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.
PG&E Rule 30: Briefs, Settlement Comments & the FERC Large-Load Question
CLECA filed opening and reply briefs and contested a partial settlement in PG&E’s Electric Rule 30 proceeding, arguing that risk-mitigation requirements designed for speculative large new loads should not apply to Decarbonizing and EITE existing customers, and that the settlement’s customer-data disclosure provisions violate Public Utilities Code § 8380. In August 2026 the assigned judge reopened the record so parties could address a FERC Order to Show Cause on transmission service for large loads.
Briefs & Interim-Rate Opposition in PG&E’s 2027 General Rate Case
In A.25-05-009, CLECA filed opening and reply briefs challenging PG&E’s proposed revenue requirement and defending cost-causation allocation for industrial customers, and, with EPUC and Indicated Shippers, opposed PG&E’s motion to begin recovering its contested 2027 revenue requirement on an interim basis, arguing the claimed savings rest on an unadjudicated $1.18 billion request that ignores non-residential customers entirely.
Opening & Reply Briefs on the Large Power Dynamic Rate
CLECA’s 2026 briefs urge 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 Avoided Cost Calculator Proposed Decision
CLECA’s 2026 comments warn that the revised ACC methodology suppresses the value of dispatchable distributed resources such as the Base Interruptible Program many members supply, because generation-capacity value is derived as a residual and pushed toward the floor by elevated GHG values. CLECA urges a reasonable cap on the GHG value and correction of the suppressed generation-capacity floor.
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 Reliable and Clean Power Procurement Program
In the integrated resource planning procurement rulemaking, CLECA recommended targeted modifications to the proposed Reliable and Clean Power Procurement Program: allocating resource obligations by demand during critical hours, expressing procurement needs as resource attributes rather than specific technologies, and providing a pathway that sustains existing demand response such as the Base Interruptible Program, which the framework’s need determination assumes but does nothing to maintain.
Comments on Demand Response Bridge-Year Funding
In the rulemaking to enhance demand response, CLECA’s comments on the staff proposal address 2028–2029 “bridge year” program funding, pressing to sustain the existing demand response portfolio, including the supply-side programs industrial customers rely on, while the next program cycle is developed.
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