Filings Archive
Earlier CLECA filings across CPUC, CAISO, CEC, CARB, and west-wide proceedings. The most recent filings are on the Filings page; the complete record is available through each agency's docket system.
Opening Comments on the Demand Response Staff Proposal
CLECA’s comments on the demand response rulemaking staff proposal carry forward its defense of reliability-oriented industrial demand response and workable program design for Base Interruptible Program participants.
Comments on the D-DEMI Straw Proposal & Issue Paper
In CAISO’s Demand and Distributed Energy Market Integration initiative, CLECA supported the Track 1 export-zeroing reform while strongly objecting to Track 2’s exclusion of RDRR minimum-on-time and startup-cost reform — the market design fixes industrial demand response needs to be dispatched accurately.
Comments on the Initial Statement of Reasons
CLECA’s ISOR comments opposed a Cap Adjustment Factor trajectory that would drop industrial allocation coverage to roughly 28% by 2035, urged suspension of CAF reductions until a border carbon adjustment exists, and pressed for a technology-neutral, workable Manufacturing Decarbonization Incentive.
Testimony in PG&E General Rate Case
CLECA witnesses submitted testimony challenging PG&E’s proposed 2027 General Rate Case, addressing A&G costs, capital expenditure justification, headcount efficiency benchmarks, and rate allocation impacts on industrial customers.
Comments on West-Wide Regional Organization
CLECA submitted detailed comments on the Pathways Initiative Step 2 proposal, supporting a designated C&I sector on the Stakeholder and Nominating Committees and advocating for an independent market monitor.
Testimony in SCE General Rate Case
CLECA filed joint ratepayer testimony in Southern California Edison’s Test Year 2025 General Rate Case, addressing rate design, dynamic pricing implementation, and affordability metrics for large industrial customers.
Comments on the D-DEMI Discussion Paper
CLECA identified its priority problem statements in CAISO’s demand and distributed energy market integration effort — RDRR startup costs, minimum on-time reform, bid-interval alignment, and partial outage reflection — and proposed a phased near-term/mid-term/long-term sequencing for 2026 through 2030.
Comments on the October 2025 Workshop
CLECA’s workshop comments supported the stronger industrial allocation concept, urged CARB to suspend Cap Adjustment Factor reductions until a border carbon adjustment is implemented, and laid out design principles for the then-new Manufacturing Decarbonization Incentive.
Comments on Working Group Session 10
CLECA proposed including RDRR startup costs in dispatch through a near-term two-tier tariff approach and adopting the 255-minute minimum on-time aligned with CAISO’s short-term unit commitment — improving the accuracy of economic dispatch for reliability demand response.
Reply Comments in Transportation Electrification OIR
CLECA opposed further ratepayer-funded transportation electrification spending on top of roughly $2.8 billion already authorized, arguing behind-the-meter charging infrastructure should not be ratepayer-funded given federal incentives, and that EV rate design belongs in utility-specific marginal-cost-based applications.
Reply Comments on Resource Adequacy Reform
CLECA opposed setting the Transmission Loss Factor adder for demand response to zero, showing that a zero TLF would inaccurately undercount demand response supply during tight system conditions — a position supported by nearly all stakeholders.
Comments on INDIGO Program Design
CLECA urged the CEC to expand INDIGO funding eligibility to efficiency projects in heat-intensive industries where full electrification is not yet feasible, and to fund projects rather than assessments.
Comments on California Demand Response Vision
CLECA proposed additions to the joint CPUC–CEC–CAISO Demand Response Vision, including explicit reference to reliability emergency conditions as a valid DR deployment trigger, consistent with longstanding BIP program design.
Comments in the Affordability Rulemaking
CLECA praised Itemized Lists of Revenue Requirements as transparency progress addressing “death by a thousand cuts” from fragmented rate approvals, and asked for aggregated customer-class impacts and benchmark comparisons of nonresidential rates against neighboring western states.
Comments on Supply-Side Demand Response Counting
CLECA advocated its LIP+LOLE qualifying capacity methodology for supply-side demand response, arguing the CPUC — not the CAISO — determines qualifying capacity for resources, and that demand response should be RAAIM-exempt like wind and solar.
Comments on PG&E 2022 ERRA Forecast Proposed Decision
CLECA opposed 12-month amortization of the ERRA undercollection, seeking 24 months to limit rate shock — holding the system average bundled increase to roughly 10% instead of cumulative increases above 20%.
Comments on Industrial Decarbonization Funding
CLECA told the CEC that cost is a significant barrier to industrial decarbonization, seeking 50–75% match funding, stable review guidelines, and a two-track review model for industrial projects.
Reply Testimony on Summer Reliability Procurement
CLECA testimony argued emergency procurement should not proceed “at any cost,” that the August 2020 heatwave was a 1-in-30-year event against a 1-in-10 reliability standard, and that RDRR and BIP should be dispatched as load-modifying reliability resources consistent with their tariffs.
Joint Comments on EITE Climate Credits
With the Direct Access Customer Coalition, CLECA urged the Commission to maintain Cap-and-Trade climate credits to Emissions-Intensive, Trade-Exposed manufacturers without change — because keeping energy-intensive manufacturing in California prevents higher-emission out-of-state production.