October 8, 2025

Regulatory Update for October 8, 2025

(Covering October 1-7, 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:

State Regulatory Agencies

• California Public Utilities Commission (CPUC)
• California Energy Commission (CEC)
• California Air Resources Board (CARB)

Federal Regulatory Agencies

• Federal Energy Regulatory Commission (FERC)

Independent System Operators (ISO) and Regional Transmission Organizations (RTO)

• California Independent System Operator (CAISO)
• ISO New England (ISO-NE)
• PJM Interconnection (PJM)

Click here to download this update as a PDF

State Regulatory Agencies

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

Proposed Decisions and Resolutions

Application (A.) 22-08-003 (Application of Pacific Gas and Electric Company for Approval of Zonal Electrification Pilot Project)

This decision grants Pacific Gas and Electric Company’s (PG&E) motion to withdraw its application for a zonal electrification project. The decision provides that, as decarbonization strategies are a California policy priority, PG&E is required to create a “lessons learned” document to summarize policy and operational take-aways from the experience of this project that may inform future electrification projects or policy in other proceedings, if relevant. 

Voting Meeting

The CPUC will hold a voting meeting in Bellflower, California on October 9, 2025 at 11:00 a.m. PT.  The energy-related items are on the agenda below:

Item 2. Res G-3606 (San Diego Gas & Electric Company (SDG&E) 2024 Natural Gas Leak Abatement Ratemaking Forecasts and Capital Costs Recovery)

This Resolution denies SDG&E’s 2024 Natural Gas Leak Abatement (NGLA) 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 AL 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 any under-recovered ongoing capital revenue requirements.  This Resolution approves no funding for Best Practices because none of the practices is 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 NGLA Program Memorandum Account for potential recovery in a future general rate case or other proceeding, where it will be subject to a reasonableness review.  The Resolution approves $222,000 for unrecovered ongoing capital costs from previously approved Compliance Plans.  

Item 3. A.22-05-002 (Application of PG&E for Approval of its Demand Response Programs, Pilots and Budgets for Program Years 2023- 2027)

This decision denies the Petition for Modification filed on February 19, 2025, by Clean Energy Alliance, San Diego Community Power, and Mission: Data Coalition, Inc. seeking to modify Decision (D.) 22-12-009.  The Petition for Modification asks that D.22-12-009 be modified to require SDG&E to reinstate ZigBee connections and to enable new ZigBee connections until SDG&E provides new smart meters that provide near real-time energy usage data access.

Item 4. A.12-05-020 (In the Matter of Application of SDG&E for a Certificate of Public Convenience and Necessity for the South Orange County Reliability Enhancement Project)

This decision grants SDG&E’s Petition for Modification of D.16-12-064 to increase the $381 million cost cap established by that decision and adopts $410 million as the increased reasonable and prudent maximum cost cap for the South Orange County Reliability Enhancement Project. 

Item 8. Rulemaking (R.) 20-05-012 (Order Instituting Rulemaking Regarding Policies, Procedures and Rules for the Self-Generation Incentive Program and Related Issues)

This decision establishes the conditions for returning ratepayer funds and closing out all activities related to the ratepayer-funded portion of the Self-Generation Incentive Program (SGIP).  The decision also implements the Greenhouse Gas Reduction Fund portion of SGIP as well as conditions for its closure in 2028.  Also included in this decision are modifications to existing rules for extending SGIP projects and participation in a qualifying demand response program for SGIP’s Residential Solar and Storage Equity budget.

Item 10. Res O-0097

This Resolution O-0097 approves Santa Fe Pacific Pipelines, L.P.’s (SFPP) request for an interim, system-wide, intrastate rate increase of 5.187% under the provisions of Public Utilities Code section 455.3 and General Order 96-B, Energy Industry Rule 8.  This Resolution does not grant any additional increase above 5.187%.  The Commission will consider the entirety of SFPP’s requested increases in SFPP’s consolidated proceeding for A.24-01-020, A.23-01-016, A.22-01-016, and A.21-01-15.

Item 11. Res E-5416

This Resolution approves PG&E request to revise its Bundled Procurement Plan -- Appendix S (Sales Framework) to update PG&E’s methodology for determining Resource Adequacy capacity volumes made available for sale.

Item 15. A.25-04-015 (Application of PG&E for Approval of Zonal Electrification Pilot Project)

This decision extends the statutory deadline in this proceeding until February 2, 2026.

Item 17. A.23-06-022 (In the Matter of the Application of Crimson California Pipeline, L.P. (Crimson) for Authority to Increase Rates for its Crude Oil Pipeline Services)

This decision approves the settlement agreement between Crimson and Phillips 66 Company that resolves all issues in this proceeding.  The settlement agreement includes a 12.52% increase in rates for crude oil pipeline services for the period of August 1, 2023 to July 31, 2024 (Rate Period).  A 12.52% increase in rates achieves an additional $3,518,744 in revenue for the Rate Period.  Phillips 66 is responsible for payment of $2,500,000 while the other shippers on Crimson’s Southern California system will be collectively responsible for payment of $1,018,744 based upon their respective volumes shipped.

Item 25. A.18-05-007 (In the Matter of the Application of SCE for a Certificate of Public Convenience and Necessity: Eldorado-Lugo-Mohave Series Capacitor Project)

This Decision grants SCE’s Petition for Modification of D.20-08-032 to increase the maximum reasonable and prudent cost for the Eldorado-Lugo-Mohave Series Capacitor Project from $239 million to $295 million.

Item 42. R.25-10-XXX (Order Instituting Rulemaking to Oversee the Resource Adequacy Program, Consider Program Reforms and Refinements, and Establish Forward Resource Adequacy Procurement Obligations)

This Order opens a new rulemaking to oversee the Resource Adequacy Program.

Upcoming Workshops and Events

Transportation Electrification Proactive Planning Webinar

The CPUC will host a webinar on October 22, 2025 to host a technical workshop and take stakeholder feedback regarding the Energy Division’s Transportation Electrification Proactive Planning (TEPP) efforts.  As outlined in the Scoping Memo for R.23-12-008, TEPP is focused on zero-emission vehicle planning related to corridor freight charging infrastructure and similar loads such as light-duty charging plazas. This proceeding is focused on improving transportation electrification-specific data, assumptions, and analyses that can ultimately be inputs into existing electric grid planning processes (e.g., Distribution Planning Process, Transmission Planning Process, etc.) that are being developed in other proceedings.  A ruling issued on October 1, 2025 requests stakeholder comments on the inputs and assumptions for TEPP modeling and related information.  Comments in response to the ruling are due October 31, 2025, and reply comments may be submitted by November 14, 2025.

Supplier Diversity En Banc and Business Expo

The CPUC will host its 23rd Annual Supplier Diversity En Banc and Small and Diverse Business Expo in Carson, California on October 6-8, 2025.  This event provides an opportunity for utilities and Load Serving Entities (LSEs) to meet with stakeholders and explore contracting opportunities with small and diverse suppliers.  Additional information, including registration details, 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 or comment deadlines and recent changes to the workshop schedule are reflected below:

• 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.

2024 IEPR Update

The CEC published a Notice of Availability and Proposed Adoption of the 2024 IEPR Update.  As outlined in the Notice of Availability, the CEC is proposing adoption of the 2024 IEPR Update at the October 8 CEC Business Meeting.  Written comments regarding the 2024 IEPR Update were due to the Docket Unit by October 6, 2025.

Electric Program Investment Charge (EPIC)

The 2025 EPIC Symposium was held on October 7, 2025 at the California Natural Resources Agency in Sacramento, California.  As set forth in the agenda, the EPIC Symposium convenes clean energy leaders, policy makers, researchers, entrepreneurs, and other stakeholders to discuss the latest innovations driven by EPIC. 

Renewables Portfolio Standard 10th Edition Guidebook Update

On September 18, 2025, the CEC released the draft Renewables Portfolio Standard Guidebook, Tenth Edition (Guidebook) for public review and comment.  CEC Staff held a remote access workshop to discuss the draft Guidebook on October 6, 2025. Written comments on the Guidebook are due to Docket 21-RPS-02 by 5:00 p.m. PT on October 20, 2025.  Instructions for attending the remote workshop are available in the workshop notice.

Long Duration Energy Storage Program

On September 11, 2025, the CEC hosted a remote access workshop regarding the Draft Energy Storage Permitting Guidebook: Guidance for Behind-the-Meter Installations (Draft Guidebook), funded under the EPIC Program (EPC-19-026).  The workshop provided the grant recipient, the Center for Sustainable Energy, with the opportunity to receive input regarding the Draft Guidebook.  According to the workshop notice, a copy of the Draft Guidebook was made available here 10 business days before the workshop date.  The notice provides that the “workshop will focus on identifying any corrections or substantive omissions to the Draft Guidebook” and “[f]eedback gathered during [the] workshop will inform the publication of the final version of the Guidebook, expected to be published in Q2 2026.”  Written comments regarding the Draft Guidebook are due by 5:00 p.m. PT on October 10, 2025 to Docket No. 23-ERDD-07.

Funding for Electric Vehicle (EV) Charging

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

Notice of Hearing to Adopt EV Charging Infrastructure Reliability Rules

On September 26, 2025, the CEC issued a notice of adoption hearing for its rulemaking to establish regulations for improved EV charger recordkeeping and reporting, reliability and data sharing.  Proposed changes to the EV Charging Infrastructure Reliability Reporting and Performance Standards have been subject to an extended period of stakeholder feedback, which can be accessed on Docket No. 22-EVI-04.

The CEC will consider adopting the proposed regulations on Wednesday, October 8, 2025 at 10:00 a.m. PT.   

Demand Side Grid Support (DSGS) Program

The CEC will host a workshop to present staff’s analysis of the DSGS Program during the 2024 season, with a focus on the Storage Virtual Power Plant performance, which is also referred to as Incentive Option 3.  The workshop notice states that this analysis may inform potential modifications to the DSGS Program Guidelines.  The workshop will be held on Wednesday, October 15, 2025, from 1:30 p.m. to 4:00 p.m. PT, and will be held remote only.  Additional information is available on the event page, here.

Pursuant to a notice issued by the CEC on October 1, the DSGS Program has budgeted funding of $109.5 million, as of the Budget Act of 2025.  From that amount, about $64 million remains after accounting for incentives for past program seasons (including the 2024 season), encumbrances (third-party contracts through 2028), and program administration expenses through the end of the 2024–25 Fiscal Year.  Program staff anticipate having sufficient funding for the 2025 program season incentive payout and continuation of the DSGS Program for the 2026 program season with modifications, to align with the funding level projected to be available after the 2025 incentive payout. Workshops will be announced at later dates to present staff’s analysis of DSGS Program performance in the 2024 program season and present potential changes to the DSGS Program for the 2026 program season.

Gas Research and Development Program

On October 13, 2025, CEC staff will host a remote access scoping workshop regarding staff’s proposed concept for funding research to advance integrated planning to support gas system decommissioning.  According to the workshop notice, “the workshop will conclude with a question-and-answer session and public comment period to advance integrated planning to support gas system decommissioning.”  A meeting agenda will be posted prior to the workshop to Docket No. 23-ERDD-02.  Written comments are due to the Docket Unit by 5:00 p.m. PT on October 20, 2025.

CEC Business Meetings

The next CEC Business Meeting is scheduled for October 8, 2025.  The meeting agenda and backup materials are available here.

CALIFORNIA AIR RESOURCES BOARD (CARB)

Climate Risk Disclosure Laws Update

CARB announced it will be issuing proposed rules for the state’s climate risk disclosure laws, Senate Bills (SB) 253 and 261, on October 14, 2025.  CARB also issued a projected cost of compliance for the laws and shared the disclosure timeline for companies covered by SB 253 to disclose their scope 1 and scope 2 emissions for the first time.  Companies covered by SB 253 should expect to report their scope 1 and scope 2 emissions by June 30, 2026.

Meetings and Workshops

On October 14, 2025, CARB will host a virtual public workshop to discuss introducing gasoline containing up to 15% ethanol (E15) in California.  California gasoline is currently blended with up to 10% ethanol by volume (E10), the maximum ethanol content allowed by the California Reformulated Gasoline Regulations.  At this workshop, CARB staff will provide an overview of the scientific evaluation of E15, current regulatory requirements, and concepts for potential regulatory updates as well as additional topics regarding the use of E15 in California.  Staff will seek stakeholder input through verbal feedback during the workshop and will open a public docket for written comments.  That public docket will be open for four weeks following the workshop through November 11, 2025.

On October 16, 2025, CARB will host a public meeting for the Assembly Bill (AB) 32 Environmental Justice Advisory Committee (EJAC).  EJAC was created under AB 32, the California Global Warming Solutions Act of 2006, to help advise the board 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 the Board in developing the Scoping Plan and any other pertinent matter in implementing AB 32.

On November 6, 2025, CARB will conduct a joint public meeting between CARB, the California Transportation Commission, and the California Department of Housing and Community Development, to coordinate their implementation of policies that jointly affect transportation, housing, and air quality, including interagency efforts.  Presentations will facilitate open dialogue amongst state agencies and the public.

On November 20, 2025, CARB will conduct a public hearing to consider approving for adoption the proposed amendments to the Regulation on Methane Emissions from Municipal Solid Waste Landfills (LMR).  CARB adopted the LMR in 2010 to reduce methane emissions from municipal solid waste landfills, which are the second-largest source of methane emissions in California.  The LMR requires owners and operators to install and optimally operate landfill gas collection and control systems to minimize emissions, monitor surface methane concentration and other performance parameters, repair emission exceedances and other performance issues, conduct source testing of combustion devices used to destroy methane, and report compliance information to CARB and local air districts.

Federal Agencies

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

FERC Commissioner Confirmations

The Senate confirmed Laura Swett and David LaCerte to serve as FERC Commissioners by a 51-47 vote. Laura Swett will serve for a term expiring June 30, 2030, and David LaCerte will serve for a term expiring June 30, 2026.

FERC Conditionally Sunsets 53 Regulations

In response to President Trump’s Executive Order “Zero-Based Regulatory Budgeting to Unleash American Energy,” FERC issued Order 913, in which it voted to conditionally sunset 53 regulations that it claims are outdated, obsolete, and unnecessary.  The proposed removals include regulations on procedure, books and records requirements, smart grid standards, gas supply and contracts, and notice requirements.

FERC issued both a Direct Final Rule and a Notice of Proposed Rulemaking (NOPR).  FERC noted in its Direct Final Rule that unless FERC receives significant adverse comments within 30 days after the rule is published in the Federal Register, the rule will become effective 15 days later, and the regulations would sunset within one year of the rule’s effectiveness. If FERC receives significant adverse comments on a proposed regulation’s sunset, FERC will withdraw that portion of the Direct Final Rule and consider whether to finalize sunsetting those regulations in its NOPR.

Meetings and Conferences

FERC noticed a technical conference on October 21, 2025 to discuss cost-effective ways to reduce the risk of wildfire ignition from the bulk power system.  FERC has directed North American Electric Reliability Corporation (NERC) to prepare a report on the best practices to reduce these risks and to assess the need for new or revised reliability standards.  NERC, in its report, must assess vegetation management, the removal of forest-hazardous fuels by transmission lines, engineering, and operational practices.

FERC noticed its fourth public meeting of the Federal and State Current Issues Collaborative on cross-jurisdictional issues relevant to FERC and state utility commissions, which will take place on November 12, 2025. The meeting will explore topics related to energy infrastructure permitting, and FERC will release an agenda for the meeting by October 29, 2025. The meeting will take place in Seattle, Washington and over Webcast.

Independent System Operators (ISO) and Regional Transmission Operators (RTO)

CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)

Stakeholder Initiatives: Upcoming Meetings and Deadlines

FERC Order No. 1920

CAISO has posted the draft tariff language for the FERC Order No. 1920 compliance filing and will hold a public stakeholder call on October 21, 2025. Comments are due October 16, 2025.  Further information is available here.

2025-2026 Transmission Planning Process

CAISO hosted a public stakeholder meeting on September 24 and September 25, 2025 to discuss the preliminary reliability study results, participating transmission owners’ reliability projects, and updates on other analysis related to the 2025-2026 Transmission Planning Process.  Written comments are due October 9, 2025.  Additional information is available here.

2026 Effective Flexible Capacity Values

CAISO has posted the final 2026 Resource Adequacy Effective Flexible Capacity list.  Additional information is available here.

Storage Design and Modeling Initiative

CAISO has posted the comment template for the Storage Design and Modeling Initiative meeting held on September 29, 2025. Comments are due October 13, 2025.  Further information is available here.

CAISO New Resource Implementation Forum

CAISO will host a New Resource Implementation (NRI) Forum on October 8, 2025.  The objective is to improve transparency surrounding the NRI process and outline expectations.  The forum will be held in person and online.  Additional information is available here.

2025-2026 Transmission Planning Process

CAISO has posted the 2025-2026 Transmission Planning Process preliminary reliability results to its website.  The request window is open until October 15, 2025.  Additional information is available here.

Western Energy Markets Regional Issues Forum

The Western Energy Markets Regional Issues Forum has announced its upcoming hybrid meeting, which will take place at the CAISO in Folsom, California on October 27, 2025.  Registration is requested for in-person attendees, and additional materials will be available prior to the meeting.  Additional information is available here.

ISO NEW ENGLAND (ISO-NE)

2026 Draft Work Plan

ISO New England published a draft of its 2026 Work Plan, which outlines the ISO’s work on continuing projects and new initiatives.  The draft plan includes capacity auction reforms, asset condition project proposal reviews, longer-term transmission planning, dynamic operating reserves, IT implementation of major FERC initiatives, FERC Order 2023 implementation, evaluation of surplus interconnection service rules, and pay-for-performance revisions. NEPOOL participants will discuss the draft plan at its October 9, 2025 Participants Committee Meeting in West Hartford, Connecticut.

PJM INTERCONNECTION (PJM)

Interconnection Changes for Distribution Resources

PJM proposed to FERC simplifying its rules surrounding generation resources interconnecting at the distribution level.  PJM’s proposal would eliminate the “First Use” test, which currently requires distribution-level interconnections to receive a FERC-jurisdictional interconnection agreement, and would instead require distribution-level connections to receive a Wholesale Market Participation Agreement from PJM.  If FERC accepts the proposal, PJM’s rule would be implemented on April 28, 2026.

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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.