California Regulatory Intelligence
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Group Files Motion to Disqualify ALJ in Diablo Canyon Cost Case

Earlier today, Californians for Green Nuclear Power (CGNP) filed a motion requesting the disqualification of Administrative Law Judge Jack Chang from PG&E's latest Diablo Canyon cost-recovery application (A.25-03-015).

  • CGNP argues that ALJ Chang has demonstrated bias and a lack of impartiality through several procedural decisions that harmed ratepayers and undermined grid reliability.
  • CGNP points specifically to ALJ Chang's denial of two CGNP motions (both submitted a day late), including one seeking to amend the scoping memo to enable payments to Diablo Canyon for providing synchronous grid inertia, a service CGNP says is critical for preventing such blackout events as the fatal Iberian Peninsula outage in April 2025.
  • CGNP claims that three denials blocked them from submitting direct testimony on synchronous grid inertia and from receiving intervenor compensation. CGNP also calls into question ALJ Chang's judicial temperament with a claim that Chang demonstrated discourteous behavior during a July 2025 site tour of the Diablo Canyon facility.

CGNP's Gene Nelson cites his own October 20, 2025 comments in this proceeding, which note:

I have concerns that Dr. Chang brings an apparent bias against nuclear power advocates such as myself (which perhaps extends to opposing Diablo Canyon extended operations) into this proceeding. During July and August, 2025, he denied a pair of CGNP's motions while ignoring CGNP's July 11, 2025 Motion to Amend the Scoping Memo. Supporting my contention, I've appended Dr. Chang's self-written LinkedIn resume with some annotations.
His highlights at the top of his resume include "Administrative Law Judge," "Renewable Hydrogen," and "Solar Development." I also include a reference to Dr. Chang's solar power advocacy article from August, 2019 written while he served as a Market Research and Energy Policy Intern for Strategen. I believe it is a conflict of interest to have a self-described renewable energy advocate serve as a CPUC ALJ for the Diablo Canyon 2026 Cost Proceeding. Dr. Chang should have recused himself from this assignment.

CGNP formally asks the CPUC to remove ALJ Chang from the proceeding.

INSTANT ANALYSIS: While this motion is procedurally doomed and highly unlikely to result in the ALJ's disqualification, it nevertheless gives CGNP another procedural tool to elevate deeper disputes regarding grid inertia, nuclear reliability compensation, and perceived ideological leanings within the regulatory process.