Filings & Proceedings
CLECA has filed hundreds of testimony submissions, comments, protests, and briefs across CPUC, CAISO, CEC, CARB, and west-wide proceedings. A selection of recent filings is below; the complete record is available through each agency’s docket system.
Briefs & Settlement Comments in PG&E Rule 30 Proceeding
CLECA filed opening and reply briefs and comments contesting a partial settlement in PG&E’s Electric Rule 30 proceeding — arguing that risk-mitigation requirements designed for speculative data center load should not apply to Decarbonizing and EITE existing customers, and that the settlement’s customer-data disclosure provisions violate Public Utilities Code § 8380.
Joint Opposition to PG&E Interim Rate Recovery
With EPUC and Indicated Shippers, CLECA opposed PG&E’s motion to begin recovering its contested 2027 General Rate Case revenue requirement on an interim basis — arguing the claimed savings rest on an unadjudicated $1.18 billion revenue requirement and that PG&E’s affordability analysis ignores non-residential customers entirely.
Supplemental Rebuttal Testimony on the Large Power Dynamic Rate
Sam Harper’s supplemental rebuttal urges the Commission to authorize the Large Power Dynamic Rate now, on a separate track from the Standard Dynamic Rate billing-system rebuild — preserving bilateral subscriptions, ten-year terms, BIP dual participation, and retail choice switching rights for large industrial customers.
Comments on the 2026 Avoided Cost Calculator Staff Proposal
CLECA’s comments oppose the staff proposal’s pivot to a single solar-plus-battery hybrid for avoided generation capacity, press for a diverse IRP-representative resource mix, a higher generation-capacity cost floor, and application of the GHG cap inside — not on top of — the integrated calculation.
Comments on the Advanced Electric Rate Design OIR
CLECA’s opening and reply comments frame the new rate design rulemaking around implementing AB 2109’s process heat recovery exemption on an expedited parallel track, keeping data-center tariff requirements off traditional industrial customers, and adding EITE customer retention as a scoped issue consistent with AB 1207.
Comments on the 15-Day Modifications
CLECA urged timely adoption of the 15-Day Modifications — supporting the improved Cap Adjustment Factor trajectory and the restructured Manufacturing Decarbonization Incentive (flat 0.8 modifier, six-to-seven-year spending window, June 2027 application date) as the settled framework EITE facilities need to commit decarbonization capital.
Agency Docket Systems
Where We Stand
Every filing applies a consistent set of positions CLECA has developed across four decades: cost-causation rate design, long-run marginal cost methodology, workable demand response, and affordability for California’s manufacturing base.
Explore Our Policy Positions