New Proposal Would Use IRP Portfolios to Trigger LSE Procurement
A June 23 ALJ ruling seeks party comments on a new option for the CPUC's Reliable and Clean Power Procurement Program (RCPPP), aimed at turning the Integrated Resource Planning process into a direct procurement obligation for load-serving entities.
Rather than tying the program closely to Resource Adequacy or creating an RPS-style clean energy mandate, the proposal would use the CPUC's Preferred System Plan and/or the CAISO Transmission Planning Process base-case portfolio to identify the mix of new resources needed five years ahead for reliability and emissions compliance. Those needs would be expressed in Net Qualifying Capacity (NQC), by resource type or attribute category, and allocated to load-serving entities based on their share of the CEC's Integrated Energy Policy Report load forecast.
Each LSE would have to put 100% of its allocated new resources under long-term contract within three years and online within five, with the first full online compliance deadline proposed for June 1, 2033. The ruling allows flexibility within resource categories (compliance bands such as 70% to 130%) but would penalize LSEs that fall short of their total NQC obligation or rely too heavily on the lowest-cost resource types. Resource accreditation would use marginal Effective Load Carrying Capability (ELCC) values rather than the RA program's Slice-of-Day framework. Resources must be incremental to the mid-term reliability baseline: online after Jan. 1, 2020 and not already counted toward a prior procurement requirement.
The ruling frames the proposal as a bridge between IRP, transmission planning and procurement, addressing a current deficiency: the CPUC and CAISO plan around portfolios that assume resources will be built, but no standing mechanism requires LSEs to procure the specific mix reflected in those portfolios.
The proposed cadence assumes the CAISO's biennial Transmission Planning Process cycle under FERC Order 1920 is adopted; if it is not, the schedule changes.
Comments are due July 22, with replies due August 7.
INSTANT ANALYSIS
The CPUC is again trying to solve the core IRP problem: portfolios get modeled, transmitted to the CAISO for transmission planning, and treated as the backbone of California's clean-reliability future...but no standing mechanism requires LSEs to procure the resource mix those portfolios assume. The new RCPPP option would make the Preferred System Plan and/or Transmission Planning Process base case the procurement anchor, translating the five-year resource need into LSE-specific NQC obligations allocated by load share.
The proposal deliberately refuses to collapse IRP into RA or RPS. Both programs would continue separately, with RCPPP layered on top as a long-term procurement compliance regime. The ruling argues that, in a ground-up design, short-term RA requirements would flow from long-term procurement needs, not the other way around. The practical cost is two accreditation systems (marginal ELCC for RCPPP and slice-of-day for RA) which the ruling acknowledges may be inefficient but justifies on the view that long-term portfolio value should track the evolving system mix.
If adopted, the framework would move California off episodic ad hoc procurement orders and onto a recurring compliance structure: 100% of allocated new resources would be under contract within three years, online within five, with penalties tied to net cost of new entry plus a separate penalty meant to deter overreliance on the cheapest resource types. The first full online compliance deadline would be June 1, 2033.
The schedule assumes the CAISO's biennial Transmission Planning Process cycle under FERC Order 1920 is adopted, with RCPPP running every two years and procurement deadlines falling every other year. If that cycle changes, the compliance calendar will change with it. The proposal also moves away from the 2025 Staff Proposal's collective Central Procurement Entity reserve, instead proposing a 1% buffer and asking parties whether that smaller cushion is sufficient.