July 1, 2025

Regulatory Update for July 1, 2025

(Covering Week of June 23, 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 held a voting meeting in Sacramento, CA on June 26, 2025 at 11:00 am PT.  The following are the results for energy-related items on the agenda:

Item 4. Application (A.)22-07-015 et al. (Crimson California Pipeline and San Pablo Bay Pipeline Rates)

This decision authorizes Crimson California Pipeline, L.P. (Crimson) to increase the rate charged for the intrastate transportation of crude oil on its KLM pipeline to $1.9566 per barrel transported effective September 1, 2022.  The decision authorizes the retroactive charge and collection of the difference between the rates billed by Crimson and the approved rate beginning March 3, 2023.  This decision also authorizes San Pablo Bay Pipeline Company LLC (SPBP) to increase the rates charged for the intrastate transportation of crude oil on its pipeline system to $1.9566 per barrel transported effective March 1, 2023.  The decision further authorizes the retroactive charge and collection of the difference between the rates billed by SPBP and the approved rate beginning March 1, 2023.  Signed, D.25-06-044.

Item 5. 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 2026 PacifiCorp Energy Cost Adjustment Clause Application.  Held to July 24, 2025.  

Item 9. A.23-11-003 (SoCalGas Cost Recovery for Catastrophic Events and COVID-19 Protections)

This decision authorizes partial recovery of costs recorded in Southern California Gas Company’s (SoCalGas) Catastrophic Event Memorandum Account (CEMA) and COVID-19 Pandemic Protections Memorandum Account (CPPMA).  The total capital expenditure/operations and maintenance costs authorized for recovery is $19,231,206, and the requested amount was $58,396,224.  Most of the disallowances are due to understatement of avoided costs in CEMA Subaccount F, which covers certain costs associated with the COVID-19 pandemic.  This decision also authorizes recovery of $2.068 million in waived charges and $297,000 in interest expense associated with the CPPMA.  Authorized costs will be recovered from customer classes using the Equal Cents Per Therm methodology on a 12-month schedule. Held to July 24, 2025.

Item 14. Rulemaking (R.) 22-07-005 (Rulemaking to Advance Demand Flexibility Through Electric Rates)

This decision corrects two errors in Decision (D.) 25-01-039 related to tracking revenues for income-graduated fixed charges (IGFCs).  D.25-01-039 corrected terms related to delivery rates that apply to IGFCs adopted in D.24-05-028.  Shortly after D.25-01-039 was issued, Commission staff identified errors in Ordering Paragraph 1 and Ordering Paragraph 3, which modified how the electric utilities should track IGFC revenues.  This decision confirms that the IGFC balancing accounts remain the appropriate mechanism for the electric utilities to use to track revenue adjustments associated with the IGFC.  Signed, D.25-06-047.

Item 17. Res E-5392 (Annual Administrative Update to Fixed Avoided-Cost Rates for the Renewable Market Adjusting Tariff Program)

This Resolution adopts updated contract prices by Product Category for the feed-in tariff program, known as the Renewable Market Adjusting Tariff (ReMAT), using price data from Renewables Portfolio Standard contracts executed between 2020 and 2024.  In addition, it orders Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and San Diego Gas & Electric Company to amend their ReMAT tariff to reflect the adopted fixed prices by Product Category.  Only the prices for the “As-Available Peaking” category changed for 2025 and the prices for “As-Available Non-Peaking” and “Baseload” remain unchanged.  The 2025 “As-Available Peaking” ReMAT price is $67.99 per MWh and compared to the 2024 “As-Available Peaking” ReMAT price of $71.94 per MWh. Approved.

Item 19. R.23-10-011 (Local Capacity Obligations, Flexible Capacity Obligations, and Refinements of the Resource Adequacy Program)

This decision adopts Local Capacity Requirements for 2026-2028, Flexible Capacity Requirements for 2026, and refinements to the Resource Adequacy (RA) program.  The RA program refinements include adopting an 18% planning reserve margin (PRM), with an extension of the effective PRM procurement target of 1,260-2,300 megawatts (MW) for June-October months, for the 2026 and 2027 RA compliance year, modifying the RA measurement hours to align with the California Independent System Operator’s availability assessment hours, and incorporating the central procurement entity data reporting requirements into the annual RA compliance filing process.  Signed, D.25-06-048.

Item 22. R.25-02-005 (Resource Adequacy Market Price Benchmark)

This decision implements revisions to the methodology the Commission uses when calculating the RA Market Price Benchmark (MPB) utilized in calculating the Power Charge Indifference Adjustment (PCIA).  The Commission is statutorily mandated to ensure that the movement of customers from bundled electric services to unbundled service does not shift costs to customers that remain with the utility or those that depart for Community Choice Aggregator or Direct Access service.  The first revision adopts a single RA MPB utilizing the time restriction on transaction data currently applicable to the local RA MPBs.  The second revision removes affiliate, swap, and duplicative sleeve transactions from the calculation.  Signed, D.25-06-049.

Item 23. A.24-06-005 (SoCalGas Year 30 Gas Cost Incentive Mechanism)

This decision approves SoCalGas’s request for a shareholder reward of $13,865,089 for Year 30 (2023–2024) of the company’s Gas Cost Incentive Mechanism performance.  The Public Advocates Office at the CPUC verified that SoCalGas’s recorded gas costs were $74,269,985 below the benchmark, which results in a reward of $13,865,089 to SoCalGas’s shareholders and a ratepayer benefit of $60,404,896.  Signed, D.25-06-050.

Item 24. Res E-5381 (PG&E Request for Amendment of Mid-term Reliability Contract Approved in Res E-5202)

This Resolution approves an amendment to the contract between PG&E and Corby Energy Storage, LLC, a subsidiary of NextEra Energy Resources Development, LLC, for 125 MW of lithium-ion battery storage.  Whereas the delivery date for the previously approved contract was June 1, 2024, the delivery date in the amended contract is August 1, 2027.  In addition, this Resolution approves the amended contract’s price increase.  Approved.

Item 26. Res E-5404 (SCE Request for Mid Term Reliability (MTR) Resource Contract and Amendments)

This Resolution approves one MTR 100 MW battery energy storage system contract with Westminster Reliability Project, LLC / RWE Clean Energy, LLC, and amendments to two existing MTR geothermal contracts previously executed as part of Phases 2 and 3 of SCE’s MTR Request for Offers.  The two geothermal contracts are a 62 MW contract with Cape Generating Station 3, LLC / Fervo Energy, LLC and a 336 MW contract with Cape Generating Station 4, LLC / Fervo Energy, LLC.   Approved.

Item 28. R.25-06-XXX (Order Instituting Rulemaking for Oversight of Electric Integrated Resource Planning and Procurement Processes)

This Order Instituting Rulemaking (OIR) will be the new primary venue for the Commission’s oversight of the integrated resources planning (IRP) process, which was designed in R.16-02-007 and continued in R.20-05-003.  The primary ongoing requirements for the IRP process are contained in Public Utilities Code sections 454.51 and 454.52, which require the Commission to identify a diverse and balanced portfolio to ensure a reliable electric supply that can integrate renewable energy in a cost-effective manner.  In addition to a focus on reliability, this proceeding is also the primary venue for plans to achieve the goals of Senate Bill (SB) 350 (Stats. 2015, Ch. 547) related to IRP and the environmental goals of SB 100 (Stats. 2018, Ch. 312) for reductions of greenhouse gas emissions from the electricity sector in California.  This proceeding will also be, to the extent necessary, the venue for considering the bundled procurement plans and procurement rules applicable to the three large electric investor-owned utilities, including activities associated with Public Utilities Code section 454.5 and other related issues pursuant to Assembly Bill (AB) 57 (Stats. 2002, Ch. 850, Sec. 3), which returned utilities to full procurement responsibilities.  The OIR finds that an update to these procurement policies and processes may be necessary, and, to the extent relevant, activities will be coordinated with the rulemaking associated with the PCIA in R.25-02-005.  Signed, R.25-06-019.

Item 30. Res O-0096 (Crimson California Pipeline L.P. Withdrawal of Northern Section of KLM Pipeline from Utility Service)

This Resolution O-0096 approves Crimson’s request to withdraw from service on the northern section of the KLM pipeline system extending from Kettleman to the Bay Area in California.  Approved.

CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)

Stakeholder Initiatives: Upcoming Meetings and Deadlines

2025 FERC Billing Rate Adjustment and 2024 FERC Fees Supplemental Billing

CAISO will adjust the 2025 FERC billing rate to $0.117240 and will issue the 2024 FERC fee supplemental billing at the rate of $0.013376. Further information is available here.

Congestion Revenue Rights Modeling and Settlement in the Extended Day-Ahead Market

CAISO has requested comments on the June 12, 2025, stakeholder workshop on Congestion Revenue Rights modeling and settlement in the Extended Day-Ahead Market by July 3, 2025.  Further information is available here.

2024-2025 Transmission Planning Process

CAISO has posted the key selection factors for the two regional transmission solutions that are eligible for competitive solicitation to its website.  Further information is available here.

Annual Policy Initiatives

CAISO has published the 2025 Policy Catalog that describes 2025 stakeholder policy initiative proposals and reflects stakeholder support for these proposals.  Further information is available here.

Cluster 15 Queue

CAISO announced that the Cluster Study for Cluster 15 has begun, and the Queue Report has been posted.  Further information is available here.

Annual Policy Initiatives Roadmap

CAISO has published the Revised 2025 Policy Roadmap, which includes new initiatives and updated timelines for several existing initiatives through the end of 2025.  CAISO incorporated stakeholder feedback from a prioritization survey and a Regional Issues Forum report to identify elements of current policy initiatives.  Further information is available here.

2025-2026 Transmission Planning Process

CAISO has published the 2025-2026 Transmission Planning Process final study plan to its website, available here.

2024-2025 Transmission Planning Process

CAISO has posted the 2024-2025 Board approved Transmission Plan to its webpage.  Further 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.  Further 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 June 27, 2025).  Upcoming workshops and recent changes to the workshop schedule are reflected below:

• July 14, 2025: IEPR Commissioner Workshop on Interconnection (remote access only) POSTPONED TO August 11, 2025
• July 29, 2025: IEPR Commissioner Workshop on Firm Zero-Carbon Resource and Hydrogen (remote and in-person at the California Natural Resources Agency Headquarters, 715 P Street, Sacramento, 95814) – note new time 10:00 am – 4:00 pm
• August 6, 2025: IEPR Commissioner Workshop on Inputs & Assumptions (remote access only)
• August 11, 2025: IEPR Commissioner Workshop on Interconnection (remote access only) – rescheduled from July 14, 2025; note new time 1:00 pm to 5:00 pm
• August 26, 2025: IEPR Commissioner Workshop on Load Modifier 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 (rescheduled from December 2, 2025)

Comments related to the June 25, 2025 workshop are due to the Docket Unit (Docket No. 25-IEPR-05) by 5:00 pm PT on July 9, 2025.  Additional instructions for submitting written comments are available in the workshop notice.

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 (Public Resources Code (PRC) section 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 (PRC section 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 pm PT on August 18, 2025.  Instructions for submitting written comments are also available here.

Electric Program Investment Charge (EPIC)

On May 7, 2025, the CEC circulated a “Save the Date” for the 2025 EPIC Symposium.  The symposium will be held on October 7, 2025 at the California Natural Resources Agency in Sacramento.  Registration and event details are forthcoming.

Hydrogen Refueling Infrastructure

On Monday, June 30, the CEC released the “Joint Agency Staff Report on Assembly Bill 126: 2024 Annual Assessment of the Hydrogen Refueling Network in California” pursuant to AB 126 (Reyes, Chapter 319, Statutes of 2023), which required the CEC and California Air Resources Board to jointly review and report on progress toward establishing a hydrogen fueling infrastructure throughout the state.  The report discusses existing station capacity, including closed and/or offline stations.

As of November 4, 2024, 42 hydrogen fueling stations were open to the public, and 20 additional stations had been offline for more than 30 days, many for more than a year, for various reasons. These 20 offline stations are expected to reopen in the future, and three new stations have opened since the last AB 126 report. The CEC’s Clean Transportation Program has allocated nearly $234 million in public hydrogen infrastructure, primarily for light-duty vehicles, though this allocation reflects Shell’s cancelled agreement for 50 stations and one declined award from Phillips 66. Through CEC’s funding and private investments, California is expected to have 129 hydrogen refueling stations by 2030 with at least 8 stations capable of fueling medium- and heavy-duty vehicles. As of November 4, 2024, grant recipients have contributed nearly $100 million in match funding and will contribute another $59 million by the end term (in 2026) of the CEC grant agreements funded under GFO-19-602. These contributions will bring the total public and private investment in hydrogen refueling stations under the Clean Transportation Program to nearly $420 million.

A link to the report is available here.

CEC Business Meetings

The next CEC Business Meeting is scheduled for July 10, 2025.  The meeting agenda and backup materials are available here.

CALIFORNIA AIR RESOURCES BOARD (CARB)

Low Carbon Fuel Standard Update

CARB announced that the updated Low Carbon Fuel Standard regulation will take effect beginning July, 1, 2025, following approval by the Office of Administrative Law. The amended regulation sets a declining target for the carbon in transportation fuels used in California; producers that do not meet established benchmarks buy credits from those that do.

MINNESOTA PUBLIC UTLILITIES COMMISSION (MPUC)

At this week’s July 1, 2025 agenda meeting, the MPUC considered: (1) adoption of the ALJ’s underlying findings regarding Northern Crescent Solar LLC’s application for a solar energy generating system site permit and battery energy storage system site permit for two solar projects in Faribault County (Docket Nos. IP7135/GS-22-57; IP7135/ESS-24-238), (2) adoption of the ALJ’s underlying findings as related to Iron Pine Solar Power, LLC’s application for a site permit and route permit for its Iron Pine Solar Project (325-MW generating system) and 230 kV Transmission Line, respectively (Docket Nos. IP7114/GS-23-414; IP7114/TL-23-415), (3) approval of Minnesota Power’s proposed 2025 capital structure and request to issue securities (Docket No. E015/S-25-138), and (4) approval of the request for additional funding and the proper methodology affected transmission owners should use to calculate the payback period of grid enhancing technologies (GETs), including the threshold value for GETs projects to be included in a GET report implementation plan and whether transmission owners should be required to evaluate cost effectiveness or payback periods of GETs projects addressing locations likely to experience high levels of congestion during the next five years (Docket No. E999/M-25-99).

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

On June 30, in 191 FERC ¶ 61,237, FERC issued a Final Rule to remove references to the Council on Environmental Quality’s (CEQ) rescinded regulations from FERC’s part 380 Regulations Implementing the National Environmental Policy Act  (NEPA) and part 385 Rules of Practice and Procedure.  FERC states that this effort was directed by President Trump’s Unleashing American Energy, Executive Order (E.O.) 14154 issued on January 20, 2025, which calls for unleashing American energy dominance through efficient permitting. In response to President Trump’s E.O. 14154, the CEQ rescinded its NEPA implementing regulations. FERC’s revisions remove all references to the now inoperative CEQ regulations.  The Final Rule finds that under 5 U.S.C. § 553(b)(B), notice-and-comment rulemaking procedures are not required because it merely clarifies and corrects FERC’s NEPA procedures by removing references to CEQ’s rescinded regulations. The Final Rule becomes effective 45 days after publication in the Federal Register.

In connection with the Final Rule, FERC also released a Staff Guidance Manual on Implementation of The National Environmental Policy Act.  The FERC staff manual provides details on how staff will: assess what actions are subject to NEPA’s procedural requirements and the requisite level of NEPA review; ensure that relevant environmental information is identified and considered early in the process to support informed decision making; conduct coordinated, consistent, predictable, and timely environmental reviews, and reduce unnecessary burdens and delays; and implement NEPA’s mandates regarding lead and cooperating agency roles, time limits, and applicant preparations of environmental documents. 

On June 26, FERC held its June Open Meeting. Summaries of orders voted on at the meeting are available here.

On June 16, FERC posted the Order No. 1920 compliance filings schedules.  Order No. 1920 requires transmission providers to submit two compliance filings.  The first compliance filing encompasses all of Order No. 1920’s requirements except for those related to interregional transmission coordination.  The second compliance filing concerns only interregional transmission coordination requirements for transmission providers.  Since FERC issued Order No. 1920 and subsequent rehearing orders, and following motions filed by transmission providers or Relevant State Entities, FERC has provided extensions of time to submit both compliance filings.  The new deadlines are summarized by transmission planning region.

Order No. 1920 additionally requires transmission providers to hold a six-month Engagement Period during which Relevant State Entities may participate in a forum for negotiating (1) an ex ante cost allocation method or methods for selected Long-Term Regional Transmission Facilities; and/or (2) a State Agreement Process – a process by which one or more Relevant State Entities may voluntarily agree to a cost allocation method for Long-Term Regional Transmission Facilities (or a portfolio of such Facilities) either before or no later than six months after the facilities are selected in the regional transmission plan for purposes of cost allocation.  In Order No. 1920-A, FERC stated that it will grant an extension of the Engagement Period for up to six additional months, if Relevant State Entities request additional time.  The schedule also notes where FERC has granted Relevant State Entities’ requests to extend the Engagement Period. 

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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.