Item 6
1 VALLEY CLEAN ENERGY ALLIANCE
Staff Report – Item 6
To: Board of Directors
From: Keyes & Fox, Regulatory Consultant
Subject: Regulatory Monitoring Report – Keyes & Fox
Date: October 8, 2026
______________________________________________________________________________ Please find attached Keyes & Fox’s September 2026 Regulatory Memorandum dated September 30, 2026 an informational summary of the key California regulatory and compliance-related updates from the California Public Utilities Commission (CPUC).
Attachment: Keyes & Fox Regulatory Memorandum dated September 30, 2026
1 Valley Clean Energy Alliance
Regulatory Monitoring Report
To: Valley Clean Energy Alliance (VCE) Board of Directors From: Sheridan Pauker, Partner, Keyes & Fox LLP
Jason Hoyle, Director of Research, EQ Research LLC
Subject: Monthly Regulatory Update
Date: September 30, 2026
Keyes & Fox LLP and EQ Research LLC are pleased to provide VCE’s Board of Directors with this informational memo describing key California regulatory and compliance-related updates from the California Public Utilities Commission (CPUC) over the past month.
PCIA/ERRA Reform
Background: This Rulemaking considers updates and reforms to the ERRA and Power Charge Indifference Adjustment (PCIA) rules and processes with the objectives of improving existing rules, mitigating rate volatility, and ensuring indifference among bundled and departing customers. Track 1 concluded in 2025, Track 2’s scope was revised to consider issues related to the valuation of pre-2019 RECs arising from 2026 ERRA forecast proceedings, and Track 3 will address broader issues in Track 3A and Track 3B.
Recent Developments: On September 22, the CPUC issued D.26-09-047 resolving Track 2 issues and setting the value of pre-2019 banked RECs at zero dollars.
Analysis: A zero-dollar valuation for pre-2019 banked RECs means that CCA customers who departed IOU generation service after 2019 paid for the RECs at the time they were created and will receive no compensation from the remaining IOU bundled customers who will now use them to reduce RPS compliance costs.
Next Steps: A staff report or proposal in Track 3A is expected in October, followed by party proposals in late 2026/early 2027, and a Q1 2027 workshop.
Additional Information: D.26-09-047 (Sep. 22, 2026); Scoping Memo and Ruling (Aug. 18, 2026); Ruling (Jun. 19, 2026); Ruling on hearing (May 28, 2026); Track 3 Workshop Ruling (May 13, 2026); Ruling (Apr. 24, 2026); Ruling and Staff Report (Mar. 27, 2026); Ruling (Feb. 20, 2026); Amended Scoping Memo (Feb. 3, 2026); Ruling (Dec. 26, 2025); CalCCA Petition for Writ of Review (Dec. 1, 2025); D.25-06-049 (Jun. 27, 2025); Scoping Memo (Apr. 8, 2025); ALJ Ruling (Mar. 21, 2025); Ruling & Staff Report on RA MPB (Feb. 26, 2025); OIR (Feb. 26, 2025); Docket No. R.25-02- 005.
RA Rulemaking
Background: This proceeding is the successor to R.23-10-011, and it will address the 2027 and 2028 RA compliance years, local RA obligations for the 2027-2029 and 2028-2030 compliance years, further refinements to the 24-hour Slice-of-Day (SOD) framework. Track 1 considered accreditation for long-duration energy storage, unforced capacity outage rates for thermal resources, accreditation for solar and wind resources, and transactability within the SOD framework during the first half of 2026. Track 2 addresses the planning reserve margin and coordination with the integrated resource plan proceeding.
Recent Developments: A September 25 Ruling modified the Track 2 schedule extending the deadlines for party proposals and comments on the Planning Reserve Margin (PRM) and Loss of Load Expectation (LOLE) studies.
Analysis: N/A.
Next Steps: A final PRM recommendation for the 2028-2029 RA years will be included in the final report from Energy Division, expected to be released in October. Party proposals on the Final 2028 LOLE studies and PRM are due November 2.
Additional Information: Ruling (Sep. 25, 2026); Scoping Memo and Ruling (Aug. 25, 2026); Ruling and Draft Loss of Load Expectation Study for 2028 (Aug. 17, 2026); D.26-07-008 (Jul. 2, 2026); Scoping Memo (Dec. 12, 2025); OIR (Oct. 15, 2025); Docket No. R.25-10-003.
2 PG&E 2027 ERRA Forecast
Background: The annual Energy Resource and Recovery Account (ERRA) forecast proceedings establish the amount of the Power Charge Indifference Adjustment (PCIA) and other non-bypassable charges (NBCs) for the following year, as well as fuel and purchased power costs associated with serving bundled customers that utilities may recover in rates.
Recent Developments: On September 22, the CPUC issued a Notice of the evidentiary hearing scheduled for October 2.
Analysis: N/A.
Next Steps: The evidentiary hearing is scheduled for October 2. The Fall Update is due October 16 to be followed by a proposed decision in November with issuance of a final decision in late 2026.
Additional Information: Notice (Sep. 22, 2026); PG&E AL 7972-E (Aug. 28, 2026); Scoping Memo and Ruling (Aug. 3, 2026); Ruling (Jun. 18, 2026); Application (May 15, 2026); Docket No. A.26-05-007.
IRP Rulemaking (2025)
Background: This proceeding governs the biennial Integrated Resource Plan (IRP) process, including load serving entity (LSE) procurement requirements, the establishment of a variety of state- and LSE-level load and procurement forecasts, greenhouse gas (GHG) reduction targets, ongoing reliability obligations, and the Commission’s oversight of the IOUs’ bundled procurement plans. This proceeding continues the work of R.20-05-003 and will be the primary forum for most future CPUC work on the Reliable and Clean Power Procurement Program framework (RCPPP).
Recent Developments: Opening comments on IRP filings were submitted on September 21.
Analysis: Comments on IRP filings raised concerns about aggregation of LSE plans to inform development of the Integrated Energy Policy Report (IEPR) resource portfolio for the next IRP cycle because LSE plans in the aggregate would procure more out-of-state wind and geothermal resources than are possible to import into California. Additional concerns were raised with respect to uncertainty in how the IRP portfolios will be integrated into the forthcoming RCPPP and the extent to which procurement requirements may be established based on near-term IRP portfolios.
Next Steps: Comments on the Bundled Procurement Plans (BPPs) are due November 13, and reply comments are due November 30. A proposed decision on the IOUs’ proposed BPP updates is expected in Q4. Reply comments on the Transmission Planning Process portfolios are due October 12.
Additional Information: Ruling (Aug. 31, 2026); 2030-2031 ELCC Study and Staff Memo (Aug. 28, 2026); Ruling (Aug. 17, 2026); VCE’s 2026 IRP (Jul. 29, 2026); Ruling on RCPPP (Jul. 13, 2026); Scoping Ruling (Oct. 28, 2025); OIR (Jul. 2, 2025); Docket No. R.25-06-019.
PG&E 2027 Phase 1 GRC
Background: Phase 1 General Rate Case (GRC) proceedings determine PG&E’s overall revenue requirement and classification of costs by function for a set period (in this case, 2027-2030).
Recent Developments: A September 23 Ruling modified the schedule for the Update Phase and cancelled the evidentiary hearing for the Update Phase. Also on September 23, the CPUC issued a Proposed Decision authorizing PG&E to recover up to $456 million through an interim rate increase beginning January 1, 2027. The increase will remain in effect until a final decision concluding this proceeding is implemented.
Analysis: The Proposed Decision will increase PG&E’s electric distribution revenue requirement by $397 million.
Next Steps: The Proposed Decision authorizing PG&E’s interim rate increase may be heard as soon as the Commission’s October 8 meeting. Update Phase Opening briefs are due October 7 and reply briefs are due October 28.
A proposed decision on Phase 1 is expected in March 2027. The Proposed Decision authorizing an interim rate increase may be heard as early as the October 29 Commission meeting. Comments on the proposed decision are due October 12 and reply comments are due October 19.
Additional Information: Proposed Decision (Sep. 23, 2026); Ruling (Sep. 23, 2026); Ruling (Aug. 11, 2026); Proposed Decision (Aug. 4, 2026); Ruling (Jun. 18, 2026); Ruling (Apr. 24, 2026); Ruling on schedule (Feb. 26, 2026); Amended Scoping Memo and Ruling (Jan. 26, 2026); Scoping Memo and Ruling (Jul. 31, 2025); Application (May 16, 2025); Docket No. A.25-05-009.
PG&E 2023 Phase 2 GRC
Background: Phase 2 General Rate Case (GRC) proceedings determine PG&E’s marginal cost of service and revenue requirement allocation among customer classes for a set period (in this case, 2023-2026). This proceeding is also considering extension of existing dynamic rate pilots (including VCE’s AgFIT pilot, now expanded across PG&E territory) and other real-time pricing (RTP) pilots as well as post-pilot dynamic rates required by the CEC’s Load Management Standards.
Recent Developments: On September 24, an ALJ Ruling directed PG&E to submit revised workpapers supporting PG&E’s dynamic rate pilot extension proposal by October 16 in the Dynamic Rate Options track.
Analysis: PG&E’s revised workpapers will standardize the presentation of data underlying its dynamic rate design to allow cross-utility comparisons and allow parties to test the model’s rate components, such as marginal cost inputs,
3 distribution capacity, and customer bill impacts, including load data. The revisions will enable meaningful evaluation of PG&E’s Stop-Gap Interim RTP Pilot Extension Proposal.
Next Steps: Rebuttal testimony in the Primary Track is due October 9, and a meet and confer will be held October 19. A Ruling on the need for evidentiary hearings in the Primary Track is expected November 20. Testimony on PG&E’s RTP Pilot stop-gap proposal is due September 30 for CalAdvocates and October 30 for other intervenors.
Additional Information: Ruling (Sep. 24, 2026); Fourth Status Report (Sep. 4, 2026); Ruling (Jul. 22, 2026); Ruling modifying schedule (Jun. 17, 2026); PG&E Supplemental Testimony (Jun. 8, 2026); Motion for bifurcated track (Nov. 6, 2025); PG&E Testimony and Change Tables (Oct. 29, 2025); Scoping Memo (Mar. 21, 2025); Application (Sep. 30, 2024); Docket No. A.24-09-014.
Demand Response Enhancements
Background: This proceeding seeks to enhance demand response (DR) resources by updating guiding principles, policies, and data system and process requirements. Demand response development is closely connected to the implementation of dynamic rates and real-time pricing (RTP), similar to VCE’s AgFIT Pilot, but across all customer classes.
Recent Developments: On September 25, the CPUC issued a Proposed Decision (PD) authorizing bridge funding maintaining the 2027 funding levels for the IOUs’ 2028-2029 DR programs and modifying the deadline for filing the next IOU DR applications to November 1, 2028 for program years 2030-2034.
Analysis: Bridge year funding will ensure program continuity while additional program refinements and related proceedings are resolved for incorporation into the next program application filings.
Next Steps: The PD may be heard as early as the October 29 Commission meeting. Comments on the PD are due October 15 and reply comments are due October 20.
Additional Information: Proposed Decision (Sep. 25, 2026); Ruling (Jul. 7, 2026); Joint Case Management Statement (Jun. 11, 2026); Ruling (Apr. 8, 2026); D.26-03-016 on Flex Alert Funding (Mar. 26, 2026); Ruling on Staff Proposal on IOUs Bridge Year Funding (Mar. 10, 2026); Scoping Memo and Ruling (Feb. 12, 2026); OIR and Guiding Principles (Sep. 29, 2025); Docket No. R.25-09-004.
Advanced Electric Rate Design
Background: This proceeding will establish advanced electric rate design policies, including rate structures and components such as time-of-use (TOU), demand charges, and the design of demand flexibility and dynamic rates.
Additionally, rate design options to support electrification for large commercial and industrial (C&I) customers, as well as rate design options for data centers and other large load customers will also be addressed.
Recent Developments: On September 3, an ALJ Ruling directed the IOUs to file a Joint Proposal addressing Assembly Bill 2109’s requirements for the implementation of the Industrial Process Heat Recovery technology customer exemption from nonbypassable charges. On September 22, the CPUC issued a Scoping Memo and Ruling establishing four tracks for the proceeding and a tentative 24-month timeframe. Track 1 will address data center tariffs, contracts, exit fees and customer protections, Track 2 will address residential rate modernization including TOU timeframes, inclusion of wildfire costs as fixed costs and adjustment to the Base Services Charge (formerly the income-graduated fixed charge), Track 3 will address modernization of non-residential rates, and Track 4 will address dynamic rates including marginal cost inputs, transmission revenue requirements and other rate design elements.
Analysis: Track 4 will address dynamic rates and the marginal cost framework, including results of expanded pilots such as VCE’s AgFIT Pilot.
Next Steps: The Joint IOU Proposal is due October 19, comments on the Joint Proposal are due November 18, and reply comments are due December 3. A Track 1 workshop on large load tariffs is planned for October. A Track 2 staff proposal is expected in Q1 2027.
Additional Information: Scoping Memo and Ruling (Sep. 22, 2026); Ruling (Sep. 3, 2026); Ruling (May 22, 2026); OIR (Apr. 10, 2026); Docket No. R.26-04-009.
PG&E 2024 ERRA Compliance
Background: The annual ERRA Compliance proceeding reviews the utility’s compliance with CPUC-approved standards for generation-procurement and cost recovery activity occurring in the prior year, such as energy resource contract administration, least-cost dispatch, fuel procurement, and balancing account entries.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: The parties anticipate the next step in this proceeding will be the issuance of a Proposed Decision.
Additional Information: Joint Settlement Motion (May 22, 2026); Ruling (Feb. 2, 2026); Ruling requiring supplemental testimony (Dec. 22, 2025); Joint Status Conference Statement (Nov. 25, 2025); Scoping Memo and Ruling (May 2, 2025); PG&E 2024 ERRA Compliance Application (Feb. 28, 2025); Docket No. A.25-02-013.
4 PG&E 2025 ERRA Compliance
Background: The annual ERRA Compliance proceeding reviews the utility’s compliance with CPUC-approved standards for generation-procurement and cost recovery activity occurring in the prior year, such as energy resource contract administration, least-cost dispatch, fuel procurement, and balancing account entries.
Recent Developments: Intervenor testimony was filed on September 11.
Analysis: N/A.
Next Steps: A joint status conference is scheduled for October 30, and a proposed decision is expected in 2Q 2027.
Additional Information: Scoping Memo and Ruling (May 26, 2026); Application (Feb. 27, 2026); Docket No. A.26-02- 019.
Climate Credit OIR
Background: This rulemaking will explore potential approaches to supporting customer affordability through cap-and-trade program proceeds returned to electric consumers via the state Climate Credit. The proceeding is divided into two tracks, and the current Track 1 has a Phase 1A and a Phase 1B. Phase 1A addressed the timing of the distribution of climate credits in 2026 and Phase 1B addresses broader changes in the residential Climate Credit.
Recent Developments: Party proposals for changes to the Climate Credit were filed on September 14. The Joint Proposal of CalCCA and Southern California Edison recommended the Commission maintain the status quo or, alternatively, provide customers enrolled in the CARE or FERA programs a higher-value Climate Credit up to twice the value of the credit received by other customers. A September 25 Ruling provided directions for utility implementation assessments of party proposals.
Analysis: N/A.
Next Steps: Utility implementation assessments on party proposals are due October 9, and a proposed decision is expected in Q1 2027.
Additional Information: Ruling (Sep. 25, 2026); Joint Proposal (Sep. 14, 2026); Ruling (Aug. 17, 2026); Ruling (Jul. 9, 2026); D.26-04-036 (May 4, 2026); D.26-03-013 (Mar. 25, 2026); Scoping Memo and Ruling (Feb. 3, 2026); Ruling (Oct. 31, 2025); OIR (Aug. 20, 2025); Docket No. R.25-07-013.
Distribution Interconnection Rules
Background: This rulemaking will review and refine distribution-level interconnection rules under Electric Rule 21, particularly those for distributed energy resources (DER) for PG&E, SCE, SDG&E and the small and multijurisdictional electric utilities. Phase 1 will consider interconnection timelines and evaluation screens, and the interconnection process for resources not interconnecting under the net billing or net metering tariffs. Subsequent phases are undefined at present, but may address issues related to interconnection processes, pathways, and standards; sharing of upgrade costs; net billing and net metering interconnections; among other topics.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: A scope for Phase 2 will be developed based on comments and workshop feedback from Phase 1.
Additional Information: Ruling (Jul. 14, 2026); Resolution E-5436 (May 4, 2026); Scoping Memo and Ruling (Mar. 3, 2026); OIR (Jul. 25, 2025); Docket No. R.25-08-004.
Building Decarbonization
Background: This proceeding explores reduction of greenhouse gas (GHG) emissions associated with energy use in buildings. The current Phase 4 will consider whether modifications to electric line extension rules would assist under-resourced customers, electric baseline allowance modifications to encourage building decarbonization, and new programmatic approaches to building decarbonization.
Recent Developments: On September 25, an ALJ Ruling provided notice of consultations held with Tribal representatives and provided parties an opportunity to comment on notes (Attachment 1, Attachment 2) from consultations.
Analysis: The consultations included discussion of either modifying utility tariffs or an advice letter process to provide Tribes the required opportunity for consultation about project activities on Tribal lands.
Next Steps: Comments on notes from Tribal consultations are due October 5. A proposed decision on the amended scope is expected in Q4 2026.
Additional Information: Ruling (Sep. 25, 2026); Ruling (Aug. 14, 2026); Scoping Ruling (Jul. 23, 2026); (Ruling on Extension (Apr. 7, 2026); Scoping Ruling (Mar. 30, 2026); PG&E AL 7642-E (Jul. 15, 2025); D.25-06-034 (Jun. 20, 2025); PG&E AL 5074-G/7615-E (Jun. 5, 2025); Scoping Memo and Ruling (Jul. 1, 2024); OIR (Feb. 8, 2019); Docket No. R.19-01-011.
5 RPS Rulemaking
Background: This proceeding addresses ongoing Renewables Portfolio Standard (RPS) requirements, including legislative mandates, and other matters related to the purchase of renewable energy. This proceeding is the forum for review of VCE’s RPS Procurement Plan and RPS Compliance reports.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: A proposed decision on Draft RPS Plans is expected in Q4 2026.
Additional Information: VCE’s Final Compliance Report for CP4 (Aug. 24, 2026); Final Resolution E-5457 (Jun. 12, 2026); VCE Draft 2026 RPS Procurement Plan (Jun. 12, 2026); Scoping Memo and Ruling (May 9, 2024); OIR (Feb. 1, 2024); Docket No. R.24-01-017.
City and County of San Francisco Municipalization
Background: The City and County of San Francisco (City or CCSF) filed this Petition in 2021 for a determination by the CPUC of just compensation for acquisition by the City of PG&E property (PG&E distribution and transmission assets to serve San Francisco) pursuant to Public Utilities Code §1401-1421.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: PG&E’s opening testimony is due October 20 and intervenor testimony is due December 22.
Additional Information: CCSF Notice of Testimony (Apr. 20, 2026); Ruling (Apr. 2, 2026); PG&E Motion (Mar. 30, 2026); Ruling (Mar. 10, 2026); Ruling (Feb. 18, 2026); Ruling on CCSF Motion to Compel (Jan. 12, 2026); D.25-10-039 (Nov. 6, 2025); Amended Scoping Memo (Jul. 1, 2025); Petition (Jul. 27, 2021); Docket No. P.21-07-012.
PG&E Diablo Canyon 2027 & VPF
Background: During the period of extended operations for the Diablo Canyon Nuclear Plant, PG&E submits an annual application forecasting its costs, market revenues from CAISO, net costs allocated to ratepayers of each large IOU, and its plan for use of volumetric performance fees (VPFs) in the upcoming calendar year.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: A proposed decision is expected in late October.
Additional Information: Joint Meet and Confer Report (Aug. 28, 2026); Scoping Memo and Ruling (Jun. 16, 2026); Application (Mar. 27, 2026); Docket No. A.26-03-031.
PG&E Billing System Modernization
Background: This proceeding addresses PG&E’s plan to upgrade its legacy billing system, some portions of which date back to the mid-1990s. PG&E proposed a three-stage upgrade that would ultimately be complete in Q4 2029 and cost an estimated $761.3 million.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: A ruling on the August 25 Motion to reopen the record to allow the Joint CCAs to submit a breakdown of the $24 million incremental cost forecast associated with the proposals in the Partial Settlement Agreement filed July 9 is expected.
Additional Information: Motion (Aug. 25, 2026); Joint Motion (Jul. 9, 2026); Joint Case Management Statement (May 7, 2026); (Ruling (Mar. 10, 2026); D.25-08-008 (Aug. 19, 2025); Joint CCA Testimony (Jun. 30, 2025); Scoping Memo (Mar. 27, 2025); Application (Oct. 23, 2024); Docket No. A.24-10-014.
Disconnections and Reconnections
Background: This proceeding addresses approaches to the disconnection and reconnection of electric customers with a focus on improving energy access and cost containment.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: A ruling or proposed decision on the joint emergency Motion is expected.
Additional Information: D.26-08-009 (Aug. 20, 2026); Ruling (Jun. 4, 2026); Joint Emergency Motion (May 28, 2026); PG&E Arrearage Management Plan Annual Report (May 1, 2026); CBO Pilot Recommendations (Dec. 11, 2025); Ruling granting extension (Oct. 21, 2025); Ruling (Oct. 13, 2025); D.25-06-012 (Jun. 17, 2025); Phase 2 Scoping Memo (Jul. 15, 2022); OIR (Jul. 20, 2018); Docket No. R.18-07-005.
6 EV Rates & Infrastructure
Background: This rulemaking is the successor to R.18-12-006 and will focus on issues related to 1) timely energization of electric vehicle (EV) charging, 2) transportation electrification grid planning to support charging infrastructure deployment, 3) deployment of behind-the-meter (BTM) charging infrastructure to support state goals, 4) vehicle-grid integration (VGI), and 5) ongoing transportation electrification policy development and collaboration.
Recent Developments: No recent developments.
Analysis: N/A.
Next Steps: N/A.
Additional Information: VGI Workshop Report (May 27, 2026); PG&E AL 7884-E Technical Assistance Program Handbook (Apr. 6, 2026); Resolution E-5434 (Feb. 27, 2026); D.25-12-005 (Dec. 5, 2025); Ruling (Oct. 14, 2025); Ruling (Oct. 1, 2025); Joint Report on the CPUC’s Submetering and Telematics Workshop (Jun. 16, 2025); Scoping Memo and Ruling (Apr. 12, 2024); OIR (Dec. 20, 2023); Docket No. R.23-12-008.
Other Dockets
The following table identifies other tracked dockets that are closed or inactive.
Docket Name Status
R.19-09-009 Microgrids
D.24-11-004 adopting implementation rules for multi-property microgrid tariffs closed the proceeding. An Application for Rehearing was denied by D.25-06- 067, and CalSSA’s Petition for Modification remains pending.
R.23-03-007 Wildfire Fund NBC
2024-2026
A September 9 Ruling allows comments on the Department of Water Resources’ 90-day Notice Regarding 2027 Wildfire Non-bypassable Charge (NBC), which estimates the 2027 Wildfire NBC at $5.42/MWh, a slight decrease from the 2026 charge of $5.91/MWh.