September 17, 2025

Regulatory Update for September 17, 2025

(Covering Week of September 8, 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

Application (A.) 25-04-015 (Application of San Diego Gas & Electric Company for Authority to Establish a Ratemaking Mechanism for Energization Projects Pursuant to Senate Bill 410)

This decision authorizes San Diego Gas & Electric Company (SDG&E) to establish a new Electric Energization Memorandum Account (EEMA) to record energization costs that are incremental to the energization costs approved in SDG&E’s 2024 General Rate Case (GRC). SDG&E is authorized to record a total of $51.188 million of incremental costs to the EEMA: $10.561 million in 2024, $20.793 million in 2025, and $19.834 million in 2026. This represents an 83 percent reduction of SDG&E’s requested cap of $310.127 million from 2024 to 2026. SDG&E’s initial request would have doubled the amount authorized to spend on energization-related projects by its 2024 GRC. This decision authorizes an 18 percent increase. This decision provides guidance for SDG&E to request revisions to the cap via petition for modification. In its next GRC application, SDG&E must demonstrate that the costs recorded to the EEMA were just and reasonable.

Voting Meeting

The CPUC will hold a voting meeting in San Francisco, California on September 18, 2025, at 11:00 a.m. PT.  The following are energy-related items on the agenda:

Item 2. 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 (NGLA) 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 NGLA Program Administration is authorized for recording in the NGLA Program Memorandum Account for potential recovery in a future GRC or other proceeding, where it will be subject to a reasonableness review.  The Resolution approves $78.8 million for ongoing capital undercollections from previously approved Compliance Plans. 

Item 3. Res G-3606 (SDG&E 2024 NGLA Ratemaking Forecasts and Capital Costs Recovery)

This Resolution denies SDG&E’s 2024 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.  Best Practice proposals are described in Attachment A, the Safety Policy Division’s Review of SDG&E’s 2024 NGLA Compliance Plan.  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 GRC 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 8. Res ALJ-482 (Appeal by Silicon Valley Clean Energy Authority of Citation No. E-4195-0143)

This Resolution resolves Silicon Valley Clean Energy Authority’s appeal of Citation Number E-4195-0143 issued by the Commission’s Consumer Protection and Enforcement Division. Citation E-4915-0143 cites and fines Silicon Valley Clean Energy Authority for failing to procure certain of its June, July, August, and September 2023 Year-Ahead System RA requirements and for failing to file its Year-Ahead System RA compliance filing at the time and in the manner required. This Resolution denies the appeal.

Item 10. Application (A.) 23-01-008 (Application of SDG&E for Authority to Update Marginal Costs, Cost Allocation, and Electric Rate Design)

This decision addresses the 2024 GRC Phase 2 proceeding of SDG&E. This decision adopts three settlement agreements: (1) the Partial Settlement Agreement, which resolves cost allocation, creation of a Medium Commercial Class, base time-of-use rates, and most of the other contested issues in this proceeding; (2) the Marginal Cost Settlement Agreement that includes proposals to set marginal costs used in cost allocation and rate design; and (3) the Medical Baseline Settlement Agreement that provides for a line-item medical baseline discount. This decision also adopts the system percentage of change methodology to update rates, resolves other bill presentment issues that were raised by parties, and approves SDG&E’s other uncontested proposals.

Item 11. Rulemaking (R). 20-05-003 (Order Instituting Rulemaking to Continue Electric Integrated Resource Planning and Related Procurement Processes)

This decision grants, with modifications, the petition for modification (PFM) of D.23-02-040 and D.24-02-047 filed by the Southern California Edison Company (SCE), seeking a waiver of the requirements for bridge contracts for resources required by D.21-06-035 and D.23-02-040, for the months not including July, August, and September of each year. SCE’s PFM argues that there is no short-term reliability needed for these bridge resources during the lower-demand months, and that load serving entities (LSEs) that have met their month-ahead system RA requirements should not be required to procure additional bridge resources not needed for short-term reliability. According to the proposed decision, this decision goes beyond the relief requested by SCE and eliminates the option for LSEs to use bridge contracts as an alternative compliance mechanism for the long-term procurement requirements of D.21-06-035 and D.23-02-040 for all months of the year, relieving ratepayers of the additional costs of those bridge resources that do not provide significant short-term reliability benefits. The decision determines that, for the purposes of satisfying procurement obligations in D.21-06-035 and D.23-02-040, the RA month-ahead requirements should provide sufficient incentive to procure the same types of resources included in most bridge contracts, if such contracts prove necessary for short-term reliability purposes.

Item 25. R.25-09-XXX (Order Instituting Rulemaking to Enhance Demand Response in California)

This Order Instituting Rulemaking seeks to evaluate and enhance the consistency, predictability, reliability, and cost-effectiveness of demand response resources. The rulemaking will update the demand response guiding principles, policies, and data system and process requirements.

Item 26. A.24-09-001 (Application of Southwest Gas Corporation for Authority to Increase Rates and Charges for Gas Service in California, Effective January 1, 2026)

This interim decision grants the motion filed by Southwest Gas Corporation to establish a GRC Memorandum Account to track changes in its revenue requirement for the period beginning January 1, 2026, through the effective date of the Commission’s final decision regarding Southwest Gas’s revenue requirement increase request through A.24-09-001, if the decision is issued after January 1, 2026.

Item 27. 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 PFM 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 43. A.23-05-010 (SCE 2025 Test Year GRC Application)

The decision approves a test year base revenue requirement of $9.756 billion for SCE for 2025-2028.  The adopted amount is a 13.68 percent increase over SCE’s current authorized revenue requirement compared to SCE’s requested 22.15 percent increase.  This decision also authorizes post-test year revenue requirement adjustments of $453 million for 2026 (a 4.64 percent increase), $411 million for 2027 (a 4.03 percent increase), and $374 million for 2028 (a 3.52 percent increase), along with the adoption of a post-test year ratemaking mechanism.  SCE requested approximately $5.104 billion in capital expenditures for wildfire mitigation from 2025 to 2028, and the decision approves approximately $3.085 billion of total capital expenditures for wildfire mitigation.  SCE is directed to implement the 2025 test year revenue requirement in rates beginning October 1, 2025, or as soon thereafter as it may be effected.  The incremental revenue increase that has accrued from January 1, 2025, through September 30, 2025, will be amortized over a 24-month period.

Upcoming Workshops and Events

R.21-06-017 (High DER Proceeding)

The CPUC will host its quarterly Integration Capacity Analysis (ICA) meeting on Wednesday, October 1, 2025, from 9:00 a.m. to 3:30 p.m. PT.  The ICA workshop provides an opportunity for the utilities to present their ICA reports, including discussion on known issues, improvements, validation measures, and stakeholder feedback.  The workshop will be held remotely via Webex and registration is available here.

CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)

Stakeholder Initiatives: Upcoming Meetings and Deadlines

Gas Resource Management

CAISO will host a virtual Gas Resource Management stakeholder meeting on September 17, 2025. This meeting agenda will focus on the GRM draft final proposal, which will be available prior to the meeting. Comments on the stakeholder meeting are due October 1, 2025.  Further information is available here.

Resource Adequacy Modeling and Program Design

CAISO will host a virtual meeting for the Resource Adequacy Modeling and Program Design working group on September 17, 2025, to discuss track 1. The session will be dedicated to discussing the draft final proposal on default counting rules and accreditation along with stakeholder comments on the straw proposal.  Further information is available here.  Further information is available here.

FERC Order No. 1920 Compliance

CAISO will hold a public virtual stakeholder call on September 18, 2025, to discuss the FERC Order No. 1920 compliance filing. Written comments on the September 18 meeting discussion are due October 2, 2025. Further information is available here.

2026 Effective Flexible Capacity Values

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

2025-2026 Transmission Planning Process

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

Western Energy Imbalance Market Modeling and Resource Registration Forum

CAISO will host a hybrid Western Energy Imbalance Market Modeling and Resource Registration Forum on October 7, 2025. In-person attendance registration is due September 30, 2025. Further 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.  Further 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. 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 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.

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.

Workshop on Petroleum Supply Stabilization

The CEC will host a remote workshop on Wednesday, September 24, 2025, from 9:00 a.m. to 12:00 p.m. PT, to discuss strategies to maintain reliable fuel supplies as California transitions away from petroleum.  Staff will discuss minimum inventory requirements, refinery resupply planning, and other stabilization tools consistent with Assembly Bill X2-1.  Additional information, including workshop access codes, is available on the notice, linked here.    

Long Duration Energy Storage Program

On September 11, 2025, the CEC will host a remote access workshop from 1:00 p.m. to 3:00 p.m. PT 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 will provide the grant recipient, the Center for Sustainable Energy, the opportunity to receive input regarding the Draft Guidebook.  According to the workshop notice, a copy of the Draft Guidebook will be made available here at least 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.

New Funding Announced for Electric Vehicle (EV) Charging

The CEC announced the launch of the Fast Charge California Project, which includes up to $55 million of in-state funding for up to 100 percent 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.

Extended Comment Period Regarding EV Charging Infrastructure Reliability Rules

On September 8, 2025, the CEC issued a notice of additional proposed changes to the EV Charging Infrastructure Reliability Reporting and Performance Standards in response to stakeholder feedback.  A link to the newly proposed changes is available here.  Changes include an expanded definition of “fleet charger” to include those used solely to charge commercial vehicles and to specifically include use by subcontractors; a revised definition of “incentive” to specifically include Low Carbon Fuel Standard program credits; and changes to the confidentiality protocols and data submission guidelines. Stakeholders may submit comments on the proposed rules through September 24, 2025. 

Informational Proceeding on Tribal Affairs and Tribal Energy Sovereignty

The CEC will host Regional Roundtable 2 (Roundtable) on September 17, 2025, at the Pechanga Resort Casino in Temecula, California in collaboration with the Pechanga Band of Indians.  The Roundtable is part of the CEC’s Informational Proceeding on Tribal Affairs and Tribal Energy Sovereignty and is open to all California Native American tribes.  Additional information is available in the Roundtable notice.  The proposed agenda includes Tribal Consultation; Tribal Energy Sovereignty; Tribal Cultural Resource Considerations Regarding Clean Energy Development; Best Practices for Tribal Energy Grants, Tribal Energy Equity Indicators, and Engaging with California Native American Tribes on Energy Projects; Tribal Energy Economy Including Tribal Enterprise and Workforce Development; AB 3: California Offshore Wind Advancement Act; and California Tribal Gap Analysis Draft Report.  A detailed agenda will be posted to Docket No. 2025-OIIP-01 prior to the event.  This is an in-person only event and public (oral) comments will be accepted at the event as set forth in the Roundtable notice.

CEC Business Meetings

The next CEC Business Meeting is scheduled for October 8, 2025.  

CALIFORNIA AIR RESOURCES BOARD (CARB)

New CARB Chair

Governor Gavin Newsom announced that CARB Chair Liane Randolph will be retiring from state service effective September 30, 2025, and named Senior Advisor to the Governor for Climate, Lauren Sanchez, to serve as the next CARB Chair. Sanchez has been Senior Advisor for Climate in the Office of Governor Gavin Newsom since 2021 and was the Senior Advisor for the Special Presidential Envoy for Climate in the Biden-Harris Administration in 2021. Sanchez was previously Deputy Secretary for Climate Policy and Intergovernmental Relations at the California Environmental Protection Agency from 2019 to 2021. She was International Policy Director at CARB from 2018 to 2019. Sanchez will begin her new role as CARB Chair effective October 1, 2025.

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.

CARB also released draft guidance on September 2 to assist reporting entities in complying with the Climate Related Financial Risk Disclosure Program.

Meetings and Workshops

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 requirements of the ACF regulation.  This rulemaking also would repeal California Code of Regulations, title 13, sections 2014 and 2015, which contain the drayage and high priority and federal 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 the U.S. Environmental Protection Agency would not be granted.  The proposed amendments will also amend the LCFS regulation set forth in California Code of Regulations, title 17, section 95486.3, to provide stronger credit support for hydrogen stations.

Public Notice and Comment Period for Proposed Emergency Amendment and Adoption of Vehicle Emissions Regulations

CARB proposes to adopt emergency vehicle emissions regulations (the Emergency Vehicle Emissions Regulation) that will amend California Code of Regulations, titles 13 and 17, and adopt new sections into California Code of Regulations, titles 13 and 17. The amendments would confirm that, until a court resolves the uncertainty created by the federal government’s actions, certain antecedent regulations (displaced by Advanced Clean Cars II and Omnibus) remain operative. CARB staff is proposing to amend its regulations to clarify that the criteria pollution provisions of the LEV III regulation (adopted as part of ACC I) and associated on-board diagnostic requirements remain operative, with the caveat that CARB may enforce the more recently adopted LEV IV requirements (adopted as part of ACC II) to the extent permitted by law, in the event a court of law holds invalid the resolution purporting to disapprove that waiver.

CARB intends to submit the Emergency Vehicle Emissions Regulation to OAL on September 22, 2025. The submitted action will appear on the list of “Emergency Regulations Under Review” on OAL’s website at: https://oal.ca.gov/emergency_regulations/Emergency_Regulations_Under_Review/

Emergency rulemakings have a five-calendar-day comment period that begins when OAL posts the notice of the pending emergency action on the OAL website.

MINNESOTA PUBLIC UTILITIES COMMISSION (MPUC)

At this week’s agenda meeting, the MPUC will consider (1) approval of Minnesota Energy Resource Corp.’s (MERC) Annual Depreciation Petition (Docket No. G011/D-25-249), (2) acceptance of MERC’s 2024 Decoupling Evaluation Report and its proposed adjustments to the revenue decoupling mechanism factors effective June 1, 2025 (Docket No. G011/M-25-52), (3) acceptance of the annual 2024 Gas Affordability Program reports for each of the Natural Gas Utilities in Minnesota, and approval of MERC’s proposal for automatic enrollment (Docket No. G002/M-25-36, et al.), and (4) whether Lemon Hill Solar, LLC’s site permit application for its 180 MW Lemon Hill Solar Project is complete, and whether to authorize review under the alternative permitting process or the full permitting review process (Docket No. IP7156/GS-25-126). In addition, public hearings are set to begin next week regarding Xcel Energy’s 2025-2026 GRC.

Additionally, the ALLETE acquisition proceeding, involving the proposed acquisition of ALLETE and its operating division, Minnesota Power, by Canada Pension Plan Investment Board and Global Infrastructure Partners (collectively, the Petitioner), has been noticed for hearing before the MPUC on September 25, 2025, with deliberations scheduled for October 3, 2025. At the hearing, the MPUC will consider whether the proposed acquisition is consistent with the public interest, whether the proposed Settlement filed jointly by the Department of Commerce and Petitioners comports with the public interest, and whether to approve the proposed acquisition. The agenda is here. MPUC Staff briefing papers are here.

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

Commissioner Nominations

The U.S. Senate Energy and Natural Resources Committee voted 12-8 to advance the FERC Commissioner nominations of Laura Swett and David LaCerte to the full Senate.

D.C. Circuit Ruling on Broadview Solar Remand

On September 9, 2025, the D.C. Circuit in Solar Energy Industries Association v. FERC affirmed FERC’s view that the power production and energy storage components of a small power production qualifying facility may have a DC capacity exceeding 80 MW, so long as the facility’s ability to send power to the grid is limited to 80 MW AC by its inverters. Additional information on this decision is available on our blog, linked here.

Meetings and Conferences

FERC will hold its September Open Meeting on September 18, 2025, from 10:00 to 11:00 a.m. ET.  A webcast link and the agenda are available the week of the FERC Meeting.

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 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.

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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.