This entry covers CLECA’s participation in CPUC proceeding A.25-05-009, PG&E’s Test Year 2027 General Rate Case. The excerpts below are drawn from CLECA’s opening and reply briefs and from the joint response, filed with EPUC and the Indicated Shippers, opposing PG&E’s motion for interim rate recovery.
The largest revenue requirement increase in PG&E’s history
CLECA opens by placing the sheer size of PG&E’s request at the center of the case.
In this proceeding, PG&E seeks the largest single-GRC-period electric revenue requirement increase in its history … an $11.7 billion cumulative increase over 2027 through 2030.
If adopted, PG&E's electric revenue requirement would increase from $7.1 billion in 2020 to the proposed $13.8 billion in 2030, a 96 percent increase from 2020 and a 37 percent increase from 2026.
Industrial rate affordability and competitiveness
CLECA stresses that PG&E’s industrial rates are already uncompetitive and threaten California jobs, investment, and decarbonization.
PG&E industrial rates have risen more than 50 percent in the last five years, are now the highest industrial rates among the large California investor-owned utilities, and exceed 300 percent of industrial rates in neighboring states.
When local production becomes uneconomic, California risks losing jobs, tax revenue, investment, and economic activity, while supply chains face added costs, potential delays, logistics burdens, and upward pressure on price inflation.
Judge the proposal on total ratepayer cost, not the headline
CLECA argues that PG&E’s accounting and procedural adjustments shrink the stated request without lowering what customers actually pay.
But a proposal is not more affordable simply because some costs are excluded from the GRC, moved to balancing accounts, capitalized, or deferred for later recovery.
A proposal that lowers the headline request while deferring or relocating the same costs does not solve the affordability problem; it obscures it.
Sizing and sequencing capital investment
CLECA challenges the scale and pace of PG&E’s capital plan, urging investment tied to observed demand rather than aspirational forecasts.
PG&E's Electric Distribution capital plan is the single largest driver of the revenue requirement increase in this Application.
Increasing electricity rates right before capital-constrained companies and individual consumers are expected to make investments to electrify is not realistic. A 'spend it, and they will come' approach simply will not work.
Administrative and general spending and headcount
Among specific cost categories, CLECA asks the Commission to freeze A&G spending and closely scrutinize staffing increases.
Reject PG&E's proposed increase in Administrative and General spending, and freeze annual A&G expense at the prior 2026 approved level.
Apply rigorous scrutiny before approving any departmental or functional headcount increases
The $99 million Academy expansion
CLECA contends PG&E failed to justify its proposed training-facility capital request or even its scaled-back alternative.
CLECA's Opening Brief demonstrates that PG&E has not established that its proposed $99 million Academy expansion is necessary or the most efficient means of meeting its training needs.
As CLECA explains, PG&E's ability to defer approximately two-thirds of the project without impairing its training program undermines the asserted need for the full request.
Closing the wildfire memorandum accounts
CLECA argues that SB 254 and the record support returning wildfire mitigation costs to the GRC and closing the WMPMA and FRMMA.
SB 254 replaced the prior requirement for wildfire mitigation memorandum accounts with a discretionary standard limited to costs that are “unforeseen and incremental” to wildfire mitigation programs and activities authorized in revenue requirements.
The Commission should therefore close the WMPMA and FRMMA to new entries effective January 1, 2027.
Opposing interim recovery of an unadjudicated revenue requirement
In the joint response with EPUC and the Indicated Shippers, CLECA urges the Commission to reject early recovery of PG&E’s still-contested request.
The Commission should deny PG&E's request for interim recovery of any portion of its proposed test year (TY) 2027 revenue requirement increase.
Because PG&E's underlying revenue request is subject to such extensive, well-supported disallowance recommendations, granting interim recovery poses an unacceptable risk of substantial ratepayer overcollection.
Read the filings
The excerpts above are drawn from CLECA’s filings in this proceeding. Read the complete documents: