MONDAY AGGREGATE: RA Proposals; Energization Replies; NG Curtailment Watch for SoCalGas/SDG&E Territories

Today's roundup looks at:

• Party proposals in the CPUC's Resource Adequacy docket that seek to correct growing misalignments between the CPUC’s Slice-of-Day Resource Adequacy framework, CAISO deliverability rules, and the resource mix needed for a decarbonized grid facing tighter reliability margins.
• Reply comments in the Commission's Energization rulemaking, where a pending proposed decision, if adopted, would establish a Standard Offer for Flexible Service Connections as part of the Commission’s broader effort to set and enforce energization timelines.
• SoCalGas's systemwide natural-gas curtailment watch covering both the SoCalGas and SDG&E service territories.

RESOURCE ADEQUACY

On January 23, parties in Track 1 of R.25-10-003 advanced a coordinated set of proposals aimed at correcting growing misalignments between the CPUC’s Slice-of-Day Resource Adequacy framework, CAISO deliverability rules, and the resource mix needed for a decarbonized, reliability-constrained grid.

• Sonoma Clean Power Authority argues that the Slice-of-Day framework undervalues energy-only and long-lead-time clean firm resources by tying RA accreditation to summer peak deliverability tests that do not reflect hour-by-hour, multi-season reliability needs, and urges the Commission to allow greater RA compliance value for energy-only resources (particularly in non-summer months) to unlock procurement of geothermal and other clean firm generation constrained by interconnection limits.
• American Clean Power-California similarly seeks to integrate energy-only resources into the RA construct, proposing that they be allowed to satisfy storage charging sufficiency requirements (without counting toward capacity obligations), paired regionally with storage and subject to must-bid and visibility requirements, while also revising solar and wind accreditation to better reflect actual reliability contributions.
• Cal Advocates focuses on long-duration storage, proposing a multi-day energy sufficiency requirement that expands Slice-of-Day accounting beyond a single 24-hour “worst day” so that multi-day storage can be credited for consecutive-day discharge while requiring load-serving entities to demonstrate sufficient forward charging energy.
• Vistra and Calpine both address capacity over- and mis-accreditation risks: Vistra proposes refined qualifying-capacity calculations for short- and long-duration storage based on commercially available energy and contracted duration, paired with an unforced capacity framework that calculates resource-specific Equivalent Forced Outage Rate on Demand values for up to three operating parameters (maximum operating limit, maximum continuous energy limit, and minimum continuous energy limit) to avoid overstating deliverable RA value, while Calpine proposes facility-level unforced capacity treatment for interdependent geothermal units so that integrated resources like The Geysers are accredited based on reliable aggregate output rather than unit-by-unit constraints that understate true reliability.
• MN8 Energy targets variable renewable accreditation, arguing that current monthly solar QC factors are anchored to peak load hours rather than hours of highest reliability risk, and should instead be recalibrated using risk-weighted methods aligned with loss-of-load analysis to avoid distorted deliverability outcomes and investment signals

INSTANT ANALYSIS: These proposals converge on a single pressure point: the Slice-of-Day RA framework is no longer aligned with how reliability risk actually manifests on a decarbonizing grid. Multiple parties argue that peak-hour, summer-centric accreditation rules are overstating some resources (notably solar and short-duration storage) while suppressing others that provide real reliability value across seasons and days, including energy-only generation, geothermal, and long-duration storage.

Collectively, the proposals push the Commission toward three shifts:

• Separating energy sufficiency from capacity deliverability so energy-only resources can support storage charging and reliability without conflicting with CAISO tariff rules;
• Reforming storage and geothermal accreditation to reflect aggregate, multi-day, and facility-level performance rather than unit-specific or single-day snapshots; and
• Recalibrating solar and wind QC to hours of highest reliability risk rather than peak load.

If adopted in whole or in part, these changes would significantly reshape RA procurement signals, reduce artificial deliverability bottlenecks, and accelerate contracting for clean firm and long-duration resources that are currently stranded under existing rules.

ENERGIZATION

Parties filed reply comments in response to opening comments on a December 24 proposed decision in R.24-01-018, which would establish a Standard Offer for Flexible Service Connections as part of the Commission’s broader effort to set and enforce energization timelines. The PD directs PG&E and SCE to file Tier 2 Implementation Advice Letters establishing the Standard Offer tariff.

Energization PD; SoCalGas AFR of Electrification Pilot

Utilities get potential energization pathways via tariff but connecting customers face interim load restrictions until upgrades arrive

CALIFORNIA REGULATORY INTELLIGENCEMC

A portion of reply comments address disputes raised in opening comments regarding the scope, structure, and implementation of the proposed standard offer, including the role of preliminary capacity assessments, eligibility and applicability across utility service territories, cost and ratepayer-benefit considerations, compliance monitoring approaches, reporting and compliance timelines, and the appropriate balance between standardized Commission requirements and utility operational discretion.

Parties remain divided over how prescriptive the Commission should be in implementing a Standard Offer for Flexible Service Connections, particularly around preliminary capacity assessments, eligibility scope, cost accountability, and timing.

Here's a look at select parties' remarks.

• CALSTART, the Environmental Defense Fund, and TURN generally support the PD's direction, arguing that early, standardized preliminary capacity assessments (Step 0/PCAs) are essential to informed customer investment decisions, that Flexible Service Connections should scale quickly without delay, and that utilities already possess the tools and experience to implement these requirements without undue burden. These parties also press for broader applicability (including extending requirements to SDG&E and, in some cases, single-phase customers) and caution against allowing utilities to defer compliance or narrow eligibility in ways that would slow electrification. EDF specifically defends the PD's "trust-and-verify" compliance model using existing Advanced Metering Infrastructure data, arguing it imposes minimal costs while avoiding expensive telemetry requirements.
• PG&E, SCE, and SDG&E emphasize operational flexibility, cost uncertainty, and safety, warning that tariff-based or overly rigid requirements could add administrative complexity, duplicate existing intake processes, strain resources, or encroach on issues better addressed in other proceedings such as High DER or General Rate Cases. The utilities consistently argue for discretion in defining upstream capacity, limiting Flexible Service Connections to true bridging use cases tied to primary-side constraints, preserving power-based load limits, and avoiding mandates related to telemetry, emergency ratings reform, secondary infrastructure, or behind-the-meter resources.
• SDG&E contests the need to prepare Flexible Service Connections offerings, claiming capacity constraints are unlikely in its territory (a position TURN challenges by noting SDG&E requested over $300 million for distribution capacity projects in its 2025 Senate Bill 410 application due to "significant forecast uncertainty" and underperformance in five energization target categories).
• TURN supports Flexible Service Connections while insisting on explicit ratepayer benefit criteria, stronger reporting, and Commission oversight through Tier 3 advice letters. TURN endorses Cal Advocates' opening comment recommendation requiring utilities to describe in their Implementation Advice Letters the specific criteria and process they will use for ratepayer cost-benefit determinations, applying a "net benefit" standard under which ratepayer value exceeds incremental implementation costs. TURN rejects arguments from CALSTART and EDF that ratepayer benefit standards would create unnecessary barriers, arguing the Commission can resolve feasibility concerns by requiring utilities to propose streamlined benefit-cost assessment criteria in their advice letters.

INSTANT ANALYSIS: The reply comments expose a clear divide over the future role of Flexible Service Connections in California's energization framework.

• Load-serving utilities argue for preserving discretion, limiting Flexible Service Connections to narrowly defined bridging scenarios, and deferring unresolved cost, safety, and technical questions to other proceedings.
• In contrast, freight, clean-energy, and consumer advocates contend that early power visibility, standardized offers, and firm implementation timelines are now essential to keep electrification projects viable and prevent avoidable project attrition.
• A separate but related dispute involves whether Flexible Service Connections should remain strictly temporary bridging solutions until upstream capacity upgrades are completed, or expand to encompass permanent load management applications such as avoiding upgrades entirely, supporting microgrids, or enabling demand response participation. (SDG&E and SCE argue that this question is out of scope here and belongs in the High DER proceeding, while TURN contends longer-term Flexible Service Connections frameworks warrant development now).

A final decision will hinge on whether Flexible Service Connections remain an operational workaround applied case-by-case, or evolve into a more durable and potentially permanent tool for managing constrained grid capacity while accelerating new load additions.

NATURAL GAS CURTAILMENTS

ENVOY NOTICE: Effective at 7:00 a.m. PST on January 26, and until further notice, SoCalGas has issued a systemwide curtailment watch covering both the SoCalGas and SDG&E service territories.

The notice cites extremely cold weather across large portions of the United States outside California, which has driven up national natural gas demand and raised the risk of upstream supply disruptions, including potential well freeze-offs in supply basins serving Southern California.

In response, storage facilities are operating at elevated utilization levels, and the combination of higher demand and reduced on-system supplies could lead to increasingly constrained system conditions. Noncore customers may be required to curtail or cease gas usage under SoCalGas Rule 23 ("Continuity of Service and Interruption of Delivery") and SDG&E Rule 14 ("Shortage of Gas Supply, Interruption of Delivery, and Priority of Service"). Customers are urged to balance usage with deliveries and to monitor Envoy for further updates.

INSTANT ANALYSIS: This curtailment watch serves as an early warning of growing constraints on the Southern California gas system driven by national weather, not in-state demand. The risk is concentrated on noncore customers, who should be prepared for curtailment if upstream disruptions persist or storage draw flexibility narrows further. Large-load customers with exposure to spot gas, imbalance penalties, or limited operational flexibility should review delivery alignment and contingency plans, particularly if cold weather in the Rockies and eastern U.S. continues to pressure production and interstate flows.

UPDATE: Effective 7:00 AM PST January 28, the systemwide curtailment watch is no longer in effect.