Parties File Post-Prehearing Conference Statements in CPUC's New Climate Credit OIR

On December 8 the California Community Choice Association (CalCCA), SoCalGas, and TURN submitted post-prehearing conference (PHC) statements following this proceeding's November 21 PHC.

The CPUC opened this rulemaking to redesign how the California Climate Credit is structured, calculated, and delivered to customers. As ALJ Sotero stated on the record, the rulemaking was initiated to consider ways to make the climate credit more effectively support customer affordability and to implement newly enacted statutory requirements that the credit be disbursed in no more than four high-bill months rather than the current spring/fall pattern.

In their post-PHC statements, parties lay out ideas for how the Commission should structure and sequence the docket.

Parties' Post-PHC Statements

• TURN calls for a limited Phase 1A, aimed solely at adopting changes to the timing and number of 2026 disbursements (specifically to ensure the fall 2026 credit can be advanced without entanglement in broader eligibility or methodological issues). TURN recommends placing more expansive policy questions into a concurrent Phase 1B and a Phase 2 triggered by the California Air Resources Board’s forthcoming Cap-and-Invest regulations.* TURN also presses for a shared modeling tool or, secondarily, a coordinated scenario-analysis process to ensure consistent distributional impact analysis across parties.
• SoCalGas also supports phasing the rulemaking. It centers its advocacy on protecting gas-customer bill impacts, adding decarbonization (not electrification) to the proceeding’s guiding principles, and clarifying that more complex eligibility or volumetric-allocation changes may require new memorandum accounts and cannot be implemented before CARB completes its rulemaking. SoCalGas also proposes moving the gas Climate Credit from April to February beginning in 2027, while keeping April 2026 unchanged.
• CalCCA opposes a narrowly focused Phase 1A, arguing that modifying the fall 2026 credit in isolation (before simultaneously evaluating timing, eligibility, frequency, and outreach) risks harming winter-peaking customers and generating customer confusion. CalCCA prefers a unified Phase 1 that evaluates all timing-related questions together, paired with standard Commission processes (workshops, staff reports) and development of a modeling tool to assess bill impacts.

INSTANT ANALYSIS: This proceeding is on the verge of becoming a full-scale redesign of the Climate Credit rather than a simple timing adjustment. Assembly Bill 1207 deadlines, Energy Resource Recovery Account constraints, and pending CARB regulations are forcing the CPUC into an unusually compressed decision cycle.

FOOTNOTE

*CARB is conducting a required update to its Cap-and-Trade (now called Cap-and-Invest) regulations under AB 1207, and the CPUC cannot finalize long-term Climate Credit reforms until CARB completes this rulemaking.