeling of alternatives in Workstream #2.  The scope of Workstream #2 requires a complete overhaul and public presentation of a revised scope of work before any alternatives modeling commences.

It is appropriate that Consultants study the Gas Transmission alternatives in Phase 3.  However, Consultants’ Phase 3 scope for the three other classes of alternatives—gas demand reduction through electrification, decarbonization of the electric grid, and significant new DC transmission into the LA Basin—should be limited to comparing the results of achieving the state’s goals in these three areas with the resource gap required to allow the closure of Aliso Canyon.

The Phase 3 Scope should be expanded to revisit Workstream #1 and include the range of investments required to also close the small gas storage facility at Playa del Rey.  The CPUC should issue a revised Scoping Memo with these changes and a revised Phase 3 schedule before any Workstream #2 modeling begins.  This will require another extension of the schedule, but even a few months’ delay to finally “get it right” is well worth the effort and is the only politically viable outcome.

On April 20, CEERT had an Ex Parte Meeting with Commissioner Martha Guzman-Aceves and members of her Staff  in which we reiterated many of the positions we had taken in our Opening Comments.  On April 27, CEERT filed Reply Comments that echoed many views expressed in our Opening Comments.

On April 14, ALJ Zhang issued a Ruling allowing parties to submit Phase 2 modeling scenario proposals by April 26.  A Status Conference on the updated Phase 2 schedule and proposals occurred on April 30.

Self-Generation Incentive Program (SGIP) (R.20-05-012)
On March 2, Assigned Commissioner Rechtschaffen issued a Ruling In R.20-05-012 Requesting Party Comment on revision to SGIP renewable generation technology requirements and party input on the Equity Resiliency Budget.  On March 22, CEERT submitted Opening Comments, arguing that the remaining funding available under SGIP should be allocated toward the cleanest technologies possible.  On March 29, we submitted Reply Comments, again holding that the remaining SGIP funding should be allocated to projects that are most consistent with California’s decarbonization goals.  We also argued that “green hydrogen” specifically should be exclusive to that which is produced from electrolysis using renewable energy or from renewable feedstock such as on-site biogas through a fuel cell.

On April 16, ALJ Fogel issued a Ruling Providing Proposal, Requesting Comment, and Updating Procedural Schedule.  This Ruling provides a Heat Pump Water Heater Staff Proposal for comment.

On April 29, Commissioner Rechtschaffen issued a Proposed Decision that revises program requirements for SGIP renewable generation technologies and addresses other issues.

Integrated Distributed Energy Resources (IDER) (R.14-10-003)
On January 5, ALJ Hymes issued a Proposed Decision Adopting Pilots to Test Two Frameworks for Procuring Distributed Energy Resources that Avoid or Defer Utility Capital Investments.  On January 27, CEERT submitted Opening Comments, arguing that the pilots outlined in the PD should serve to lower additional barriers to further integrate DERs beyond distribution investment deferral, and that the timeline for the proposed pilots should be accelerated.  Parties submitted Reply Comments on February 1.  Final Decision D.21-02-006 was issued on February 12.

Other CPUC Proceedings CEERT Continues to Track
As detailed in previous Quarterly Reports, CEERT is either a party to or on the service list for numerous CPUC proceedings that have required or could require CEERT participation, and that CEERT continues to track in anticipation of participating now or in the future.  Information on any upcoming events in these proceedings is provided in the Schedule of Upcoming Events at page 1 of this Report.

However, because these proceedings were not the focus of CEERT’s efforts from January to May 2021, only limited information about these proceedings is provided here, but is available from CEERT’s regulatory counsel, Megan Myers ( or Sara Myers at (  Please do not hesitate to contact them for information on any of the following proceedings as to status or next steps.

PG&E’s Regionalization (A.20-06-011)
On April 2, 2021, parties submitted Comments on PG&E’s Updated Regionalization Proposal.  In addition, a Virtual Status Conference is scheduled for May 18 at 10:00 a.m.

Public Utility Regulatory Policies Act (PURPA) (R.18-07-017)
On January 11, Assigned Commissioner Rechtschaffen issued an Amended Scoping Memo and Ruling.  Parties submitted Comments on February 10.

Energy Efficiency (R.13-11-005)
On January 20, the CPUC issued D.21-01-004, a Decision Providing Directions for Implementation of School Energy Efficiency Stimulus Program.

On February 17, ALJ Kao issued a Ruling that denies the September 16 Motion of Sierra Club and NRDC, which requests that the CPUC direct SoCalGas to terminate its Energy Efficient New Homes Program, and to sanction SoCalGas for violations of CPUC rules.  The Ruling invites parties to comment on whether and what criteria the CPUC should adopt for delineating between program changes that require Staff approval via Advice Letter submission and program changes that only require an Implementation Plan addendum.

On April 16, ALJs Fitch and Kao issued a Proposed Decision Regarding Assessment of Energy Efficiency Potential and Goals and Modification of Portfolio Approval and Oversight Process.

On April 21, a Presiding Officer’s Decision finds that SoCalGas spent ratepayer funds on activities that misaligned with the CPUC’s intent for energy efficiency codes and standards.  This Decision does not order a financial penalty, but does order remedies for appreciable harm to the regulatory process, and that SoCalGas refund ratepayer expenditures and associated shareholder incentives.  Any party may file an Appeal of this Decision within 30 days of the date of issuance.

On April 23, ALJ Kao issued a Ruling Inviting Comments on a consultant report for energy savings and total system benefit goals for energy efficiency program administrators from 2022 to 2032.

Improvements to Rule 21 (R.17-07-007)
On April 7, Commissioner Guzman Aceves issued a Proposed Decision Addressing Remaining Phase 1 Issues.  Opening Comments were submitted on April 27 and Reply Comments on May 3.  On April 8, ALJ Hymes issued a Ruling Directing Comments on Proposed Scope and Schedule for Phase II.  Parties submitted Opening Comments on April 23 and Reply Comments on April 30.

Power Charge Indifference Adjustment (PCIA) (R.17-06-026)
On April 5, ALJ Wang issued a Proposed Phase 2 Decision on PCIA Cap and Portfolio Optimization.  Opening Comments were submitted on April 26 and Reply Comments on May 3.

Distribution Resource Plans (DRP) (R.14-08-013, et al.)
On January 27, ALJ Mason issued a Ruling that grants, in part, the Joint Parties’ Motion for an Order Requiring Refinements to the Integration Capacity Analysis (ICA).  The Ruling groups the Joint Parties’ requests into three categories: ICA Data Validation Refinements, Continuing Improvements to the DRP Data Portals, and Compliance Issues.

Additional proceedings tracked, but where there has been no activity in the last several months:

  • A.17-01-012, et al.: DR Applications & Third-Party DR Providers Load Impact Protocols
  • R.19-01-011: Building Decarbonization
  • R.18-04-019: Climate Change Adaptation