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# SATURDAY BRIEFING: CPUC Tees Up DER Market-Design Battle; PG&E's Mosquito Fire Bill Comes In at $22M
- URL: https://www.calregulatory.com/saturday-briefing-cpuc-tees-up-der-market-design-battle-pg-es-mosquito-fire-bill-comes-in-at-22m/
- Published: 2026-07-11T19:10:37.000Z
- Updated: 2026-07-11T19:10:37.000Z
- Author: MC
- Tags: Mosquito Fire, Safety and Enforcement Division, R.21-06-017, TSO-DSO, Advanced Metering Infrastructure, DERMS, DER orchestration, Transmission Centralized Inspection Review Team, SPD, SAIDI, SAIFI, CAIDI, MAIFI, CEMI, CELID, Major Event Days, R.25-09-004, Emergency Load Reduction Program, ELRP

Good afternoon.

The CPUC is beginning to turn years of discussion about flexible distributed resources into a concrete regulatory framework. New questions in the High DER proceeding ask parties to define how utility pilots, open-access platforms and CPUC-led working groups should fit together and to quantify the ratepayer savings that DER orchestration could produce.

Elsewhere, the CPUC's Safety and Enforcement Division has proposed a **$22 million** Mosquito Fire settlement with PG&E that subjects the utility’s transmission-repair review process to an independent examination. Separately, a proposed decision would create a far more granular annual record of customer outages. 

Last, an email ruling clears testimony and hearings from the Demand Response bridge-year funding dispute, setting up a decision on the written record.

---

### DISTRIBUTED ENERGY RESOURCES 

A new CPUC ruling [enters](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K354/610354178.PDF?ref=calregulatory.com) two Track 2 workshop reports into the record of the Commission's High DER proceeding ([R.21-06-017](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M390/K664/390664433.PDF?ref=calregulatory.com)), with opening comments due **July 27** and replies due **July 31**. 

The reports cover:

- A May 21 workshop on [distribution system operator-led DER orchestration](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K355/610355488.PDF?ref=calregulatory.com); and
- The June 5 [TSO-DSO coordination](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K353/610353842.PDF?ref=calregulatory.com) workshop held with the CAISO in Folsom.

Energy Division prepared the first report, while the CAISO and the three large electric IOUs prepared the second. The ruling’s first question invites parties to identify factual inconsistencies or needed clarifications in either account.

These workshops examined how utilities could use batteries, electric vehicles, smart thermostats, water heaters and other flexible loads to meet location-specific grid needs, defer capital projects, accelerate energization and improve reliability. 

The record spans DER visibility, communications standards, dispatch/aggregator roles, valuation, incentives, utility readiness, and the data CAISO needs from distribution operators to forecast and operate the system. The ruling’s 18 questions ask parties to address sequencing, working-group scope, pilot integration, Advanced Metering Infrastructure and DERMS capabilities, customer-owned technology fit, circuit-level flexibility modeling and specific opportunities for ratepayer savings.

**INSTANT ANALYSIS:** Even the utilities are not pressing for immediate, full-scale DER orchestration applications. 

- SCE recommends an advice-letter pathway with balancing or memorandum accounts for iterative pilots ahead of its next General Rate Case.
- PG&E proposes a Tier 2 advice letter and memorandum account covering a 2026-27 trial phase, piloting through 2030 and scaling afterward.
- SDG&E wants the framework adopted first, applications filed only when readiness justifies them, and no Commission-mandated timeline.
- Cal Advocates goes further, arguing that the CPUC should build the framework before deciding whether applications are needed at all.

The July comment round therefore will help determine who designs the interim work (Commission-led working groups, utility pilots or both) and on what schedule. What "open access" means in practice remains an open question. 

- PG&E describes a competitive marketplace, and SDG&E supports transparent procurement.
- [Universal Devices](https://www.universal-devices.com/?ref=calregulatory.com) pointed to PG&E’s acknowledgment at a February Track 3 workshop that its current aggregator interface is proprietary and non-standardized, and warned that without a Commission-level framework each IOU could build its own system, forcing manufacturers and aggregators to integrate separately with each utility.
- CalCCA urged the Commission to evaluate an independent marketplace operator, citing [Piclo](https://www.piclo.com/?ref=calregulatory.com)’s UK track record and 2025 U.S. launch.
- The Utility Consumers' Action Network (UCAN) called for procurement of a statewide flexibility platform, pointing to Piclo's Connecticut deployment and the California Resource Adequacy marketplace. UCAN also argued that each additional year of piloting risks locking in distribution upgrades that an operating flexibility market could defer, given the IOUs' forecast of **$42 billion** to **$48 billion** in distribution investment through 2040.

The CPUC wants quantified showings. Question 17 requires explicit examples of cost reductions and how they change at scale, while Question 13 requires dependability accounting grounded in actual customer behavior and resource availability. 

---

### WILDFIRES

The CPUC's [Safety and Enforcement Division](https://www.cpuc.ca.gov/about-cpuc/divisions/safety-and-enforcement-division?ref=calregulatory.com) (SED) has proposed a **$22 million** settlement with PG&E to resolve its investigation of the [2022 Mosquito Fire](https://en.wikipedia.org/wiki/Mosquito%5FFire?ref=calregulatory.com), which burned 76,788 acres in Placer and El Dorado counties and destroyed 78 structures after igniting near [Oxbow Junction Reservoir](https://www.onwaterapp.com/us/california/water/oxbow-reservoir-w2?ref=calregulatory.com) on September 6, 2022\. 

Under a [proposed Administrative Consent Order](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M610/K764/610764138.pdf?ref=calregulatory.com), PG&E shareholders would pay **$21 million** to the state General Fund and up to **$1 million** for an independent review of the utility's Transmission Centralized Inspection Review Team, the internal unit that reviews inspection findings and decides which transmission repairs proceed. Any unused review funds would also go to the General Fund.

For settlement purposes, PG&E admits four violations of [General Order 95: ](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M550/K438/550438485.pdf?ref=calregulatory.com)

- Overdue corrective repairs;
- Failure to preserve the removed pole and attached equipment due to an internal coordination error;
- Six years of missed function tests on the two Oxbow Junction switches; and
- Inadequate clearance between a jumper and the interconnection switch rod, the condition SED alleges created the September 6 electrical fault.

PG&E does not contest a vegetation-clearance allegation at the same pole. It disputes two others, involving loose tie wires and six cancelled transmission-maintenance notifications, and the agreement states that most of the cited conditions were unrelated to ignition. SED dismissed an eighth allegation, a late initial incident report.

The Administrative Consent Order would resolve all claims SED brought or could have brought from the Mosquito Fire investigation, with no formal adjudicatory proceeding. SED retains authority to open separate enforcement against the inspection-review team based on the third-party report. The earliest the CPUC will consider this item is **August 13**.

**INSTANT ANALYSIS**: Twenty-two million dollars is a rounding error next to Zogg (**$150 million**) and Dixie (**$45 million** from the CPUC, plus **$34.75 millio**n to five county district attorneys). The record explains the discount: no deaths, no injuries, an agreement that expressly detaches most cited conditions from ignition, and two allegations PG&E was prepared to litigate. SED traded those disputes for certainty rather than testing them.

The disputed allegations go to how PG&E's inspection-review team cancels repair notifications, and SED's record shows the team cancelled 131,119 notifications created in 2023 alone. The $1 million examination is confined to the team's general policies and procedures, not the specific Oxbow cancellations, but SED reserved the right to open separate enforcement based on what the third party finds. 

The question of how PG&E decides which transmission defects get fixed stays open, now with an SED-approved contractor inside the process and a one-year report deadline attached.

---

### ELECTRIC RELIABILITY/RESILIENCY 

A new [proposed decision](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K354/610354736.PDF?ref=calregulatory.com) would require PG&E, SCE, and SDG&E to file a unified annual "Customer Reliability Report" with the CPUC's [Safety Policy Division](https://www.cpuc.ca.gov/about-cpuc/divisions/safety-policy-division?ref=calregulatory.com) (SPD) beginning in 2027, due within 30 days after **July 15** each year. The filing would absorb the existing "[Annual Electric Reliability Report](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/infrastructure/electric-reliability/electric-system-reliability-annual-reports?ref=calregulatory.com)" unchanged and consolidate outage information now spread across multiple reports.

The PD's template goes beyond what the utilities proposed. For each outage, they would report:

- The percentage of the circuit that is overhead versus underground;
- The conductor type (bare, covered or insulated) of the circuit or segment involved;
- Start and end times;
- Whether the event was a Public Safety Power Shutoff or occurred on a Fast-Trip-enabled circuit; and
- Counts of Medical Baseline and essential customers.

PSPS and Fast-Trip events would be categorized separately from other unplanned outages.

Utilities would explain how they notify customers before, during and after outages, with separate reporting for maintenance outages, de-energizations, weather events and Fast-Trip interruptions. The reports would also delineate communications by customer class and describe outreach to public safety partners and medically vulnerable customers.

The template adds [SAIDI](https://en.wikipedia.org/wiki/SAIDI?ref=calregulatory.com), [SAIFI](https://en.wikipedia.org/wiki/SAIFI?ref=calregulatory.com), [CAIDI](https://en.wikipedia.org/wiki/CAIDI?ref=calregulatory.com) and [MAIFI](https://en.wikipedia.org/wiki/MAIFI?ref=calregulatory.com) to the utilities’ proposed [CEMI and CELID](https://www.sandc.com/en/gridtalk/2020/july/21/moving-beyond-average-reliability-metrics/?ref=calregulatory.com) measures. Those metrics would be reported with and without "Major Event Days" and sortable by income, poverty level and urban, suburban or rural location. Customer- and outage-level tables would also incorporate wildfire mitigation data.

The PD retains annual reporting over party proposals for monthly, quarterly or semiannual filings. The utilities would file the reports by advice letter, with SPD preparing a resolution for CPUC consideration. Every three years beginning in 2029, the utilities may propose limited template updates. The earliest the PD will be considered is **August 13**.

**INSTANT ANALYSIS:** The PD converts reliability reporting from a systemwide scorecard into a granular record of who lost power, for how long, under what grid conditions and with what notice. It imposes no new reliability standard or spending mandate. However, the schema could shape later rate cases, wildfire proceedings and distribution-investment reviews by making persistent outage patterns traceable to specific circuits, infrastructure types and customer groups. 

---

### DEMAND RESPONSE

In a July 7 [email ruling](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M610/K353/610353914.PDF?ref=calregulatory.com) in the CPUC's Demand Response rulemaking ([R.25-09-004](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M582/K072/582072320.PDF?ref=calregulatory.com)), ALJ **Brandon Gerstle** eliminated testimony, evidentiary hearings and briefs from the schedule for the DR bridge-year funding issue. The ruling concludes that the written record is sufficient for a decision. 

Cal Advocates was the only party to request testimony, seeking to oppose an increase in the [Emergency Load Reduction Program](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/demand-response-dr/emergency-load-reduction-program?ref=calregulatory.com) (ELRP) budget, but Gerstle said he is not inclined to change that budget at this time. 

**INSTANT ANALYSIS:** The ruling closes the evidentiary phase of the bridge-year funding dispute and puts the matter on a path toward a proposed decision. Cal Advocates lost its bid for testimony, but Gerstle’s reluctance to change the ELRP budget favors the outcome it sought: no budget increase.