September 3, 2025

Regulatory Update for September 3, 2025

(Covering Week of August 25, 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
• 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

Rulemaking (R.) 20-02-012 (Self-Generation Incentive Program Rulemaking)

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).  Ratepayer funds support both residential and non-residential projects.  SGIP participants include utility residential, commercial, and industrial customers, technology developers, utility, and non-utility program administrators among others.  The deadline for new applications for ratepayer-funded SGIP projects is December 30, 2025, and ratepayer-funded SGIP waitlists will close on December 30, 2025.  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.

Resolution (Res) O-0097

(Santa Fe Pacific Pipelines, L.P. Intrastate Rate Increase).  This Resolution approves Santa Fe Pacific Pipelines’ request for an interim, system-wide, intrastate rate increase of 5.187 percent under the provisions of Public Utilities Code section 455.3 and General Order 96-B, Energy Industry Rule 8.  The rate increase is requested pursuant to rate case Application (A.) 24-01-020 et. al, wherein Santa Fe Pacific Pipelines has requested an aggregate increase of 15.706 percent, inclusive of the 10 percent increase that was approved in Res O-0088 and the 5.187% increase that is the subject of this Res O-0097.  The Commission will consider the entirety of Santa Fe Pacific Pipelines’ requested increases in the consolidated proceeding, A.24-01-020.

Voting Meeting

The CPUC held a voting meeting in San Francisco, California on August 28, 2025, at 11:00 a.m. PT.  The results for energy-related items on the agenda are below:

Item 2. 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.  Withdrawn.

Item 3. 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 (EE) Portfolio Business Plan for Northern California Rural Regional Energy Network and the revised 2024-27 EE Portfolio Business Plan for Central California Rural Regional Energy Network.  The cost is $60,029,938 to Pacific Gas & Electric Company (PG&E) customers, $7,267,800 to Southern California Edison (SCE) customers, and $2,180,340 to Southern California Gas Company (SoCalGas) customers for a four-year period.  Approved.

Item 4. 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 general rate case (GRC) 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.  Held to September 18, 2025.

Item 5. Res G-3606 (San Diego Gas & Electric (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 under-recovered ongoing capital revenue requirement.  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 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 NGLA Program Memorandum Account for potential recovery in a future GRC 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.  Held to September 18, 2025.

Item 10. R.20-07-013 (Order Instituting Rulemaking to Further Develop a Risk-Based Decision-Making Framework for Electric and Gas Utilities)

This decision adopts refinements to the Risk-Based Decision-Making Framework to: (1) require representation of Consequence Risk Event as a probability distribution; (2) incorporate overall residual risk reporting into the Risk-Based Decision-Making Framework; (3) require the presentation of optimized risk mitigation portfolios with Risk Assessment Mitigation Phase filings, including budget scenarios which will be based on the forecasted costs of Mitigations and Controls that the utility has proposed in its most recent GRC; (4) incorporate the Risk Reporting Unit into the Risk-Based Decision-Making Framework; (5) provide guidelines for the Risk Mitigation Accountability Report; (6) provide minor key refinements to the Risk-Based Decision-Making Framework; and (7) provide the Risk Assessment Mitigation Phase Data Template and Guidelines.  Signed, Decision (D.) 25-08-032.

Item 12. R.25-04-010 (Order Instituting Rulemaking for Oversight of EE Portfolios, Policies, Programs, and Evaluation)

This decision adopts total system benefit and energy savings goals for ratepayer-funded EE portfolios for 2026-2037.  California Public Utilities Code sections 454.55 and 454.56 require the Commission, in consultation with the California Energy Commission to identify all potentially achievable cost-effective electricity and natural gas efficiency savings and “establish efficiency targets” for electrical and gas corporations to achieve.  Commission staff manage the development of a study that provides the technical analysis for assessing the cost-effective energy savings, and associated system benefits, potentially available in the state’s residential and commercial building stocks, residential and commercial equipment and processes, and the industrial, agricultural and mining sectors.  The Commission uses this study primarily to set goals for the large investor-owned utilities.  Signed, D.25-08-034.

Item 14. R.24-01-018 (Energization Timelines Rulemaking)

This decision partially grants PG&E’s Motion to Revise the Energization Cost Caps adopted in D.24-07-008.  D.24-07-008 authorized PG&E to: (1) create an Electric Capacity New Business Interim Memorandum Account (interim memorandum account) to track specific costs incurred for energizing new customers over the years 2024, 2025, and 2026 up to annual caps, and (2) recover costs tracked in the account for completed energization projects in amounts determined through the Annual Electric True-Up (AET) process on an interim basis pending a reasonableness review by the Commission.  In its motion, PG&E seeks to increase the Commission-authorized capital cost caps established in D.24-07-008 for the years 2025 and 2026.  PG&E also seeks authorization to use these capital cost caps across 2025 and 2026 and requests that the Commission eliminate the secondary revenue requirement caps for 2024, 2025, and 2026.  Specifically, PG&E’s motion requests that the Commission: (1) increase the 2025 capital costs cap from $618 million to $2.115 billion; (2) increase the 2026 capital costs cap from $669 million to $2.302 billion; (3) authorize the ability to spend authorized amounts across 2025 and 2026; and (4) eliminate the secondary revenue requirement caps for 2024-2026.  This decision denies the amounts requested by PG&E for 2025 and 2026 cap increases and grants lower amounts.  PG&E’s capital cost caps are increased by $1,367.9 for 2025 and $1,015.7 for 2026.  Accordingly, the new interim memorandum account capital cost caps are $1,985.9 for 2025 and $1,684.7 for 2026.  This decision approves PG&E’s request for inter-year flexibility between the 2025 and 2026 capital expenditure caps.  Additionally, this decision grants the request to eliminate the secondary annual revenue requirement caps.  The annual revenue requirement additions will continue to be calculated through the AET process based on the costs of projects placed in service each year and subject to claw back after a reasonableness review in PG&E’s GRC.  Signed, D.25-08-036.

Item 18. Res G-3614 (SoCalGas 2024 Southern System Reliability Purchases and Sales)

This Resolution approves SoCalGas’s Annual Compliance Report on the Utility System Operator’s Southern System Reliability Purchases and Sales for the period from October 1, 2023, through September 30, 2024.  The SoCalGas System Operator made 54 purchases and 113 sales to satisfy the Southern System minimum flow requirement at a net cost of $6,327,043.  This net cost includes $10,184,777 for purchases and $1,204,142 for transportation costs, minus $5,061,876 in revenue from sales.  This Resolution finds all the actions taken by SoCalGas to be reasonable and approves all transactions based on their verifiability.  Approved.

Item 35. R.22-07-005 (Order Instituting Rulemaking to Advance Demand Flexibility Through Electric Rates).  This decision adopts guidelines for PG&E, SCE, and SDG&E to design demand flexibility rates and comply with the California Energy Commission’s Load Management Standards.  Specifically, this decision adopts guidance for how various cost components should be incorporated into demand flexibility rate proposals to provide accurate price signals that promote economically efficient load shifting and support grid reliability.  Further, this decision adopts guidance for the design of customer options that promote load shifting in response to electricity pricing.  Signed, D.25-08-049.

Item 36. 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 2025-2028, 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 affected.  The incremental revenue increase that has accrued from January 1, 2025 through September 30, 2025 will be amortized over a twenty-four-month period.  Held to September 18, 2025.

CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)

Stakeholder Initiatives: Upcoming Meetings and Deadlines

Study Timeline for Cluster 15

CAISO has issued an Updated Resource Interconnection Standards Study Timeline for Cluster 15.  Further information is available here.

2026 Net Qualifying Capacity

CAISO has posted the Final 2026 Resource Adequacy Net Qualifying Capacity list for requesting resources.  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.

Price Formation Enhancements

CAISO has posted the straw proposal for the Price Formation Enhancements initiative to its webpage and will hold a stakeholder session on September 4, 2025.  The objective of these meetings is to review all of the elements included in the straw proposal and seek stakeholder input.  Further 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.

Storage Design and Modeling

CAISO extended the deadline to submit written comments on the Storage Design and Modeling revised straw proposal on outage management to August 14, 2025.  Further information is available here.

Western Energy Markets Governing Body, Joint, ISO Board of Governors, and Committee Meetings

CAISO has posted the draft agendas for the Western Energy Markets Governing Body, Joint, ISO Board of Governors, Audit Committee, and Department of Market Monitoring Oversight Committee meetings on September 9 to 11, 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 July 2, 2025).  Upcoming workshops or comment deadlines and recent changes to the workshop schedule are reflected below:

• August 26, 2025: IEPR Commissioner Workshop on Energy Demand Forecast Load Modifier Scenario Design (remote access only).
  • Written comments are due to the Docket Unit by 5:00 p.m. PT on September 9, 2025
• 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.

Suspension of Solar Photovoltaic (PV) and Storage Requirements for Homes Impacted by Los Angeles Wildfires

On August 29, 2025, the CEC issued a notice that Executive Order N-29-25 suspends the solar PV and battery energy storage requirements of the California Energy Code (Sections 140.10(a-b), 150.1(c)14, and 170.2(f-h)) as they apply to newly constructed residential dwellings. 

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 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 ten (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 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 September 10, 2025.  The meeting agenda and additional 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 September 9, 2025, CARB will hold a public meeting as part of CARB’s work on developing an embodied carbon reporting regulation pursuant to Assembly Bill (AB) 2446 and AB 43.  At this meeting, participants will discuss in detail the methodology used to estimate the 2026 point-in-time baseline for California’s greenhouse gas emissions from the building sector.  This meeting will be a collaborative discussion among CARB program staff and external parties from academia, industry, and non-profits.  Interested parties, outside experts, and members of the public are invited to attend either in-person or online via Zoom.

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, §§ 2014 and 2015, which contains 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, § 95486.3, to provide stronger credit support for hydrogen stations.

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

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

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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.