This entry covers CLECA’s comments in CPUC proceeding R.20-05-003, the electric Integrated Resource Planning and procurement rulemaking, on the proposed Reliable and Clean Power Procurement Program (RCPPP). The excerpts below are drawn from CLECA’s August 14, 2026 comments.
Support for a programmatic framework, with targeted modifications
CLECA welcomes a predictable procurement framework but does not support the proposal as written.
CLECA appreciates the Commission’s continued effort to establish a predictable, programmatic framework for electricity procurement to replace ad hoc procurement orders.
The framework will only achieve the goals of IRP with the targeted modifications described in these comments.
Affordability and reasonable cost
CLECA stresses that the program must meet the state’s resource needs at a reasonable cost without unduly burdening ratepayers.
This program must meet the state’s resource needs at a reasonable cost. Buffers, accreditation volatility, compliance complexity, and stacking penalties (including those resulting from aggressive procurement deadlines) must not unduly burden already strained ratepayers.
CLECA supports the ALJ Proposal’s recommendation of a one-percent buffer in the Staff Proposal as a maximum reasonable value.
Allocate resource obligations by demand during critical hours
CLECA recommends allocating each load-serving entity’s share by its demand in critical hours to reflect cost causation and preserve load-management incentives.
CLECA supports allocation based on demand in critical hours. The need being allocated is primarily a capacity need that arises during a limited set of critical hours, and cost causation principles require that each LSE’s share reflect its contribution to that need.
A critical-hours basis also preserves the incentive the ruling identifies: that LSEs “would be incentivized to affect their load shape and/or their load in general through investment in demand-side management.”
Express need as resource attributes, not technologies
CLECA urges the Commission to define need by resource attributes so every capable resource can compete at the lowest reasonable cost.
The Commission should express procurement need through resource attributes (availability during critical hours, dispatchability, duration, and carbon intensity) rather than resource categories, thereby allowing all capable resources to compete to meet reliability needs at the lowest reasonable cost to ratepayers.
A level playing field among resources is essential to achieving the statute’s least-cost objective. When every capable resource competes, the need is met at the lowest cost to consumers.
Sustain the existing demand response the need determination assumes
CLECA warns that the framework relies on existing demand response such as the Base Interruptible Program yet does nothing to maintain it.
CLECA’s principal concern is that the framework depends on existing resources it does nothing to sustain. The need determination begins from a portfolio in which existing resources, including supply-side demand response such as the Base Interruptible Program (BIP), are assumed to continue performing at modeled values indefinitely.
The framework should therefore provide a pathway for incremental demand response resources to satisfy the new resource obligation, while also preserving the baseline demand response that the need determination assumes.
Read the filings
The excerpts above are drawn from CLECA’s filings in this proceeding. Read the complete documents: