> ## 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 Energization Quagmire: Bad Data and Big Backlogs
- URL: https://www.calregulatory.com/the-energization-quagmire-bad-data-and-big-backlogs/
- Published: 2026-06-01T12:30:41.000Z
- Updated: 2026-06-02T05:17:13.000Z
- Author: MC
- Tags: R.24-01-018, D.24-09-020, Section 935

A new [ruling](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M607/K627/607627593.PDF?ref=calregulatory.com) in its Timely Energization docket directs PG&E, SCE, and SDG&E to respond to [questions](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M607/K583/607583175.PDF?ref=calregulatory.com) arising from [Guidehouse's review](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M607/K644/607644153.PDF?ref=calregulatory.com) of the utilities' September 2025 Biannual Energization Reports. All parties may answer the same questions. 

### **THE** KEY FINDING

[Guidehouse](https://guidehouse.com/?ref=calregulatory.com) determined that the September 2025 data are insufficient to assess utility compliance with the energization targets established by the CPUC in a 2024 decision ([D.24-09-020](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M540/K806/540806654.PDF?ref=calregulatory.com)). The data are directional only.

### **WHY THE DATA FAILED**

D.24-09-020 established [enforceable average and maximum energization targets](https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M540/K809/540809275.PDF?ref=calregulatory.com), an eight-step framework, and a twice-yearly reporting obligation covering tariff projects under Rules 15, 16, 29, and 45, plus main panel upgrades. The September 2025 reports cover projects with complete applications from January 31, 2023 through June 30, 2025, a window that straddles the decision's September 2024 issuance date, mixing pre- and post-decision projects throughout.

Each utility's tracking systems failed in a distinct way. 

- PG&E is still integrating systems and cannot reliably track Step 6 (IOU Site Readiness) or Step 8 (Energization); only 6.3% and 47% of completed tariff projects, respectively, have start or end dates for those steps. PG&E did, however, produce the most complete dataset overall, including a methodology for allocating overlapping utility and customer time and outlier flags on individual project records. (***PG&E's report is available*** [***here***](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M582/K104/582104343.PDF?ref=calregulatory.com)***.***)
- SCE provided complete step-date data across all eight steps (the only utility to do so) but its systems cannot separate IOU-controlled time from customer or third-party time, which means SCE cannot compare its reported timelines to the CPUC's utility-controlled targets at all. (***SCE's report is available*** [***here***](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M582/K082/582082543.PDF?ref=calregulatory.com)*.*)
- SDG&E struggled with multiple steps, could not track utility-controlled time separately from customer time, and cannot provide reliable end-to-end cycle data. SDG&E also cited funding constraints as a barrier to system improvements, noting that many required initiatives were not included in its most recent general rate case. (***SDG&E's report is available*** [***here***](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M582/K028/582028396.PDF?ref=calregulatory.com)***.***)

Guidehouse assessed data sufficiency against two thresholds: 

- 95% availability for compliance data points (tariff type, IOU-controlled steps, aggregate IOU-controlled and end-to-end timelines); and
- 75% for contextual data points (capacity, costs, upstream triggers, delay causes).

None of the three utilities met those thresholds. Approximately one-third of required data fields were missing for more than 75% of projects across all three IOUs.

Beyond the timeline data failures, Guidehouse found that cost data at the time of energization is unreconciled for six to 12 months after project completion; that outlier treatment was inconsistent across all three IOUs; and that none of the utilities could reliably identify when a tariff project triggered an upstream capacity upgrade.

### **WHAT THE RULING IS BUILDING TOWARD**

The ruling's [questions](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M607/K583/607583175.PDF?ref=calregulatory.com) cover the full range of problems Guidehouse identified. The CPUC is asking utilities and parties to address: 

- How IOU systems will be upgraded and when;
- How overlapping IOU and customer time should be allocated;
- How step start and end dates should be defined where no clear energization or meter-set date exists;
- How upstream capacity triggers should be tracked;
- How cost reconciliation should be standardized;
- What data fields the annual [Section 935](https://law.justia.com/codes/california/code-puc/division-1/part-1/chapter-4/article-14-5/section-935/?ref=calregulatory.com) staffing reports should contain, including job classifications, staffing levels, and apprentice pipeline information;
- How staffing levels should demonstrate a relationship to energization timeline performance; and
- Whether the proposed data sufficiency thresholds, outlier definitions, and data template modifications should be adopted.

The ruling is a step toward deciding what data will count when the CPUC evaluates energization performance, and toward determining what happens when a utility's data do not meet the threshold required to support that evaluation.

### **INSTANT ANALYSIS**

The CPUC cannot yet say whether PG&E, SCE, or SDG&E are meeting the energization targets adopted in D.24-09-020\. But Guidehouse's review is also a roadmap for making the next reporting cycles enforceable.

The risk for the utilities is that bad data may become its own regulatory problem. The ruling's [questions](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M607/K583/607583175.PDF?ref=calregulatory.com) ask whether utilities that fail Guidehouse's proposed sufficiency thresholds should be required to file additional reporting on their energization backlogs. 

Whichever parties shape the definitions of utility-controlled time, customer delay, upstream capacity triggers, actual project costs, and outliers will shape how future energization performance is judged.