August 5, 2025

Regulatory Update for August 5, 2025

(Covering Week of July 28, 2025)

Our energy regulatory team has compiled a list of state and federal energy regulatory developments to keep you up to speed on key energy regulatory matters from across the United States. Stoel’s energy regulatory team is always available to answer questions about any of these developments. Click here to meet the energy regulatory team.

Jump to the following jurisdictions:

• California Public Utilities Commission
• California Independent System Operator
• California Energy Commission
• California Air Resources Board
• Minnesota Public Utilities Commission
• Federal Energy Regulatory Commission

Click here to download this update as a PDF

CALIFORNIA PUBLIC UTILITIES COMMISSION (CPUC or COMMISSION)[1]

Proposed Decisions and Resolutions

None to report.

Voting Meeting

The CPUC will hold a voting meeting in Sacramento, California on August 14, 2025 at 11:00 a.m. The following are energy-related items on the agenda:

Item 3. Resolution (Res) E-5398 (PacifiCorp Cap-and-Trade Program) 

This Resolution directs PacifiCorp to remove costs for compliance with the Washington Cap-and-Invest Program from California rates from Advice Letter (AL) 751-E. The Commission finds that California PacifiCorp ratepayers would face additional costs if rates include costs from both the California Cap-and-Trade Program and the Washington Cap-and-Invest Program for the same emissions. The Resolution finds that this issue should be addressed once the state agencies responsible for each program finalize an agreement to harmonize the two systems. The respective state agencies responsible for these programs, the California Air Resources Board and the Washington Department of Ecology, are currently considering an agreement that would link their carbon markets and determine a unified compliance obligation for utilities, such as PacifiCorp, that operate under both systems. Lastly, the Commission directs PacifiCorp to determine Washington Cap-and-Invest Program costs already collected or costs owed from California ratepayers in either the 2025 or the 2026 PacifiCorp Energy Cost Adjustment Clause Application.

Item 4. Res E-5400 (2024-2027 Energy Efficiency Portfolio Business Plans for Northern California Rural Regional Energy Network and Central California Rural Regional Energy Network)

This Resolution approves the revised 2024-27 Energy Efficiency Portfolio Business Plan for Northern California Rural Regional Energy Network and the revised 2024-27 Energy Efficiency Portfolio Business Plan for Central California Rural Regional Energy Network. The cost is $60,029,938 to Pacific Gas and Electric Company (PG&E) customers, $7,267,800 to SCE customers, and $2,180,340 to SoCalGas customers for a four-year period.

Item 7. Res G-3605 (SoCalGas’s 2024 Compliance Plan, Forecasts, and Caps for Its Natural Gas Leak Abatement Program)

This Resolution approves in part and denies in part SoCalGas’s 2024 Natural Gas Leak Abatement Compliance Plan and the ratemaking forecasts as presented in AL 6277-G-B. SoCalGas requested a forecasted total revenue requirement of $483.12 million. This Resolution approves $102 million for Blowdown Reduction Activities, as it is the sole cost-effective measure in the program. All other costs for Best Practices and Research Development & Demonstration are denied. An additional $4.245 million for SoCalGas’s Natural Gas Leak Abatement Program Administration is authorized for recording in the Natural Gas Leak Abatement Program Memorandum Account for potential recovery in a future general rate case or other proceeding, where it will be subject to reasonableness review. The Resolution approves $78.8 million for ongoing capital undercollections from previously approved Compliance Plans.

Item 9. A.24-06-01 (Application of Pacific Gas and Electric Company for Authority to Issue Wildfire Rate Relief Bonds)

This decision finds that the request by PG&E to issue bonds and securitize up to $2.356 billion fails to meet the public interest standard required by Pub. Util. Code § 850.1(a)(1)(A), and denies PG&E’s request in its entirety. The decision finds that PG&E’s proposal, with a one-year bill credit and a nine year bill increase, does not meet the public interest standard required by Pub. Util. Code § 850.1(a)(1)(A)(ii)(II) because PG&E fails to establish short-term and long-term economic benefits to ratepayers and otherwise fails to establish the proposed transaction meets any of the other considerations under the public interest standard, including whether the proposed transaction maintains the safe and reliable operation of the utility, or maintains or improves the quality of service to public utility ratepayers or maintains or improves the financial condition of the utility.

Item 16. R.24-01-017 (Order Instituting Rulemaking to Continue Implementation and Administration, and Consider Further Development, of California Renewables Portfolio Standard Program)

This decision denies the request from PG&E, Southern California Edison Company, and San Diego Gas & Electric Company (SDG&E), as made in their respective, individual 2024 Renewable Portfolio Standard (RPS) plans, for the Commission to adopt a framework for pre-approval of short-term RPS transactions based on the transactions’ compliance with achievable, upfront standards. This decision maintains the California RPS program rule set forth in Decision (D.)14-11-042 requiring investor-owned utilities to seek approval from the Commission concerning the review of short-term RPS transactions through submission of Tier 1 Advice Letters.

Item 17. Resolution (Res) E-5409 (PG&E Mid-Term Reliability Procurement)

This Resolution approves PG&E’s request for approval of one mid-term reliability (MTR) long-term resource adequacy agreement with energy settlement storage contracts with Calpine Corporation’s Pastoria Power, LLC (owner of Pastoria Power Bank Project) for a 15-year contract term for a total of 80 megawatts of nameplate capacity. Under the contract, deliveries are expected to begin on July 1, 2026. PG&E procured this resource to satisfy a portion of its MTR requirement.

Item 19. Res G-3606 (SDG&E 2024 Natural Gas Leak Abatement (NGLA) Ratemaking Forecasts and Capital Costs Recovery)

This Resolution denies SDG&E’s 2024 Natural Gas Leak Abatement ratemaking forecasts as presented in AL 3285-G-A for costs for its 2024 Compliance Plan. SDG&E forecasts a total revenue requirement of $24.859 million in Advice Letter 3285-G-A: $22.919 million for Best Practices; $1.29 million for Research, Development, and Demonstration (RD&D) projects; $0.428 million for Program Administration; and $0.222 million for under-recovered ongoing capital revenue requirement. Best Practice proposals are described in Attachment A, Safety Policy Division’s (SPD) Review of SDG&E’s 2024 NGLA Compliance Plan. This Resolution approves no funding for Best Practices because none of the practices are cost-effective. Costs for RD&D are also denied. SDG&E is authorized to record up to $0.428 million for NGLA Program Administration, if applicable, in the Natural Gas Leak Abatement Program Memorandum Account (NGLAPMA) for potential recovery in a future general rate case or other proceeding, where it will be subject to reasonableness review. The Resolution approves $222,000 for unrecovered ongoing capital costs from previously approved Compliance Plans.

Item 39. Rulemaking (R.) 25-8-XXX (Order Instituting Rulemaking to Update Distribution Level Interconnection Rules and Regulations)

The Commission opens this rulemaking to consider refinements to the interconnection of distributed energy resources under Electric Tariff Rule 21 (Rule 21) of PG&E, Southern California Edison Company, and SDG&E, and the equivalent tariff rules of the small and multi-jurisdictional electric utilities. The purpose of this proceeding is to update and improve Rule 21 and associated interconnection procedures concerning the safety and reliability of the electric grid as distributed technologies continue to evolve, promote greater transparency and certainty around interconnection processes, and to contain costs for all ratepayers that use the electric grid.

Upcoming Events

Workshop on Customer-Generated Renewables for Priority Communities (R.25-01-005)

On August 20, 2025, beginning at 9:00 a.m., the Commission will host an in-person workshop at the Granlibakken Tahoe Resort to discuss issues in the Customer-Generated Renewables proceeding. Specifically, the workshop is designed to provide guidance for small multi-jurisdictional utilities (Bear Valley, Liberty Utilities, and PacifiCorp) regarding customer generation tariffs and consumer protections. Additional information and attendance details are available here.

General Order (GO) 131-E Pilot Program Metrics Workshop (R.23-05-018)

On August 21, 2025, from 3:00 p.m. to 5:00 p.m., the Commission will host a workshop to present the proposed pilot project metrics and to receive verbal input from parties. In D.25-01-055, the Commission adopted new GO 131-E, superseding GO 131-D, and directed Energy Division staff to administer a pilot program to evaluate the Commission’s existing California Environmental Quality Act (CEQA) review process for electric transmission projects and evaluate ways to accelerate existing CEQA processes. The workshop can be accessed here, and the meeting password is : YPkYN8XZe38.

CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)

Stakeholder Initiatives: Upcoming Meetings and Deadlines

Gas Resource Management

CAISO will hold calls relating to the Gas Resource Management initiative on August 12 and August 13, 2025. The August 12 call will review the straw proposal that was published on July 25, 2025. The August 13 call is a technical workshop relating to the implementation of the gas nomogram within the CAISO administered markets.  Additional information is available here.

2026 Effective Flexible Capacity Values for Resource Adequacy Resources

CAISO has posted the preliminary 2026 Resource Adequacy Effective Flexible Capacity list. Scheduling coordinators are requested to review their information and submit comments by August 20, 2025.  Additional information is available here.

Interconnection Process Enhancements 5.0

CAISO will post a straw proposal for the Interconnection Process Enhancements 5.0 initiative by end of day August 4, 2025, and will host a stakeholder workshop on August 11, 2025. Written comments are due August 25, 2025.  Additional information is available here.

Markets Training: CAISO Balancing Authority Participation Rules

CAISO will offer a market-focused training session on August 18, 2025, tailored for Scheduling Coordinators involved in or impacted by the upcoming Spring 2026 launches of Day-Ahead Market Enhancements (DAME), Extended Day-Ahead Market (EDAM), and EDAM ISO Balancing Authority Area Participation Rules.  Additional information is available here.

CPUC Annual Resource Adequacy Subpoena

The CPUC served its annual Resource Adequacy subpoena on CAISO on July 17, 2025. The CPUC is requesting data from CAISO in 31 broad categories. The due date for any objections to the production of responsive information is August 11, 2025 at 12:00 p.m. Additional information is available here.

California Energy Commission Demand Response Data Request

The CEC has requested confidential demand response (DR) data to support its work related to supply side DR. Specifically, the data supports: (1) testing proposals under the supply-side DR qualifying capacity (QC) working group and determining incremental capacity, (2) calculating incentives under the Demand Side Grid Support program Option 2 incentive for market-integrated DR, and (3) implementing a comparison group-based load impact measurement methodology. This data request includes confidential demand response bid, schedule, settlement, and registration data. The due date for any objections to the release of this data is August 26, 2025 at 12:00 p.m. Additional information is available here.

2026 Import Capability Assignment

CAISO has posted the CAISO Maximum Resource Adequacy Import Capability for Year 2026 document, as a first step to the 2026 import capability assignment process. Additional information is available here.

2025 Intra-Cluster Reliability Network Upgrade Prioritization

CAISO has posted its 2025 Intra-Cluster Reliability Network Upgrade Prioritization Study Plan and Methodology document, and a list of Interconnection Customer projects with qualifying Reliability Network Upgrades where available capacity to interconnect earlier may exist. Eligible interconnection customers will receive an email with application instructions. Additional information is available here.

Transmission Development Forum

CAISO, in conjunction with the CPUC and participating transmission owners, will hold its biannual stakeholder call on July 30, 2025, to provide status updates on the transmission planning process and network upgrades identified in the generation interconnection process. Written comments on the stakeholder call discussion are due August 13, 2025. Additional information is available here.

CALIFORNIA ENERGY COMMISSION (CEC)

2025 Integrated Energy Policy Report (IEPR)

The CEC has released the 2025 IEPR workshop schedule and opened a new proceeding number (25-IEPR-01) for the 2025 IEPR. Workshop topics and dates included in the notice are below (note: the workshop schedule is subject to change and the current schedule was released on July 2, 2025). Upcoming workshops and recent changes to the workshop schedule are reflected below:

• July 29, 2025: IEPR Commissioner Workshop on Firm Zero-Carbon Resources and Hydrogen (remote and in person at the California Natural Resources Agency Headquarters, 715 P Street, Sacramento, California 95814) – note new time: 9:30 a.m. to 5:00 p.m.
  • Written comments are due to the Docket Unit by 5:00 p.m. on August 19, 2025
• August 6, 2025: IEPR Commissioner Workshop on Energy Demand Forecast Inputs and Assumptions (remote access only). The meeting schedule is available here.
  • Written comments are due to the Docket Unit by 5:00 p.m. on August 20, 2025
• August 11, 2025: IEPR Commissioner Workshop on Accelerating Interconnection and Energization (remote access only)
  • Written comments are due to the Docket Unit by 5:00 p.m. on August 25, 2025
• August 26, 2025: IEPR Commissioner Workshop on Energy Demand Forecast Load Modifier Scenario Design (remote access only)
• November 13, 2025: IEPR Commissioner Workshop on Load Modifier Results (remote access only)
• December 11, 2025: IEPR Commissioner Workshop on Forecast (remote access only) – rescheduled from December 2, 2025

On July 22, 2025, the CEC released a Revised Scoping Order for the 2025 IEPR, which updates the original Scoping Order posted in March 2025.

Assembly Bill (AB) 3 California Offshore Wind Advancement Act

On June 18, 2025, CEC staff hosted a remote access workshop to present CEC staff’s proposed scope and strategy for developing the reports required by AB 3, and to receive public comment on staff’s proposals. Staff’s Scoping Document and Literature Assessment, as well as all related workshop items, can be accessed here. Under AB 3, the CEC is required to prepare and submit reports to the Governor and Legislature after consulting with various state agencies as follows:

• Report 1 is a second-phase plan for seaport readiness due by December 31, 2026 (Pub. Res. Code, § 25991.8).
• Report 2 is a feasibility study of achieving 50% and 65% in-state assembly and manufacturing of offshore wind energy projects due by December 31, 2027 ( § 25991.9).

The CEC issued a 30-day extension to the original July 18, 2025 comment deadline. Written comments on the Scoping Document and the general workshop topics are now due to Docket No. 25-AB-03 by 5:00 p.m. on August 18, 2025. Instructions for submitting written comments are also available here.

Electric Program Investment Charge (EPIC)

The CEC has opened registration for the 2025 EPIC Symposium, which will be held on October 7, 2025, at the California Natural Resources Agency in Sacramento. The EPIC symposium is held in collaboration with the state’s three largest investor-owned utilities, and it convenes clean energy leaders, policy makers, researchers, entrepreneurs, and other stakeholders to discuss the latest innovations driven by EPIC. In-person attendance is limited due to venue capacity, so early registration is encouraged. Additional information and the registration link are available here.

Electric Vehicle (EV) Charger Reliability

On June 27, 2025, the CEC issued a notice of proposed rulemaking to establish regulations for EV charger recordkeeping and reporting, reliability, and data sharing. These regulations would apply to EV charging ports installed in California, for purposes of tracking the reliability of publicly or ratepayer-funded fast-charging ports and to set a 97% uptime standard. The proposed express terms are available here and a CEC staff report on the proposed regulations is available here.

The CEC will host a public hearing on the proposed regulations on Wednesday, August 13, 2025 at 10:00 a.m. The public hearing can be attended either in person (715 P Street, Sacramento, California 95814) or remotely via Zoom. Additional information is available here.

Workshop on EV Load Modeling for Publicly Owned Utilities

The CEC will host a workshop on August 7, 2025 from 10:30 a.m. to 12:00 p.m. to showcase an EV charging load estimation modeling framework and toolset. This toolset is being developed in partnership with the Pacific Northwest National Laboratory (PNNL). During the workshop, CEC and PNNL staff will present technical details of the model’s methodology and demo a prototype version of an interactive web tool they are developing for use by publicly owned utility (POU) grid planning staff. CEC staff will also discuss how PNNL’s work is connected to the Electric Vehicle Service Equipment Deployment and Grid Evaluation (EDGE) mapping and visualization tool (EDGE tool). This workshop is designed specifically for POU distribution planning staff and will include a request for feedback and assistance. Additional information and attendance information is available here.

Demand Side Grid Support Program

CEC staff will host a remote workshop from 1:30 p.m. to 4:00 p.m. on August 14, 2025 “to present staff’s analysis of the performance of Demand Side Grid Support (DSGS) Program during the 2024 season,” with a focus on Storage Virtual Power Plant (VPP) performance. Additional information, including remote access instructions, is available in the workshop notice.

New Funding Announced for EV Charging

On August 5, 2025, the CEC announced the launch of Fast Charge California Project, which includes up to $55 million in-state funding for up to 100% of the installation costs for EV chargers at businesses and public sites across the state. Funding applications will be accepted through October 29, 2025, and priority will be given to tribal areas and low-income and underserved communities. Eligibility details and other application requirements are available here.

CEC Business Meetings

The next CEC Business Meeting is scheduled for August 13, 2025. The meeting agenda and backup materials are available here.

CALIFORNIA AIR RESOURCES BOARD (CARB)

Meetings and Workshops

On August 14, 2025, CARB will host a public meeting for the Assembly Bill (AB) 32 Environmental Justice Advisory Committee (EJAC). EJAC was created under AB 32 to help advise CARB in developing the Climate Change Scoping Plan and on pertinent issues related to AB 32. The California Global Warming Solutions Act of 2006 calls for CARB to convene the EJAC, to advise CARB in developing the Scoping Plan, and any other pertinent matter in implementing AB 32.

On September 25, 2025, CARB will conduct a public hearing to consider proposed amendments to the Advanced Clean Fleets (ACF) and the Low Carbon Fuel Standard (LCFS) regulations. According to CARB, the proposed amendments would provide more flexibility to public agency utilities subject to the State and Local Government (SLG) requirements of the ACF regulation. This rulemaking also would repeal Cal. Code Regs., tit. 13, §§ 2014 and 2015, which contains the drayage and high priority and federal (HPF) fleet requirements of the ACF regulation. In January 2025, CARB withdrew its request for a waiver and authorization for the addition of the ACF regulation to California’s emissions control program foreseeing that the waiver request to U.S. EPA would not be granted. The proposed amendments will also amend the LCFS Regulation set forth in Cal. Code Regs., tit. 17, § 95486.3, to provide stronger credit support for hydrogen stations.

MINNESOTA PUBLIC UTILITIES COMMISSION (MPUC)

At its August 7, 2025 agenda meeting, the MPUC will consider: (1) adoption of the Administrative Law Judge’s (ALJ) findings and recommendations for the site permit requested for the 200 MW Gopher State Solar Project, and approval of the site permit (Docket No. IP7127/GS-24-106); (2) adoption of the ALJ’s findings and recommendation regarding the 235 MW Coneflower Solar Project site permit application, and approval of the site permit (Docket No. IP7132/GS-24-215); and (3) acceptance of Xcel Energy’s Renewable*Connect Pilot, Flex, and Long Term Programs compliance filing and tracker report, and approval of the associated revised tariff sheets, rates, and neutrality charges (Docket No. E002/M-25-184).

Additionally, on August 4, 2025, the Minnesota Court of Appeals rendered its opinion affirming the MPUC’s May 30 and August 16, 2024 Orders authorizing the modification of existing contracts between developers and Xcel Energy, specifically authorizing a change in bill credit type in those contracts from the applicable retail rate (ARR) to the value of solar (VOS) (Case Nos. A24-1450; A24-1454; A24-1455; A24-1700; A24-1741; A24-1750). The opinion is available here.

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

FERC held its July Open Meeting on July 24, 2025 from 10:00 a.m. to 11:00 a.m. ET. The Commission issued Order No. 909, Reliability Standards for Frequency and Voltage Protection Settings and Ride-Through for Inverter-Based Resources, which approved reliability standards aimed at protecting grid reliability as intermittent power generation technologies increase penetration of the grid. The standards are the latest in the Commission’s series of grid reliability orders pertaining to inverter-based resources (IBRs), most commonly wind and solar generators.

Developed by the North American Electric Reliability Corporation (NERC), the standards address issues regarding IBR performance and require IBRs to stay connected to the grid during voltage and frequency disturbances to avoid the loss of power from IBRs, also known as “ride-through” capability. The standards are a response to the broader directive in FERC’s Order No. 901, issued in October 2023, which instructed NERC to develop comprehensive IBR-related reliability standards over a three-year period.

The final rule largely adopts the proposals from the Commission’s December 2024 Notice of Proposed Rulemaking. Historically, most mandatory reliability standards were designed for traditional synchronous generators. IBRs use power electronics to convert direct current to alternating current. Order No. 909 aims to ensure that IBRs are required to meet reliability expectations similar to synchronous generators. The final rule becomes effective 30 days after publication in the Federal Register.

Also at the July Open Meeting, FERC issued 192 FERC ¶ 61,077, which partially grants PJM’s Order Nos. 2023 and 2023-A compliance filing, and directs PJM to submit a further compliance filing, including any necessary revisions to its tariff, within 60 days of the date of the order. FERC granted PJM several independent entity variations, finding them to be just and reasonable, not unduly discriminatory, and consistent with the goals of Order Nos. 2023 and 2023-A. Notable independent entity variations include: retention of PJM’s three-phase cycle process instead of the pro forma cluster study structure; retention of PJM’s 180-day application window and 90-day review period instead of the pro forma 45-day window to accommodate PJM’s large volume of interconnection requests and provide more preparation time; approval of PJM’s request to hold scoping meetings by transmission owner zone, not RTO-wide, due to PJM’s large footprint; and retaining the unilateral interconnection customer option for a one-year commercial operation extension post-Generator Interconnection Agreement execution instead of a three-year extension.

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[1] Per the CPUC’s Rules of Practice and Procedure Rule 14.3, comments on proposed decisions are due 20 days after issuance of the proposed decision, and reply comments are due five days thereafter.  Comments on draft resolutions are due 20 days after the draft resolution appears in the CPUC’s daily calendar, per Rule 14.5.