> ## Content Index > Fetch the complete content index at: https://www.calregulatory.com/llms.txt > Use this file to discover other available public pages before exploring further. # The CPUC's RA Reset: UCAP, Storage Penalties, EO Limits, and the End of Paper Capacity - URL: https://www.calregulatory.com/the-cpucs-ra-reckoning-ucap-storage-penalties-eo-limits-and-the-end-of-paper-capacity/ - Published: 2026-06-02T12:30:38.000Z - Updated: 2026-06-24T19:09:41.000Z - Author: MC - Tags: R.25-10-003, Local Capacity Requirements, Flexible Capacity Requirements, Unforced Capacity, EFORd, Must-Offer Obligation, Qualifying Capacity, Slice of Day, Pmax, LDES, Forward Charge Period, pumped storage hydropower The CPUC issued a [proposed decision](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M608/K058/608058096.PDF?ref=calregulatory.com) in R.25-10-003, adopting 2027-2029 Local Capacity Requirements, 2027 Flexible Capacity Requirements, and a set of Slice-of-Day RA reforms that change what it means to hold RA capacity in California. The earliest the CPUC will consider this item is **July 2**. Comments are due **June 22**. --- ### **LOCAL & FLEXIBLE CAPACITY** The PD adopts the CAISO's recommended Local Capacity Requirements: - **23,618 MW** for 2027; - **24,545 MW** for 2028; and - **25,480 MW** for 2029\. The LA Basin climbs from 6,823 MW to **7,721 MW** over the three years. Seven of 10 local areas carry the CAISO’s resource-deficiency notation, meaning resource shortfalls or storage charging constraints could cause load shed after a first contingency at summer peak. The Western LA Basin is already hitting charging limits; the Eastern LA Basin hit them in 2025\. The PD adopts the 2027 Flexible Capacity Requirements without modification, peaking in November at **30,058 MW** system-wide and **28,448 MW** for CPUC-jurisdictional areas. ### **UNFORCED CAPACITY** Effective for the 2028 RA compliance year, dispatchable thermal, nuclear, geothermal, and non-hybrid storage resources will have their accreditation reduced by their Equivalent Forced Outage Rate during RA Measurement Hours. The formula is ***UCAP = (1 − EFORd) × Pmax***, applied separately for summer and non-summer seasons, using the best three of the prior four calendar years of CAISO outage data for each resource individually. New resources receive class-average EFORd values until unit-specific history accumulates. Thermal generators get weather-normalized ambient-temperature derates using NOAA 30-year typical weather-year data, preventing an anomalous hot year from permanently depressing a unit's accreditation value. Preliminary UCAP values will be published in early 2027 for party comment, with final values distributed in September 2027, leaving load-serving entities and counterparties about 15 months to assess what their contracted resources will be worth before the first compliance year opens. The PD defers six implementation questions to Track 2: - Hybrid resource methodology; - The Must-Offer Obligation basis once UCAP replaces Qualifying Capacity; - How EFORd will be calculated for the energy component of storage resources; - Fifth-hour foldback treatment; - Flexible RA interaction; and - Slice-of-Day template integration. None of those open items will delay the 2028 effective date. ### **STORAGE ACCREDITATION** The PD makes two distinct changes to storage accreditation, both effective immediately. The storage QC calculation is revised to address foldback: rather than treating Pmax as a constant, the new formula uses **MAX\_CONT\_ENERGY\_LIMIT** minus **MIN\_CONT\_ENERGY\_LIMIT** from the CAISO Master File, divided by four, constrained by the Point of Interconnection. The Master Resource Database's Maximum Continuous Energy default field is also revised to use that same calculation, though that is an administrative database change, not a modification to the accreditation formula itself. On energy-only resources, the PD issues three directives. - EO resources may not count toward RA capacity requirements (the PD rejects that proposal outright, as EO resources have never been studied for deliverability during stressed system conditions). - Whether standalone EO resources may count toward storage charging sufficiency is deferred pending CAISO's 2026–2027 Transmission Planning Process study, with preliminary results expected in November 2026\. - What the PD does adopt, beginning in 2027, is a same-Point of Interconnection rule: excess energy from an EO resource co-located with deliverable storage at the same point of interconnection may count toward charging sufficiency after subtracting the paired storage resource's own energy sufficiency need. ### **LONG-DURATION ENERGY STORAGE** LDES is defined as any storage resource capable of discharging at maximum capacity for at least eight continuous hours. Effective for 2027, load-serving entities may count LDES capacity across the full 24-hour Slice-of-Day period using a Forward Charge Period multiplier ranging from **2x** (eight-hour resources) to **8x** (72-hour-plus resources), grounded in the existing worst-day framework. No assumed initial state of charge is adopted. Closed-loop pumped storage hydropower receives LDES treatment; open-loop PSH is deferred. ### CHARGING SUFFICIENCY PENALTY AND DR The PD also closes an enforcement gap in the storage charging rules. Beginning in 2027, a load-serving entity with an MWh charging sufficiency shortfall would have that shortfall converted into a flat 24-hour MW adder. The adder would be applied to each hourly position, and the largest resulting hourly deficiency would determine the RA penalty. For Demand Response, the PD adopts a near-term correction to a Slice-of-Day misalignment. The CPUC will provide the CAISO with three Demand Response values: - The maximum showing value; - The peak showing value; and - The average hourly MW value during event hours within the Availability Assessment Hour window. Any non-event hour would be excluded from that average. ### **REJECTIONS & DEFERRALS** The PD rejects hourly load obligation trading. Energy Division's[ Transactability Report](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M599/K960/599960179.PDF?ref=calregulatory.com) found no demonstrated inability for load-serving entities to meet Slice-of-Day obligations under existing mechanisms. Future proposals must prove a problem exists and clear five additional conditions. The PD does not adopt broader exceedance methodology changes; only a transmission-event protection rule for non-dispatchable resources takes effect in 2027. ### **INSTANT ANALYSIS** This PD prices operational performance into RA value. A thermal unit that trips frequently will be worth less. Storage that folds back before four hours will be credited accordingly. A load-serving entity that cannot cover charging sufficiency will now face a penalty with MW consequences. The six open UCAP implementation questions deferred to Track 2 are not minor. Hybrid resource methodology, Must-Offer Obligation basis, and Slice-of-Day template integration all affect how UCAP operates in compliance practice, and they remain unsettled 15 months before the first UCAP compliance year opens. The EO directive comes in three distinct parts. Anyone negotiating EO contracts should track all three components, particularly the Transmission Planning Process timeline. The LDES multiplier framework gives eight-hour-plus storage a formal RA accreditation pathway for the first time. That's important at a time when IRP procurement orders are already pushing toward longer-duration resources and developers have been contracting without a clear counting rule. The transactability rejection closes the question for now, but the Commission is explicit about what a future proposal would need to prove. If 2026 or 2027 Slice-of-Day compliance data show that load-serving entities cannot meet hourly obligations under existing mechanisms, CalCCA will be back with a record built around those findings. --- **Attachments:** - [Appendix A: Summary of Load Forecast Process Under Slice-of-Day RA Framework](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M608/K058/608058317.PDF?ref=calregulatory.com) - [Appendix B: Unforced Capacity Framework](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M608/K058/608058097.PDF?ref=calregulatory.com)