On Sept. 12, 2024, the California Public Utilities Commission (CPUC) issued its final decision, D.24-09-020, for phase 1 of its Rulemaking to Establish Energization Timelines, R.24-01-018. The final decision differed from the original Proposed Decision (PD) (previously described in our Aug. 16, 2024 blog) in several important ways.
The primary differences between the original PD and the final decision are as follows:
1. Recognizing that the large investor-owned utilities (IOUs) are responsible for certain types of site readiness, the CPUC split the site readiness step into two separate steps, one to track “Customer Site Readiness” and the other to track “Large Electric IOU Site Readiness.”
2. The CPUC emphasized that the average and maximum energization targets established in the decision “are intended to encompass the time necessary for large electric IOUs to complete their portion of the energization steps described above for all energization requests, even those that trigger upgrades for more than one tariff.”
3. Although acknowledging that Pub. Util. Code §453 prohibits utilities from engaging in discriminatory practices when providing electric services, meaning IOUs cannot prioritize energization requests, the CPUC said that differing “timelines at the ‘project type’ level may be considered in the future so long as they do not require prioritization over other projects, which disadvantages other customers.”
4. Finding that “timely completion of upstream capacity work is critical to achieving California’s economic and climate goals,” the CPUC adopted “maximum timelines” for upstream capacity project timelines provided by the IOUs, based on the average timelines provided by the IOUs. By setting “conservative maximum” timelines, the CPUC intends that IOUs will “incorporate these timelines into their planning processes” in order to “drive reductions” in the timelines for work that exceeds the average timelines. The CPUC will continue to gather evidence about upstream capacity project timelines to further refine the timelines in phase 2 of the proceeding.
5. In response to various parties’ requests, the CPUC agreed to consider, in phase 2 of the proceeding, whether to establish a working group to address remaining issues, including how to accelerate energization targets. In addition, whether in phase 2 of this proceeding or a subsequent proceeding, the CPUC may consider potential enforcement mechanisms if the IOUs fail to comply with the adopted targets, timelines and associated requirements.
Contact: Ron Liebert, Lynn Haug
