This entry covers CLECA’s opening comments in CPUC proceeding R.25-09-004, the rulemaking to enhance demand response, on the staff proposal for 2028-2029 bridge-year funding of the investor-owned utilities’ demand response programs. The excerpts below are drawn from CLECA’s April 30, 2026 comments.
Two-year bridge funding for 2028 and 2029
CLECA supports the staff proposal to authorize a two-year bridge extension of the utilities’ demand response programs.
The Staff Proposal's recommendation to authorize a two-year “bridge” extension of the investor-owned-utilities' (IOUs) demand response (DR) program operations for 2028 and 2029 is reasonable.
This approach would preserve program continuity, avoid premature applications, and allow the Commission sufficient time to finalize its determinations here.
Flexibility to adjust budgets during the bridge years
CLECA urges the Commission not to over-constrain program operations and to allow reasonable budget adjustments.
The Commission should ensure the IOUs have sufficient flexibility to request and implement reasonable budget adjustments to accommodate DR program growth during the 2028 and 2029 bridge years.
A fixed budget over the extended bridge period risks constraining the IOUs' ability to respond to enrollment growth, increased dispatch frequency, or changing grid conditions.
Sustaining the Base Interruptible Program
CLECA emphasizes that the Base Interruptible Program its industrial members rely on delivers fast-acting, reliable capacity.
Maintaining strong BIP participation is critical because industrial customers have consistently provided meaningful load reductions during periods of extreme grid stress.
Demand response, especially BIP, delivers unique system benefits precisely because it can scale quickly and does not require new interconnections, permitting, or transmission upgrades.
BIP incentive increases and mid-cycle review
CLECA supports PG&E’s pending request to raise BIP incentives and a mechanism to make further adjustments during the bridge years.
The Commission should approve PG&E's proposed increases to BIP incentives for program years 2026 and 2027, as requested in the Pending MCR, to stabilize and grow program participation heading into the 2028 and 2029 bridge years.
Accordingly, the Commission should provide a workable pathway for the IOUs to seek targeted DR budget and incentive adjustments during the bridge years … via Tier 1 or Tier 2 Advice Letters.
Extending the 2030-2034 application deadline
CLECA supports extending the deadline for the utilities’ next five-year applications to January 1, 2029.
The Commission should authorize an extension of time for the IOUs' 2030-2034 demand response applications until January 1, 2029.
Together, these actions preserve program continuity, avoid premature and incomplete applications, and ensure that the next DR portfolio fully reflects the Commission's policy objectives developed in this proceeding.
The ELRP pilot and BIP dual participation
If the Commission extends the ELRP pilot, CLECA asks it to let BIP customers be compensated for incremental curtailment.
If the Commission authorizes the bridge years and extends the ELRP as considered under Question 4.1.h. below, it should also modify the rules for BIP-ELRP dual participation.
Because no BIP event is active during non-overlapping ELRP dispatches, the Commission should modify the rules to compensate BIP customers for curtailment that is incremental to their normal operating load, rather than requiring reductions below the customer's FSL as a precondition for ELRP compensation.
Read the filings
The excerpts above are drawn from CLECA’s filings in this proceeding. Read the complete documents: