High DERs Update: How the CPUC Treats New Electrification Study Will Determine Billions in Utility Spending Authority
Below is a synthesis and comparison of stakeholder comments in the CPUC's High DER Future docket, which were filed in response to Cal Advocates' "Distribution Grid Electrification Model 2025 Study and Report" (DGEM 2025).
We explain how consumer advocates, investor-owned utilities, and clean-energy and transportation stakeholders interpret DGEM 2025’s findings, where their views align, and where they diverge (particularly on the role DGEM should play relative to utility "Electrification Impact Studies Part 2," which CRI covered here).

The DGEM 2025 Study has generally been welcomed into the High DER Futures record as a valuable, independent assessment of how widespread electrification could affect California’s distribution grid costs.
There is notable agreement among comments that the study complements the utilities’ Electrification Impact Studies Part 2 by offering a top-down, system-wide perspective that contrasts with the utilities’ bottom-up planning analyses. However, parties diverge on how much weight the Commission should assign to DGEM 2025 when evaluating infrastructure needs and cost forecasts.
WHO SHOULD CARE: Anyone exposed to future distribution spending (or trying to avoid paying for unnecessary infrastructure) should be paying close attention.
