The rate gap, documented over eight years
CLECA has tracked the gap between California industrial electricity rates and those of neighboring states in filing after filing. In 2023 testimony in A.22-05-002, the premium was 138 percent above neighboring states; by 2025 comments it was more than 250 percent higher; and CLECA's 2026 testimony in PG&E's TY2027 GRC, A.25-05-009, put PG&E industrial rates at over 300 percent of the average industrial rates in states bordering California.
The trend line matters as much as the level. The gap has widened through successive general rate cases, wildfire cost recovery, and program spending — each increase small in isolation, cumulative in effect.
Who bears it
CLECA — the California Large Energy Consumers Association — represents sixteen industrial customers: steel mills, cement plants, glass and industrial-gas producers, a major pipeline operator, a cold-storage chain, and other heavy manufacturers, with a combined load on the order of five hundred megawatts. Every member treats electricity as a top-three cost of production; several treat it as the single largest expense. Almost all are exposed to global competition, which means they cannot pass California-specific rate increases through to customers who can buy from producers in other states or countries.
Emissions leakage: the climate case for affordability
CLECA is not opposed to clean energy, climate policy, or wildfire mitigation; it is opposed to the industrial-rate consequences of how those policies are implemented. Its recurring argument is that the rate gap drives emissions leakage: when production migrates to states or countries with higher-emitting grids and weaker standards, global emissions rise even as California's fall on paper. A rate structure that pushes out the manufacturers the state wants to decarbonize is self-defeating on the state's own terms — a diagnosis that AB 1207's leakage-prevention interest, and the converging analysis of NRDC and Sierra Club on industrial electrification, now reflect.
The statutory anchor: section 451
Whatever the proceeding, CLECA anchors its affordability argument in Public Utilities Code section 451's requirement that rates be just and reasonable — the statute that appears in more CLECA positions than any other citation. A Commission order that leaves industrial rates demonstrably unjust or unreasonable is, in CLECA's framing, a section 451 problem regardless of the policy preference behind it.
CLECA has pressed the point institutionally in the affordability rulemaking R.18-07-006, arguing that affordability metrics must cover non-residential customers, and in the Climate Credit rulemaking R.25-07-013, where it notes that EITE customers face electric rates approximately 250 percent higher than those in neighboring states.
Beyond the CPUC
The affordability record extends to the Legislature and CARB. CLECA opposed SB 254's fire-risk cost provisions, supported AB 825 on regional market pathways, and has engaged CARB's Cap-and-Invest amendments on industry assistance and leakage protection for Emissions-Intensive Trade-Exposed (EITE) sectors. The through-line is consistent: as a large energy consumers association, CLECA's ask is not exemption from climate policy but rates and allocations that keep energy-intensive production — and its decarbonization — in California.