Energy Planning & Resources Committee
of the Clean Power Alliance of Southern California
Regular Meeting
Wednesday, July 22, 2026
12:15 p.m.
Visit CPA’s YouTube Channel to watch a Live Stream of the Meeting *There may be a streaming delay of up to 90 seconds. This is a view-only live stream.
Clean Power Alliance
Executive Conference Room
801 S. Grand Ave., Suite 400
Los Angeles, CA 90017
Members of the public may also participate in this meeting remotely at the following locations:
City of Oxnard Service Center 1
East Conference Room
214 South C Street
Oxnard, CA 93030
Alhambra City Hall
Conference Room A
111 S. First Street
Alhambra, CA 91801
Carson City Hall
Executive Conference Room
701 East Carson Street
Carson, CA 90745
LA County Sanitation District
Conference Room A
1955 Workman Mill Road
Whittier, CA 90601
West Hollywood City Hall
3rd Floor Conference Room
8300 Santa Monica Blvd.
West Hollywood, CA 90069
Manhattan Beach City Hall
City Manager Conference Room
1400 Highland Avenue
Manhattan Beach, CA 90266
PUBLIC COMMENT: Members of the public may submit their comments by one of the following options:
• Email Public Comment: Members of the public are encouraged to submit written comments on any agenda item to [email protected] up to four hours before the meeting. Written public comments will be announced at the meeting and become part of the meeting record. Public comments received in writing will not be read aloud at the meeting.
• Provide Public Comment During the Meeting: The General Public Comment item is reserved for persons wishing to address the Committee on any Clean Power Alliance-related matters not on today’s agenda. Public comments on matters on today’s Consent Agenda and Regular Agenda shall be heard at the time the matter is called. Comments on items on the Consent Agenda are consolidated into one public comment period.
Members of the public who wish to address the Committee at CPA’s Office are requested to complete a comment card and provide it to staff.
If you are attending from a remote location, please identify yourself to a CPA representative when your item is called. Each speaker is limited to two (2) minutes (in whole-minute increments) per agenda item with a cumulative total of five 5 minutes to be allocated between the General Public Comment, the entire Consent Agenda, or individual items in the Regular Agenda. Please refer to Policy No. 8 – Public Comment for additional information.
Agenda Page 1
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ACCESSIBILITY: Meetings are accessible to people with disabilities. Individuals who need special assistance or a disability-related modification or accommodation to participate in this meeting, or who have a disability and wish to request an alternative format for the meeting materials, should contact the Clerk of the Board at least two (2) working days before the meeting at [email protected] or (213) 713-5995. Notification in advance of the meeting, while not required, will enable us to make reasonable arrangements to ensure accessibility to this meeting and the materials related to it.
CALL TO ORDER & ROLL CALL
GENERAL PUBLIC COMMENT
CONSENT AGENDA
1. Approve Minutes from the June 24, 2026, Energy Committee Meeting
2. Receive and File June 2026 Risk Management Team Report
REGULAR AGENDA
3. Approve CPA’s 2026 Integrated Resource Plan (IRP) Filing Package for submission to the California Public Utilities Commission by the Filing Deadline in a Form Substantially Similar to the Attached IRP
4. 2026 Clean Energy and Reliability RFO Longlist Overview
COMMITTEE MEMBER COMMENTS
ADJOURN – NEXT MEETING AUGUST 26, 2026
Public Records: Public records that relate to any item on the open session agenda for a Committee Meeting are available for public inspection. Those records that are distributed less than 72 hours prior to the meeting are available for public inspection at the same time they are distributed to all, or a majority of, the members of the Committee. Public records are available for inspection at CPA’s Office at 801 S. Grand Ave., Suite 400, Los Angeles, CA 90017, or online at www.cleanpoweralliance.org/agendas.
Agenda Page 2
Staff Report – Agenda Item 1
To: Energy Planning & Resources Committee
Subject: Approve Minutes from the June 24, 2026, Energy Planning & Resources Committee Meeting
Date: July 22, 2026
RECOMMENDATION
Approve.
ATTACHMENT
1. Minutes
Agenda Page 3
Energy Planning & Resources Committee Item 1
MINUTES
Energy Planning & Resources Committee of the
Clean Power Alliance of Southern California
Regular Meeting
Wednesday, June 24, 2026, 12:15 p.m.
Meeting videos are available on CPA's YouTube Channel.
http://www.youtube.com/@CPApublicmeetings
Board members participated from the following locations:
City of Oxnard Service Center 1
East Conference Room
214 South C Street
Oxnard, CA 93030
Clean Power Alliance
Executive Conference Room
801 S. Grand Ave., Suite 400
Los Angeles, CA 90017
Sierra Madre City Hall
Council Chambers
232 W. Sierra Blvd.
Sierra Madre, CA 91024
Temple City City Hall
City Hall Conference Room
9701 Las Tunas Drive
Temple City, CA 91780
West Hollywood City Hall
3rd Floor Conference Room
8300 Santa Monica Blvd.
West Hollywood, CA 90069
LA County Sanitation District
Conference Room A
1955 Workman Mill Road
Whittier, CA 90601
Carson City Hall
Executive Conference Room
701 East Carson Street
Carson, CA 90745
Alhambra City Hall
Conference Room A
111 S. First Street
Alhambra, CA 91801
CALL TO ORDER & PLEDGE OF ALLEGIANCE
Chair Parkhurst called the meeting to order at 12:15 p.m.
ROLL CALL
Annie Mendoza, Deputy Clerk of the Board, conducted roll call.
Roll Call
Alhambra Jeff Maloney Committee Member Remote
Carson Reata Kulcsar Committee Member Remote
La Canada Flintridge Stephanie Fossan Committee Member Remote Manhattan Beach David Lesser Committee Member Absent
Oxnard Kathleen Mallory Committee Member Remote
Sierra Madre Robert Parkhurst Chair Remote
South Pasadena Diana Mahmud Committee Member Remote
Temple City Ed Chen Committee Member Remote
West Hollywood Chelsea L. Byers Committee Member Remote Agenda Page 4
Energy Planning & Resources Committee Item 1
All votes are unanimous unless otherwise stated.
GENERAL PUBLIC COMMENT
There was no public comment.
CONSENT AGENDA
1. Approve Minutes from the May 27, 2026, Energy Committee Meeting
2. Receive and File May 2026 Risk Management Team Report Motion: Committee Member Mahmud, South Pasadena
Second: Committee Member Byers, West Hollywood
Vote: The Consent Agenda was approved by roll call vote.
REGULAR AGENDA
3. Oral Update from the Vice President of Power Supply
Lindsay Descagnia, Vice President, Power Supply, provided an update on CPA's Innovation Solicitation, including recent refinements to the solicitation process intended to improve project evaluation and proposer experience. Ms. Descagnia noted that staff continues to evaluate proposals and implement process improvements as the program evolves.
Ms. Descagnia also announced that she will begin maternity leave the following month and advised the Committee that she expects to miss the July and August Energy Committee meetings. She expressed confidence in the Power Supply team during her absence. Committee Members congratulated Ms. Descagnia and wished her well.
4. Recommend Approval of the Proposed Amendments to the Energy Risk Management Policy to the Board of Directors
Ms. Descagnia introduced the item and explained that the proposed amendments were part of CPA's annual review of the Energy Risk Management Policy (ERMP).
She introduced Lyon Hardgrave, Director, Energy Risk Management, to present the proposed revisions. Mr. Hardgrave explained that the ERMP, originally adopted in 2018, establishes CPA's framework for energy hedging and risk management activities, and is reviewed annually to ensure it reflects current operational practices and market conditions. The proposed amendments primarily consist of clarifying language, administrative updates, and limited policy revisions rather than significant changes to CPA's overall risk management strategy. He noted that the revisions were intended to clarify existing practices and did not alter CPA's hedging strategy.
Ms. Descagnia reviewed proposed amendments to Section 5.1.3 governing project commercial operation date extensions. She explained that the revisions clarified when project delays and liquidated damages required Board approval by distinguishing between delays already contemplated in existing contracts and extensions that exceeded established approval thresholds specified in contracts.
Committee Member Mahmud questioned the proposed 12-month threshold for delegated authority related to commercial operation date extensions, suggesting that a six-month threshold may provide more appropriate Board oversight. Ms.
Agenda Page 5
Energy Planning & Resources Committee Item 1
Descagnia responded that the 12-month threshold had existed within the ERMP for several years and was intended to ensure that extended project delays ultimately return to the Board for consideration.
Ms. Descagnia presented proposed updates regarding CAISO commercial interest point allocations. She explained that the amendments clarify that assigning commercial interest points and executing associated right-of-first-offer agreements were procedural actions that preserved CPA's opportunity to evaluate future projects but did not commit the agency to procurement or contract negotiations.
As such, staff recommended that these actions no longer require approval from the Energy Committee.
Committee Member Mahmud requested additional clarification regarding how the proposed process differed from CPA's existing solicitation process. Ms. Descagnia explained that commercial interest point allocations occurred through a separate solicitation coordinated with CAISO's deliverability schedule and simply preserved CPA's opportunity to receive future project proposals without committing the agency to negotiate or procure energy. Committee Member Mahmud recommended emphasizing the relationship between the proposed process and CAISO's schedule when the item is presented to the Board. Ms. Descagnia agreed that the additional context would be helpful.
Mr. Hardgrave then reviewed proposed additions to the ERMP's list of authorized transaction types, including California Carbon Allowances and newly established CAISO ancillary service and reliability products. He explained that the revisions reflected evolving CAISO market products and ensured CPA maintained authority to participate in routine market transactions necessary for grid operations. Ted Bardacke, Chief Executive Officer, noted that additional market products were expected as western grid integration continued to expand and that the proposed revisions would provide operational flexibility while maintaining annual Board oversight through the ERMP review process.
Committee Member Mahmud recommended that newly established CAISO market products continue to be specifically identified during each annual ERMP update to maintain Board transparency, while allowing staff to transact in newly created products between annual updates as necessary. Committee Member Kulcsar expressed support for that recommendation. Committee Member Byers asked whether the proposed authorization language represented a change from prior policy. Staff explained that CAISO historically introduced new products infrequently, but recent market developments warranted additional flexibility while preserving the Committee's annual review process.
Committee Member Mahmud also recommended adding a definition of "base load equivalent position" to Appendix A, as the term appeared in the policy but was not currently defined. Staff agreed to incorporate the recommendation.
Committee Member Kulcsar requested clarification regarding documentation of delegated authority under Section 5.1.2. Mr. Bardacke explained that CPA maintained a centralized internal delegation log, jointly managed with Nancy Whang, General Counsel, that documented delegated authorities and distributed updates to staff to ensure organizational transparency and consistent Agenda Page 6
Energy Planning & Resources Committee Item 1
implementation. Committee Member Mahmud expressed appreciation for the process and commented that it reflected a well-run organization.
Following discussion, Committee Members directed staff to incorporate the Committee's recommendations into the proposed amendments, including adding a definition of "base load equivalent position," emphasizing the relationship between commercial interest point allocations and the CAISO schedule in the Board presentation, and continuing to specifically identify newly established CAISO market products during future annual ERMP updates.
Motion: Committee Member Maloney
Second: Committee Member Mahmud
Vote: The Energy Committee unanimously recommended that the Board approve the proposed amendments to the Energy Risk
Management Policy, as modified to incorporate the feedback and recommendations provided by the Energy Committee. This item was approved by roll call vote.
COMMITTEE MEMBER COMMENTS
Chair Parkhurst thanked the Committee for their engagement and support during his five years as Chair of the Energy Committee. He also thanked incoming Chair Maloney for agreeing to assume leadership of the Committee and expressed confidence in the Committee's continued success under his leadership.
Committee Member Maloney stated that he looks forward to working with Committee Members and staff to continue the Committee's work.
Committee Member Mahmud shared that she will be relocating to Minneapolis later this year but plans to continue on the Committee during the transition.
ADJOURN
Chair Parkhurst adjourned the meeting at 1:08 p.m.
Agenda Page 7
Staff Report – Agenda Item 2
To: Energy Planning & Resources Committee
From: Lyon Hardgrave, Director, Energy Risk Management
Approved By: Ted Bardacke, Chief Executive Officer
David McNeil, Chief Financial Officer
Subject: Receive and File June 2026 Risk Management Team Report Date: July 22, 2026
June 2026 RMT REPORT
Key Actions
• Reviewed the counterparty credit exposure summary
• Reviewed March 2026 day-ahead load forecast performance • Reviewed May 2026 market performance
• Reviewed 2026 - 2030 energy position recommendations
• Reviewed 2026 - 2030 Renewable and Carbon-Free positions • Reviewed PCC1 purchase and sales strategy
• Reviewed CF purchase and sales strategy
• Reviewed the 2026 Voluntary Allocation update
• Reviewed Sunzia generation and Solar Star test energy forecast • Reviewed 2026 - 2028 slice of day RA position
• Reviewed RA purchase and sales strategy
• Reviewed Energy Risk Management Policy (ERMP) compliance for RA, REC, CF, and Energy
• Reviewed Long-Term Energy Contract amendments and terminations • Reviewed June 2026 CRR Allocations
• Reviewed the Negative REC Price strategy
Agenda Page 8
Energy Planning & Resources Committee Item 2
Policy Compliance
Policy Deviation Required Action
The renewable energy hedge ratio exceeds
the maximum hedge percentage for 2027-
2031 due to cumulative PPA supply
additions, a reduction in the load forecast,
and updates to product content strategy that
reduced clean power RE targets in 2027-
2030.
None.
The deviations for 2027-2031 will be
resolved as CPA nears these years and
the maximum hedge percentages
increase.
ATTACHMENT
None.
Agenda Page 9
Staff Report – Agenda Item 3
To: Energy Planning & Resources Committee
From: Lindsay Descagnia, Vice President, Power Supply
Anthony Boukarim, Resource Planner, Power Supply
Reviewed By: Matthew Langer, Chief Operating Officer
Nancy Whang, General Counsel
Approved By: Ted Bardacke, Chief Executive Officer
Subject: 2026 Integrated Resource Plan
Date: July 22, 2026
RECOMMENDATION
Approve CPA’s 2026 Integrated Resource Plan (IRP) filing package (attached as Exhibit A) for submission to the California Public Utilities Commission (CPUC) by the filing deadline in a form substantially similar to the attached IRP.
BACKGROUND
The CPUC’s IRP process is a long-term planning requirement for load-serving entities (LSEs), including community choice aggregators (CCAs), established under SB 350 and subsequent CPUC direction. CPA’s 2026 IRP supports statewide planning coordination and demonstrates conformance with CPUC requirements for the 2026 cycle, including CPUC-assigned greenhouse gas (GHG) benchmarks, satisfaction of reliability planning requirements under the CPUC IRP framework, and demonstration that CPA’s portfolio supports compliance with state renewable and GHG-free energy requirements.
The IRP is used by the CPUC and other entities for statewide planning efforts to assess how LSE portfolios can meet California policy objectives over time, and how the outputs may inform future Commission procurement direction and related planning activities, including broader system and transmission planning. CPUC IRP requirements can evolve Agenda Page 10
Energy Planning & Resources Committee Item 3
across cycles, and CPA’s filing reflects the requirements, tools, and assumptions adopted for the 2026 IRP cycle.
The IRP is not a procurement commitment. It does not bind CPA to specific contracts, counterparties, project locations, or a contracting schedule, and it does not supersede CPA’s procurement authority or governance. CPA’s procurement decisions continue through CPA’s established processes and remain subject to delegated authority and/or Board approvals, market conditions, deliverability considerations, evolving regulatory requirements, and community priorities.
The filing package consists of three components for this cycle: (1) the IRP Narrative, which describes CPA’s planning approach, assumptions, and modeled Preferred Conforming Portfolio; (2) the Resource Data Template (RDT), which contains the CPUC-required portfolio and contract reporting used to evaluate planning reliability and conformance; and (3) the Clean System Power (CSP) calculator outputs, which report portfolio emissions results under the CPUC’s standardized emissions accounting methodology.
The CPUC filing deadline for CPA’s 2026 IRP is August 10, 2026. Committee approval is needed to finalize and submit the filing by the deadline.
DISCUSSION
Process and Governance History
On February 10, 2026, the CPUC released the 2025–2026 IRP Inputs and Assumptions needed for CPA to complete its IRP. Staff developed the 2026 IRP using CPUC-assigned forecasts and CPUC-required tools and templates, with a planning horizon of 2027 through 2045. Staff refined outputs through multiple iterations to ensure conformance with CPUC filing requirements while also reflecting CPA’s internal policy objectives, including CPA’s renewable energy and GHG-free targets as articulated by the Board at its September 26, 2025 retreat.
Agenda Page 11
Energy Planning & Resources Committee Item 3
Staff presented initial IRP results to the Energy Planning & Resources Committee (Energy Committee) at its May 27, 2026 meeting and incorporated feedback from committee members.
On July 2, 2026, staff presented an IRP overview to the Board, who provided feedback, and then delegated authority to the Energy Committee to approve the IRP. Delegating approval ensured staff can finalize all the documents in time to meet the August 10 submission deadline. This approach is consistent with CPA’s past IRP submissions process (2018, 2020, and 2022) and reflects Energy Committee’s technical focus and expertise to review and approve the final IRP materials.
Study Design Summary
For this filing cycle and consistent with CPUC direction, CPA is submitting one Conforming Portfolio, which also serves as CPA’s Preferred Conforming Portfolio.
CPA’s modeling uses a two-stage, PLEXOS-based1 workflow. For this IRP, CPA configured PLEXOS to represent CPA’s individual portfolio and net market position, and the rationale for CPA’s approach was to create a broadly analogous system to the CPUC’s system-level pairing of capacity expansion and reliability assessment tools.
CPA uses PLEXOS workflow in two stages. Stage 1 uses PLEXOS Long Term Plan module to identify cost-optimal resource additions over the planning horizon. Stage 2 uses PLEXOS Midterm and Short-Term Schedules module to perform hourly simulations, producing chronological operational outputs including dispatch, curtailment, net market position, and inputs needed for CSP emissions accounting (including storage operating profiles).
1 PLEXOS is an industry-standard power system modeling platform used by utilities and system planners to evaluate resource buildouts and simulate hourly grid operations.
Agenda Page 12
Energy Planning & Resources Committee Item 3
In keeping with CPUC directive, CPA documented three alternative assumptions relative to the statewide default inputs used in this IRP cycle:
• Hourly load profile: CPA used a custom hourly load profile based on internal forecasts, normalized to CPUC annual energy totals, rather than the default hourly assumption provided by the CPUC.
• Hourly energy price forecasts: CPA used third-party hourly energy price forecasts from Ascend Analytics, anchored in the near term to observed market forwards and then blended into longer term fundamental forecasts, rather than the CPUC’s default approach of dispatching all resources to serve load based on underlying production costs.
• Candidate resource pricing: CPA updated candidate resource cost assumptions based on CPA’s procurement experience and current market conditions, then projected those costs forward using the National Laboratory of the Rockies (formerly the National Renewable Energy Lab) Annual Technology Baseline, including adjustments for federal incentive impacts where relevant.
CPA’s Key Results
Portfolio Resource Mix
CPA’s Preferred Conforming Portfolio reflects a diversified clean resource mix anchored by wind and solar supported by 4-hour and 8-hour battery storage, with geothermal and biomass providing operational diversity and clean firm capability that supports reliability and reduces reliance on higher-emitting system power over time. The portfolio reflects market availability and a practical balance between long-term contracting and targeted use of short-term products to manage residual needs.
CPA’s modeled buildout includes meaningful additions over time, with planned resources increasing as legacy contracts expire and as load grows across the horizon. The resource strategy also reflects intentional technology substitutions relative to statewide buildouts, particularly in storage duration selection and the balance of in-state versus out-of-state wind, based on cost-effectiveness and modeled operational value.
Agenda Page 13
Energy Planning & Resources Committee Item 3
Narrative Figure 10: CPA Conforming Portfolio Long-Term Contracts Resource Mix The IRP identifies incremental planned need in 2030 including 400 MW of solar and 400 MW of 4-hour storage as planned resources. During IRP development, CPA executed the Rexford II solar-plus-storage contract (executed July 6, 2026) for 200 MW solar and 200 MW 4-hour storage. Even though Rexford II was not finalized in time for IRP inclusion, its addition aligns with the IRP buildout and can support CPA’s results for the early-2030s. 2 Narrative Table 1: Summary of Conforming Portfolio in Cumulative Nameplate MW Renewable and GHG-Free Content
Beyond the technology mix, CPA’s Preferred Conforming Portfolio is structured to exceed California’s minimum RPS and GHG-free energy requirements. This portfolio’s clean resource strategy is also designed to support CPA’s internal customer product commitments across its three energy products (Lean, Clean, and 100% Green) by 2 While the IRP modeling analysis does not include Rexford II, CPA provides detailed information about the impact of Rexford II in the IRP Narrative.
8 MMT Case 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 Contracted Resources 4,028 4,081 4,184 4,164 4,152 4,427 4,427 4,405 4,405 4,365 3,951 3,851 3,385 2,351 2,051 1,276 1,228 1,140 690 Geothermal 182 230 230 230 230 230 230 230 230 230 166 66 66 66 66 66 18 18 18 Hydro 32 32 32 12 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Onshore Wind 1,022 1,022 1,022 1,022 1,022 1,022 1,022 1,000 1,000 1,000 1,000 1,000 1,000 1,000 700 0 0 0 0 Solar 1,407 1,411 1,421 1,421 1,421 1,421 1,421 1,421 1,421 1,381 1,281 1,281 999 410 410 410 410 362 62 Solar DG 11 11 11 11 11 11 11 11 11 11 11 11 11 6 6 6 6 6 6 BESS 4hr 1,301 1,301 1,394 1,394 1,394 1,394 1,394 1,394 1,394 1,394 1,144 1,144 959 519 519 519 519 479 329 BESS 8hr 75 75 75 75 75 350 350 350 350 350 350 350 350 350 350 275 275 275 275 Planned Resources 0 0 0 950 1,500 2,050 3,366 4,187 4,847 5,397 5,797 6,197 6,597 7,294 8,094 9,294 9,959 10,359 10,932 Biomass 0 0 0 0 0 0 50 50 50 50 50 50 50 50 50 50 50 50 50 Geothermal 0 0 0 0 0 0 50 100 100 100 100 100 100 100 100 100 100 100 100 Onshore Wind 0 0 0 0 0 0 150 300 400 400 400 400 400 577 777 977 977 977 1,000 Solar 0 0 0 400 400 400 916 987 997 997 997 1,397 1,797 2,316 2,916 3,516 3,800 3,800 3,800 BESS 4hr 0 0 0 400 800 1,200 1,600 2,000 2,400 2,800 3,200 3,200 3,200 3,200 3,200 3,600 3,982 4,382 4,782 BESS 8hr 0 0 0 150 300 450 600 750 900 1,050 1,050 1,050 1,050 1,050 1,050 1,050 1,050 1,050 1,200 Total 4,028 4,081 4,184 5,114 5,652 6,477 7,793 8,592 9,252 9,762 9,748 10,048 9,982 9,645 10,145 10,570 11,188 11,500 11,622 Agenda Page 14
Energy Planning & Resources Committee Item 3
maintaining sufficient renewable and GHG-free supply to meet customer needs while preserving flexibility to adapt to market conditions and evolving compliance requirements.
Narrative Figure 12: Conforming Portfolio RPS Content
Narrative Figure 13: Conforming Portfolio GHG Free Content GHG Emissions
Using the CPUC’s CSP methodology and calculator, CPA’s Preferred Conforming Portfolio demonstrates emissions at or below CPA’s benchmark in each milestone year.
The benchmark values and portfolio results are reported in the table below.
Agenda Page 15
Energy Planning & Resources Committee Item 3
Target 2030 2035 2040 2045
CA State 30 MMT 25 MMT 16 MMT 8 MMT
CPA’s Share 1.243 MMT 1.050 MMT 0.860 MMT 0.443 MMT
CPA Portfolio Results 1.240 MMT 0.143 MMT 0.242 MMT 0.123 MMT Narrative Table 8: CPA Preferred Conforming Portfolio GHG Emissions Results This performance is supported by increasing clean energy content over time and by energy storage that shifts charging toward lower-emitting hours and discharge toward higher-emitting hours under the CSP’s hourly emissions intensity framework. CPA also incorporated its custom hourly load shape and modeled storage charging/discharging profiles in CSP calculator to improve consistency between dispatch modeling and emissions accounting.
Reliability
Under the IRP ELCC planning framework, CPA’s Preferred Conforming Portfolio meets or exceeds CPA’s modeled reliability need across the planning horizon, with a limited and explained exception in 2026. The RDT shows a modest negative effective capacity position3 in 2026 (shown in the table below), which reflects gaps in IRP planning assumptions, rather than a deficiency in CPA’s RA compliance posture.
Narrative Table 11: Conforming Portfolio Resource Adequacy Position by Contract Status 3 The 2026 artifact is driven by CPA’s exclusion of Diablo Canyon attributes after August 26, 2025, for long-term IRP planning (while still using Diablo allocations for RA compliance) and by IRP ELCC vs. RA accreditation differences for thermal and storage. CPA’s September 2026 month-ahead RA filing (July 18, 2026) showed compliance using Diablo allocations. This is a known discrepancy that the CPUC is aware of.
2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 LSE reliability need (MW) 3,183 3,247 3,311 3,020 2,729 2,819 2,909 2,997 3,086 3,173 3,242 3,310 3,378 3,446 3,514 3,541 3,569 3,596 3,623 3,649 ELCC by contract status (effective MW)
Online 3,086 2,988 2,589 2,115 1,650 1,672 1,666 1,398 1,384 1,377 1,210 883 867 784 430 339 125 122 107 48 Development - 271 292 256 149 143 137 130 124 118 120 121 123 125 127 127 103 60 59 59 Review - - - - - - - - - - - - - - - - - - - -
PlannedExisting - 91 498 629 685 617 513 576 499 503 609 910 919 987 1,238 1,226 1,299 1,283 1,273 1,260 PlannedNew - - - - 189 317 515 802 978 1,066 1,183 1,268 1,336 1,407 1,550 1,685 1,884 1,976 2,035 2,150 BTM PV 61 67 75 77 80 89 99 110 118 127 135 143 152 161 170 165 160 155 150 145 LSE total supply (effective MW) 3,148 3,418 3,454 3,076 2,753 2,838 2,929 3,016 3,103 3,190 3,257 3,325 3,396 3,464 3,514 3,542 3,571 3,597 3,625 3,661 Net capacity position (+ve = excess, -ve = shortfall) (effective MW) (36) 170 142 56 25 20 20 19 17 17 15 15 18 1 18 1 2 1 2 12 Agenda Page 16
Energy Planning & Resources Committee Item 3
Narrative Figure 28: Conforming Portfolio Resource Adequacy Contribution by Category Reliability is met through a mix of long-term contracts and targeted short-term RA purchases from existing resources. This approach provides near-term reliability flexibility while avoiding long-term fossil fuel commitment, given that short-term RA contracts can be adjusted as rules, markets, and resource availability evolve.
Cost Impacts
CPA’s Preferred Conforming Portfolio represents a least-cost bulk power supply plan co-optimized to meet CPA’s clean energy objectives, statewide reliability planning requirements, and GHG benchmarks. CPA’s IRP projects that CPA’s generation costs are likely to rise by an average of 2.67% per year from 2028 through 2045, driven primarily by the forecasted load growth (2.9% compound annual growth over the same period) and the need to bring incremental resources online at higher market prices than portions of the legacy contracted portfolio.
The cost scope reflected in the IRP is limited to power supply and related procurement components used in the modeling framework. Transmission and distribution service, Power Charge Indifference Adjustment (PCIA), and other retail bill components are outside the scope of the IRP cost metric and remain governed through separate mechanisms applicable to CPA customers.
Agenda Page 17
Energy Planning & Resources Committee Item 3
Comparison to CPUC System Plan
CPA’s Preferred Conforming Portfolio is directionally consistent with statewide planning trends reflected in the CPUC Reference System Plan and the broader 2025–2026 TPP Portfolio assumptions. Two prominent, intentional variances are highlighted in the IRP Narrative: (1) a storage duration mix that leans more heavily into 4-hour and 8-hour storage rather than location-constrained 12-hour storage, reflecting modeled cost-value tradeoffs under expected CAISO price shapes and operational constraints; and (2) a shift toward out-of-state wind relative to in-state wind based on market availability and complementary value to the California system.
The portfolio’s out-of-state wind planning is supported by transmission developments discussed in the narrative, including SunZia becoming operational in May 2026, with CPA as the project’s largest off-taker (700 MW contracted), and the expectation of additional Wyoming wind beginning in 2033.
Action Plan Summary
CPA’s IRP Action Plan describes how CPA operationalizes long-term planning insights while maintaining procurement flexibility and preserving governance control over actual contracting decisions. CPA’s primary procurement pathways include the following:
• Annual Clean Energy & Reliability RFO
• Annual Innovation Solicitation for Emerging Technologies • Short-term procurement
The IRP Action Plan also summarizes CPA’s procurement order compliance. The narrative includes CPA’s allocated requirements for various CPUC procurement orders, and notes that CPA filed its June 2026 IRP procurement Mid-Term Reliability Compliance Filing showing it has met obligations to date and is fully contracted to meet existing obligations, with remaining need focused on additional Clean Firm and Long-Duration Energy Storage volumes associated with the CPUC’s latest procurement order, issued on March 5, 2026 (D.26-02-057).
Agenda Page 18
Energy Planning & Resources Committee Item 3
Limitations of the IRP
The IRP is inherently assumption-driven, and portfolio outcomes can materially change with updates to key drivers. Key sources of uncertainty identified in the narrative include load growth, hourly load shapes, technology cost trajectories, market price forecasts, transmission deliverability and import capability, evolving RA rules and counting methods, and regulatory policy changes.
The IRP is a planning and conformance document, not a procurement mandate. Actual procurement will continue through CPA’s established governance and solicitation processes and will be adjusted as market conditions, deliverability constraints, and CPUC requirements evolve.
The narrative also highlights some external procurement pathways, such as potential centralized procurement pursuant to AB 1373, that remain uncertain in scope, timing, and cost. CPA therefore did not include AB 1373 long lead-time resources in the baseline modeled portfolio for this filing and expects to revisit assumptions as progress on statewide procurement becomes clearer in future IRP cycles.
NEXT STEPS
Upon Committee approval, staff will finalize the IRP filing package and submit it to the CPUC by August 10, 2026.
ATTACHMENT
1. 2026 Integrated Resource Plan Filing Package4:
a. 2026 IRP Narrative
b. 2026 IRP Resource Data Template
c. 2026 IRP Clean System Power Tool
4 Consistent with industry practice, portions of the RDT and CSP have been redacted to protect market sensitive information and CPA’s ratepayers, as revealing sensitive information on CPA’s clean energy and reliability positions could weaken CPA’s competitive position in procuring projects. Committee members who wish to review the redacted information should contact Chief Operating Officer Matt Langer ([email protected]) to arrange a briefing.
Agenda Page 19
1 2026 Integrated Resource Plan
CLEAN POWER ALLIANCE OF SOUTHERN CALIFORNIA
2026 Integrated Resource Plan
August 10, 2026
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2 I. Executive Summary ............................................................................................................................. 4 II. Study Design ........................................................................................................................................ 6 a. Objectives ...................................................................................................................................... 10 b. Methodology.................................................................................................................................. 11 i. Modeling Tool(s)........................................................................................................................ 12 ii. Modeling Approach ................................................................................................................... 12 iii. Alternative Assumptions....................................................................................................... 17 III. Study Results ..................................................................................................................................... 20 a. Conforming and Alternative Portfolios.......................................................................................... 20 b. Preferred Conforming Portfolio..................................................................................................... 22 c. GHG Emissions Results................................................................................................................... 29 d. Local Air Pollutant Minimization and Disadvantaged Communities .............................................30 i. Local Air Pollutants.................................................................................................................... 30 ii. Focus on Disadvantaged Communities ..................................................................................... 30 e. Cost and Rate Analysis................................................................................................................... 34 f. System Reliability Analysis............................................................................................................. 36 g. Existing Resource Planning ............................................................................................................ 38 h. Hydro Generation Risk Management ............................................................................................ 39 i. Long-Duration Storage Planning .................................................................................................... 40 j. Clean Firm Power Planning ............................................................................................................ 41 k. Non-CAISO, including Out-of-State, Wind Planning ...................................................................... 41 l. Offshore Wind Planning................................................................................................................. 42 m. Transmission Planning............................................................................................................... 43 IV. Action Plan ..................................................................................................................................... 45 a. Proposed Procurement Activities and Potential Barriers.............................................................. 45 i. Resources to meet IRP mandated procurement requirements, including D.21-06-035 and D.23-02-040:...................................................................................................................................... 45 ii. Plans for resources that are currently non-candidate in CPUC’s IRPs not described above.....46 iii. Other renewable and/or zero carbon resources not described above ................................46 iv. Other energy storage not described above .......................................................................... 46 v. Other demand response not described above.......................................................................... 46 vi. Other energy efficiency not described above....................................................................... 47 vii. Other distributed generation not described above .............................................................. 47 viii. Transportation electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR)............................................47 Agenda Page 21
3 ix. Building electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR).............................................................. 47 x. Potential Centralized Procurement, pursuant to AB-1373........................................................ 47 xi. Other ..................................................................................................................................... 48 b. Disadvantaged Communities (DACs) ............................................................................................. 48 c. LSEs’ Tribal Customers................................................................................................................... 52 d. Procurement Products................................................................................................................... 52 e. Commission Direction of Actions................................................................................................... 53 V. Lessons Learned ................................................................................................................................ 54 Agenda Page 22
4 I. Executive Summary
Clean Power Alliance of Southern California (CPA) is a Load Serving Entity (LSE) and administrator of a Community Choice Aggregation (CCA) program. Formed as a Joint Powers Authority, CPA’s 38 member jurisdictions include the unincorporated areas of Los Angeles and Ventura Counties, as well as the cities of Agoura Hills, Alhambra, Arcadia, Beverly Hills, Calabasas, Camarillo, Carson, Claremont, Culver City, Downey, Hawaiian Gardens, Hawthorne, Hermosa Beach, La Cañada Flintridge, Lynwood, Malibu, Manhattan Beach, Monrovia, Moorpark, Ojai, Oxnard, Paramount, Port Hueneme, Redondo Beach, Rolling Hills Estates, Santa Monica, Santa Paula, Sierra Madre, Simi Valley, South Pasadena, Temple City, Thousand Oaks, Ventura, West Hollywood, Westlake Village, and Whittier. CPA serves over 1 million customer accounts representing over 3 million residents and businesses. CPA is governed by a Board of Directors (Board) comprised of elected officials and staff and public experts appointed by its member cities and counties, spanning a territory that is diverse in geography, climate, and customer demographics.
CPA began offering service to municipal customers of unincorporated Los Angeles County in February 2018 and began service to non-residential customers of unincorporated Los Angeles County, Rolling Hills Estates, and South Pasadena beginning in June 2018. CPA enrolled residential customers from 31 of its member jurisdictions in February 2019 and completed enrollment of its then-current non-residential customers in May 2019. Both residential and non-residential customer enrollments in Westlake Village occurred in June 2020. In March 2024 CPA completed enrollment for all customers in Hermosa Beach, Monrovia, and Santa Paula, and in October 2025 all customers in La Canada Flintridge, Lynwood, and Port Hueneme began transitioning to CPA service. Additionally, CPA filed Addenda Number 6 to its implementation plan and will enroll all customers in the cities of Cudahy and Fillmore beginning in October 2027.
As set out in its Joint Powers Agreement (JPA), CPA is a mission-driven organization. CPA is charged with to developing and maintaining an electric supply portfolio with overall lower greenhouse gas (GHG) emissions than that of the local investor owned utility (IOU), Southern California Edison (SCE). CPA’s JPA encourages the use and development of cost-effective renewable and distributed energy resources and discourages the use of unbundled renewable energy credits (RECs). CPA also seeks to manage its energy portfolio and products in a manner that provides customer value, support public health, promotes regional economic benefits and workforce development, and offers customers a choice of differentiated renewable products.
Now in its eighth year of operations, CPA relies on a blend of short- and long-term procurement products and resources to meet the needs of its customers while remaining price-competitive and satisfying regulatory requirements. CPA currently offers three supply options: Lean Power (a minimum of 40 percent clean energy content), Clean Power (a minimum of 50 percent clean energy content), and 100% Green Power (100 percent renewable energy content). CPA procures electricity for its customers from a variety of resources guided by policies adopted by CPA’s governing body and by regulatory requirements established by the Legislature and state regulatory agencies. CPA is committed to providing safe, reliable, Agenda Page 23
5 affordable, and clean energy to its customers and to collaborating with statewide energy stakeholders to support California’s energy goals.
Consistent with CPA’s governance practices and Public Utilities Code section 454.52, this Integrated Resource Plan (IRP) was approved on July 22, 2026, by the CPA Energy Planning & Resources Committee, the standing committee to whom the Board delegated authority for approval of the IRP through formal action on July 2, 2026, similar to the approval process used for CPA’s 2018, 2020, and 2022 IRPs.
This IRP describes CPA’s planning approach and modeling results to support statewide coordination and demonstrate portfolio conformance with the California Public Utilities Commission’s (CPUC’s or Commission’s) 2026 IRP filing requirements. CPA developed one Preferred Conforming Portfolio consistent with the 8 MMT by 2045 GHG benchmark framework, using assumptions that are aligned with CPUC planning requirements and statewide modeling conventions. CPA estimated portfolio emissions using the CPUC’s Clean System Power (CSP) Calculator to demonstrate that portfolio emissions are at or below CPA’s CPUC benchmark levels. The Preferred Conforming Portfolio reflects a diversified mix of long-term clean resources, anchored by wind and solar and supported by 4-hour and 8-hour storage, along with geothermal and biomass resources that contribute to operational diversity and clean firm capability to support reliability and reduce GHG emissions. Overall, the preferred portfolio is directionally consistent with broader statewide trends reflected in the CPUC’s Reference System Plan.
This IRP is intended to inform planning and demonstrate conformance with state policy goals; it is not a procurement commitment or a binding contracting schedule. CPA’s actual procurement decisions will continue to be made through CPA’s established procurement and governance processes (including competitive solicitations and as needed market purchases) and will remain subject to CPA’s Board and/or delegated authority approvals, market conditions, project deliverability, evolving regulatory requirements, and community priorities. Because there are material differences between certain CPUC-required planning assumptions and the assumptions and constraints CPA uses for day-to-day procurement execution, the specific buildout shown in this IRP may differ from CPA’s eventual contracting outcomes; however, the portfolio provides a good-faith, analytically supported representation of CPA’s long-term resource needs and contribution to statewide reliability and emissions objectives.
The remainder of this narrative is organized to follow the CPUC template. Section II (Study Design) summarizes CPA’s modeling process, key inputs and assumptions, and any alternative assumptions used (including load shapes, market price forecasts, and candidate resource pricing). Section III (Study Results) presents the Preferred Conforming Portfolio results, including clean energy content, emissions outcomes, costs, and reliability performance. Section IV (Action Plan) describes CPA’s procurement pathways and potential barriers, including how CPA intends to use competitive solicitations, innovation-focused procurement, and short-term products to manage gaps while maintaining flexibility. Section V (Lessons Learned) describes key insights from this cycle and identifies areas for future improvement in data, tools, and planning alignment.
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6 II. Study Design
This IRP study was designed to provide CPA, its Board, and management with a long-term resource plan that supports CPA’s needs for renewable energy content, reduced greenhouse gas (GHG) emissions, resource diversity, reliability, and cost-effectiveness. The filing is also intended to demonstrate conformance with applicable regulatory and statutory requirements for the 2026 IRP cycle. CPA’s IRP was prepared based on CPA’s internal policy objectives and planning targets and informed by the CPUC’s Final 2025 Inputs and Assumptions (I&A) for the 2024–2026 IRP cycle.
Load Assignments for Each LSE
CPA used the energy and peak demand load forecasts and behind-the-meter photovoltaic (BTM PV) values approved in the Administrative Law Judge (ALJ) Ruling dated January 16, 2026 as the basis for IRP modeling. Over the planning horizon, CPA’s assigned annual retail sales and peak demand increase steadily, reflecting continued electrification and load growth; overall retail load growth is approximately 2.9% compound annual growth over the core study period. For modeling purposes, CPA represents load both at the retail meter and at the generation busbar by applying a consistent loss treatment, such that the busbar load reflects retail sales grossed up for transmission and distribution losses in a manner consistent with the CSP workbook. Figure 1 summarizes CPA’s annual retail and busbar load forecast for select years.
Figure 1: CPA's Retail and Wholesale Load Forecast for the 2026 IRP BTM PV within CPA’s service territory is also forecast to grow across the planning horizon, increasing both annual generation and installed capacity. Figure 2 summarizes the forecasted BTM PV energy and nameplate capacity trajectory used for CPA’s assigned load and net load representation in this IRP.
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7 Figure 2: BTM Solar PV Forecast: Annual Generation (GWh) and Installed Capacity (MW) For hourly modeling, CPA applied a custom hourly load shape in lieu of the default hourly profiles sourced from the 2024 Integrated Energy Policy Report (IEPR) Policy Scenario Demand Forecast. The custom hourly shape is derived from CPA’s internal load forecast and is normalized to preserve the CPUC-assigned annual retail sales totals. This approach is intended to improve the representation of intra-day and seasonal patterns while maintaining consistency with the CPUC’s planning total annual retail sales. Figure 3 compares: (1) the CPUC-assigned contribution to system peak derived from the CSP workbook using CPA’s normalized profile, (2) CPA’s reliability procurement need (RPN) as defined by the Resource Data Template (RDT), and (3) CPA’s internal estimate of annual peak demand. Differences across these metrics are expected because the RPN reflects CPA’s coincident contribution to CAISO system peak conditions, whereas the internal peak estimate reflects CPA’s non-coincident peak within its service territory.
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8 Figure 3: CPA Assigned Annual Peak Load Forecast versus Internal Required and Optional Portfolios
CPA’s IRP filing presents a unified strategy for satisfying the agency’s energy and capacity obligations over the planning horizon, guided by CPA’s goals and policies and the State’s requirements for load-serving entities, including Renewable Portfolio Standard (RPS) and GHG obligations. CPA analyzed supply-side options over the 2027–2045 planning horizon consistent with the objectives described below.
CPA submits one Conforming Portfolio as its individual IRP filing for the 2026 cycle, thereby serving as its de facto Preferred Conforming Portfolio (PCP). The PCP satisfies all Commission-adopted Conforming Portfolio criteria, as detailed below. In addition, CPA has accounted for the costs and benefits of resources subject to the Cost Allocation Mechanism (CAM), consistent with Commission requirements.
CPA’s PCP is consistent with the Commission-adopted Conforming Portfolio criteria by:
• Meeting the 2045 GHG emissions benchmark: achieving GHG emissions equal to or less than CPA’s proportional share of the 2045 8 MMT (Million Metric Tons) target; • Using the assigned load forecast: applying the energy and BTM PV forecasts assigned by the CPUC per the January 16, 2026, ALJ ruling in CPUC Rulemaking R.25-06-019 (ALJ Rulemaking); • Meeting reliability needs in all years, except for 2026 due to the non-inclusion of Diablo Canyon1:
ensuring the portfolio’s perfect-capacity-equivalent MW meets or exceeds CPA’s assigned reliability procurement need (RPN) in each planning year; 1 Pursuant to Public Utilities Code Sec. 454.52 (f) CPA did not include energy, capacity, or any attribute from Diablo Canyon Unit 1 or 2 beyond August 26, 2025
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9 • Maintaining proper load shapes in the CSP Calculator: keeping total annual energy consistent with the assigned load forecast, with all “Demand Inputs” tab checks reporting “TRUE”; • Using proper custom resource shapes: following CPUC formatting requirements for any custom production profiles, with all “Supply Inputs” tab checks reporting “TRUE”; • Using standard inputs and assumptions: applying inputs and assumptions from the 2025–2026 Transmission Planning Process (TPP) Portfolio (with updates), with any deviations from CPUC defaults identified and justified; and
• Completing all filing documents: submitting fully completed RDT, CSP calculator, and narrative template in accordance with the CPUC’s completeness definition.
GHG Emissions Benchmark
CPA’s 2045 GHG Emissions Benchmark was established via the ALJ Ruling. The benchmark reflects the electric-sector planning target methodology applied in the prior IRP cycle and is consistent with the California Air Resources Board’s 2022 Climate Change Scoping Plan for Achieving Carbon Neutrality. CPA used the CPUC’s Clean System Power (CSP) methodology and CSP Calculator Tool to conduct GHG accounting and determine the emissions associated with CPA’s Preferred Conforming Portfolio.
To maintain consistency with CSP accounting, CPA’s portfolio optimization and emissions evaluation reflect key CSP concepts, including: the application of hourly system power GHG emission intensities, the treatment of hours in which system power is not on the margin (with associated non-displaceable emissions allocated on a pro rata basis), and the ability for portfolios to receive emissions reduction credit when generating excess GHG-free energy during hours in which system power is on the margin. CPA’s milestone-year benchmark values and portfolio results are summarized in Table 1. Table 1 also reflects administratively assigned emissions elements embedded in the CSP framework, including in-front-of-meter combined heat and power (IFM CHP) allocations and non-displaceable system power emissions, as described in the CSP workbook. While behind-the-meter CHP emissions are not directly represented in the CSP calculator, the CPUC accounts for those emissions at the system level during development of the Preferred System Plan.
Table 1: CSP Portfolio GHG Emissions by Category (MMT/yr) Emission Metric 2028 2030 2035 2040 2045
IFM CHP 0.253 0.239 0.247 0 0
System Power 1.289 1.001 (0.104) 0.242 0.123
Total Emissions 1.542 1.240 0.143 0.242 0.123
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10 a. Objectives
CPA’s IRP is designed to guide CPA’s Board, management, and stakeholders in identifying a Preferred Conforming Portfolio that maintains reliability and affordability while advancing GHG reductions over the planning horizon. The IRP also supports the Commission’s statewide planning by demonstrating how CPA’s portfolio contributes to California’s reliability and policy objectives using the Commission’s required inputs, templates, and emissions accounting approach.
CPA’s portfolio development reflects Board and stakeholder input on resource preferences, diversity, risk management, and cost-effectiveness, and is designed to comply with applicable statutory and regulatory requirements governing load-serving entities, including CCAs. In addition to meeting statewide minimum requirements, CPA’s planning reflects locally adopted objectives—particularly above-compliance voluntary renewable procurement, lower portfolio emissions than the incumbent investor-owned utility, and a focus on minimizing localized impacts to Disadvantaged Communities (DACs).
CPA’s IRP methodology and Preferred Conforming Portfolio are intended to achieve the following objectives:
• Meet statutory IRP planning requirements applicable to CCAs, including demonstrating that CPA’s plan addresses the requirements of Public Utilities Code Section 454.52(a)(1) (and related IRP statutes governing plan development and Commission review/certification). • Satisfy Commission specifications for a Conforming Portfolio, including use of the Commission-assigned load forecast and conformity with required filing tools and assumptions. • Demonstrate portfolio conformance with CPA’s CPUC-assigned GHG Emissions Benchmarks, using the Commission’s required Clean System Power (CSP) methodology and calculator (with benchmark values presented in Table 1).
• Demonstrate progress toward meeting or exceeding Renewable Portfolio Standard (RPS) and SB 100 goals, including CPA’s approach to maintaining compliance while reflecting customer-driven renewable energy demand. • Demonstrate contribution to system reliability and satisfaction of Resource Adequacy (RA) needs, including showing that the portfolio can meet reliability needs across the planning horizon through a feasible mix of contracted, planned, and market resources.
Beyond the state’s minimum renewable procurement requirements, CPA has additional renewable energy procurement requirements through CPA’s product offerings: Lean Power (a minimum of 40 percent clean energy from a mix of renewables and zero-carbon hydroelectric power), Clean Power (a minimum of 50 percent clean energy), and 100% Green Power (100 percent renewable energy). Each of CPA’s 38 communities selects a preferred energy option for their individual cities or counties (a “default product”) and then individual customers can choose which product suits their needs. Based on these community selections and individual customer choices, approximately two-thirds of CPA’s customers receive the 100% Green Power product.
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11 Both the Lean Power and Clean Power tiers include escalating annual renewable and/or zero-carbon energy content requirements over the planning horizon, which drives a progressively cleaner overall portfolio. Across the planning horizon, CPA’s retail mix remains relatively stable, with approximately 67 percent of retail load served under 100% Green Power, 16 percent under Clean Power, and 17 percent under Lean Power. As a result of this voluntary procurement, CPA expects to meet or exceed SB 100 renewable targets ahead of the 2030 RPS compliance deadline.
Consistent with CPA’s Joint Powers Agreement, CPA has a goal of achieving overall lower GHG emissions than the local IOU. To support that objective, CPA’s planning includes procurement of non-RPS carbon-free resources, including existing large hydroelectric generation, in addition to renewable procurement undertaken to serve customer demand and meet compliance obligations. The assumptions and treatment of this procurement are described in more detail in the Methodology section.
Figure 4: CPA Internal Portfolio RPS, Clean Energy, and GHG-Free Targets by Year (% of Retail Load) Figure 4 presents CPA’s internal RPS, clean energy, and GHG-free targets as a percentage of retail load across the planning horizon. CPA also considered community impacts in selecting its Preferred Conforming Portfolio, including prioritizing portfolios that minimize negative impacts and emphasize benefits for DACs, and that reduce procurement and market risks through long-term contracting for renewable resources at fixed prices.
b. Methodology
This section provides an overview of the data, analytical tools, and methods CPA used to assess resource portfolio performance in this IRP.
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12 i. Modeling Tool(s)
For the 2026 IRP cycle, CPA used Energy Exemplar’s PLEXOS® production cost modeling software (version 11 R6) to perform its portfolio optimization modeling exercise. PLEXOS® is a chronological unit commitment model that employs a mixed integer linear programming (MIP) approach to simulate the economic dispatch of power plants while observing real-world operational constraints including emission reduction targets, plant operating limits, and renewable energy availability. PLEXOS® has an integrated Long-Term Plan (LT Plan) feature that produces a resource expansion plan given resource options and constraints around those options. The full set of standard operational and cost parameters for new and existing resources is considered in the LT Plan, providing a robust framework from which to evaluate different technologies with different operational (intermittent vs. baseload) cost and incentive profiles.
For CPA's 2026 IRP, the constraints applied in the LT Plan include annual and cumulative build limits for new resources, maximum allowed hourly market purchases and sales, GHG reduction targets, and minimum RPS and clean energy generation volumes. The PLEXOS® LT Plan module determines optimal investment decisions over the IRP planning horizon by minimizing the net present value (NPV) of the combined portfolio production cost and capital investment cost, subject to portfolio operational and investment constraints, to identify the least-cost resource portfolio. ii. Modeling Approach
Figure 5 depicts CPA's regional zonal model topology, spanning three regions: the CPA load zone, the CAISO market, and an Attributes region. CPA's retail load settles at the Southern California load zone (SCE_DLAP). CPA’s generators and battery storage located in Southern California are defined at the Supply_SP15 node and settle against the SP15 trading hub, while generators and battery storage in Northern California are defined at the Supply_NP15 node and settle against the NP15 trading hub. This two-zone structure enables CPA to account for forecasted price congestion between the northern and southern parts of the state along the Path 26/Path 15 corridor, a key transmission interface connecting Pacific Gas and Electric (PG&E) to Southern California Edison in the south and a common source of inter-zonal price differences. The Attributes region contains supply nodes for GHG-free attributes and renewable energy certificates, which are decoupled from CPA's physical energy position and used solely to satisfy clean energy requirements under CPUC mandates and CPA's own procurement commitments.
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13 Figure 5: Three-Region Model Topology for CPA's Portfolio Optimization Framework The CPUC’s preferred system-level planning tools are RESOLVE for capacity expansion and SERVM for reliability assessments. CPA’s 2026 IRP employs a two-stage modeling process to develop its PCP that is structurally analogous to this pairing. The key distinction between CPA’s portfolio optimization planning workflow and the CPUC’s is the set of loads and resources of interest. The CPUC is performing planning at the CAISO system level, accounting for all LSEs and direct access organizations. CPA’s modeling is designed for an individual LSE and reflects CPA’s specific set of loads and resources and the corresponding net position with the market. Stage 1, analogous to RESOLVE, uses the PLEXOS LT Plan to identify cost-optimal resource additions across the planning horizon using a sampled set of operating days; Stage 2, analogous to SERVM, uses the PLEXOS MT-ST Schedule to apply a full 8,760-hour commit-and-dispatch simulation for select planning years to capture commitment and dispatch decisions at an hourly resolution.
Figure 6 provides a summary of CPA's two-stage portfolio optimization process. Stage 1 runs across the full planning horizon, which spans 2027–2045.2 In each investment-decision year, the model selects the type, amount, timing, and approximate location of new resources to minimize total cost while satisfying all applicable planning constraints. Stage 1 represents time at reduced resolution (one sampled representative week per month), keeping the multi-year optimization computationally tractable. 2 Because modeling commenced in Q1 2026, CPA's horizon for its internal modeling started in 2027.
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14 Figure 6: CPA Two-Stage Portfolio Optimization Process After Stage 1 completes its investment optimization, Stage 2 performs an 8,760-hour full dispatch simulation of CPA’s total portfolio, including both existing power purchase agreements (PPAs) and those selected during Stage 1. Unlike Stage 1, Stage 2 performs these grid simulations for a select number of years in the planning horizon. To optimize the custom profiles for storage dispatch, both stand-alone and hybrid, CPA simulated the five years modeled in the CSP workbook during Stage 2. Other key outputs of Stage 2 include CPA’s net market position (positive when CPA is net long and sells excess supply to the market; negative when CPA is short and purchases from the market), economic curtailments, and forecasted GHG emissions. The market model uses hourly energy price forecasts developed using a third-party market forecast from Ascend Analytics, which is widely used in the industry for market intelligence and price forecasts. To ensure near-term prices reflect observable market expectations, CPA aligns the forecast to the latest tradable forward quotes for NP15 and SP15: the first three years use market curves sourced from ICE (Intercontinental Exchange), after which prices are blended over a two-year transition period into Ascend’s longer-term fundamental CAISO forecast. This approach preserves near-term market realism while maintaining a consistent long-term fundamental view for portfolio optimization.
Hourly SCE_DLAP prices are modeled consistently with the zonal topology and hub forecasts, reflecting intra-CAISO congestion and basis differentials between NP15, SP15, and SCE_DLAP.
After completing both modeling stages, CPA enters its portfolio into the RDT's unique contracts tab to verify that all applicable reliability planning constraints are satisfied. Specifically, the aggregate perfect-capacity-equivalent MW of all qualifying resources in CPA’s portfolio (calculated as each resource’s nameplate capacity multiplied by its marginal effective load-carrying capability, or “ELCC”) must equal to or exceed CPA’s assigned RPN in every planning year through 2045. Only contracts designated as “EnergyCapacity” or “CapacityOnly” in the RDT count toward this requirement; energy-only and attribute-only resources are excluded. Qualifying contracts must also satisfy a delivery window requirement: the contract start date must be on or before June 1 of the applicable planning year, and the contract end date must be on or after October 1 of that year. The reliability contribution of BTM solar was netted out of the reliability constraint applied in Stage 1, preserving the credit without requiring BTM solar to be modeled as an explicit candidate resource. This treatment was adopted for computational efficiency.
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15 After populating the RDT and verifying that all reliability planning requirements are satisfied, CPA transfers the values from the CSPReportSheet tab in the RDT into the CSP workbook, per CPUC filing requirements.
Within the CSP workbook, CPA applies its custom inputs for load and storage dispatch. Together, these inputs drive the portfolio’s net GHG emissions calculation, covering both native emissions from CPA’s bundled PPAs and GHG emissions associated with net market purchases of system power. As previously discussed, the model's load forecast directly accounts for the impacts of BTM solar.
Inputs and Assumptions
CPA’s 2026 IRP inputs and assumptions are broadly consistent with those published in the CPUC's 2025– 2026 Integrated Resource Planning Inputs and Assumptions document. Specifically, CPA applied the same candidate resource technology types (drawing from a subset of the CPUC's RESOLVE candidate resources, as listed in Table 2), ELCC values, resource operational specifications, statewide mandatory minimum RPS and clean energy requirements, and GHG decarbonization targets. Where CPA's assumptions deviate from the CPUC's published defaults, those deviations are identified and justified in the Alternative Assumptions section.
Contracted Resources
CPA’s generation supply consists of a mix of geothermal, hydroelectric, wind, solar PV, and battery storage resources. To date, CPA has executed dozens of long-term power purchase agreements (PPAs). Table 2 presents a current list of CPA's signed PPAs, including resource type, status, PPA start date, and contracted capacity. CPA's executed PPAs are provided in the Resource Data Template (RDT) and are accounted for in both phases of the PLEXOS optimization process.
Table 2: CPA Signed PPAs
Project Resource Type Status PPA Start Date Term (Years) Renewable MWs Storage MWs Arica Solar + Battery Online 4/23/2024 15 93.5 71
Arlington Solar + Battery Online 3/21/2022 17 233 132
Cape 18 Geothermal Development 6/1/2028 15 18
Cape Station Geothermal Development 6/1/2028 15 30
Carson 1 Solar Online 2/24/2026 20 0.68
Commerce 4 Solar Online 1/26/2026 20 1.24
Daggett 2 Solar + Battery Online 12/8/2023 15 65 52
Daggett 3 Solar + Battery Online 11/17/2023 15 123 61.5 Denali Storage Development 12/29/2028 20 93.1
Desert Quartzite Solar + Battery Online 12/20/2024 20 300 150 Dominguez Solar Online 8/12/2025 15 0.96
Eaves 1 Solar Development 12/1/2026 20 0.68
Eaves 3 Solar Development 12/1/2026 20 0.67
El Segundo Solar Online 7/29/2025 15 0.64
Elkhorn Solar Development 12/31/2027 20 4.99
Estrella Solar + Battery Online 12/31/2023 16 56 28
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16 Fillmore Solar Development 12/31/2028 20 2.46
Geysers Geothermal Online 1/1/2022 15 50
Geysers (100MW) Geothermal Planned
Existing 6/1/2027 10 100
Geysers (18MW) Geothermal Online 6/1/2026 20 18
Golden Fields Solar Online 12/21/2020 15 40
Heber Geothermal Online 1/1/2022 15 14
High Desert Solar + Battery Online 12/17/2021 15 100 50 Isabella Hydro Online 12/8/2020 10 11.95
Kaweah Hydro Online 6/16/2020 10 20.09
Key BESS Storage Development 6/1/2027 20 190
Key Long Duration Storage Development 12/1/2026 15 75
Luna Storage Online 8/3/2022 15 100
Pivot Beverly Solar Online 2/28/2025 15 0.4
Pivot San Gabriel Solar Online 2/28/2025 15 0.27
Resurgence Solar + Battery Online 9/14/2023 21 48 40
Rexford Solar + Battery Online 2/21/2025 15 300 240
Rexford II3 Solar + Battery Development 5/1/2029 20 200 200 Road 232 Solar Solar Development 12/31/2028 20 3
Sagebrush Storage Online 11/1/2024 15 40
Sanborn Storage Online 11/15/2021 15 100
Saticoy Solar Development 12/31/2028 20 4
Solar Star 3 Solar + Battery Development 10/1/2026 20 24 23 Solar Star 4 Solar + Battery Development 10/1/2026 20 24 23 Southbay 20 Solar Online 1/27/2026 20 1.32
Southbay 6 Solar Development 12/1/2026 20 1.38
SunZia Wind North Wind Online 5/26/2026 15 37.3
SunZia Wind North Wind Online 5/20/2026 15 171.5
SunZia Wind South Wind Online 5/26/2026 15 87.7
SunZia Wind South Wind Online 5/20/2026 15 403.5
Voyager Wind Online 12/28/2018 15 21.6
White Hills Wind Online 12/15/2020 20 300
Wilmington 1 Solar Online 9/25/2025 15 1.8
Candidate Resources
Table 3 lists the candidate resources modeled in CPA's 2026 IRP. The candidate set includes a broad mix of technology types: biomass, geothermal, solar, lithium-ion battery storage (4-hour and 8-hour), and wind (with distinct options for in-state wind, out-of-state wind, and offshore wind). Any additional costs 3 Rexford II was executed on July 6, 2026 (after the base portfolio inputs for this IRP’s modeling were finalized) and therefore was not included in the modeled base portfolio for the Preferred Conforming Portfolio results. The contract is for 200 MW solar and 200 MW 4-hour storage and has a commercial operation date of May 2029. As such, it aligns with and may be interpreted as partially meeting the IRP-identified need for incremental solar and 4- hour storage in the early 2030s.
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17 from transmission or network upgrades required to interconnect new resources are assumed to be incorporated into each technology's overall build cost and are not modeled as separate cost items.
Table 3: CPA Candidate Resource Projects for the 2026 IRP Resources Technology CSP Gen Profile
Biomass – CA Biomass CSP (Biomass)
Geothermal – NV to SCE Geothermal CSP (Geothermal)
Enhanced Geothermal System – NV to SCE Geothermal CSP (Geothermal) Solar – PGE Kern Solar CSP (Solar New PG&E)
Solar – SCE Eastern Solar CSP (Solar New SCE SDG&E)
Solar – SCE Arizona Solar CSP (Solar New SCE SDG&E)
Onshore Wind – SCE Northern In-State Wind CSP (Wind New SCE SDG&E) Onshore Wind – PGE Kern In-State Wind CSP (Wind New PG&E) Onshore Wind - NM to SCE Out-of-State Wind CSP (Wind New Mexico) Onshore Wind - WY to SCE Out-of-State Wind CSP (Wind Wyoming) Offshore Wind – Morro Bay Offshore Wind CSP (Wind Offshore Morro Bay) Li-ion Battery (4-hr) Li-ion Battery Storage Resource
Li-ion Battery (8-hr) Li-ion Battery Storage Resource
Li-ion Battery (12-hr) Li-ion Battery Storage Resource
Li-ion Battery (24-hr) Li-ion Battery Storage Resource
Li-ion Battery (100-hr) Li-ion Battery Storage Resource iii. Alternative Assumptions
CPA made three focused departures from the Commission’s statewide Inputs & Assumptions (I&A) used for this IRP cycle: (1) a custom normalized hourly load profile (in place of default IEPR-based hourly shapes), (2) third-party hourly market price forecasts (in place of price outputs derived from statewide production cost modeling), and (3) updated candidate resource pricing assumptions informed by CPA’s solicitation results and recent market conditions. Each departure is described below, including the rationale, primary data sources, and how CPA preserved consistency with Commission-assigned load totals and conforming-portfolio requirements.
Hourly Load Profile Shape
CPA applied a custom, normalized hourly load shape in lieu of the Commission’s default hourly profiles sourced from the 2024 IEPR Demand Forecast. The custom load shape was developed using a historical analysis of CPA’s prior five years of retail sales and was designed to better represent CPA’s observed intra-day and seasonal consumption patterns.
The hourly profile was normalized such that the total energy (the area under the hourly curve) matches CPA’s CPUC-assigned annual retail sales for each planning year. As a result, CPA’s total annual load forecast (MWh) used for portfolio evaluation is unchanged from the Commission-assigned value; only the intra-hour distribution differs from the default IEPR profile. CPA used this approach to improve the Agenda Page 36
18 realism of hourly dispatch, net load shapes, and the resulting valuation of flexible resources (including storage, demand-side resources, and firm clean capacity).
Energy Market Assumptions
CPA used third-party hourly energy price forecasts from Ascend Analytics in the 2026 IRP portfolio optimization and dispatch analysis. The forecast covers the three price nodes used in CPA’s market representation: NP15, SP15, and SCE DLAP. CPA used node-level hourly prices to better reflect locational differences in market conditions that affect dispatch economics, storage arbitrage value, and net procurement costs.
To align near-term modeled economics with observable market information, CPA anchored the near-term portion of the forecast to tradable forward curves for NP15 and SP15, and blended those curves into Ascend’s longer-term fundamental CAISO forecast. This blended approach is intended to improve consistency with near-term market pricing while maintaining a coherent long-run price signal for investment decisions across the planning horizon.
Figures 7 through 9 present representative month-hour price patterns (January, April, July, and October) across all three nodes for select years.
Figure 7: Average Month-Hour Energy Price Forecast by Node (January, April, July, October) - 2028 Agenda Page 37
19 Figure 8: Average Month-Hour Energy Price Forecast by Node (January, April, July, October) - 2035 Figure 9: Average Month-Hour Energy Price Forecast by Node (January, April, July, October) - 2045 Candidate Resources PPA Pricing Assumptions
CPA developed candidate resource pricing assumptions using an internal forecast that reflects the most recent price signals available through CPA’s procurement activity and prevailing market conditions.
Candidate PPA pricing inputs were informed by recent bid and offer information from CPA’s competitive solicitations (including RFO results and market terms observed through active procurement). CPA then projected these prices forward using technology cost trajectories from the NREL Annual Technology Baseline (ATB) to reflect expected year-over-year changes in capital costs and fixed operating costs.
Where relevant to the commercial pricing CPA expects to face, CPA incorporated policy-related adjustments reflecting differences in expected federal incentive impacts (for example, tax credit availability and monetization considerations for renewables and storage). This approach is broadly consistent in structure with the Commission’s I&A framework, but updates and calibrates candidate pricing to reflect more recent and procurement-specific market information than is captured in statewide inputs. The purpose of this departure is to improve the realism of modeled costs and resulting portfolio selection by the capacity expansion model.
Agenda Page 38
20 III. Study Results
a. Conforming and Alternative Portfolios
CPA is submitting one Conforming Portfolio that balances procurement flexibility between short-term and long-term contracts with resource diversity and minimizes costs to ratepayers, while meeting regulatory requirements for clean energy and reliability and achieving emissions that are less than CPA’s proportional share of the 8 MMT by 2045 GHG targets. The Conforming Portfolio also meets CPA’s internal RPS and GHG-Free targets that are more aggressive than state requirement. Figure 10 below represents CPA’s cumulative long-term resource mix for the Preferred Conforming Portfolio.
Figure 10: CPA Conforming Portfolio Long-Term Contracts Resource Mix The portfolio reflects a diverse mix of renewable and storage resources and takes advantage of CPA’s commitment to contracting for new build resources. The ratios of solar, wind, geothermal, and storage resources are a reflection of their availability in the market. Figure 11 below shows the annual incremental build relative to CPA-contracted resources. Most PPAs additions are from solar and storage resources.
Wind, geothermal, and biomass help CPA meet its resource adequacy requirements and RPS targets in the mid-2030s. Contracted PPAs that end by the 2040s are replaced with similar technologies.
Figure 11: Incremental Build of Long-term Contracts (relative to CPA-contracted resources) Agenda Page 39
21 During development of this IRP, CPA executed a solar-plus-storage contract for Rexford II (executed July 6, 2026) with a commercial operation date of May 2029, totaling 200 MW solar and 200 MW 4-hour storage. Because the contract was executed late in the IRP development timeline and after the base portfolio inputs were finalized for modeling, it was not reflected in the modeled base portfolio. The project aligns closely with the IRP-identified resource need and can be interpreted as partially satisfying the modeled 2030 solar and 4-hour storage buildout.
Table 4 below summarizes the annual cumulative nameplate capacities of CPA’s Conforming Portfolio aggregated by technology and contract status. CPA is expecting to bring a significant number of new clean resources online, more than doubling its currently contracted capacities by 2045.
Table 4: Summary of Conforming Portfolio in Cumulative Nameplate MW CPA’s Preferred Conforming Portfolio is directionally consistent with the resource mix reflected in the 2025–2026 TPP Portfolio (presented in the 2026 CPUC Filing Requirements Modeling document) in that both rely on substantial additions of solar and storage supported by incremental clean firm resources and wind to meet reliability and emissions objectives. As shown in Table 5, the most significant variances are driven by two intentional tradeoffs in CPA’s optimization: (1) storage duration mix and (2) the balance of in-state versus out-of-state wind. Relative to CPA’s share of the TPP buildout, CPA’s IRP selects materially higher volumes of 4-hour and 8-hour lithium-ion storage and does not select the location-constrained 12- hour storage additions shown in the TPP. This outcome reflects observed market dynamics and modeled operations: under current and expected CAISO price shapes (including the evolving duck curve), the incremental arbitrage and system value of 12-hour storage is often not sufficient to justify its higher cost relative to procuring a combination of 4-hour and 8-hour resources, which can capture a large share of net-peak value more economically. In addition, longer-duration (e.g., 8-hour/12-hour) storage technologies can exhibit lower round-trip efficiency than 4-hour systems, and under Slice-of-Day RA counting they can also realize lower effective RA value when charging sufficiency and hour-specific 8 MMT Case 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 Contracted Resources 4,028 4,081 4,184 4,164 4,152 4,427 4,427 4,405 4,405 4,365 3,951 3,851 3,385 2,351 2,051 1,276 1,228 1,140 690 Geothermal 182 230 230 230 230 230 230 230 230 230 166 66 66 66 66 66 18 18 18 Hydro 32 32 32 12 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Onshore Wind 1,022 1,022 1,022 1,022 1,022 1,022 1,022 1,000 1,000 1,000 1,000 1,000 1,000 1,000 700 0 0 0 0 Solar 1,407 1,411 1,421 1,421 1,421 1,421 1,421 1,421 1,421 1,381 1,281 1,281 999 410 410 410 410 362 62 Solar DG 11 11 11 11 11 11 11 11 11 11 11 11 11 6 6 6 6 6 6 BESS 4hr 1,301 1,301 1,394 1,394 1,394 1,394 1,394 1,394 1,394 1,394 1,144 1,144 959 519 519 519 519 479 329 BESS 8hr 75 75 75 75 75 350 350 350 350 350 350 350 350 350 350 275 275 275 275 Planned Resources 0 0 0 950 1,500 2,050 3,366 4,187 4,847 5,397 5,797 6,197 6,597 7,294 8,094 9,294 9,959 10,359 10,932 Biomass 0 0 0 0 0 0 50 50 50 50 50 50 50 50 50 50 50 50 50 Geothermal 0 0 0 0 0 0 50 100 100 100 100 100 100 100 100 100 100 100 100 Onshore Wind 0 0 0 0 0 0 150 300 400 400 400 400 400 577 777 977 977 977 1,000 Solar 0 0 0 400 400 400 916 987 997 997 997 1,397 1,797 2,316 2,916 3,516 3,800 3,800 3,800 BESS 4hr 0 0 0 400 800 1,200 1,600 2,000 2,400 2,800 3,200 3,200 3,200 3,200 3,200 3,600 3,982 4,382 4,782 BESS 8hr 0 0 0 150 300 450 600 750 900 1,050 1,050 1,050 1,050 1,050 1,050 1,050 1,050 1,050 1,200 Total 4,028 4,081 4,184 5,114 5,652 6,477 7,793 8,592 9,252 9,762 9,748 10,048 9,982 9,645 10,145 10,570 11,188 11,500 11,622 Agenda Page 40
22 availability constraints are applied, whereas multiple 4-hour resources can often provide more flexible, higher-counting capacity across critical hours.
Table 5: Comparison of the CPA Preferred Conforming Portfolio to CPA’s Load Share of the 25-26 TPP Buildout The table also shows a shift away from in-state wind and toward out-of-state wind in CPA’s IRP buildout relative to the TPP share. This variance is driven in part by current market dynamics: based on recent market solicitations, the availability of cost-competitive, developable new in-state wind has been very limited. At the same time, wind resources from regions such as New Mexico and Wyoming often provide higher complementary value to the California system (including improved alignment with net-peak and seasonal reliability needs) and can deliver higher capacity value relative to certain in-state wind profiles, making them attractive in a least-cost optimization that must meet reliability and emissions requirements.
Additionally, the SunZia Transmission project and TransWest express, as discussed further in section IV. k, provide clearer signals of the resource’s availability to LSEs. Overall, these differences reflect CPA’s effort to use the same statewide planning framework while calibrating resource choices to market availability, operational value, and cost-effectiveness, resulting in a portfolio that generally aligns with TPP directions while optimizing key technology substitutions that reduce cost and maintain reliability. b. Preferred Conforming Portfolio
The above Conforming Portfolio is CPA’s Preferred Conforming Portfolio for the 8 MMT GHG target. It is the most cost-effective option that meets internal targets and state mandates, given the inputs and assumptions provided. CPA’s Conforming Portfolio is also consistent with each relevant statutory and administrative requirement stated in PU Code Section 454.52(a)(1), as follows:
A. Meet the greenhouse gas emissions reduction targets
The Preferred Conforming Portfolio achieves emission targets that are below the GHG emissions benchmarks set by the Commission, which are based on the GHG emission reduction targets set by the California Air Resources Board for the electricity sector.
CPA’s Preferred Conforming Portfolio achieves emission targets that are below the GHG emissions benchmarks set by the Commission for every milestone year, including the outer years where the portfolio outperforms the 2045 benchmark. The results are illustrated in Table 6 below. This outcome is driven by 2030 2035 2040 2045 2030 2035 2040 2045 2030 2035 2040 2045 Geothermal 117 163 163 163 230 330 166 118 113 167 3 (45) Geothermal (Enhanced) - - - 36 - - - - - - - (36)
Biomass - - - - - 50 50 50 - 50 50 50
In-State Wind 63 322 424 557 22 - - - (42) (322) (424) (557) Out-of-State Wind 269 358 807 970 1,000 1,400 1,577 1,000 731 1,042 770 30 Offshore Wind - - - - - - - - - - - -
Solar 1,372 2,728 3,336 4,222 1,821 2,418 2,727 3,862 449 (310) (609) (360) Li-ion Battery (4-hr) 215 225 225 347 1,794 3,794 3,719 5,111 1,579 3,569 3,494 4,764 Li-ion Battery (8-hr) 312 715 715 1,077 225 1,250 1,400 1,475 (87) 535 685 398 Location Constrained Storage (12-hr) 15 199 409 434 - - - - (15) (199) (409) (434) Generic Long Duration Storage (12-hr) - - - - - - - - - - - - Generic Long Duration Storage (24-hr) - - - - - - - - - - - - Generic Long Duration Storage (100-hr) - - - - - - - - - - - - Share of 25-26 TPP Buildout CPA 2026 IRP Difference (IRP - Share of TPP) Agenda Page 41
23 CPA’s more aggressive internal RPS and GHG-Free targets, which bring additional renewables and storage online and reduce reliance on emissions-associated system power over time.
Table 6: CPA Preferred Conforming Portfolio GHG Emissions Results Target 2030 2035 2040 2045
CA State 30 MMT 25 MMT 16 MMT 8 MMT
CPA’s Share 1.243 MMT 1.050 MMT 0.860 MMT 0.443 MMT
CPA Portfolio Results 1.240 MMT 0.143 MMT 0.242 MMT 0.123 MMT This “better-than-benchmark” performance is also supported by the portfolio’s significant battery energy storage (BESS) buildout and operations. In the modeling, BESS dispatch is optimized using hourly emissions profiles, which tends to shift charging toward lower-emitting hours and discharge toward higher-emitting hours, reducing overall portfolio emissions while still supporting net-peak operations and reliability needs.
B. Procure at least 60% eligible renewable energy resources Figure 12 and Figure 13 represent the RPS and GHG-Free content in the Conforming Portfolio, respectively.
The CPA portfolio maintains RPS and GHG-Free energy content consistently above statewide requirements across the study horizon, reflecting CPA’s procurement strategy and customer product mix that targets higher clean energy content than the statutory floor. Across both figures, solar is the largest contributor to delivered RPS and GHG-Free energy, with wind as the second-largest contributor, underscoring the portfolio’s reliance on mature, cost-effective renewable technologies as the backbone of clean energy supply.
Figure 12: Conforming Portfolio RPS Content
The figures also show that CPA’s portfolio is intentionally structured to balance long-term RPS contracts with short-term PCC1 REC and other GHG-Free purchases that are used to close any remaining gaps as Agenda Page 42
24 conditions change (e.g., load variability, fluctuating generation from contracts). Maintaining a small residual share served through market purchases preserves operational and procurement flexibility and acts as a hedge against sunk costs while keeping overall RPS and GHG-Free performance well above requirements.
Figure 13: Conforming Portfolio GHG Free Content
C. Enable each electrical corporation to fulfill its obligation to serve its customers at just and reasonable rates
While this requirement does not apply to CPA as CPA is not an electrical corporation, CPA works to serve its customers at reasonable rates and minimize rate volatility by constructing a balanced and conservatively hedged power supply portfolio, building significant financial reserves and minimizing rate changes when possible. Total system costs for the 8 MMT Conforming Portfolio are comparable to CPA’s current average costs, as described further in Section E (Cost and Rate Analysis). The steady projected portfolio costs indicate that CPA ratepayers can expect their rates to receive increasingly clean electricity service at stable rates.
D. Minimize impacts on ratepayers’ bills
CPA’s Preferred Conforming Portfolio meets the goal of minimizing impacts on ratepayers’ bills by identifying a least-cost bulk power supply portfolio that is simultaneously optimized to achieve CPA’s RPS and GHG-Free targets, satisfy state requirements for reliability and GHG emissions reductions, and minimize the cost to serve load over the planning horizon. This cost analysis reflects only the power supply components of serving CPA’s retail load as a Community Choice Aggregator; the incumbent IOU remains responsible for transmission and distribution service to retail customers. Based on the portfolio optimization and associated cost outputs, the cost of procuring the resources in the Preferred Conforming Portfolio is forecasted to increase CPA’s power supply costs at an average rate of 2.67% annually between 2028 and 2045, reflecting primarily forecast load growth and the need for incremental procurement at higher market prices than CPA’s existing contracted portfolio. Additionally, CPA’s portfolio accounting Agenda Page 43
25 includes the Resource Adequacy (RA) benefits of IOU resources that CPA customers support and are allocated to CPA through the Cost Allocation Mechanism (CAM).
E. Ensure system and local reliability on both a near-term and long-term basis, including meeting the near-term and forecast long-term resource adequacy requirements CPA’s Preferred Conforming Portfolio meets the requirement to ensure system and local reliability on both near-term and long-term basis, including meeting the CPUC-forecasted Resource Adequacy (RA) needs over the planning horizon. For this IRP, CPA assessed system reliability using the RA assumptions and accounting framework provided in the CPUC Resource Data Template. CPA’s reliability procurement requirement (RPR) was calculated by applying CPA’s share of load during critical hours to the CAISO’s Reliability Procurement Need (RPN), and portfolio RA contributions were evaluated by applying the applicable Effective Load Carrying Capability (ELCC) values by resource type (including solar, wind, 4- hour storage, and 8-hour storage) to determine the portfolio’s effective capacity position over time.
Under this framework, the Preferred Conforming Portfolio meets CPA’s modeled reliability needs through a combination of executed long-term contracts and targeted short-term RA purchases from existing resources, which provides flexibility to meet near-term RA requirements without locking in long-term reliability commitments from fossil resources. Additional details on the RA position are provided in Section F (System Reliability Analysis).
In addition to the ELCC-based assessment required for IRP planning, CPA also tested the portfolio under the Slice-of-Day RA framework accreditation methodology used for month-ahead/year-ahead RA compliance (while recognizing this is not an IRP requirement). This supplemental check indicates the portfolio is generally adequate across the planning horizon, but it also highlights that seasonal gaps can appear in certain summer or winter months under Slice-of-Day counting rules. These results reinforce the importance of aligning IRP planning accounting with compliance accounting used in the RA program and procurement orders, since differences in rules can lead to a portfolio that is either over-committed (increasing costs to customers) or short in specific critical months that may not be fully captured by an annual ELCC framework. A key driver of the difference is how storage is treated: Slice-of-Day counting requires charging sufficiency and hour-specific availability to count, whereas the IRP ELCC approach reflects a generalized capacity contribution as a percentage of nameplate, which may not fully reflect portfolio- and month-specific charging constraints.
F. Ensure that at least 65% of RPS procurement is from long-term contracts Figure 14 below compares CPA’s Preferred Conforming Portfolio long-term RPS content to the SB 350 minimum long-term contracting requirement of 65%. It shows that CPA’s portfolio consistently exceeds the statutory floor across the planning horizon. In several years, CPA’s long-term RPS content is more than double the SB 350 minimum, reflecting CPA’s strategy to rely primarily on executed long-term renewable contracts to meet customer demand and compliance needs while reducing exposure to short-term market volatility. This sustained long-term RPS position also provides a buffer against year-to-year variability in load, generation profiles, and contract performance, while keeping only a limited residual need to be managed through short-term market activity.
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26 Figure 14: CPA Preferred Conforming Portfolio Long-Term RPS Content Relative to SB350 Requirement G. Strengthen the diversity, sustainability, and resilience of the bulk transmission and distribution systems, and local communities
CPA’s Preferred Conforming Portfolio strengthens the diversity, sustainability, and resilience of the bulk power system and local communities by maintaining a balanced mix of resource types and procurement products that can perform across a wide range of operating conditions and grid needs. The portfolio and procurement strategy consider a broad set of candidate resource options, including utility-scale solar, onshore wind, offshore wind, geothermal, and biomass, paired with a range of energy storage durations (including 4-hour batteries and longer-duration storage options extending up to 100 hours) to support both net peak reliability needs and multi-hour or multi-day risk periods. In addition to physical supply resources, CPA maintains flexibility through a limited, targeted use of short-term PCC1 purchases, GHG-Free purchases, and Resource Adequacy (RA) purchases to manage near-term gaps, shape risk, and avoid locking customers into long-term commitments that could become misaligned with evolving reliability rules, technology performance, or market conditions.
CPA evaluates prospective resources with a focus on operational resilience and deliverability—such as hourly load-matching performance, congestion and deliverability risk, and how incremental additions interact with CPA’s existing supply on an hourly basis over the full contract term. This approach supports a resource mix that is less exposed to single-technology performance risk and provides multiple pathways to maintain reliability while increasing clean energy content. To implement this diversified strategy, CPA is pursuing competitive solicitations that can bring forward both mature and emerging solutions.
CPA’s 2026 Clean Energy & Reliability Request for Offers (RFO) is designed to source a broad range of resources—including baseload renewables, intermittent renewables, and storage—that can contribute to clean energy goals and reliability needs over multiple time horizons. In parallel, CPA’s 2026 Innovation Solicitation for Emerging Technologies is intended to identify and evaluate projects that may not fit Agenda Page 45
27 standard eligibility or evaluation structures in the primary clean energy RFO, supporting technology diversity and longer-term system resilience.
H. Enhance distribution systems and demand-side energy management CPA’s Preferred Conforming Portfolio meets the requirement of enhancing demand-side management.
Based on CPA’s Local Programs for Clean Energy Future Strategic Plan, which was developed through a community outreach process and subsequent Board direction, CPA plans to continue deploying programs that provide demand side energy management support as well as air pollution mitigation in Disadvantaged Communities (“DACs”) within its territory, in the following three strategic program areas:
resiliency and grid management, electrification, and local clean energy procurement.4 CPA actively supports EV charging infrastructure and management and distributed energy resource activities to meet its renewable energy goals. CPA is partnering with customers to utilize energy storage systems for demand response and/or reliability. In addition, CPA’s customer programs, such as Power Response and Peak Management Pricing, incentivize residential, commercial and public agency customers to reduce their energy consumption during periods of grid stress and elevated wholesale energy prices.
I. Minimize localized air pollutants and other greenhouse gas emissions, with early priority on disadvantaged communities
CPA’s Conforming Portfolio results in emissions lower than CPA’s assigned benchmark. CPA does not procure electricity directly from any natural gas or other fossil resource power plants, rather any direct emissions are the result of system power purchases or administratively assigned emissions. CPA’s Preferred Conforming Portfolio meets the requirement of minimizing localized air pollutants, with an emphasis on DACs. CPA’s portfolio relies primarily on renewable generation for its energy supply and thus has low GHG and localized air pollutant emissions. As mentioned above, CPA also plans to deploy customer programs with an emphasis on DACs to further reduce localized air pollution in its service territory.
CPA currently administers several programs aimed at minimizing air pollutants and GHG emissions, see section IV. a and b for details on each program.
J. Maintain a diverse portfolio of energy resources, which may include eligible energy resources procured by the Department of Water Resources.
CPA’s Preferred Conforming Portfolio maintains a diverse mix of energy resources, including both existing contracted resources and a broad set of candidate resources evaluated in the IRP modeling. While eligible resources procured through the Department of Water Resources (DWR) may contribute to statewide portfolio diversity over time, CPA did not force specific Assembly Bill (AB) 1373 DWR allocations into the 4 See Section IV. a & b. for information regarding specific CPA programs Agenda Page 46
28 base IRP portfolio used for this filing because the scope, timing, and availability of those resources remain uncertain. Given that the IRP results depend heavily on when resources are assumed to come online and how they perform operationally, forcing uncertain DWR allocations into the baseline portfolio could have materially altered the optimized buildout and produced results that are not representative of a realistic procurement pathway for CPA. Additionally, CPA notes the current federal administration’s actions toward offshore wind will likely, at a minimum and despite pushback by California officials, add significant delays to the build-out of such resources.
Instead, CPA structured the modeling to preserve portfolio diversity by including a wide range of candidate technologies and allowing the capacity expansion and production cost modeling to co-optimize among them based on cost and performance while meeting CPA’s clean energy targets and IRP planning constraints. Candidate resources available for selection included, among others, offshore wind, geothermal, long-duration storage, and multi-day storage (approximately 100-hour duration), alongside other renewable and storage options. This approach enables the preferred portfolio to reflect a cost-effective and operationally feasible resource mix, while maintaining flexibility to incorporate DWR-procured resources in future planning updates as those procurement pathways become more defined.
Table 7: Comparison of 8 MMT Conforming Portfolio (2026 IRP) to 25 MMT Conforming Portfolio (2022 IRP) The 2026 IRP Preferred Conforming Portfolio (8 MMT by 2045) remains broadly consistent with the 2022 IRP portfolio (25 MMT by 2035) in its overall strategy of relying on a diversified mix of renewables and storage, but the updated buildout (as shown in Table 7 for 2030 and 2035) reflects how CPA’s resource strategy evolves under deeper decarbonization and updated planning conditions. Relative to the 2022 IRP, the 2026 portfolio includes more out-of-state onshore wind, more 8-hour storage, and continued reliance on short-term RA purchases from existing gas resources in 2030 to satisfy near-term reliability 2030 2035 2030 2035 2030 2035
LSE reliability need (MW) 2,793 2,363 2,729 3,173 -64 810 ELCC-adjusted capacity (MW) 2,793 2,363 2,753 3,190 -40 827 hybrid 927 472 358 309 -569 -163
in_state_wind_south 12 5 3 - -9 -5
in_state_wind_north 20 9 - - -20 -9
out_of_state_wind_WY - 30 - 83 - 53
out_of_state_wind_IDWAOR - - - - - -
out_of_state_wind_AZNM 152 136 360 503 208 367
offshore_wind_north - 54 - - - -54
offshore_wind_south - - - - - -
utility_pv 45 54 46 113 1 59
btm_pv 32 51 80 127 48 76
4hr_batteries 860 467 215 489 -645 22
8hr_batteries - - 88 275 88 275
12hr_batteries - - - - - -
24hr_batteries - - - - - -
100hr_batteries - - - - - -
pumped_storage - - - - - -
demand_response - - 48 14 48 14
hydro - - - - - -
small_hydro 5 - 3 - -2 -
geothermal 208 216 199 287 -9 71
biomass_wood - - - 49 - 49
biogas - - - - - -
nuclear - - - - - -
gas_cc 518 854 1,064 565 546 -289
gas_ct 13 14 289 378 276 364
cogen 2 - - - -2 -
ice - - - - - -
2022 IRP 2026 IRP 2026 IRP - 2022 IRP
Agenda Page 47
29 needs while avoiding long-term fossil fuel lock-in. These differences are driven by updated planning assumptions and requirements across cycles, including changes to the load forecast, reliability need and ELCC values, emissions targets and intensity assumptions, resource cost and market conditions, and CPA’s updated internal RPS and GHG-Free targets, all of which influence the model’s cost-optimal selection of resource types, timing, and the role of short-term market products. c. GHG Emissions Results
CPA estimated GHG emissions for its Preferred Conforming Portfolio using the CPUC’s CSP Calculator, consistent with the 2026 IRP Filing Requirements. Portfolio-level GHG results by milestone year are provided in Table 8. As shown, the Preferred Conforming Portfolio achieves emissions outcomes that are below CPA’s benchmark in each milestone year evaluated, reflecting the portfolio’s increasing clean energy content and the operational role of storage in reducing reliance on emissions-associated system power.
Table 8: CPA Preferred Conforming Portfolio GHG Emissions Results Target 2030 2035 2040 2045
CA State 30 MMT 25 MMT 16 MMT 8 MMT
CPA’s Share 1.243 MMT 1.050 MMT 0.860 MMT 0.443 MMT
CPA Portfolio Results 1.240 MMT 0.143 MMT 0.242 MMT 0.123 MMT For this filing, CPA used a custom hourly load shape in the CSP Calculator to better reflect CPA customer usage patterns while maintaining consistency with statewide planning totals. CPA’s hourly load shape is developed bottom-up from AMI interval data for active CPA customers (2021–2025), aggregated by rate class, energy product, vintage, and CARE status and normalized on customer counts. A random forest model is trained using calendar features and hourly weather from four stations within CPA’s service territory (Burbank KBUR, Los Angeles KLAX, Camarillo KCMA, and Fullerton KFUL). Each rate is forecasted independently and then aggregated to a system-level retail forecast; distribution losses are added by voltage, month, and hour to produce a loss-adjusted, system-level hourly load. To project the hourly shape across the planning horizon, CPA runs ten historical weather scenarios (2016–2025) through the model and averages the resulting hourly profiles. Load modifiers are then added using CPA-territory-specific hourly profiles, including: light-duty EV charging (based on an assumed mix of unmanaged, customer-managed, and smart-managed profiles informed by CPA’s managed charging program), behind-the-meter PV shapes (from the CEC hourly PV forecast for SCE zones 7 and 8), behind-the-meter storage profiles (from the 2021–2022 SGIP Impact Evaluation by Verdant Associates, LLC), medium/heavy-duty EV profiles (from the CEC MDHD forecast for zones 7 and 8), and building electrification impacts (derived from a billing analysis comparing CPA customers with and without electric heating). Importantly, CPA’s forecast remains scaled to the CEC annual energy forecasts and peak demand values; the custom approach affects the hourly shape used for dispatch and emissions estimation, not the annual totals.
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30 CPA also used user-specified storage charging and discharging profiles in the CSP Calculator to reflect modeled portfolio operations. Storage dispatch for the Preferred Conforming Portfolio was simulated in PLEXOS, where the aggregate storage fleet was dispatched to maximize system value while minimizing emissions consistent with the hourly emissions profiles used in CSP. CPA then input a normalized charging and discharging profile representing the aggregate storage fleet into the CSP Calculator so that emissions impacts reflect the modeled timing of charging (tending toward lower-emitting hours) and discharging (tending toward higher-emitting hours), rather than relying on generic storage operating assumptions.
This approach improves consistency between the production-cost simulation and the CSP emissions accounting and supports a more accurate estimate of portfolio GHG impacts under the Preferred Conforming Portfolio.
d. Local Air Pollutant Minimization and Disadvantaged Communities i. Local Air Pollutants
Table 9 summarizes the NOx, PM2.5, and SO2 emissions associated with CPA’s Preferred Conforming Portfolio:
Table 9: Local Air Pollutants Estimate from CSP
The only contribution to air pollutants in CPA’s portfolio is from system power and those administratively-assigned emissions from IFM CHP resources as well as the pro rata share of the non-displaceable system power. As CPA continues to increase the portion of its portfolio under long-term contract with clean energy resources and more storage resources come online to minimize the emissions intensity of system power during net peak load hours, CPA will reduce its reliance on system power and its portfolio’s contribution to local air pollution.
ii. Focus on Disadvantaged Communities
Per its Joint Powers Agreement, CPA intends to provide and manage its energy portfolio and products in a manner that promotes public health in areas impacted by energy production, including Disadvantaged Communities (DACs), as defined in this IRP based on CalEPA’s CalEnviroScreen tool.
Emissions Total Unit 2028 2030 2035 2040 2045
CO2 MMt/yr 1.54 1.240 0.143 0.242 0.123
PM2.5 tonnes/yr 94 76 89 101 98
SO2 tonnes/yr 9 7 33 34 34
NOx tonnes/yr 128 102 224 220 214
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31 Description of Disadvantaged Communities
For purposes of this IRP, a disadvantaged community is defined as the following based on CalEPA’s designation:5
I. Census tracts receiving the highest 25 percent of overall scores in CalEnviroScreen 4.0 (1,984 tracts).
II. Census tracts lacking overall scores in CalEnviroScreen 4.0 due to data gaps, but receiving the highest 5 percent of CalEnviroScreen 4.0 cumulative pollution burden scores (19 tracts) III. Census tracts identified in the 2017 DAC designation as disadvantaged, regardless of their scores in CalEnviroScreen 4.0 (307 tracts).
IV. Lands under the control of federally recognized tribes CPA serves approximately 1,070,092 customer accounts across a service territory that includes 1,155 unique census tracts. CPA has determined that 404 of those census tracts have customers within a DAC or approximately 34.9%. Additionally, CPA serves 281,129 customer accounts located within a DAC, or approximately 26.2% of all customer accounts served are located within a DAC. CPA has also identified and provides in Table 10 below a further breakdown of its customer accounts on CARE and FERA rates including those within a DAC.
Table 10: CPA's Retail and Wholesale Load Forecast for the 2026 IRP Total
Customers
Customers in
DAC
Total CARE
Customers
CARE Customers in
DAC
Total FERA
Customers
FERA Customers in
DAC
1,070,092 281,129 242,977 101,198 9,366 3,626
CPA notes that all of its long-term contracted resources for energy are renewable or non-emitting resources, even those located in or near a DAC, and its main driver of local air pollutants are system power purchases. CPA has continued to grow its generating resource portfolio as it has been operating, reducing its overall reliance on system power as its years of operations have increased.
CPA has identified 869 census tracts and two tribal reservations that are within a DAC and within a five-mile radius of a CPA generating facility. The two maps below provide a visual representation of DAC census tracts within a five-mile radius of a CPA generating facility. As noted above, all these generating facilities rely on non-emitting resources.
5 SB 535 Disadvantaged Communities | OEHHA (ca.gov). CPA understands that OEHHA had released CalEnviroScreen 5.0 on July 1, 2026, but did not have sufficient time to utilize the latest tool in time for this IRP.
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32 Figure 15: DAC Census Tracts of Generating Facilities within 5-mile Radius:
Figure 16: DAC Census Tracts of CPA Generating Facilities within 5-mile Radius Close Up LA County Agenda Page 51
33 Procurement Considerations Related to Disadvantaged Communities In all RFOs for RPS-eligible or storage contracts, CPA has a strong preference for providing benefits to DACs. Each project submittal receives a “Benefits to Disadvantaged Communities” ranking of either high, medium, neutral, or low. Those projects receiving a high score must be located within a DAC and provide community development benefits, while a project not located within a DAC but can demonstrate DAC benefits and has completed a community outreach effort would receive a medium score.
Additionally, in any RFO that solicits non-RPS-eligible thermal resources, CPA requires such contract to include provisions for transitioning to cleaner operations while also providing a ranking for DAC impacts.
Specifically, for this type of project, CPA considers the impacts of projects on DACs, and prefers projects not located in a DAC or projects that can demonstrate benefits to DACs. To date, CPA has not executed a long-term energy contract for non-RPS-eligible thermal resources.
CPA’s procurement efforts are based on input from DAC representatives, both from CPA’s Community Advisory Committee and other stakeholders, and guided by CPA’s Local Programs for Clean Energy Future Strategic Plan which was developed through a community outreach process and subsequent Board direction.6 CPA plans to continue deploying local programs that provide air pollution mitigation in DACs within its territory, in the following three strategic program areas:
• Resiliency and grid management, including clean back-up power for essential facilities, demand response for when energy use is high, a virtual power plant consisting of behind the meter energy storage systems, and peak management pricing;
• Electrification, including incentives for public and multifamily electric vehicle (“EV”) charging and managed EV charging, incentives for efficient electric appliances, and building electrification codes;
• Local clean energy procurement, including the DAC-GT and CSGT Power Share programs.
CPA plans to follow up with its Community Advisory Committee to present the final results to inform the development of this and future IRPs, as well as its procurement and program design strategies.
In addition, CPA relies on a network of more than 300 community-based organizations (CBOs) that we regularly engage through outreach, information sharing, and collaboration opportunities, including organizations serving disadvantaged communities. Through regular dialogue with these organizations and the communities they serve, CPA's resource planning and procurement strategies, rate and product offerings, and customer program designs are informed by the feedback we receive. These activities help inform CPA's IRP and organization-wide strategy to better serve our customers, with a special focus on improving air quality and expanding access to clean energy in disadvantaged communities. 6 See https://cleanpoweralliance.org/community-advisory-committee/ for CPA's Community Advisory Committee information. AND SEE https://cleanpoweralliance.org/2023/07/14/actionplan/ for CPA's Local Programs Action Plan for 2023-2025.
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34 e. Cost and Rate Analysis
CPA’s Preferred Conforming Portfolio is a least-cost power supply plan that is co-optimized to meet CPA’s clean energy objectives (RPS and GHG-Free), statewide reliability planning requirements, and GHG emissions reduction benchmarks while minimizing the cost to serve load. Figure 17 summarizes projected generation costs in selected milestone years (2028, 2030, 2035, 2040, and 2045) across key cost components, including: (1) contracted costs associated with existing PPAs, (2) planned resource costs associated with new PPAs added under the IRP buildout, (3) cost to serve load at DLAP representing the cost of serving CPA’s wholesale load at DLAP, (4) short-term RA purchases reflecting the cost of existing and incremental RA procurement used to meet reliability needs, (5) short-term PCC1 REC and GHG-Free purchases used to manage residual compliance and volumetric gaps, and (6) dispatch revenue from resources (shown as a negative value) reflecting market value from dispatching resources at their modeled pricing nodes. The overlaid line shows normalized generation costs in USD per MWh of retail load, which provides a consistent view of cost trends as load changes over time.
Figure 17: Conforming Portfolio Projected Generation Costs • Contracted Costs ($’000): reflect the total cost of CPA’s existing executed PPAs and other long-term contracts that are online or otherwise committed in the baseline portfolio. This component is intended to represent the ongoing cost of resources already under contract (including fixed Agenda Page 53
35 payment structures and any modeled variable components, consistent with the cost inputs used in the portfolio analysis).
• Planned Resource Costs ($’000): reflect the cost of new (not yet executed) long-term PPAs and planned resources added under the Preferred Conforming Portfolio buildout. This component represents the incremental cost of new supply contracted (or modeled as procured) to meet forecast load growth and portfolio requirements, including the cost attributes associated with bringing those new resources online over time.
• Cost to Serve Load at DLAP ($’000): represents the cost of serving CPA’s wholesale load at the applicable Default Load Aggregation Point (DLAP). In the context of this analysis, it functions as the modeled cost of meeting residual wholesale energy needs at DLAP after accounting for contracted and planned resource delivery and dispatch outcomes. • ST RA Purchases ($’000): represent the cost of short-term Resource Adequacy (RA) procurement, including existing and incremental RA products purchased to meet CPA’s reliability procurement requirement over time. This component is used to reflect the cost of meeting reliability needs with short-duration contractual products, rather than assuming all reliability needs are met exclusively through new long-term supply contracts.
• ST REC and GHG Purchases ($’000): represent the cost of short-term PCC1 Renewable Energy Credit (REC) purchases and other GHG-Free energy/attribute purchases used to manage residual RPS and GHG-Free compliance gaps and to preserve procurement flexibility. This component is intended to capture the portfolio’s reliance on market-based, short-term clean attribute products as a complement to long-term contracted renewable and carbon-free supply. • Revenue from Resources ($’000): represents the market revenue associated with dispatching portfolio resources to their modeled delivery locations (p-nodes), and it is shown as a negative value because it offsets total gross costs. This component reflects the market value captured by energy and storage operations (and, depending on how your model is configured, may also reflect congestion- and timing-driven value differences across resources). • Total Generation Cost ($/MWh): is the normalized generation cost metric shown as the line over the bar chart. It is calculated by taking the net costs reflected in the stacked bars and dividing by total retail load served in each modeled year.
Under this IRP plan, CPA’s generation costs are projected to rise by an average of 2.67% per year from 2028 through 2045. This increase is driven primarily by forecasted load growth, which requires incremental resource procurement over time; those incremental resources are expected to enter service at higher market prices than CPA’s legacy contracted portfolio, increasing the overall cost of service even as the portfolio becomes cleaner and remains reliable. As the portfolio evolves, the composition of costs shifts from a greater reliance on existing contracted supply and market transactions toward a larger share of costs associated with planned long-term resources and reliability products, while dispatch revenues partially offset gross costs by capturing market value from generation and storage operations.
These cost estimates are inherently assumption-driven and will vary with future market conditions and policy implementation, including load growth realization, technology cost trajectories, RA rules and accounting (including storage counting treatment), congestion and nodal price outcomes, and the Agenda Page 54
36 availability and pricing of short-term RA and clean attribute products. Consistent with the scope of this IRP analysis, the results reflect generation and wholesale procurement costs and do not represent a full bundled retail rate forecast, since transmission and distribution service, Power Charge Indifference Adjustment (PCIA), and certain non-energy costs are addressed through separate IOU and administrative cost structures applicable to CPA customers.
f. System Reliability Analysis
CPA evaluated system reliability for the Preferred Conforming Portfolio using the CPUC RDT, consistent with the 2026 IRP filing guidance. Table 11 presents CPA’s annual system reliability accounting in effective MW (i.e., perfect capacity equivalent MW), including total reliability need, total effective supply, and the resulting net capacity position for each study year. Except as noted below for 2026, the Preferred Conforming Portfolio meets or exceeds CPA’s reliability requirement in every year of the planning horizon, demonstrating that the portfolio contributes its fair share to statewide system reliability under the IRP ELCC-based planning framework.
Table 11: Conforming Portfolio Resource Adequacy Position by Contract Status The RDT table shows a modest negative net position in 2026. This outcome is driven by differences between IRP planning rules and the operational RA compliance framework rather than an indication of noncompliance in the actual RA program. First, under IRP planning standards and California statutory planning requirements7
, Diablo Canyon is not included for long-term planning purposes; however, CPA can and does rely on allocations from Diablo Canyon for RA compliance, and excluding these volumes in the IRP planning framework creates a gap that is isolated to 2026.8 Second, the IRP ELCC framework applies lower ELCC values for thermal resources relative to the Net Qualifying Capacity (NQC) values those resources may contribute under Slice-of-Day and related RA compliance counting. CPA remains fully compliant for all months of 2026 under the Commission’s RA program, and the 2026 negative position shown in the RDT table should be interpreted as an artifact of these accounting differences rather than a deficiency in CPA’s compliance posture.
7 See Public Utilities Code § 454.52 (f)
8 CPA notes it filed its September 2026 Month Ahead RA Compliance filing on July 18, 2026 and was fully compliant while utilizing allocations from Diablo Canyon. 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 LSE reliability need (MW) 3,183 3,247 3,311 3,020 2,729 2,819 2,909 2,997 3,086 3,173 3,242 3,310 3,378 3,446 3,514 3,541 3,569 3,596 3,623 3,649 ELCC by contract status (effective MW)
Online 3,086 2,988 2,589 2,115 1,650 1,672 1,666 1,398 1,384 1,377 1,210 883 867 784 430 339 125 122 107 48 Development - 271 292 256 149 143 137 130 124 118 120 121 123 125 127 127 103 60 59 59 Review - - - - - - - - - - - - - - - - - - - -
PlannedExisting - 91 498 629 685 617 513 576 499 503 609 910 919 987 1,238 1,226 1,299 1,283 1,273 1,260 PlannedNew - - - - 189 317 515 802 978 1,066 1,183 1,268 1,336 1,407 1,550 1,685 1,884 1,976 2,035 2,150 BTM PV 61 67 75 77 80 89 99 110 118 127 135 143 152 161 170 165 160 155 150 145 LSE total supply (effective MW) 3,148 3,418 3,454 3,076 2,753 2,838 2,929 3,016 3,103 3,190 3,257 3,325 3,396 3,464 3,514 3,542 3,571 3,597 3,625 3,661 Net capacity position (+ve = excess, -ve = shortfall) (effective MW) (36) 170 142 56 25 20 20 19 17 17 15 15 18 1 18 1 2 1 2 12 Agenda Page 55
37 Figure 18: Conforming Portfolio Resource Adequacy Contribution by Category Figure 18 summarizes the resource-category contributions to CPA’s RA obligation under the IRP ELCC framework (e.g., solar, wind, storage, and other resource categories) and illustrates the portfolio strategy used to satisfy reliability needs. The figure shows that CPA meets its reliability requirement through a deliberate combination of long-term contracted supply and short-term RA purchases from existing resources, with storage and short-term purchases representing major contributors to effective capacity.
Storage, particularly the 4-hour and 8-hour battery fleet, is the largest driver of incremental effective capacity in the preferred portfolio buildout and is optimized to support net-peak reliability and load-resource balancing. Where the portfolio relies on RA purchases from existing gas resources, these products are expected to be associated with resources that operate at very low capacity factors and primarily serve as contingency reliability support during stressed conditions; as a result, the emissions associated with this reliability backstop are expected to be limited. Using short-term RA contracts for existing resources also helps CPA avoid locking customers into long-term fossil reliability commitments, preserving flexibility as reliability rules, accounting methods, and market conditions evolve.
In addition to the ELCC-based IRP reliability assessment reported through the RDT, CPA also evaluated the Preferred Conforming Portfolio under the Commission’s Slice-of-Day RA framework as a supplemental check (noting that Slice-of-Day is used for the Commission’s RA compliance program). This additional review indicates the portfolio is generally adequate across the planning horizon, but it also identifies seasonal/month-specific gaps that can arise in certain summer or winter months under Slice-of-Day counting rules. These differences reinforce that misalignment between the IRP ELCC planning framework and Slice-of-Day compliance accounting can lead to portfolios that are either over-procured (increasing ratepayer costs) or short in specific critical months even when annual ELCC-based planning adequacy is demonstrated. A primary driver of this divergence is the treatment of storage, where Slice-of-Day accounting can require charging sufficiency and hour-specific availability for capacity counting, while the IRP ELCC approach applies an effective-capacity value that may not fully capture month- and portfolio-specific BESS charging constraints. CPA’s results highlight the value of continued Agenda Page 56
38 Commission efforts to better align reliability accounting across IRP planning, RA filings, and procurement orders.
g. Existing Resource Planning
CPA’s Conforming Portfolio results in significant new build resources while maintaining a prudent and reasonable approach to utilizing existing resources. For starters, CPA notes that resources that have already been built and placed into service from a purely capital cost perspective often represent the cheapest generation resource available.
Energy
In addition to long-term contracts with new build RPS-eligible resources, CPA also expects to meet its energy demand using PCIA VAMO from existing resources, long- and short-term contracts for renewable energy from existing RPS resources and system power purchases. Existing RPS-eligible resources come from currently online RPS-eligible resources (mainly solar and geothermal) that CPA has under long-term contract or from generic solar resources that are generally going to be available in the out years of the planning horizon given the amount of solar resources that have come online within the past five years and will be coming online shortly.
Capacity
For purposes of reliability need, CPA’s 2026 IRP does rely on existing resources, including thermal, DR, and RPS-eligible, to meet its RA requirement and believes this is a prudent and reasonable decision to ensure a cost-effective portfolio. CPA also notes having a thermal resource available through an RA contract does not mean that it will actually run and could be available only for stressed grid conditions. In addition to thermal resources CPA’s reliability need from existing resources is a mix of currently online hybrid, geothermal, out of state wind, and minimal amounts of demand response. Table 12 below shows that the amount of CPA’s reliability needs being met from existing resources decreases through the outer years of the planning horizon.
2026 IRP Comparison to 2022 IRP
When comparing the 2026 IRP to the 2022 IRP, CPA notes that it is not necessarily a direct comparison as many factors have changed in the past four years, including a fairly significant increase in load as compared to 2022. Many resources that were considered planned in the 2022 IRP are now online and, for direct comparison, the only years that appear in both the 2022 IRP and the 2026 IRP are 2030 and 2035.
Table 12 below identifies how the percentage of online and planned existing resources in CPA’s reliability need portfolio compares from its 2026 IRP to its 2022 IRP. CPA notes its percentage for the 2026 IRP decreases over the planning horizon corresponding to the increased supply of new build resources.
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39 Table 12: Comparison of All Resource Types Online and Planned Existing Resources in CPA’s 2026 IRP vs. the 2022 IRP as a Percentage of Total Reliability Need
Online & Planned Existing Resources (%) 2030 2035 2040 2045 2026 IRP
Online & Planned Existing 87% 61% 50% 37%
2022 IRP (25 MMT Case)
Online & Planned Existing 42% 56% N/A N/A
h. Hydro Generation Risk Management
CPA’s portfolio has limited exposure to in-state drought. CPA’s portfolio contains RPS-eligible hydro, including the 11.95 MW Isabella facility and the 20.09 MW Kaweah facility, which are existing resources and would be impacted by changing rainfall/snowpack. Given the relatively small size of these contracts, they pose minimal risk and are expected to have a negligeable impact on costs, GHG emissions and reliability. While having a small overall impact on CPA’s portfolio and expected costs, there are four distinct risks and potential impacts associated with these resources related to drought:
• Energy: CPA expects to know ahead of the impacted year what the impact of a drought will be on production. Any energy shortfall will be addressed through CAISO spot market purchases. • Capacity: CPA’s small-scale hydro resources represent less than 1% of total nameplate capacity for all CPA’s contracted resources and therefore capacity risk for hydro generation is negligible. • RPS: CPA expects to achieve and exceed RPS compliance requirements for the 2026-2045 study period, which means any shortfall of RPS due to hydro generation will likely not affect the RPS compliance for CPA.
• GHG: A shortfall of hydro energy will reduce the amount of carbon-free energy in CPA’s portfolio.
However, hydro generation’s impact on CPA’s GHG emissions is small, and CPA expects to be able to make up for any shortfall with short-term RECs purchases.
In developing its Conforming Portfolio, CPA took several steps to manage the risk of reduced hydropower availability due to in-state or out-of-state drought. Compared to CPA’s 2022 IRP, which did not include any in-state or out-of-state large hydro in its 25 MMT preferred portfolio beyond 2026, CPA’s 2026 IRP does include some hydro generation beyond what is already contracted to date as shown in Table 13 below. However, CPA’s IRP modeling assumed there would be no out-of-state hydro available over the planning horizon as well as reduced assumptions on the availability of in-state hydro as the planning horizon approaches 2045.
Table 13: Comparison of Planned Hydro Resources in CPA’s 2026 IRP vs. the 2022 IRP Planned Hydro Resources (GWh) 2030 2035 2040 2045
2026 IRP
Existing Large Hydro (In-State) 650 790 590 395
Existing Large Hydro (OOS) 0 0 0 0
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40 2022 IRP (25 MMT Case)
Existing Large Hydro (In-State) 0 0 N/A N/A
Existing Large Hydro (OOS) 0 0 N/A N/A
CPA recognizes that a drought could reduce the delivery of carbon-free energy from contracted hydro resources and put CPA at risk of buying short-term energy purchases at high prices. To mitigate this risk, CPA plans to increase the amount of solar PV and wind in its portfolio and thereby reduce expected emissions to less than the benchmark GHG amounts. Higher levels of solar PV and wind in CPA’s portfolio may also help reduce the overall costs of electricity for CPA’s customers.
CPA’s hedging of supply risk is focused on the forward 5-year period and includes securing a variety of resources to ensure delivery at stable costs of all the attributes needed in CPA’s portfolio, including energy, RA, GHG emissions, and RPS requirements. Due to their short-term nature, hedging decisions are not directly part of the IRP or able to address hydro delivery risk towards the end of the forecast period.
However, if CPA’s carbon goals are deemed to be at risk, the hedging policy will seek to minimize that risk by procuring additional capacity or energy from carbon-free resources up to 5 years in advance. i. Long-Duration Storage Planning
Pursuant to D.21-06-035 CPA has a requirement to procure 59 MW NQC of Long Duration Energy Storage (LDES). D.25-02-057 further requires CPA to meet a subset of its procurement obligation with LDES or Clean Firm resources, which would require an additional 89 MW to be online by 2032, resulting in a total of 148 MW NQC from LDES in CPA’s portfolio.
CPA currently has a 75 nameplate-MW contract with an LDES resource (Key Long Duration Energy Storage) that is planned to reach commercial operation by December 2026. CPA’s Preferred Conforming Portfolio calls for the procurement of additional LDES resources to meet the D.25-02-057 procurement obligation to be online by 2032 and to procure additional volumes above its LDES procurement obligation. CPA believes this is the most prudent choice for a variety of reasons including its price point as well as the reality of the resource mix currently available in the CAISO interconnection queue.
LDES in the portfolio mix represents a resource diversity benefit that adds both CPA specific and system wide reliability benefits given its duty cycle. At the same time adding LDES to the portfolio does represent a technology risk (if the long-duration storage technology is nascent) as well as increased costs for customers to meet storage needs as compared to other lower-cost storage configurations.
CPA’s 2026 IRP assumes procuring more LDES resources than its 2022 IRP. This reflects the additional LDES ordered by D.25-02-057 as well as additional 8-hour battery procurement in various years in the planning horizon beginning in 2030.
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41 j. Clean Firm Power Planning
Pursuant to D.21-06-035, CPA has a requirement to procure 59 MW of Clean Firm resources. D.25-02-057 further requires CPA to meet a subset of its procurement obligation with LDES or Clean Firm resources, which would require an additional 89 MW to be online by 2032.
CPA currently has contracted for 66 MW of nameplate capacity from two unique geothermal resources (Cape Station and Geysers) that meet the requirements for clean firm power from D.21-06-035. 18 MW from the Geysers geothermal resource has already reached COD and the remaining 48 MW from Cape Station is scheduled to reach commercial operation by June 2028. CPA’s Preferred Conforming Portfolio shows the D.25-02-057 subset procurement obligation is best met with LDES resources, although CPA’s Preferred Conforming Portfolio does identify a biomass and geothermal resource to come online by 2033.
Clean firm power in the portfolio mix represents a resource diversity benefit that adds both CPA-specific and system-wide reliability benefits given its firm generation profile. However, there are risks associated with including clean firm power resources in the portfolio mix, including delays to the resource’s online date due to nascent technology or transmission availability, curtailment risk, as well as increased costs for customers to meet renewable energy needs that could otherwise be met with lower-cost, more flexible technologies. Additionally, given the backlog of CAISO interconnection queue, it is more prudent to include LDES resources as a larger percentage of the Preferred Conforming Portfolio than Clean Firm generating resources.
CPA’s 2022 IRP included new generic geothermal as does the 2026 IRP, although the volumes and start dates differ. Additionally, CPA’s 2022 IRP did not include any biomass resource while the 2026 IRP includes some volume of biomass in the Preferred Conforming Portfolio. While inclusion of geothermal is in both IRPs, the reason for the inclusion of biomass in this IRP is based on multiple factors including higher system need than in 2022, costs, limited availability of firm resources, and an increasing focus on capacity in addition to energy.
k. Non-CAISO, including Out-of-State, Wind Planning
The CAISO filed its Subscriber Participating Transmission Owner (SPTO) tariff amendment with the FERC on September 22, 2023, and it was approved by FERC in March 2024. 9 The approval of this PTO model
allowed SunZia (both the generation and transmission elements), the nation’s largest wind farm, to reach commercial operations and begin delivering power to CAISO in May of this year. The SPTO model will help California meet its long-term goals, with benefits already being realized.10 CPA is the largest off-taker of 9 See https://www.caiso.com/documents/sep22-2023-tariff-amendment-subscriber-participating-transmission-owner-model-er23-2917.pdf 10 https://www.utilitydive.com/news/california-gas-generation-down-60-percent-from-2024-as-solar-and-imports-surge/823104/ Agenda Page 60
42 SunZia with 700 MW of contracted nameplate capacity to date and represents a significant resource within CPA’s Preferred Conforming Portfolio.
In addition to SunZia transmission utilizing the SPTO model, CAISO also approved TransWest Express LLC’s application to become a SPTO in 2022.11 The TransWest Express project is a 732-mile combined HVDC/AC line that will stretch from Southern Wyoming to the border of California in Nevada. The 2025-2026 TPP notes the project allows for 1,500 MW of Wyoming wind to integrate with the CAISO.
In addition to the existing contract with SunZia, CPA’s Preferred Conforming Portfolio identifies additional wind resources in Wyoming beginning in 2033 which is consistent with the online date for the TransWest express line.12 CPA’s Conforming Portfolio also identifies additional Arizona and New Mexico wind in future years which is consistent with CPA’s current contract end date with SunZia, and is consistent with the long term transmission availability for OOS wind resources.
CPA’s 2022 IRP included both New Mexico wind and Wyoming wind and are again included in the 2026 IRP given the transmission development of SunZia and TransWest express, which are plausible resources to meet this need.
l. Offshore Wind Planning
CPA acknowledges that there is a vast amount of offshore wind potential off the Pacific Coast. However, development of these resources is challenged by the depth of the seafloor (which could necessitate floating applications) and the current lack of transmission to areas with the best wind conditions. In this IRP, CPA did consider offshore wind as a candidate resource in the modeling framework, including potential additions in the mid-2030s. Under the cost and performance assumptions used for this cycle, the model does not select offshore wind because its levelized costs and overall portfolio economics are less favorable than onshore wind and other candidate resources. While offshore wind can provide higher capacity factors and potentially higher RA contribution relative to some alternatives, the modeling results indicate that those reliability benefits do not offset the incremental costs compared to other available resource options.
13 AB 525 directed the CEC to evaluate and quantify the maximum feasible capacity of offshore wind and set a statewide goal for procurement. Additionally, D. 24-08-064, the implementation Decision of AB 1373, found that California needs up to 10.6 GW of new long lead-time (LLT) resources, including 7.6 GW of 11 https://www.caiso.com/documents/decision-pto-application-transwestexpressllc-motion-dec2022.pdf, CAISO board voted 5-0 to approve TransWest Express’ application 12 https://www.transwestexpress.net/about/timeline.shtml 13 See https://www.utilitydive.com/news/trump-administration-buys-out-four-more-offshore-wind-leases-for-765m/823314/. Trump Administration to date has "bought out" 8 offshore wind leases at a cost of more than $2.5 billion, including in Morro Bay from the Golden State Wind project.
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43 offshore wind. On February 24, 2025, the Commission formally requested the DWR to begin its function as a central procurement entity for such LLT resources. 14 CPA has not included any AB 1373 resources within its Preferred Conforming Portfolio and believes this is a prudent decision at this time. CPA notes that the largest portion of the LLT need identified in D. 24-08- 064 is offshore wind (7.6 GW of the total 10.6 GW). CPA also recognizes that offshore wind project development is subject to significant external uncertainties (including permitting, supply chain, interconnection, transmission development, and broader policy and market conditions), which may affect project timing and delivered costs. As such, CPA’s Preferred Conforming Portfolio is designed to remain feasible and cost-effective without relying on offshore wind, while continuing to track offshore wind cost and implementation developments in future planning cycles.
CPA’s 2022 IRP included offshore wind from both Morro Bay and Humboldt based on expectations that offshore wind would become technologically mature and that transmission and enabling infrastructure could be available in the early- to mid-2030s, with costs supported by then-expected federal incentives.
Since the 2022 filing, federal policy changes have removed wind-related tax credits, increasing expected costs for both onshore and offshore wind compared to prior assumptions, while development timelines have become more uncertain. The preferred 2026 portfolio still includes some onshore wind because it remains comparatively cost-effective and operationally valuable within the modeled resource options while offshore wind, given its higher baseline cost and additional infrastructure and transmission requirements, becomes less economic under the updated assumptions. Accordingly, offshore wind is not included in the 2026 Preferred Conforming Portfolio based on modeling outcomes and the considerations outlined in this subsection.
m. Transmission Planning
Background information
CPA has a number of contracted resources that are contingent on interconnection upgrades, as summarized below:
Table 14: CPA Contracted Resources Requiring Interconnection Upgrades Facility
Name
Technology
Type MW Location COD
Expected
Network
Upgrades
Milestone
Key 75 MW
Long
Duration
Storage 75 Fresno County 12/1/2026 8/1/2026
Key 190 MW Storage 190 Fresno County 6/1/2027 1/1/2027
14 See https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/ab1373/cpuc-ab-1373-procurement-request_dwr.pdf.
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44 Denali Storage 93.1 San Joaquin
County 12/29/2028 5/29/2028
Cape Station
30 MW Geothermal 30 Beaver County, Utah 6/1/2028 6/1/2028 Cape Station
18 MW Geothermal 18 Beaver County, Utah 6/1/2028 6/1/2028 Rexford II Solar +
Storage
200 MW PV /
200 MW
Storage
Tulare County 5/1/2029 5/15/2027
CPA notes the IRP is not meant to identify specific locations for future resources and rather acts as a guide for LSEs to navigate what resources may be needed to meet each LSE’s and the State’s unique energy needs and goals. Therefore, the exact transmission needs associated with the buildout from this IRP cannot be known with certainty at this time, and CPA will continue to be engaged at the CPUC and CAISO on TPP development.
Although the IRP does not designate specific interconnection locations, CPA’s modeling framework incorporates transmission limitations by constraining candidate resource availability by region to reflect deliverability into CAISO and transfer limitations within CAISO. Specifically, candidate resource build options located outside CAISO are limited based on assumed import capability and deliverability across key interties, consistent with the expectation that imports are constrained by available transfer capability and import rights. In addition, CPA’s two-zone CAISO representation (NP15/SP15 with SCE_DLAP settlement) reflects intra-CAISO transfer constraints and congestion (e.g., Path 26/Path 15), which affects both the relative value of resources by region and the feasible contribution of resources to serving CPA load. These constraints ensure the modeled portfolio does not rely on unlimited imports or unconstrained north–south transfers and provides a more realistic representation of how transmission limitations can shape cost-effective resource selection.
CPA has followed TPP closely and opted into the newly created LSE Commercial Interest Point (CIP) process—created in the Interconnection Process Enhancements (IPE) 2023 initiative—beginning with Queue Cluster (QC) 15. CPA launched its QC 16 CIP point allocation RFO on July 8, 2026, which helps ensure that CPA has access to resources within the CAISO interconnection process.
CPA’s portfolio identifies new solar and onshore wind resources outside of the CAISO balancing area and believes the existing TPP captures the ability for these resources to connect to the CAISO grid. Specifically, the TransWest express line would ensure Wyoming wind will reach California and with SunZia Transmission now operational there are new potentials for Arizona and New Mexico resources to connect to CAISO, in addition to SunZia wind.
CPA notes that any import resource requires a corresponding Import Allocation Right (IAR) for the resource to count toward CPA’s full RA needs. CPA actively manages its IAR portfolio through the annual Import Capability Assignment process in CAISO Tariff § 40.4.6.2.1, and since the launch of the New Use Import Commitment (NUIC) process in 2021 has been actively managing and increasing its long-term IARs to correspond with CPA’s current and future out of state resources. Looking forward, CPA anticipates a Agenda Page 63
45 continued need to expand long-term IAR to support delivery of additional high-value out-of-state resources, particularly wind and geothermal, which can provide strong reliability contributions and support a diversified, cost-effective clean portfolio.
CPA will continue to monitor CAISO’s Transmission Planning Process and the status of different transmission projects as it develops new resources for its Preferred Conforming Portfolio.
IV. Action Plan
a. Proposed Procurement Activities and Potential Barriers i. Resources to meet IRP mandated procurement requirements, including D.21- 06-035 and D.23-02-040:
In D.21-06-035, the Commission ordered LSEs to procure 11,500 MW NQC of new resources between August 2023 and 2026. The Commission further required that of the total 2,500 MW must be from zero-emitting generation to replace Diablo Canyon, 1,000 MW must be from firm zero-emitting resources, and 1,000 MW must be from LDES. The Commission specifically allocated to CPA the following procurement obligations:
CPA’s MTR Procurement Requirement from D.21-06-03515
2023 2024 2025 2026 (LLT) Minimum Zero-Emitting
Capacity by 2025
Total
118 354 89 118 148 679
In. D.23-02-040, the Commission ordered LSEs to procure an additional 2,000 MW NQC by 2026 and another 2,000 MW NQC by 2027, specifically allocating to CPA the following procurement obligations:
CPA’s MTR Procurement Requirement from D.23-02-04016
2026 2027 Total
117 117 235*
*due to rounding the sum of 2026 and 2027 do not equal the stated total from the Commission Most recently the Commission in D.26-02-057 ordered LSEs to procure an additional 6,000 MW by 2032 spread out between 2030, 2031, and 2032 with an additional requirement that one-quarter of the total MW be from either Clean Firm resources and/or LDES. The Commission specifically allocated to CPA the following procurement obligations.
15 See Ordering Paragraph 3 of D.21-06-035
16 See Ordering Paragraph 3 of D.3-02-40
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46 CPA’s Procurement Requirement from D.26-02-05717
2030 2031 2032 Total Clean Firm/LDES
118 118 118 354 89
CPA notes it recently filed its June 2026 IRP procurement MTR Compliance Filing showing it has met its MTR obligations to date and pursuant to the MTR orders is fully contracted to meet its existing MTR procurement order obligations save for the need to procure additional volume of either Clean Firm and/or LDES resourcesfrom D.26-02-057 that CPA would procure, as it does all of its long-term resources, through its existing RFO and Board approval process.
ii. Plans for resources that are currently non-candidate in CPUC’s IRPs not described above
CPA’s Conforming Portfolio does not include any non-candidate resources. iii. Other renewable and/or zero carbon resources not described above CPA’s Conforming Portfolio anticipates procurement of additional volumes of solar to come online on various dates from 2030 through 2043. Additionally, to ensure a diverse portfolio that can help address CPA’s various procurement needs—including RPS, RA, and complementary load profiles to solar and storage—CPA’s Conforming Portfolio also anticipates procurement of additional geothermal, biomass, and wind resources that would come online between 2033 and 2045 as discussed further in section III. j and k. CPA would procure these resources, as it does all of its long-term resources, through its existing solicitation and Board approval processes.
iv. Other energy storage not described above
CPA’s Conforming Portfolio anticipates procurement of additional volumes of 4- and 8-hour storage beyond procurement order requirements to come online for various dates from 2030 through 2045 and would procure these resources, as it does all of its long-term resources, through its existing solicitation and Board approval processes.
v. Other demand response not described above
CPA’s Conforming Portfolio does not plan for additional demand response resources beyond what is included in the IEPR forecast. However, CPA notes there is an ongoing CAISO initiative, the Demand and Distributed Energy Market Integration (DDEMI), that may impact the overall Demand Response market and could lead to additional volumes not currently planned for in this IRP. 17 See Ordering Paragraph 6 of D.26-02-057
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47 vi. Other energy efficiency not described above
CPA’s Conforming Portfolio has no additional energy efficiency resources beyond what is included in the IEPR forecast.
vii. Other distributed generation not described above
CPA’s Conforming Portfolio has no additional distributed generation beyond what was included in its IEPR forecast. However, CPA operates numerous programs aimed at distributed generation resources as discussed in more detail in IV. b. below. Additionally, as noted above, the CAISO’s DDEMI initiative may impact the overall distributed generation market and could lead to additional volumes not currently planned for in this IRP.
viii. Transportation electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR) CPA currently administers the following programs that aid in the adoption of transportation electrification (TE):
• Energized Communities-Community EV
• Energized Communities-Fleet Electrification
• Electric Vehicle Charging (CALeVIP)
• REACH Codes
ix. Building electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR) CPA currently administers the Energized Communities-Building Electrification (“BE”) program that assists partner communities in reaching sustainability and decarbonization goals by providing technical support and financial support, up to $250,000. BE includes:
• Technical feasibility and infrastructure plans for BE • Electrical load and energy infrastructure analyses regarding upgrade needs Additionally, CPA administers a reach code program to help member agencies adopt building electrification codes that meet climate reduction goals. x. Potential Centralized Procurement, pursuant to AB-1373 In addition to discussion in Section III. m. related to AB 1373, CPA notes that it does not include any LLT Centralized Procurement resources in its Preferred Conforming Portfolio for this IRP cycle. As described above, a significant portion of the AB 1373 LLT need identified by the Commission is associated with offshore wind, which is subject to substantial development and delivery uncertainty. In addition, AB 1373 includes procurement volumes for geothermal and long-duration storage (including 12-hour storage and multi-day storage). While these resource types may provide system reliability and clean energy benefits, CPA believes it is prudent to exclude specific AB 1373 centralized-procurement resources from its Agenda Page 66
48 Conforming Portfolio at this time given uncertainty regarding what will ultimately be procured, the timing of deliveries, interconnection development status, and the costs of these emerging resource options under current market conditions.
If DWR proceeds to solicit, procure, and bring online LLT resources pursuant to AB 1373, CPA expects the portfolio and customer cost implications would depend on what resources are procured, the contract terms and delivered costs, and the timing of commercial operation relative to CPA’s planned resource buildout. In particular, to the extent DWR-procured geothermal and biomass resources are delivered on a timeline comparable to resources in CPA’s Preferred Conforming Portfolio, those centralized-procurement deliveries could partially offset, or shift the timing of, geothermal and biomass additions otherwise reflected in CPA’s plan. Similarly, if LDES (including 12-hour storage) are procured and delivered at scale and at competitive costs, such deliveries could offset or reduce portions of CPA’s and other LSEs’ planned storage procurements (for example, by reducing the need for additional 8-hour storage additions, depending on the performance characteristics, RA value, and timing of delivery).
Conversely, if DWR-procured resources differ materially from CPA’s planned resource mix, particularly with respect to offshore wind and multi-day storage, the outcome could require either (a) an adjustment to CPA’s planned buildout to integrate those resources efficiently, or (b) incremental costs relative to the Preferred Conforming Portfolio, depending on timing, delivered costs, and how those resources interact with system needs and existing contracts. In all cases, CPA anticipates that any DWR-procured LLT resources, if delivered, would contribute positively to statewide clean energy and reliability objectives. The principal uncertainty for CPA’s planning is how those deliveries would be reflected in CPA’s procurement pathway and customer costs relative to the Preferred Conforming Portfolio.
CPA will revisit these assumptions in the next IRP cycle, and its portfolio will evolve as needed to reflect DWR’s progress on AB 1373 centralized procurement, including clearer information on resource selections, delivery timelines, and contract costs, as well as updated market conditions and modeling inputs.
xi. Other
CPA’s Conforming Portfolio includes procurement of unbundled RA from thermal plants but CPA believes the amount of procurement is commensurate with the existing thermal fleet and notes there are innovative ways to reduce the GHG emissions of the thermal fleet including transitioning to alternative fuel types and adding battery storage.
b. Disadvantaged Communities (DACs)
CPA administers several activities and programs that address the needs of disadvantaged communities. • Power Share: Provides utility scale clean energy at a 20% bill discount for income-qualified, residential customers in DACs who are enrolled in CARE or FERA. CPA actively engages in outreach Agenda Page 67
49 and marketing efforts within DACs. CPA currently has approximately 10,000 customers enrolled in this program.
• Solar and Battery Access: This program makes sustainable, renewable energy accessible by helping qualified homeowners receive solar and battery storage with no out-of-pocket expenses for equipment and installation. Customer participation is limited to households with incomes at or below 80% of the Area Median Income (AMI) verified through proof of total household income.
Homeowners who are enrolled in one of the Energy Saving Assistance programs are likely to qualify for the 80% AMI threshold. CPA currently has 177 active enrollments, and 48 on the waitlist.
• Sun Storage Rebate: CPA residential customers who install a solar battery storage system can apply for a rebate of up to $750 with an additional $250 for income-eligible customers (CARE/FERA) with the Sun Storage Rebate program. This program currently has 224 enrollments. • Apartment Building Cooling Assistance (ABCA) Program: The program will be launching within the next six months and will provide outreach and engagement, technical assistance, and rebates to owners of multifamily properties within CPA’s service territory to support their purchase and installation of efficient cooling equipment such as efficient air conditioners (AC) or room heat pumps. Multifamily properties are defined as attached properties of two (2) or more units. The ABCA program will also offer customer support and rebate administration for tenants of multifamily properties who are interested in purchasing and installing the equipment themselves.
The ABCA program has set a goal to reserve 30% of the rebate funds for properties within DACs. • EV Smart Charge: EV SmartCharge helps CPA customers save money on their electricity bills by automating their vehicle charging at the most cost-effective time. The app-based program works by managing a vehicle’s charging schedule, automatically charging during off-peak periods when electricity demand and costs are lower. CPA currently has 1,585 enrollments over 300 of those enrollments are either low-income or living in a DAC.
• Power Response: This program incentivizes customers to temporarily reduce their electricity usage during periods of high energy demand, known as "Energy Saving Events," by offering financial rewards for participating, helping to stabilize the electrical grid and promote energy conservation within the community. CPA offers a no-cost thermostat to income-eligible (CARE/FERA) customers. CPA currently has 3,926 enrollments. • Power Ready: Power Ready is a community benefit program offered to CPA’s member agencies and community critical sites. The program enhances energy and community resiliency by installing solar-plus storage systems as a clean energy backup source that is available when a power outage occurs. Power Ready supports solar and battery backup power to public emergency evacuation centers and cooling centers that are open to the public, including within DACs, that can benefit from these services during times of grid outage events. CPA currently has 11 enrollments. • Multifamily EV Charging Program: The program will be launching within the next six months and will provide technical assistance and rebates to multifamily customers to support the installation of smart outlet EV chargers, L1, and L2 EV chargers. CPA will be tracking participating within DACs and offering higher incentives for properties where two or more of the residents and/or tenants are on CARE/FERA or in affordable housing.
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50 • Energized Communities & Innovation Fund: This program assists partner communities in reaching sustainability and decarbonization goals by providing financial (up to $250,000) and technical support. The Innovation Fund includes projects that extend beyond the other Energized Communities Pathways and focus on resilience and grid management, electrification, or local clean energy procurement. CPA partners with participating agencies to provide targeted DAC marketing and outreach support.
• Energy Team: This program offers CPA residential and small business customers expert energy guidance, virtual assessments, and online calculator tools at no cost to the customer. • Instant AC Savings: CPA residential CARE or FERA customers can receive a $300 instant coupon toward the purchase of an eligible ENERGY STAR certified room AC unit. Outreach is focused on communities with high CARE, FERA, DAC, and low-income customers. CPA currently has 74 reservations, of which 17 have received their redemptions.
In addition to the programs discussed above and to expand DACs’ access to renewable energy, CPA makes available higher tiers of renewable product offerings to all its customers, including its customers that receive rate assistance through CARE, FERA, and Medical Baseline programs. CARE, FERA, or Medical Baseline customers located in jurisdictions that have selected CPA’s 100% renewable as their default energy product are defaulted into CPA’s 100% renewable product at a rate that matches the overall bill cost those customers would pay on SCE’s discounted bundled rate, inclusive of PCIA and their existing discounts. This program provides equitable access to renewable energy options for customers that might otherwise have difficulty accessing other traditional renewable energy programs and avoids increasing generation costs for CPA’s most vulnerable customers.
CPA also has several programs that aim to reach disadvantaged communities and expand their access to the clean energy economy:
• Community Benefits Grant Program: An annual funding program that invests in nonprofit organizations advancing clean energy, environmental sustainability, workforce development, and community resilience throughout CPA's service area in Los Angeles and Ventura counties. The program is funded by Calpine Community Energy; CPA develops the grant guidelines, conducts community outreach, and collaborates on the review and selection of award recipients. The grant supports projects that expand equitable access to clean energy and create meaningful environmental and economic benefits for local communities. Priority funding areas include:
o Research that advances clean energy and sustainability solutions. o Resilience projects that strengthen community preparedness and climate adaptation. o Environmental and Social Justice initiatives serving disadvantaged and historically underserved communities.
o Workforce Development programs that prepare residents for careers in the clean energy economy.
o Education efforts that promote environmental stewardship and clean energy awareness.
Grant awards typically range from $15,000 to $30,000 for one year. Since its launch in 2021, the program has invested over a million dollars in more than 40 community-based organizations Agenda Page 69
51 delivering innovative projects such as clean energy education, youth environmental leadership, workforce training, resilience planning, and sustainability initiatives. In recent years, the program has expanded its funding to include support for organizations responding to climate-related emergencies, including wildfire recovery efforts.
• Multi-Craft Core (MC3) Pre-Apprenticeship Programs: MC3 pre-apprenticeship programs provide bootcamp training for students in underserved communities and help place them into union construction trade apprenticeship programs under the North America Building Trades Unions and the Los Angeles and Orange County Building and Construction Trades Council. CPA has invested $1.47 million over a three-year period to fund student support services and training stipends, supporting 600 pre-apprentices over that time. CPA works with three partners: Flintridge Center in Pasadena, Women in Non-Traditional Employment Roles (WINTER) in Los Angeles, and the Workforce Development Board of Ventura County (WDBVC), with trainings planned at Oxnard College. Together, these partners deliver pre-apprenticeship training to underrepresented individuals, including those who are previously incarcerated, gang-impacted, women, low-income, people of color, veterans, or recently out of foster care. To date, CPA funding has supported 178 students across the three organizations.
• Voyager Scholarship: The Voyager Scholarship is a workforce development initiative created by CPA to help prepare the next generation of clean energy professionals. Established in 2019 with initial funding provided by the Voyager Wind project developer, Terra-Gen, with additional funding approved by the CPA Board in 2024. The program provides scholarships to community college students pursuing careers in pathways such as renewable energy, electrification, environmental science, advanced transportation, and related energy fields at participating community colleges throughout Los Angeles and Ventura counties. The scholarship is designed to:
o Expand access to higher education for students pursuing clean energy careers. o Strengthen Southern California's renewable energy workforce. o Reduce financial barriers for students studying fields such as electric vehicles, electrical technology, environmental science, renewable energy, and advanced transportation technologies.
o Support equitable workforce development by investing in local talent from CPA's service area.
Since its launch, the program has expanded from seven to eleven participating community colleges and represents a long-term investment in developing a skilled workforce to support California's clean energy transition. Scholarship awards are administered through participating college foundations, which determine recipient selection based on their scholarship processes and areas of study. To date, over $116,000 in scholarships have been awarded to students. CPA has committed a total of $435,000 in continued funding for the scholarship program.
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52 c. LSEs’ Tribal Customers
CPA currently does not serve any customers located on tribal lands. d. Procurement Products
CPA primarily procures through competitive solicitations and supplements with short-term products and market transactions to manage reliability, RPS, and GHG-Free compliance needs while maintaining flexibility. The table below summarizes key products across multiple solicitations.
Product Description of Product
Clean Energy & Reliability
RFO – Renewable
Generation Only Contracts
Long-term physical PPAs for standalone renewable generation that deliver energy into CAISO and support CPA’s RPS/GHG-Free and IRP portfolio needs.
Clean Energy & Reliability
RFO – Renewable
Generation Plus Storage
Contracts
Long-term physical PPAs for co-located/hybrid renewable generation paired with storage to improve load-matching and increase effective capacity contribution. These contracts support clean energy delivery and reliability value, depending on storage duration and operating constraints.
Clean Energy & Reliability
RFO – Standalone Storage
Contracts
Long-term agreements for standalone storage (durations of at least 4 hours) to provide dispatchable capacity, net-peak support, and grid flexibility. These products support reliability and reduce curtailment risk by shifting energy across hours.
Clean Energy & Reliability
RFO – RA Only Contracts
(Long Term)
Long-term procurement of RA capacity products intended to meet system and/or local RA obligations without procuring bundled energy or clean attributes. These contracts provide a capacity-based reliability product and preserve flexibility as RA requirements evolve.
Clean Energy & Reliability
RFO – PCC1 Energy Only
(Fixed Price or Index Plus)
Contracts
Energy-only contracts that provide PCC1-eligible renewable energy/attributes, structured as either fixed-price or index-plus products. These products help manage RPS positioning and maintain flexibility alongside long-term contracted supply. They don’t include any RA attributes from the facilities.
Clean Energy & Reliability
RFO – Dispatchable
Thermal Energy with RA
Contracts
Dispatchable thermal energy products with cleaner operations and include RA capacity value, sourced from existing thermal resources (including configurations with attached batteries or running on blended fuels). These products have shorter term lengths and are used primarily as a reliability backstop and structured to limit long-term fossil lock-in where feasible.
Innovation Solicitation for
Emerging Technologies
(Annual)
Annual solicitation pathway for emerging/non-standard technologies and project structures that do not fit the standard Clean Energy & Reliability RFO categories. This channel supports portfolio diversity and resilience by evaluating innovative solutions with an emphasis on learnings, scalability, and future applicability.
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53 Short-Term RA Purchases
(RA RFOs / Bilateral /
Brokers)
Short-duration RA procurement (month-ahead, seasonal, or annual) used to manage near-term reliability needs, bridge timing gaps, and maintain flexibility.
Short-Term PCC1
Purchases (RFOs /
Bilateral / Brokers)
Short-term PCC1-eligible purchases used to manage residual RPS compliance needs and volumetric gaps due to load variability, contract shapes, and market availability.
Short-Term Clean Energy
Purchases (RFOs /
Bilateral / Brokers)
Short-term clean energy purchases (including hydro) used to manage residual GHG-Free targets and provide flexibility while long-lead resources are developed and brought online.
e. Commission Direction of Actions
The Commission’s development of the Reliable and Clean Power Procurement Program (RCPPP) and related procurement direction is occurring alongside major, discrete procurement mandates that materially affect LSE planning and implementation. The Commission released the RCPPP Staff Options Paper (September 2022) shortly before LSEs filed their 2022 IRPs, and since then has issued significant procurement orders, including D.23-05-040, which required an additional 4,000 MW of NQC to come online in 2026 and 2027, and D.25-02-057, which required an additional 6,000 MW of NQC, with at least 1,500 MW coming from LDES or Clean Firm resources, to come online in three tranches starting in 2030. In addition to these unique procurement orders, the Commission has issued numerous decisions that affect procurement requirements and LSE compliance obligations across proceedings.
In April 2025, the Commission issued the “Staff Proposal: Reliable and Clean Power Procurement Program” as a follow-up to the 2022 Staff Options Paper, supported by a two-day workshop and party comments. On June 23, 2026, the ALJ issued the “Ruling Seeking Comments on Additional Proposal for a Reliable and Clean Power Procurement Program.” CPA appreciates the Commission’s effort to develop a durable long-term procurement framework through RCPPP; however, CPA’s study results and implementation planning identify several areas where additional Commission direction would materially improve alignment, reduce duplicative compliance friction, and ensure that procurement signals are implementable and durable.
First, CPA requests the Commission better integrate any RCPPP and the IRP generally with RA accounting methodologies across (a) month/year ahead filings which rely on Slice-of-Day accreditation, (b) IRP portfolio modeling, which commonly relies on ELCC-based RA accounting, and (c) procurement orders, where ELCC concepts may be applied in ways that differ from IRP planning (including values that are calculated differently and are marginal rather than portfolio-average). In practice, this misalignment can create conflicting procurement signals and complicate contracting strategies because an LSE may appear balanced under one framework while appearing short (or long) under another, and both pose financial risks and costs to ratepayers. CPA recommends the Commission adopt a clear approach that results in a single consistent planning standard so that IRP modeling, procurement order compliance demonstrations, and RA filings are aligned in a way that LSEs can execute without duplicative procurement or unintended over/under-procurement outcomes.
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54 Second, CPA requests Commission direction to improve load forecast integration for IRP planning. CPA’s experience is that the standardized forecast used for IRP planning can diverge materially from LSE internal forecasts that incorporate more localized, service-territory-specific information and may better reflect evolving drivers of load growth and load shape, particularly around data center development and electric vehicle adoption. Because load assumptions strongly influence modeled resource needs, buildout timing, and cost/reliability outcomes, CPA recommends the Commission and staff establish a clearer process to incorporate and reconcile LSE-provided forecast intelligence with the CEC forecast framework used for IRP planning. CPA further recommends that this integration be paired with structured scenario analysis so that procurement direction remains robust across plausible load trajectories and shapes, rather than being optimized to a single point forecast that may become outdated.
Third, CPA requests Commission direction to expand and formalize scenario and sensitivity analysis in the IRP process to more explicitly address uncertainty and improve the durability of procurement signals that flow through RCPPP and procurement orders. A key opportunity to improve IRP modeling and planning is to systematically evaluate uncertainty by varying major drivers that materially affect portfolio selection and feasibility, including resource costs, resource availability and development constraints, out-of-state import capability and deliverability, load forecast levels and shapes, emissions intensities, and broader WECC policy/market conditions that affect CAISO prices and regional supply-demand balance. These uncertainties can meaningfully change the “least-cost” portfolio result and can affect whether assumed procurement pathways remain feasible by the time they are implemented.
In addition to a broader set of deterministic sensitivities, CPA recommends the Commission consider incorporating stochastic capacity expansion modeling (or a comparable approach) to evaluate portfolios that perform well across a range of plausible futures rather than optimizing to a single base case with point assumptions. This would better identify least-regrets strategies, quantify the value of hedging actions, and reduce the risk that procurement direction is overfit to a single assumed future that may not reflect conditions at the time of contracting and delivery. CPA believes these improvements would strengthen alignment between IRP planning, RCPPP program design, and procurement order implementation, and would provide clearer, more durable procurement signals for LSEs executing procurement on behalf of customers.
V. Lessons Learned
The IRP is a long-term planning exercise intended to provide a credible path for an LSE to meet reliability, clean energy, and emissions obligations over the planning horizon using the best information available at the time of filing. CPA views the process as most valuable when it produces outputs that are useful for procurement planning and that remain durable as market conditions, loads, and policy requirements evolve. In this filing cycle, CPA identified several practical improvements that would strengthen the IRP’s ability to support statewide policy goals while reducing implementation risk and unnecessary rework.
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55 A recurring lesson learned is the importance of alignment between planning constructs and compliance constructs, particularly for Resource Adequacy. As discussed in Section III.f, CPA assessed its portfolio under both the IRP’s ELCC-based framework and the RA program’s Slice-of-Day framework, even though such dual-checking was not required. That comparison provided direct insight into how planning against two standards can create misaligned signals for procurement timing and product selection can result in over-procurement or under-procurement depending on the framework and can reduce confidence that an IRP portfolio is readily implementable under the compliance framework that LSEs must ultimately satisfy. Consistent with Section IV.e, CPA encourages the Commission to pursue a durable long-term solution that uses SOD accreditation so that IRP planning outputs can be more directly applied to RA compliance and procurement execution, supporting reliability while avoiding duplicative procurement driven by methodological differences.
The second lesson learned relates to uncertainty management and scenario development. A key opportunity to improve the IRP modeling and planning process is to treat uncertainty more explicitly through expanded scenario and sensitivity analysis, particularly around the inputs and assumptions that drive portfolio buildout and cost and reliability outcomes. The process would benefit from systematically varying major drivers such as resource costs, resource availability and development constraints, out-of-state import capability and deliverability, load forecast levels and shapes, emissions intensities, and broader WECC policy or market changes that affect CAISO prices and regional supply-demand balance.
These uncertainties materially affect both optimal resource selection and the feasibility of assumed procurement pathways and making them explicit would improve the Commission’s ability to issue procurement direction that remains robust over time.
In addition to deterministic sensitivities, CPA recommends that the Commission evaluate methods such as stochastic capacity expansion modeling (or a comparable approach) to identify portfolios that perform well across a range of plausible futures rather than optimizing to a single base case with point assumptions. This type of approach can help identify least-regrets strategies and quantify the value of hedging actions, improving the likelihood that procurement direction supports SB 100 and emissions objectives while maintaining reliability under changing conditions. Even if full stochastic modeling is not adopted near-term, CPA recommends establishing a more systematic and transparent scenario framework so that parties can clearly see which uncertainties drive outcomes and how portfolio choices change under different futures.
A third lesson learned is that the usefulness of IRP outputs depends heavily on maintaining current and realistic inputs and assumptions, especially for rapidly evolving drivers. When the IRP cycle spans multiple years, point assumptions for key drivers can become stale relative to observed market conditions, technology cost trajectories, and evolving load and policy dynamics by the time portfolios are developed and filed. CPA recommends focusing on a more current base case and pairing it with structured sensitivity analysis so that conclusions are not overly dependent on a single assumption set. This supports state policy goals by reducing the risk that procurement direction is based on conditions that no longer reflect the market environment when contracting occurs.
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56 Relatedly, CPA’s experience is that load forecast divergence can meaningfully affect modeled needs and portfolio outcomes. Standardized forecasts used for IRP planning can diverge from LSE internal forecasts that incorporate more granular, service-territory-specific information, particularly around localized drivers such as data center development and electrification (including EV adoption). CPA recommends that the Commission and staff continue improving the integration between statewide forecasting frameworks and LSE localized intelligence, including scenario analysis around load levels and load shapes.
Improved load forecast integration would strengthen the Commission’s ability to achieve state reliability and clean energy goals because resource need determinations and procurement signals would better reflect conditions likely to materialize in specific service territories.
Finally, CPA recommends targeted process improvements that would strengthen filing quality and reduce avoidable filing risk, supporting the Commission’s policy goals by improving consistency and confidence in submitted materials. CPA suggests that office hours occur more frequently and earlier in the cycle so that expectations and template usage questions can be resolved before filings are largely complete. In addition, CPA recommends establishing a clearer, more transparent pathway for logging template or tool issues (for example, with acknowledgement, prioritization, and expected response timelines) so that LSEs can address time-sensitive questions consistently and avoid divergent workarounds.
CPA also encourages continued improvement to the stability, usability, and documentation of the RDT and CSP calculator tools. In CPA’s experience, multiple template iterations and lingering formula or data-quality issues can increase workload under tight deadlines and introduce inconsistent approaches across filers. CPA recommends continued quality assurance prior to posting “final” tools and clearer documentation where methodological choices affect outcomes. For example, CPA suggests that future enhancements to CSP consider improved representation of evolving hourly load shapes across years and clearer emissions accounting documentation (including key allocation assumptions), to support more consistent and decision-useful emissions estimation while preserving the Commission’s objective of a simple and uniform reporting framework.
CPA appreciates the Commission and staff’s continued efforts to refine the IRP process, and offers these lessons learned to support a process that is more implementable, transparent, and durable. CPA believes that aligning reliability constructs, strengthening uncertainty analysis, improving load forecast integration, and continuing to enhance filing tools and support processes would facilitate the ability of both the Commission and LSEs to achieve California’s clean energy, emissions reduction, and reliability goals. CPA is committed to providing safe, reliable, affordable, and clean energy to its customers and to collaborating with statewide energy stakeholders to support California’s energy goals.
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Staff Report – Agenda Item 4
To: Energy Planning & Resources Committee
From: John McNamara, Director, Structured Contracts
Reviewed by: Lindsay Descagnia, Vice President, Power Supply Matthew Langer, Chief Operating Officer
Approved By: Ted Bardacke, Chief Executive Officer
Subject: 2026 Clean Energy and Reliability RFO Longlist Overview Date: July 22, 2026
Staff will provide a presentation on the item.
ATTACHMENT
1. 2026 Clean Energy and Reliability RFO Longlist Presentation Agenda Page 76
2026 Clean Energy and
Reliability RFO Longlist
July 22, 2026
Agenda Page 77
CPA received 100 compliant proposals in 2026 Clean Energy and Reliability RFO compared to 106 proposals received in the 2025 Clean Energy and Reliability RFO
The majority of offers received were for either Standalone Storage or Renewable Generation + Storage. For renewable generation, all offers were for solar aside from two wind proposals CPA received 27 Long-Duration Energy Storage (LDES) storage offers which may be utilized to meet a new CPUC Procurement Order
There were 33 proposals that requested Fast-Track consideration, the most common reason being that they need a PPA by March 2027 to retain their Full Capacity Deliverability Status (FCDS) Projects may become unavailable as proposers seek a PPA that will allow them to retain their (FCDS) and withdraw from the RFO
Renewable generation prices are higher and more volatile than last year’s RFO but storage prices continue to stabilize and drop
Staff is performing due diligence on proposals, and the results will be presented to the RFO Review Team and Energy Committee in September
2 Executive Summary
Agenda Page 78
2026 RFO Overview and Goals
The purpose of the 2026 Clean Energy and Reliability RFO is to solicit competitive proposals to fill a larger portion of CPA's portfolio needs with long-term contracts, reducing the need to procure products such as Resource Adequacy (RA) and renewable energy in volatile short-term markets CPA set PPA Start Dates to range from January 1, 2029 to December 31, 2033 to best align with CPA’s portfolio needs Similar to recent RFOs, the 2026 RFO has a ‘fast-track’ path that allows CPA to start negotiations on high-value projects before CPA’s Energy Committee considers the Review Team’s shortlist recommendation. Staff is still considering fast track projects
CPA has implemented several changes to the RFO protocol this year including:
Increased focus on Clean Firm Resources and Long-Duration Energy Storage (LDES) to support compliance with CPUC Procurement Order D.26-02-057
Introduction of a new product category, "RPS Generation or Storage Paired with an Existing CPA Resource“, to encourage development of co-located projects that leverage existing contracted resources and interconnection capacity Revisions to project eligibility requirements, including reducing maximum project size limits across most product categories to better align procurement volumes, manage risk, and improve portfolio flexibility 3 Agenda Page 79
RFO Offer Overview
Summary Stats
Number of conforming offers 100
Number of offers with Full Capacity Deliverability
Status (FCDS) 81
Number of sellers submitting offers 34
Counties spanned by submissions 25
States represented by offers 3
Number of new facility offers 93
Number of existing facility offers 7
Number of offers with CPUC-eligible LDES (8-hour
duration) 27
Local Projects 22
Bundled Offers 9
Fast-Track Requests 33
Earliest online date 1/1/2029
Latest online date 12/31/2033
Product Type Total Local
Standalone Storage 51 16
RA-only 19 6
RPS + Storage 18 0
RPS only 5 0
RPS Generation or Storage
Paired with an Existing
CPA Resource
0 0
PCC1 Energy
(Fixed or Index Plus) 5 0
Tolls (Dispatchable Gas) 2 0
Total 100 22
4 Agenda Page 80
Offer Locations are Concentrated
Los Angeles, Kern, Riverside and San Joaquin Counties were the dominant regions for Stand-Alone storage projects whereas renewable project development are more dispersed 5 Agenda Page 81
Offers by Product and Technology Type
Solar and storage were the dominant technologies offered into this RFO. Two wind projects were offered. No geothermal or biomass resources were received Lithium-ion continues to dominant storage technology. Some sodium-ion and compressed air storage bids were received
6 Agenda Page 82
7 Large Scale Projects Are Popular
CPA received a healthy mix of project sizes in this year's RFO Ranked Offers by Offered Size (MW)
Agenda Page 83
Developers are Targeting Early Online Dates
The majority of online dates are in 2029, 2030, and mid 2031 8 Agenda Page 84
Storage Pricing is Less Volatile
Energy generation prices continue to increase but Stand-Alone Storage pricing is relatively stable and trending slightly downward
9 Agenda Page 85
Reduced Emissions Thermal Toll Offer Overview
CPA received bids from two Sellers for 2 total thermal toll offers Projects are located in Riverside and Kern counties
These are existing natural gas facilities that intend to add a battery to their operations Integrating a battery energy storage system allows a natural gas facility to dispatch stored energy for specific durations, potentially reducing the need to bring the thermal plant online and/or reduce its runtime. This results in a reduction to the overall GHG emissions of the plant
Gas Toll Product Type Count
Existing dispatchable gas (with RA) paired with storage 2 Existing dispatchable gas with blended fuels (renewable biogas or hydrogen)
0 10
Agenda Page 86
Next Steps
Staff is performing due diligence of proposals and considering fast track offers Review Team will meet in September to review confidential valuation results and form a recommendation for the shortlist and waitlist
A shortlist and waitlist will be presented to the Energy Committee for consideration in September
11 Agenda Page 87
2026 Clean Energy and Reliability RFO Schedule
Date Item
May 19, 2026RFO Opened
June 29, 2026Deadline to submit RFO Proposals
Mid-September 2026 RFO Review Team reviews offers (schedule TBD) September 23, 2026Energy Committee shortlist consideration Late September 2026 Proposers notified of shortlist status August 2026* – February 2027
Power Purchase Agreement (PPA), Energy Storage
Agreement (ESA) Resource Adequacy Agreement
(RAA) negotiations
November 2026 – March 2027 Board Consideration of PPAs
* Includes Fast-Tracked projects
12 Agenda Page 88
Appendix
Agenda Page 89
Product Types and Eligibility
Product Types Description of Eligible
Resources
Term
(Years) Size (MW) 2 Earliest
Online Date
Latest Online
Date 3
Renewable Portfolio
Standard (RPS)
Generation Only
Solar, wind, geothermal, biomass, small
hydro (bundled with RA or energy-only) 10 to 201 15 to 150 January 1, 2029 December 31, 2033 RPS Generation +
Storage RPS generation paired with storage 10 to 20 15 to 150 January 1, 2029 December 31, 2033 RPS Generation or
Storage Paired with
Existing CPA Resource
RPS generation paired with storage where
one component is an existing CPA resource 10 to 20 15 MW up to the existing interconnection capacity January 1, 2029 December 31, 2033 Standalone Storage Standalone storage facilities with a minimum duration of at least 4 hours 10 to 20
15 to 100 (8hr)
15 to 150 (4hr)
January 1, 2029 December 31, 2033
Resource Adequacy (RA)
- Only
Offers from any technology for RA capacity
(no energy) 5 to 15 15 to 150 January 1, 2029 December 31, 2033 Blended or Hybrid Tolls
Natural gas facilities that reduce emissions
by converting to a blended fuel source and/or
adding battery energy storage
2 to 10 10 MW Minimum January 1, 2029 December 31, 2033 1 Term limits for Energy Only offers will be 5 to 20 years 2 The minimum size eligibility requirement for projects located within Los Angeles or Ventura county (excluding product type Blended or Hybrid Tolls) will remain at 5 MWs 3 Clean firm and LDES projects will have a latest online date of June 1, 2032 to align with the eligibility requirements for CPUC Decision D.26-02-057.
To reflect CPA’s needs this year, CPA has updated the project size and extended the latest online date to 2033 14 Agenda Page 90
Evaluation Criteria
With the exception of natural gas tolls, projects will be ranked using CPA’s standard criteria:
Environmental
Stewardship
Workforce
Development
Quantitative
Evaluation
(Value)
Development
Risk
Project
Location
Benefits to
DACs
Tariff and Tax
Credit Price
Adjuster
15 Agenda Page 91
Development Risk
Projects will be ranked from high (good) to low (bad)
The development risk metric is a composite rank based on a number of factors impacting project risk:
o Site control
o Interconnection status
o Environmental screens
o Land use and permits
o Project financing
o Developer experience
16 Agenda Page 92
Environmental Stewardship
Projects are ranked high, neutral, and low based on the following prioritization:
HIGH
LOW
NEUTRAL
Project is located in a multi-benefit or renewable energy zone or is located on non-natural land (e.g. commercial or industrial areas, areas with existing energy infrastructure).
Project is not located in a multi-benefit area, renewable energy zone, or high-conflict area.
Project is located in a high-conflict area or on natural, undisturbed lands that are not located in a multi-benefit area or renewable energy zone. 17 Agenda Page 93
Workforce Development
Projects are ranked high, medium or low based on the following prioritization:
The project will secure a multi-trade project labor agreement or will utilize a combination of targeted-hire and union labor (including requirements for state-apprenticeship graduates)
HIGH
The project does not commit to have a project labor agreement, but will pay prevailing wages, use union labor, and make targeted hire commitments MEDIUM The project does not demonstrate the requirements for a High or Medium score
LOW
18 Agenda Page 94
Benefits to Disadvantaged Communities
(excluding tolls)
Projects are ranked high, medium, neutral, and low based on the following prioritization:
Located within a DAC and demonstrates DAC workforce and community development benefits HIGH
Project not located within a DAC but can demonstrate DAC benefits and has completed community outreach MEDIUM
LOW Project is inconsistent with community priorities
NEUTRAL Project does not demonstrate DAC benefits
19 Agenda Page 95
Project Location (excluding tolls)
HIGH In Los Angeles and Ventura counties
The project is located in another county within California or it is located within a Federally-designated energy community or on tribal lands with demonstrated community support (including outside of California) MEDIUM
Projects outside of California not located in a Federally-designated energy community or on tribal lands without demonstrated community support LOW
Projects are ranked high, medium, and low based on the following prioritization:
20 Agenda Page 96
Quantitative Evaluation
All projects will be assessed for market performance against the relevant project Pnode
Valuation will be performed using Ascend’s PowerSIMMTM platform, dispatching resources against simulated Pnode prices
Projects will be valued for their Resource Adequacy as well as revenues across all relevant Day-Ahead, Real-Time, and ancillary markets Data provided by proposers in the Offer Form Template will be used to model proposals
21 Agenda Page 97
Tariff and Tax Credit Price Adjusters
CPA will consider the incremental reductions in contract price, identified in the Offer Form, if the Seller receives an Investment Tax Credit (ITC) or Production Tax Credit (PTC) above the proposer’s stated benchmark. Projects will be ranked based on the percentage decrease relative to the Contract Price offered at the benchmark ITC/PTC rate identified by the Proposer.
Tariff Price Adjusters: CPA will rank based on projects that minimize the percentage increase in Tariff Price Adjusters relative to the Contract Price.
22 Agenda Page 98
Toll Evaluation Criteria (Dispatchable
Thermal Energy with RA Contracts)
CPA received tolling offers from hybrid natural gas facilities that incorporate battery energy storage
Only offers that can demonstrate a plan for this cleaner alternative are eligible for participation in this RFO
CPA will use the following criteria when evaluating these offers:
Workforce
Development
Quantitative
Evaluation
(Value)
Plan for
Transition to
Cleaner
Operations
Benefits to
DACs
23 GHG
Emissions
Agenda Page 99
Transition to Cleaner Operations
Projects are required to explain how their project will transition to cleaner operations in their Narrative document.
Proposals for natural gas tolling agreements that do not provide a transition to a cleaner alternative and extend the retirement plans for an existing natural gas facility will be ineligible for participating in the RFO. 24 Agenda Page 100
GHG Emissions
CPA will forecast the expected generation and associated GHG emissions of each blended fuel or hybrid fuel/battery storage facility CPA may receive offers from facilities that are very efficient and are expected to run frequently and offers from facilities that are less efficient and expected to run infrequently
CPA will use forecasted data to analyze a facility’s total GHG output and the facility’s efficiency and determine the effects such facility will have on CPA's Product Content Label and GHG emissions profile
This will be a quantitative measure, not ranked High, Medium, Low 25 Agenda Page 101
Disadvantaged Community Impacts
Blended fuel and hybrid natural gas/battery storage resources will have differing impacts on DACs than renewable resources. Impacts to DACs will be assessed in conjunction with scoring in the three qualitative evaluation criteria; 1) impacts of the agreement on a transition to cleaner operations, 2) workforce development, and 3) GHG emissions
HIGH Demonstrates DAC benefits, including transition to cleaner operations NEUTRAL Project does not demonstrate additional DAC benefits, or is not located in a DAC LOW Project is harmful or inconsistent with community priorities 26 Agenda Page 102
Workforce Development
CPA will use its traditional workforce development criteria with a slight modification to address existing facilities
The project is a union site or will use targeted-hire, union labor, or multi-trade project labor agreements (including requirements for state-apprenticeship graduates) HIGH
The project is not a union site or does not have a labor agreement, but can demonstrate prevailing wage, union labor, and targeted hire commitments MEDIUM
The project does not demonstrate prevailing wage, union labor, and targeted hire commitments
LOW
27 Agenda Page 103