Where CLECA Stands
Four decades of participation in California energy proceedings have produced a consistent, technically grounded record. These are the positions CLECA carries into the CPUC, CAISO, CEC, CARB, and the Legislature — each drawn directly from our filings.
— CLECA Opening Testimony, PG&E 2027 General Rate Case (A.25-05-009), February 2026
Industrial Rate Affordability & Competitiveness
California industrial electricity rates are roughly 300 percent of the rates in neighboring states. CLECA argues that gap drives emissions leakage, undermines the state's climate goals by exporting production, and threatens the manufacturing base whose decarbonization the state says it wants. Every CLECA position is, at bottom, an application of that frame to a specific regulatory venue. This position informs every other position CLECA takes.
Read the Position →Resource Adequacy & Slice of Day
CLECA supports a reformed Resource Adequacy program, including the Slice of Day framework, but argues the Commission has implemented the reform in ways that systematically devalue the industrial demand-response resources its members operate. The fight runs from the central procurement debate in R.17-09-020 through D.21-06-029 and D.23-06-029 into the current R.25-02-005 record.
Read the Position →Demand Response & the Base Interruptible Program
The Base Interruptible Program (BIP) is the principal way CLECA members provide grid services: industrial customers commit to curtail load on short notice in exchange for capacity payments. CLECA defends BIP as among the most cost-effective Resource Adequacy resources available, and has fought decisions that erode its economic foundation across more than eighty BIP filings.
Read the Position →Rate Design & Dynamic Rates: The Large Power Dynamic Rate
CLECA argues that SCE's Large Power Dynamic Rate (LPDR) should be authorized and implemented separately from the broader Standard Dynamic Rate, preserving the bilateral subscriptions, sigmoidal price curves, and ten-year contract term that make it work for large industrial customers. Holding the LPDR to the SDR billing-system rebuild would deprive industrial customers of a dynamic-rate option for years longer than necessary.
Read the Position →Cost Allocation & General Rate Cases
CLECA participates in every recent PG&E and SCE General Rate Case Phase 2, advocating that marginal cost be measured on a long-run basis using methods the Commission has applied for decades. Cost allocation is not just an engineering exercise: methods that push cost responsibility onto industrial classes without a cost-causation basis worsen the affordability gap and accelerate emissions leakage.
Read the Position →Direct Access & the PCIA Exit Fee
The Power Charge Indifference Adjustment (PCIA) is the exit fee paid by CCA and Direct Access customers to keep bundled customers indifferent to departed load. With roughly half its accounts bundled and half unbundled, CLECA is a distinctively even-handed advocate on PCIA design — opposing cost shifts in either direction and supporting an eventual PCIA sunset.
Read the Position →Wildfire Cost Recovery & PSPS Notification
Industrial customers cannot safely shut down a steel mill or cement kiln on a few hours' notice, so CLECA argues transmission-level customers need 48 to 72 hours of advance PSPS notification. On the cost side, CLECA presses for robust oversight of AB 1054 securitization and for distribution-based allocation of wildfire cost recovery — allocation that follows cost causation — rather than equal-cents-per-kilowatt-hour.
Read the Position →The Avoided Cost Calculator
The Avoided Cost Calculator is the model the CPUC uses to value distributed energy resources — including the industrial demand response CLECA members provide. When the model undervalues capacity, every program built on it is undervalued too. CLECA has litigated the ACC's methodology across seventy positions since 2018.
Read the Position →Industrial Decarbonization & EITE Retention
CLECA's newest posture is affirmative: not just defending industrial customers against new cost burdens, but reforming rate design so that industrial decarbonization — electrification, process heat recovery, carbon capture — is economically possible in California.
Read the Position →CARB Cap-and-Invest & the Manufacturing Decarbonization Incentive
California extended and renamed its carbon market through 2045 under AB 1207. CLECA fought for — and largely won — allowance allocation and Manufacturing Decarbonization Incentive rules that protect trade-exposed manufacturers while making real industrial decarbonization investable.
Read the Position →The Regulatory Vocabulary
California energy regulation runs on acronyms. The short glossary below covers the terms that appear most often in CLECA’s positions and filings.
CPUC (California Public Utilities Commission)
The state agency that regulates California's investor-owned electric utilities, including PG&E, SCE, and SDG&E. Most CLECA advocacy takes place in CPUC rulemakings (R.), applications (A.), and decisions (D.).
Resource Adequacy (RA)
The CPUC program requiring load-serving entities to procure enough capacity to keep the grid reliable. RA rules determine how the grid values the curtailable load industrial customers provide.
Slice of Day
The reformed Resource Adequacy framework, adopted in D.22-06-050, that measures capacity obligations in twenty-four hourly windows rather than a single monthly showing.
Base Interruptible Program (BIP)
An emergency demand response program in which large industrial customers commit to curtail load on short notice in exchange for capacity payments. BIP accounts for 804 MW of roughly 1,500 MW of California supply-side demand response.
Demand Response (DR)
Programs and rates that compensate customers for reducing electricity use when the grid needs it. Industrial demand response is fast, fuel-independent, all-weather, and zero-carbon.
Power Charge Indifference Adjustment (PCIA)
The exit fee paid by Community Choice Aggregation and Direct Access customers so that customers who leave utility bundled service neither escape the costs of generation procured on their behalf nor subsidize those who remain.
Direct Access (DA)
Retail electric service purchased from a competitive Electric Service Provider rather than the incumbent utility. SB 237 expanded California's Direct Access cap by 4,000 GWh.
Community Choice Aggregator (CCA)
A local government entity that procures electricity for customers in its territory, with the incumbent utility continuing to deliver it. CCA customers pay the PCIA exit fee on departed load.
Avoided Cost Calculator (ACC)
The CPUC model used to value distributed energy resources, including demand response. If the ACC undervalues capacity, downstream programs such as BIP see their cost-effectiveness understated.
General Rate Case (GRC)
The CPUC proceeding that sets a utility's finances: Phase 1 determines the total revenue requirement, and Phase 2 determines cost allocation and rate design — how that revenue is split across customer classes.
Public Safety Power Shutoff (PSPS)
A preemptive utility de-energization to reduce wildfire ignition risk. CLECA advocates 48 to 72 hours of advance notification for transmission-level industrial customers, whose processes cannot be safely shut down on short notice.
Emissions-Intensive Trade-Exposed (EITE)
The cap-and-trade designation, adopted by CARB and reflected in CPUC D.12-12-033, for industries with high emissions intensity and exposure to out-of-state competition. EITE protection exists to prevent emissions leakage.
Effective Load Carrying Capability (ELCC)
A methodology for measuring how much a resource contributes to grid reliability. CLECA argues its application to demand response misaligns CPUC and CAISO programs and understates industrial DR value.
Long-Run Marginal Cost (LRMC)
The cost basis CLECA advocates for allocating utility costs across customer classes in GRC Phase 2 — measuring what utility service actually costs to provide over time, so allocation follows cost causation.
Large Power Dynamic Rate (LPDR)
An SCE dynamic rate designed for large industrial customers, filed in A.24-06-014, featuring bilaterally negotiated subscriptions, sigmoidal price curves, and a ten-year contract term. CLECA argues it should be approved separately from the broader Standard Dynamic Rate.
CAISO (California Independent System Operator)
Operates California's wholesale electricity grid and markets. CLECA participates in CAISO stakeholder initiatives — including D-DEMI — where market rules for demand response are set.
CARB (California Air Resources Board)
The state's climate regulator, administering the Cap-and-Invest Program. CLECA engages CARB rulemakings on EITE allowance allocation and the Manufacturing Decarbonization Incentive.
RDRR (Reliability Demand Response Resource)
The CAISO market category through which emergency demand response like BIP is dispatched. Its trigger, startup-cost, and minimum-on-time rules are recurring CLECA issues.
TOU (Time-of-Use Rates)
Rates that vary by time period to reflect when power costs more to supply. Large industrial customers take service on TOU rates such as TOU-8; dynamic rates go further with hourly pricing.
MDI (Manufacturing Decarbonization Incentive)
A new Cap-and-Invest mechanism reserving roughly 118 million allowances (~$4 billion) for industrial facilities undertaking major on-site decarbonization projects, with applications opening June 2027.
ROWE (Regional Organization for Western Energy)
The independent non-profit created through the Pathways Initiative to govern voluntary west-wide electricity markets. CLECA advocated for designated Large C&I representation in its governance.
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