FRIDAY AGGREGATE: IRP Rehearing Tests a Constrained Procurement Model as Demand Response and Pole Access Rules Move
Today's briefing includes:
- Updates to our April 9 summary of CPUC Resolution E-5440, whose final redlined changes are now available;
- An AFR addressing the CPUC's recent procurement order in the Integrated Resource Planning docket;
- A Demand Response ruling focused on the ELRP and DSGS programs;
- SoCalGas NG curtailment updates; and
- A President Reynolds PD updating access to utility poles.
Collectively these items showcase how the CPUC is dealing with live systems rather than abstract policy: allocating procurement tied to load that cannot freely move, extending DR programs that were never built to last, and imposing more defined rules on who can touch the grid (and when). As we regularly see now: cost exposure and access conditions are fluid developments.
INTEGRATION CAPACITY ANALYSIS (UPDATE)
Yesterday we reported that the CPUC adopted Resolution E-5440, which approves remediation plans submitted by the investor-owned utilities to fix accuracy, transparency, and usability problems in their Integration Capacity Analysis tools.
Since our post went live, redlined changes to Resolution E-5440 surfaced in an obscure corner of the CPUC's document feed, which we've incorporated into our April 9 summary.
The key modifications are:
- A change indicating that SDG&E must publish its redacted generation fields within 30 calendar days (not 15); and
- Language that softens the resolution's original characterization of SDG&E being explicitly out of compliance.
We've also drawn attention to PG&E's introduction of a "safety bank" technical criterion, as highlighted in the CPUC's final edit. Those updates are now fully incorporated into yesterday's summary (available here).
MC
INTEGRATED RESOURCE PLANNING
A new application for rehearing surfaced in the CPUC's Integrated Resource Planning docket. The following groups (the "Rehearing Parties") filed an AFR of the CPUC's February 2026 procurement order (D.26-02-057):
- The Alliance for Retail Energy Markets;
- The California Coalition of Large Energy Users;
- The Regents of the University of California; and
- Shell Energy North America.
The Rehearing Parties argue that D.26-02-057 unlawfully allocates new resource procurement obligations by relying on current load share while ignoring the statutory cap on Direct Access, which prevents Electric Service Providers from serving new load.
As a result, ESPs are assigned responsibility for capacity tied to future demand growth they cannot legally serve, creating improper cost shifting onto DA customers. The applicants contend this violates multiple provisions of the Public Utilities Code, particularly requirements around cost causation and prohibitions on shifting costs between customer classes.
They assert that D.26-02-057 lacks sufficient evidentiary support and fails to align procurement obligations with actual system contributions. As remedies, they propose either reopening Direct Access to allow ESPs to compete for new load or reallocating procurement obligations to entities that can actually serve that load.
CRI's coverage of the February procurement order is available here.
MC
INSTANT ANALYSIS: This filing is a coordinated strike on the CPUC’s IRP procurement framework, centered on a single vulnerability: the CPUC allocated future capacity obligations based on static load share, while the Direct Access cap freezes ESP participation. That mismatch creates a clean cost-causation problem. ESPs are being assigned procurement tied to load growth they are legally barred from serving (especially large new loads like data centers).
The filing is constructed around statutory hooks. Section 397, 454.52(c), and 366.2(d)(1) of the Public Utilities Code all point to the same constraint: procurement costs must track contribution and cannot be shifted across customer classes. The parties are building a record that the CPUC ignored its own cost allocation doctrine (and decades of departing load precedent).
Rehearing is paired with a parallel push to reopen Direct Access, which reframes the issue from an allocation dispute to a question about market access. If DA expands, the allocation problem dissolves. If it does not, the Commission faces pressure to reallocate billions in procurement responsibility.
This filing represents an early test of how the CPUC plans to handle load growth from data centers and electrification under a constrained retail market. If the current framework holds, cost fights between utilities, Community Choice Aggregators, and ESPs will intensify. If it breaks, Direct Access expansion moves back onto the table in a serious way.
DEMAND RESPONSE
A new ruling in R.25-09-004 resets the schedule for resolving Demand Response bridge-year funding. It builds on a March 10 ruling and keeps the focus on interim funding for the Emergency Load Reduction Program and Demand Side Grid Support Program, which were both created as emergency responses to the 2020 heat events.
Opening comments are due April 30, with replies on May 21. Substantively, the ruling asks whether the Emergency Load Reduction Program should continue, be redesigned, or sunset, and whether the Demand Side Grid Support Program offers elements worth carrying forward. The CPUC is no longer just extending these programs, it is forcing the question of what they become.
INSTANT ANALYSIS:
The Commission is managing a live gap: the Emergency Load Reduction Program is still being used, but it was never built to last, and nothing fully formed has replaced it. The program has been extended year after year as a stopgap, and the ruling now puts that status on the table: continue it, change it, or end it.
The Demand Side Grid Support Program complicates the picture further. It sits outside CPUC control and does not have stable funding beyond 2026, leaving the state with overlapping programs and no guaranteed continuity.
Either these programs are absorbed into the system on firmer footing, or they start to unwind. Either path will bring cost-allocation battles, especially if bridge-year funding continues to carry programs that were never designed to be permanent.
NATURAL GAS CURTAILMENT
SoCalGas filed Advice Letter 6623-G (available here) to report Q1 2026 maintenance-related gas curtailments covering January 1 through March 31. The filing lists three localized events in Riverside, Goleta/Oxnard, and Sun Valley, each tied to planned maintenance work.
SoCalGas states that all affected noncore customers were fully curtailed during the outage windows and that the events complied with its tariff rules. Customer notification relied on account managers and ENVOY postings, while customer-specific data remains confidential.
Separately, SoCalGas issued an ENVOY notice for a planned noncore curtailment in Glendale on April 14–15 (6 a.m. to 6 p.m. daily) to support maintenance work, with customer-specific usage limits to be set ahead of the event and timing subject to change.
INSTANT ANALYSIS: This routine filing shows how SoCalGas is managing localized reliability through planned curtailments rather than emergency actions. Three events across Riverside, the Central Coast, and the LA Basin indicate a system that still requires targeted outages to complete maintenance, with noncore customers serving as the primary shock absorbers.
The Glendale ENVOY notice follows immediately after the quarter, pointing to a steady pipeline of maintenance-driven constraints rather than isolated events. For large gas users, curtailment exposure is an ongoing operating condition. There is no rate impact, but the pattern is notable. Maintenance is happening on a live system, and noncore customers are carrying the burden.
RIGHTS OF WAY/UTILITY POLE ACCESS
CPUC President John Reynolds issued a proposed decision that would adopt General Order 178, governing access to poles, conduit, and rights-of-way across California. The PD updates the framework established in a 2022 decision (D.22-10-025) and denies pending petitions for modification.
A proposed General Order standardizes make-ready timelines, expands one-touch make-ready and self-help pathways, and imposes additional transparency requirements around contractor qualifications and construction practices. The proposed GO also adds a formal overlashing provision, allowing existing attachers to add facilities to existing lines with advance notice rather than prior approval, subject to defined conditions.
The PD increases penalties tied to unauthorized attachments and strengthens consequences for data reporting failures, with a greater emphasis on tracking, documentation, and compliance visibility. Pole owners would be required to submit regular compliance information identifying unauthorized attachments and their resolution status, including geographic detail. The framework also contemplates a standardized self-help agreement to be filed for CPUC approval within a defined implementation window.
The earliest the CPUC will consider this item is May 14. Comments are due April 30.
INSTANT ANALYSIS: The Commission is shifting leverage toward attachers while forcing utilities to maintain a defensible record of every attachment on the system. At the same time, required tracking of attachments, locations, and resolution status creates a strong record of what is on the system.
In short, the Commission is closing the window on “we didn’t know what was on the pole.” Utilities are expected to play a more active role in identifying and addressing noncompliant attachments while maintaining defensible records. That combination raises the likelihood of disputes between pole owners and attachers as the new framework is implemented.