Proof of Value

From 2008 to 2025, regulatory analyst Michael Cade (founder of CRI) served as the primary regulatory intelligence engine for legal teams representing California's largest energy consumers in CPUC proceedings governing billions of dollars in utility cost recovery.

While at Buchalter and Alcantar & Kahl, his monitoring and analysis informed work that:

Reduced utilities' authorized Cost of Capital adjustments (D.24-10-008);
Challenged utility wildfire cost-recovery authorizations (D.25-12-023);
Contributed to development of the CPUC's Safety Model Assessment Proceeding (S-MAP) framework for identifying and prioritizing utility safety risks (D.14-12-025);
Supported continued use of the Aliso Canyon natural gas storage facility at levels necessary for system reliability and affordability (D.24-12-076); and
Shaped favorable rate-design outcomes in General Rate Case litigation involving PG&E, SoCalGas, and SCE.

CRI now delivers that same analytical capability (real-time monitoring of CPUC filings, same-day interpretation of regulatory decisions, and forward-looking assessment of rate and reliability impacts) directly to energy companies and other entities operating in California.

This intelligence is now available as a direct subscription service (or embedded intelligence partnership) at a fraction of traditional consulting costs.

Clients Served Through Law-Firm Engagement

Energy Producers and Users Coalition (EPUC) and the Indicated Shippers (coalitions representing Aera, BP, California Resources Corporation, ConocoPhillips, ExxonMobil, Marathon Petroleum, PBF Energy, Phillips 66, Shell)
California Community Choice Association (CalCCA)
California Large Energy Consumers Association (CLECA)
Clean Energy
Cogeneration Association of California (CAC)
Electrochaea
Olivine

Recent Examples Where CRI's Analysis Provided Unique Advantage

The following examples demonstrate how CRI's analysis provides operational and financial advantages unavailable from general publications, law-firm updates, or episodic consulting.

SDG&E January 2026 Rate Increase – Capital vs. Energy Cost Attribution

What general coverage reported: SDG&E rates would increase 10% effective January 1.
What CRI delivered: The increase wasn't driven by energy procurement (SDG&E's ERRA revenue requirement actually dropped $67 million). The real drivers were capital recovery mechanics invisible in any press releases: a $172 million TACBAA transmission true-up (past cost reconciliation, not new investment), $616 million in PABA undercollection signaling bundled/departed load tension, and GRC base margin increases. Most critically, residential delivery rates rose 19.4%.
Why it mattered: CRI readers could distinguish between temporary procurement volatility and structural cost pressure, and industrial customers could see the distributional politics building around residential subsidization.

PG&E B-20 Rates: Where the Money Lives for Industrial Customers

What general coverage reported: New PG&E industrial rates took effect January 1, including B-20 rate schedule.
What CRI delivered: CRI's "Where the Money Lives" analysis broke down the actionable levers for a 5 MW secondary-voltage customer on B-20 rates: $460K/month in demand charges (before any consumption), $272K/year in Time-of-Use arbitrage value through load shifting, the "Option R" demand charge trap, and Peak-Day Pricing risk-reward calculus. CRI quantified exactly which billing components drive costs and where operational flexibility creates savings.
Why it mattered: Energy managers could model financial impact of load-shifting investments, self-generation timing, and rate schedule choices with precision unavailable from utility press releases.

SoCalGas CAP Filing – "Normalized" Rate Presentation Didn't Tell the Full Story

What general coverage reported: SoCalGas filed its Cost Allocation Proceeding (CAP) for 2027-2029.
What CRI delivered: When this filing appeared in September 2025, CRI spotted that SoCalGas was comparing its proposed rates to "normalized" September 2025 baselines rather than actual rates, which created an illusion of rate decreases. This realization was also noted by the Southern California Generation Coalition (SCGC), whose analysis showed electric-generation transmission service would actually increase 23% under the proposal. CRI surfaced SCGC's protest, which argued that SoCalGas was replacing the storage/balancing regime from a 2024 Cost Allocation Proceeding settlement without sufficient justification, with reductions in injection/withdrawal capacity that would hit noncore industrial users hardest.
Why it mattered: Sophisticated energy buyers could see past SoCalGas's normalized baseline presentation to understand actual rate impacts. CRI's curation of SCGC's protest surfaced critical analysis that would have been missed in standard regulatory feeds.

Aliso Canyon Biennial Assessment – Storage Reduction Impact on Unbundled Storage Program

What general coverage reported: Energy Division recommends 10 Bcf reduction at Aliso Canyon.
What CRI delivered: CRI connected the inventory reduction to Decision 24-07-009's cascading impact on the Unbundled Storage program (a 10 Bcf cut would automatically shrink UBS capacity from 25 Bcf to 15 Bcf, materially reducing seasonal flexibility for noncore shippers). CRI also caught that Staff's own analysis showed 550 MMcfd withdrawals needed on 1-in-10 winter peak days, contradicting the reduction logic. Additionally, CRI identified Staff hedging their own recommendation ("a smaller incremental or no reduction may be appropriate") due to LNG export pressures and Energía Costa Azul startup.
Why it mattered: Refiners and generators could quantify operational risk and price exposure from reduced storage optionality (not just abstract "reliability concerns").

Representative Areas of CPUC Proceedings (2008-2025)

Illustrative scope of work; not a comprehensive list

CRI's analytical work spans hundreds of CPUC proceedings and select FERC matters, including:

Risk-based decision-making frameworks and utility safety oversight (S-MAP);
De-energization and Public Safety Power Shutoff (PSPS) planning;
Biomethane and renewable gas policy;
Natural gas safety, storage, and price investigations;
Pipeline Safety Enhancement Plans;
Zonal electrification and decarbonization pilots;
Building electrification initiatives;
Hydrogen demonstration and blending proposals; and
Demand response and load flexibility programs

Full pricing options available here.