Proof of Value

Real-Time Intelligence on CPUC Decisions that Move Billions in Utility Costs

From 2008 to 2025, regulatory analyst and CRI founder Michael Cade 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);
Successfully contested wildfire mitigation cost-recovery requests to ensure reasonableness and ratepayer protection (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 eliminates regulatory shock. We translate thousands of pages of CPUC filings into the specific financial and operational levers that impact your bottom line, delivered with the speed required to act before the market moves.

This intelligence is now available through direct subscriptions or enterprise retainers 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 basic 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 the financial impact of load-shifting investments, self-generation timing, and rate schedule choices with precision unavailable from utility news 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: The CPUC's Energy Division recommends a 10 Bcf reduction at Aliso Canyon.
What CRI delivered: CRI connected the inventory reduction to a 2024 CPUC decision's cascading impact on the Unbundled Storage program (a 10 Bcf cut would automatically shrink UBS capacity from 25 Bcf to 15 Bcf, significantly reducing seasonal flexibility for noncore shippers). And pursuant to a SoCalGas compliance filing, CRI caught that CPUC 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: By mining useful knowledge from an obscure, 11-page compliance filing, CRI gave refiners and generators an opportunity to quantify their operational risk and price exposure from reduced storage optionality (not just abstract "reliability concerns").

Warned Large Gas Transportation Customers of a 54.6% Backbone Transportation Service Increase Embedded in SoCalGas’s 2026 Rate Consolidation

What general coverage reported: SoCalGas’s January 1, 2026 consolidated rate update produces a modest net systemwide revenue decrease.
What CRI delivered: CRI identified that the filing masked a massive cost reallocation, with Backbone Transportation Service absorbing a $224.3 million increase (a 54.6% rate jump) driven by layered regulatory account amortizations, integration adjustments, and CAP allocation mechanics. In deciphering the January 1 filing, CRI explained that BTS was functioning as the residual allocator of system-level transmission costs even as overall revenues declined. This means that non-volumetric risk is shifted onto backbone transportation customers rather than distribution classes.
Why it mattered: CRI forecasted the BTS increase months in advance, allowing traders and industrial customers to adjust hedging strategies, renegotiate contracts, and model exposure before implementation. By identifying the cost-shift mechanism in a routine rate consolidation filing, CRI provided early warning of a major transmission cost risk affecting dispatch economics and pricing.

Identified that a PG&E Interest Adjustment Increased Carrying Costs on Regulatory Balances

What general coverage reported: PG&E filed a non-descript advice letter to implement the CPUC’s Yield Spread Adjustment for regulatory account interest calculations.
What CRI delivered: CRI identified that the newly established 125-basis-point spread increases financing costs on major balancing and memorandum accounts across PG&E’s gas and electric portfolios, thereby raising the cost of carrying wildfire, procurement, and other large balances over time despite no immediate rate change.
Why it mattered: This analysis warned stakeholders that procedural delays and unresolved balances now carry a higher embedded financing cost that will surface in future rates, affecting long-term exposure for customers, counterparties, and market participants.

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. If you operate in California’s energy markets, you cannot afford to be surprised by CPUC decisions. CRI ensures you never are.

Enterprise retainers available now.