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# Draft Resolution Would Advance Utility-Controlled EV Load Management While Deferring Bi-Directional Hardware Support
- URL: https://www.calregulatory.com/draft-resolution-would-advance-utility-controlled-ev-load-management-while-deferring-bi-directional-hardware-support/
- Published: 2026-02-12T16:35:17.000Z
- Updated: 2026-02-12T17:02:14.000Z
- Author: MC
- Tags: Low Carbon Fuel Standard, Vehicle-Grid Integration, Orchestrated Charging and Advanced Resiliency for Distribution, ORCHARD, electric vehicles, Distributed Energy Resource management, DERMS, Time-of-Use, SCE, holdback funds, flexible load, load flexibility, D.20-12-027, Vehicle-to-Everything, SDG&E, PG&E

The CPUC issued [Draft Resolution E-5452](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M598/K873/598873013.PDF?ref=calregulatory.com), which approves with modifications SCE's request to update its [Low Carbon Fuel Standard](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/infrastructure/transportation-electrification/charging-infrastructure-deployment-and-incentives/low-carbon-fuel-standard?ref=calregulatory.com) Holdback Implementation Plan to add a new vehicle-grid integration program known as Orchestrated Charging and Advanced Resiliency for Distribution (ORCHARD).

**TLDR:** The main storyline is that California is treating EVs primarily as controllable load assets, not compensated grid-export resources. Market participants should plan around that sequencing. The earliest the CPUC will consider this item is **March 19**.

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ORCHARD would integrate a software layer into SCE’s [Distributed Energy Resource management system](https://www.cgi.com/us/en-us/article/derms-utilities?ref=calregulatory.com) to directly manage residential electric vehicle charging in order to:

- Reduce localized distribution peaks caused by Time-of-Use charging patterns;
- Defer transformer upgrades; and
- Lower system costs.

SCE targets enrollment of 25,000 customers on circuits with less than one megawatt of available capacity and at least 100 EVs. The program is limited to light-duty, residential drivers; the draft resolution declines intervenor requests to extend eligibility to medium- and heavy-duty vehicles.

The draft resolution authorizes **$11,464,112** in LCFS holdback funds for the orchestrated load management component and approves a **$75** sign-up incentive plus annually declining participation incentives starting at **$50** and reaching **$0** by the customer's fifth year of enrollment. The draft resolution requires SCE to file a supplemental Tier 2 advice letter detailing its budget and methodology for evaluating enrollment and incentive adjustments.

The draft resolution denies, without prejudice, SCE's proposed bi-directional charging equipment rebates, finding the justification insufficient. Specifically, SCE proposes no export compensation mechanism and instead relies on the pending [Vehicle Grid Resource Proposal](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M579/K066/579066253.PDF?ref=calregulatory.com) and a Dynamic Rate Pilot that, according to the Commission, lacks sufficient funds to cover the 8,700 targeted bi-directional participants.

The draft resolution also identifies ambiguity around required operational modes (Momentary Parallel vs. Isolated) and the associated interconnection requirements. 

### **INSTANT ANALYSIS**

This draft resolution approves utility-controlled managed charging while rejecting subsidized bidirectional hardware. ORCHARD’s orchestrated load management moves forward; [Vehicle-to-Everything](https://en.wikipedia.org/wiki/Vehicle-to-everything?ref=calregulatory.com) rebates do not. For now, the CPUC is backing distribution deferral through flexible load control, not export-based vehicle-to-grid economics without a defined compensation structure.

The Tier 2 advice letter requirement is substantive. SCE must provide detailed budget allocations, attrition and participation thresholds, incentive-adjustment methodology, and analysis of interaction with dynamic rates. That filing will shape whether ORCHARD remains a bounded pilot or becomes a scalable load-flexibility platform.

The draft resolution's treatment of the 20% resiliency expenditure requirement is also notable. SCE argued the threshold is "prohibitively difficult" to meet given the narrow definition of resiliency provided by the CPUC in 2020 decision ([D.20-12-027](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M356/K223/356223853.PDF?ref=calregulatory.com)). The draft resolution accepts that reasoning (in part because CARB recently added VGI to the pre-approved non-equity holdback project list). That interpretation could influence how PG&E and SDG&E frame their own holdback filings going forward.

### WHO SHOULD CARE?

- Utilities' regulatory and grid-planning teams. This draft resolution affirms that managed charging qualifies for LCFS holdback support and can be framed as a distribution deferral tool. The draft resolution also suggests that [Vehicle-to-Everything](https://en.wikipedia.org/wiki/Vehicle-to-everything?ref=calregulatory.com) hardware incentives will face scrutiny absent a defined export compensation pathway.
- VGI aggregators and EV software platforms. The Commission is comfortable with utility-orchestrated load control at scale. Vendors positioned around [one-way managed charging](https://fermataenergy.com/sp%5Ffaq/what-is-v1g-unidirectional-smart-managed-or-controlled-charging-and-how-does-this-differ-from-v2x-v2g/?ref=calregulatory.com) and [Distributed Energy Resource Management System](https://www.cgi.com/us/en-us/article/derms-utilities?ref=calregulatory.com) integration have a clearer runway than those anchored in export monetization.
- Automotive OEMs and charging manufacturers. Bi-directional capability alone is not enough. Without rate design or compensation mechanisms, hardware-forward Vehicle-to-Grid strategies will struggle to secure ratepayer-backed incentives.
- Policy staff tracking legislation and load-shift goals. ORCHARD reinforces that load flexibility, not new infrastructure, is the near-term tool for meeting electrification-driven peak growth.
- Energy traders and Resource Adequacy modelers. If orchestrated charging scales, controllable EV load may increasingly factor into distribution planning and future flexible capacity assumptions.