> ## Content Index > Fetch the complete content index at: https://www.calregulatory.com/llms.txt > Use this file to discover other available public pages before exploring further. # DER Update: CPUC Moves Toward Flexible Connections, Statewide DER Rules - URL: https://www.calregulatory.com/der-update-cpuc-moves-toward-flexible-connections-statewide-der-rules/ - Published: 2026-07-29T12:30:21.000Z - Updated: 2026-08-23T00:04:57.000Z - Author: MC - Tags: High DER Future, Integration Capacity Analysis, Grid Edge DERMS, Limited Generation Profile, AMI 2.0, Load Control Management System, DERMS The CPUC’s High DER Future docket produced three significant developments this week, all aimed at making better use of the distribution grid as electrification increases demand for new connections. A July 28 proposed decision would reduce Integration Capacity Analysis workshops while requiring standardized biennial reports on utility grid-modernization spending and results. Comments filed the previous day revealed disagreements over two emerging policies. Flexible service connections let customers energize under operating limits instead of waiting for upgrades. DER orchestration would compensate or direct distributed resources to relieve grid constraints. Parties broadly support both concepts. The dispute is over how quickly to scale them, whether utilities or third parties should control the necessary platforms, and whether the CPUC should permit three utility-specific systems or establish a common statewide framework. --- ### INTEGRATION CAPACITY ANALYSIS On July 28, Commissioner **Darcie Houck** issued a [proposed decision](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K543/612543867.PDF?ref=calregulatory.com) that would cut the CPUC's Integration Capacity Analysis (ICA) workshops from quarterly to twice a year beginning in the first quarter of 2027\. The proposal would cancel the workshop scheduled for the fourth quarter of 2026 and align future workshops with the utilities' twice-yearly ICA reports. PG&E, SCE, and SDG&E could seek further schedule changes through Tier 2 advice letters. However, they would have to show that the workload is unduly burdensome or that the status and implementation schedule of ICA improvements do not support twice-yearly updates. The PD would also require the three utilities to serve Grid Modernization Progress Reports on the CPUC's Energy Division by **October 1** of every even-numbered year, starting in 2026\. The reports would support the CPUC's biennial grid-modernization report to the Legislature and governor and replace the one-off data requests Energy Division has used to collect utility information. They would cover: - Grid-management systems; - Communications and cybersecurity infrastructure; - Engineering and planning tools; - Advanced metering and grid-edge applications; and - Other relevant technologies. For each area, the utilities would report project status, milestones, benefits, use cases, challenges, changes from earlier plans, costs incurred and anticipated, and planned applications. SDG&E opposed the reporting requirement and argued that the existing data-request process is sufficient. PG&E and SCE preferred to use the grid-modernization reports included in their general rate cases, supplemented by updated reports when the GRC information is insufficient. Both objected that requiring cost information would duplicate GRC reporting, while SCE also sought to limit duplicative cost reporting for advanced-metering investments. Energy Division and the utilities would review the reporting template four months before each deadline, and staff could revise it to reflect technological or industry developments. Comments are due **August 17**. The earliest the CPUC will consider this item is **September 3**. **INSTANT ANALYSIS:** The progress reports are notable. They would replace one-off data requests with a standard report every two years. In theory, that could make utility spending, deployments and claimed benefits easier to compare. Their value will depend on whether they add new information or merely repackage material from GRC filings. Reducing ICA workshops from four to two a year aligns them with the existing report schedule. It also gives parties fewer opportunities to identify errors and question delayed remediation. --- ### FLEXIBLE SERVICE CONNECTIONS On July 27, multiple parties filed comments on [an assigned commissioner's proposal](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K354/610354105.PDF?ref=calregulatory.com) to expand flexible service connections, which allow customers to energize load under agreed limits rather than wait for a full grid upgrade. It would establish static, variable and dynamic offerings; create permanent non-bridging options; deploy Grid Edge DERMS; and enroll some participants in real-time pricing by default. [Flexible Service Connections ProposalThe CPUC issued a proposal in R.21-06-017 that would make flexible service connections a standing distribution-planning tool for the large IOUs.![](https://storage.ghost.io/c/36/77/3677b301-4c92-43b7-8e2f-c7265d6b0b59/content/images/icon/Electromagnetic_radiation-1---1--3-e28e8bb2-24b0-46ed-865d-9ad63846ae75.png)CALIFORNIA REGULATORY INTELLIGENCEMC![](https://storage.ghost.io/c/36/77/3677b301-4c92-43b7-8e2f-c7265d6b0b59/content/images/thumbnail/iterograph_Tue-Oct-28-2025--1--8315d2e6-a856-465c-8beb-3871f52d0e69.png)](https://www.calregulatory.com/flexible-service-connections-cpuc-proposal-would-make-controlled-load-a-standing-alternative-to-distribution-upgrades/) The parties support flexible connections in principle. They disagree over how quickly to move beyond pilots, which technologies to require and what customers should receive for accepting less than firm service. - All three utilities support temporary bridging connections that accelerate energization. They resist making flexible service the automatic first choice or scaling more complex offerings before their value is established. - PG&E [opposes](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K764/610764766.PDF?ref=calregulatory.com) default Limited Power and real-time pricing. It would develop non-bridging service later. PG&E says only one Limited Generation Profile application has reached study-approved status. It also argues that only about 20% of forecast secondary-system costs may be candidates for flexible service. - SCE [takes a similar position](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K428/612428813.PDF?ref=calregulatory.com) and would tie a Flex Connect-style offering to the readiness of DERMS, AMI 2.0 and related systems. It points to its Load Control Management System pilot, where customers received service about 20 months sooner than they would have by waiting for upgrades. - SDG&E [says](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777735.PDF?ref=calregulatory.com) there is no demonstrated demand in San Diego and that its systems lack several capabilities assumed by the proposal. It would measure customer interest before building new programs. For permanent flexibility, SDG&E prefers compensated DER orchestration over asking customers to accept indefinite limits without payment. - The Utility Consumers' Action Network (UCAN) [is the proposal’s strongest supporter](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777743.PDF?ref=calregulatory.com). It wants Limited Power as the default mitigation, Flex Connect at SCE and SDG&E, Grid Edge DERMS and permanent non-bridging service. Avoided projects should be removed from utility capital plans, and interoperability rules should be adopted now. UCAN would make real-time pricing opt-in because local operating limits may prevent customers from taking advantage of low system prices. - The Environmental Defense Fund also [supports](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K543/612543843.PDF?ref=calregulatory.com) the proposal and is the clearest supporter of default real-time pricing. It emphasizes compensation for customers accepting permanent limits. - Cal Advocates and the [Interstate Renewable Energy Council](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K543/612543860.PDF?ref=calregulatory.com) want stronger evidence before broad deployment. Cal Advocates [would compare](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K335/612335423.PDF?ref=calregulatory.com) each flexible connection with the wires upgrade it replaces. Both question whether permanent limited service can be reconciled with the utility obligation to serve. - The California Community Choice Association (CalCCA), the California Solar & Storage Association (CALSSA) and Advanced Energy United want third-party providers considered before utility platforms become entrenched. CalCCA [would evaluate](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K353/612353887.PDF?ref=calregulatory.com) a demand-flexibility marketplace before authorizing more Grid Edge DERMS spending. CALSSA [wants](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K543/612543850.PDF?ref=calregulatory.com) large loads to bring their own virtual power plant capacity. Advanced Energy United [favors](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K353/612353903.PDF?ref=calregulatory.com) utility communication with aggregators rather than direct control of each customer device. - The fleet parties emphasize predictable capacity. CALSTART and [Terawatt](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777776.PDF?ref=calregulatory.com) favor Limited Power or Static Operating Envelopes and oppose a blanket UL 3141 requirement. CALSTART [estimates](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777736.PDF?ref=calregulatory.com) certification could cost **$100,000** to **$120,000** per service. - The Mobility House [favors](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K426/612426526.PDF?ref=calregulatory.com) voluntary real-time pricing and asks the CPUC to reconsider the proposed 10-year non-bridging term. - SPAN.IO, by contrast, [wants](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K445/612445974.PDF?ref=calregulatory.com) UL 3141 to be the sole acceptable control standard. - WeaveGrid [supports](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777750.PDF?ref=calregulatory.com) allowing each utility to procure a Grid Edge DERMS platform suited to its architecture. **INSTANT ANALYSIS:** Static and bridging offerings are closest to adoption. Permanent non-bridging service, Grid Edge DERMS and default real-time pricing remain contested. The non-bridging debate turns first on customer value. California’s Distribution Investment Deferral Framework produced few deferrals before the CPUC discontinued it. The utilities see evidence that the savings rarely materialize. UCAN sees a compensation failure that can be fixed. A second question may be decisive: can a flexible connection replace an upgrade indefinitely, or does the obligation to serve require the wires eventually to be built? SDG&E will likely win additional time, but its lack-of-demand argument does not answer that question. Permanent flexible service could avoid an upgrade even where energization was never delayed. --- ### DER ORCHESTRATION FRAMEWORK Separately on July 27, multiple parties also filed comments in response to CPUC questions on DER orchestration. All parties support using DERs to relieve grid constraints, speed energization and reduce infrastructure spending. The utilities want pilots to shape the framework. Most other parties want statewide market, governance and data rules first. - [PG&E](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777734.PDF?ref=calregulatory.com) and [SCE](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K353/612353883.PDF?ref=calregulatory.com) propose targeted programs through Tier 2 advice letters and new cost-recovery accounts. Results would inform later applications; SCE would wait at least 21 months after a Track 2 decision to file. SDG&E [wants](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K353/612353885.PDF?ref=calregulatory.com) the Commission to complete the framework first, then allow optional, readiness-driven applications. - Most non-utility parties support a time-limited working group followed by a Commission framework. [Advanced Energy United](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K212/612212906.PDF?ref=calregulatory.com), [CalCCA](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K353/612353886.PDF?ref=calregulatory.com), [Clean Coalition](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K353/612353890.PDF?ref=calregulatory.com) and the [California Energy Storage Alliance](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K445/612445964.PDF?ref=calregulatory.com) (CESA) want common standards, open market access and protections against utility self-preference. The Center for Biological Diversity [would](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K426/612426499.PDF?ref=calregulatory.com) consider utility incentive reform or an independent distribution system operator before applications proceed. - UCAN [proposes](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K777/612777743.PDF?ref=calregulatory.com) three statewide functions under neutral administration: a DER registry, data hub and flexibility market. It seeks three months of framework development and initial market activity within about 18 months. Advanced Energy United broadly agrees. CalCCA supports evaluating a marketplace but also wants decentralized data-sharing considered. - CALSSA supports a six-month working group but wants immediate programs allowing large loads to bring virtual-power-plant capacity to overcome energization constraints. It would treat contracted DERs as distribution capacity, with applications following in six to 12 months. WeaveGrid likewise [says](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K212/612212904.PDF?ref=calregulatory.com) existing grid-edge platforms can address local constraints without waiting for enterprise DERMS. - Parties generally accept three use cases: system peak reduction, speed to power and more efficient grid investment. CALSSA considers the latter two urgent but says peak reduction may belong elsewhere. Clean Coalition wants DER portfolios screened before conventional infrastructure and seeks compensation for resilience and microgrid services. - Cost, technology and coordination rules remain unsettled. EDF [seeks](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K426/612426498.PDF?ref=calregulatory.com) common evaluation and cost-allocation rules. CESA wants storage to stack distinct distribution, wholesale and reliability revenues. - Several parties favor common, protocol-neutral interfaces without waiting for AMI 2.0, while the utilities oppose a prescribed architecture. The CAISO [wants](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M612/K212/612212901.PDF?ref=calregulatory.com) clear priority between distribution and bulk-system commitments, consistent data exchange and semiannual coordination workshops. **INSTANT ANALYSIS:** The Commission's approach has moved away from immediate applications. The remaining choice is whether pilots produce three utility-led systems or operate within one statewide framework. A likely compromise would establish common access, data and reporting rules while allowing targeted programs to begin. Neutral market administration, cost recovery and the treatment of DERs as dependable distribution capacity would remain the most challenging issues.