Utilities Must Fix and Reconcile Integration Capacity Maps Under CPUC Draft Resolution

The CPUC issued Draft Resolution E-5440, which would approve, with modifications, remediation plans submitted by PG&E, SCE, and SDG&E to fix accuracy, transparency, and usability problems in their Integration Capacity Analysis tools. These tools estimate how much distributed energy can be added to the grid without upgrades.

TLDR

Draft Resolution E-5440, tentatively scheduled for consideration on March 19, approves utility plans to fix errors and gaps in the maps that show where new energy projects and large loads can connect to the grid without upgrades, while imposing new tracking to measure when those maps diverge from real interconnection outcomes.

Utilities must improve data transparency, reduce redactions, update maps more consistently, and report the causes of discrepancies. For developers and large customers, the message is straightforward: the state is auditing whether grid capacity information is reliable, and preparing to fix it if it isn’t.

Summary of Draft Resolution E-5440

The draft resolution requires the utilities to correct data errors, reactivate inactive circuits on maps, improve the timeliness of map updates, and expand reporting so stakeholders can track when Integration Capacity Analysis results diverge from real interconnection outcomes.

• It also establishes a formal concordance/discordance framework that categorizes interconnection and energization application into one of four scenarios based on whether the ICA map value and the actual engineering outcome aligned. In so doing, it creates, for the first time, a structured taxonomy for measuring ICA usefulness across all three major electric utilities.
• The draft resolution orders SDG&E to stop excessive redactions of generation data, directs all utilities to publish more complete system information (including substations up to the transmission level) on public planning portals, and establishes new metrics to measure whether Integration Capacity Analysis outputs align with actual engineering results.
• The draft resolution codifies new definitions, distinguishing "ICA accuracy" (whether the utility correctly followed the approved methodology) from "ICA alignment" (whether ICA results match real-world engineering outcomes).

Draft Resolution E-5440 concludes that stronger tracking and standardized reporting are needed before further methodological changes, and instructs the utilities to collect concordance data, report progress in biannual filings, and later propose improvements to the Integration Capacity Analysis methodology based on those findings.

The draft resolution explicitly declines to impose automatic penalties for noncompliance at this time, though it notes existing penalty authority remains available.

INSTANT ANALYSIS

This draft resolution is the Commission’s clearest move yet to turn Integration Capacity Analysis from a planning artifact into an accountability tool.

By forcing the utilities to track when Integration Capacity Analysis results diverge from real interconnection outcomes, the CPUC is indicating that inaccurate hosting-capacity maps are now a regulatory compliance issue, not just a stakeholder frustration. The draft resolution finds SDG&E explicitly out of compliance on redaction practices, reinforcing that these are enforceable obligations.

For developers, DER providers, and large load customers, the main takeaway is that Integration Capacity Analysis outputs will become more auditable over the next six to 12 months as the new tracking and reporting requirements take effect. Whether ICA results also trend more conservative remains to be seen (the draft resolution does not direct any change in ICA values, but utilities facing new concordance scrutiny may err toward caution).

The draft resolution also increases transparency requirements that had limited Integration Capacity Analysis usefulness, especially SDG&E's redactions and the absence of substation-level visibility. That change improves siting intelligence for projects near transmission-connected nodes, while the reaffirmed expectation to refresh changed circuits monthly puts pressure on utilities to keep maps current as electrification accelerates. The draft resolution acknowledges reasonable exceptions to the monthly cadence where model run times or failures prevent timely updates, but the new trigger-date tracking will make delays visible for the first time.

At the operational level, the new concordance framework requires utilities to categorize every discordant outcome by root cause:

• Miscalculation of limiting criteria;
• Minor system adjustments made by the distribution engineer; or
• Other limitations of ICA's current scope and methodology.

These categories will determine whether future corrective action targets data quality, engineering practice, or ICA methodology itself.

In plain English, the Commission is laying groundwork for a future Integration Capacity Analysis methodology overhaul without reopening the underlying proceeding yet.

The next conflict may involve whether Integration Capacity Analysis should become a quasi-interconnection screening tool or remain a high-level planning estimate. Draft Resolution E-5440's careful distinction between "accuracy" and "alignment" already frames the terms of that argument. This distinction will shape how quickly DER, EV infrastructure, and large loads can move from concept to application across the investor-owned utilities' territories.

WHO SHOULD CARE?

• DER developers and storage providers. Integration Capacity Analysis maps are the first screen for where projects can interconnect without upgrades. More accurate (and more conservative) Integration Capacity Analysis results will affect site selection, queue strategy, and project timelines across all three IOU territories. The new concordance data will also reveal, for the first time, how often each utility's ICA maps overstated or understated available capacity (intelligence that enhances due diligence).
• Large load customers (data centers, hydrogen, electrified industry, large campuses). Load ICA is becoming a gating tool for energization timelines. If you are planning megawatt-scale new load, the CPUC is building the data infrastructure to evaluate whether ICA results are meaningfully aligned with actual engineering outcomes, which will eventually inform whether utilities are steering projects appropriately or delaying capacity access.
• EV infrastructure companies and fleet electrification planners. The draft resolution specifically addresses EV charging application reporting and load hosting accuracy. SCE was found to have interpreted its EV application reporting requirements too narrowly by excluding non-financially-complete projects, and is now ordered to align with PG&E and SDG&E. This directly affects where fast-charging depots and corridor projects can be built without triggering distribution upgrades.
• Interconnection attorneys, consultants, and regulatory teams. The new reporting regime creates a paper trail for disputes over upgrade requirements, timeline delays, and alleged map inaccuracies. Expect Integration Capacity Analysis concordance data to appear more often in protests, settlement talks, and evidentiary filings. The four-scenario framework and root-cause categories give intervenors a structured basis for challenging utility explanations of ICA discrepancies.
• Utilities' distribution planning and grid modernization teams. They now face measurable compliance exposure if maps are stale, incomplete, or misaligned with engineering outcomes. This shifts Integration Capacity Analysis from a planning support tool to something closer to a performance metric. SCE has already reduced its inactive circuits from 1,026 to 311 as of December 2025, with full reactivation ordered by September 30, 2026.
• Policy watchers and market entrants (microgrids, Virtual Power Plants, community energy). The CPUC is shaping the rules for how distributed capacity gets discovered and allocated. The concordance framework will generate the first cross-utility dataset on ICA reliability, which will influence where capital flows in California's next wave of electrification projects.

In sum, anyone whose project depends on finding available distribution capacity (generation or load) should care. ICA is moving from "informational map" toward a tool with real regulatory accountability behind it, and the data the Commission is now requiring will determine how far and how fast that transformation goes.