> ## 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. # THURSDAY BRIEFING: CPUC Asks Whether PCIA Reform Should Get Bigger - URL: https://www.calregulatory.com/thursday-briefing-cpuc-asks-whether-pcia-reform-should-get-bigger/ - Published: 2026-06-25T12:30:07.000Z - Updated: 2026-06-25T12:30:07.000Z - Author: MC - Tags: PCIA, ERRA, Risk Spending Accountability Report, RSAR, non-bypassable charge, Volumetric Performance Fee - Today's briefing covers a new ruling in the ERRA/PCIA reform docket that opens the door for parties to argue that Track 3 in the proceeding should go beyond technical PCIA refinements. - SCE's 2025 Risk Spending Accountability Report shows a significant underspend against authorized safety, reliability, and maintenance work. The report raises familiar questions about forecast-based authorizations, execution constraints, and whether risk-reduction work is being delayed or shifted. - A new scoping memo addresses PG&E's latest cost-recovery application for Diablo Canyon extension costs. --- ### ERRA/PCIA REFORM The CPUC issued a [ruling](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M609/K173/609173180.PDF?ref=calregulatory.com) in the ERRA/PCIA Reform docket that opens post-workshop comments in Track 3\. Parties may now address issues raised at the June Track 3 Planning Workshops, issues from earlier Track 3 comments, and a specific set of ALJ questions in the ruling. For the Day 1 (June 8 workshop) questions, the ALJ asks whether four topics clear a net-benefits threshold sufficient to warrant inclusion in Track 3 scope: - Targeted recovery for uneconomic legacy resources; - Revisiting allocation, including potential mandatory allocations; - Mechanisms to reduce volatility and stabilize rates; and - Other frameworks for achieving indifference that produce greater ratepayer net benefits and promote competition among load-serving entities. Parties must also state whether any topic should be treated as mutually exclusive with the others. Day 2 (the June 9 workshop) involves ERRA and PCIA refinements. Parties should identify their two or three highest-priority issues and describe the record-development complexity each requires, including the analysis needed. Day 3 (the June 15 workshop) covers data access. The ALJ proposes a template for a joint data-access issues list (type of data desired, why it is necessary and relevant to scope, the providing party's concerns, and joint options for addressing those concerns), drawing data desired from both Community Choice Aggregators and utilities. Two further questions ask parties to identify a shared underlying motivation behind any opposed data-access proposal, and how much time is needed between the Track 3 scoping memo and the deadline for load-serving entities to meet and confer and file a joint case management statement. Comments are due **July 9**, with reply comments due **July 16**. **INSTANT ANALYSIS:** Track 3 may become more than a technical PCIA clean-up. The ALJ is expressly asking whether parties want a fundamental reform in scope. The ruling now lets parties contest whether the indifference framework itself should be supplemented or partially redesigned, rather than confining their arguments to PCIA mechanics. The mandatory-allocation reference raises the possibility of a move away from after-the-fact cost recovery toward direct assignment or sharing of legacy resource obligations. The mutual-exclusivity question lets parties argue that one reform forecloses another. If Track 3 moves toward meaningful reforms, the scope and symmetry of access between utilities and CCAs will shape the evidentiary record. Parties seeking major PCIA changes must show the current framework produces problems and that their alternative delivers net benefits, reduces volatility, and preserves real competition among LSEs. --- ### UTILITY RISK SPENDING SCE filed its [2025 Risk Spending Accountability Report](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M609/K237/609237726.PDF?ref=calregulatory.com) (RSAR), which shows a **$932 million** capital shortfall against authorized levels for safety, reliability, and maintenance work. Recorded Safety, Reliability, and Maintenance-eligible capital came in at about **$5.01 billion**, 16% below authorization. O&M ran much closer to the original plan: about **$1.78 billion** recorded, $51 million (3%) under. - Distribution drove the capital shortfall at $523 million below authorized (−14%). SCE points to early-2025 storm restoration that diverted crews, the late-September issuance of its 2025 GRC decision, and the time needed to ramp contractor resources and work scope. Transmission capital came in at **$327 million** under (−35%), part of it FERC-jurisdictional, the rest deferred by permitting, licensing, outage, contractor, redesign, environmental, and access constraints. - On O&M, the underspending concentrated in Distribution (**−$71 million**, −8%) and "Other" (**−$77 million**, −12%): lower work volumes, fewer dead and diseased tree removals, reduced inspection find rates, accounting shifts, and timing. Transmission O&M went the other way: **$101 million** over authorized (+69%), driven by storm response and field remediation above forecast. - By risk area: wildfire O&M ran **$48 million** under, wildfire capital came in at **$256 million** under, and underground equipment failure capital came in **$130 million** under. RAMP-related totals were **$77 million** under on O&M (−16%) and **$430 million** under on capital (−22%). SCE frames the variances as timing and execution rather than scope reduction, and stresses that 2025 authorized amounts rested on forecasts built years earlier and not approved until late in the test year. **INSTANT ANALYSIS**: The filing tests how far safety-spending accountability can ride on GRC forecasts built years before the money is approved. SCE's answer is that 2025 was a transition year. Storms, permitting, outage limits, contractor ramp, changed field conditions, accounting treatment, and a GRC decision that did not surface until September moved authorized work across programs and years rather than erasing it. The numbers raise a question: when does coming in under authorization reflect prudent flexibility, and when does it mean authorized risk-reduction work is slipping? SCE leans on CPUC precedent affording utilities room to reprioritize, and several explanations hold up (emergency storm response genuinely consumed finite crews). But the scale invites scrutiny. A logical inference is that RSARs are turning into back-end accountability forums for wildfire, reliability, and safety capital. --- ### DIABLO CANYON COST RECOVERY Commissioner **Karen Douglas** issued a [scoping memo](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M609/K032/609032588.PDF?ref=calregulatory.com) for PG&E's application to recover **$595 million** in 2027 Diablo Canyon operating costs from ratepayers. The proceeding will examine PG&E's: - Forecast operations and maintenance costs; - Nuclear fuel expenses to be amortized through 2030; - Resource Adequacy substitution capacity costs and true-up costs; and - The netting of CAISO revenues against the 2027 Record Period revenue requirement. The proceeding will also review: - The statewide non-bypassable charge and related rate proposals from PG&E, SCE, and SDG&E; - PG&E's 2027 Volumetric Performance Fee spending plan; - A proposed **$26 million** reclassification from the Diablo Canyon Transition and Relicensing Memorandum Account to the Extended Operations Balancing Account; and - Whether PG&E's testimony satisfies prior CPUC requirements from four Diablo Canyon extension decisions. The ruling deems cost-effectiveness review, historical cost review, and modifications to the fixed management fee escalation method as out of scope, citing the absence of statutory triggers and the accelerated ERRA-like schedule's unsuitability for a broader inquiry. **INSTANT ANALYSIS**: The ruling confines this case to rate recovery. PG&E's $595 million revenue requirement will be contested on forecast reasonableness, not on whether the plant should be running. Intervenor testimony is due **July 17**, with rebuttals due **August 14**. A proposed decision is expected on October 30, with a final decision on **December 3**.