We Support CCA in California
CalCCA supports legislation and regulatory policies that protect and foster CCAs within the state. We promote competitive neutrality and a level playing field. We oppose legislation and regulatory policies that unfairly discriminate against CCAs or CCA customers, or reduce CCA policy- or decision-making autonomy.
Regulatory Compliance
CCAs, as load serving entities, engage with numerous state and federal agencies, including the California Energy Commission, the California Public Utilities Commission, California Air Resources Board, and the Federal Energy Regulatory Commission, to ensure compliance in a number of areas including renewable energy mandates, grid reliability, and power content reporting. CCAs work cooperatively with all agencies having authority over CCA operations to ensure efficient and safe delivery of energy and energy-related programs. CCAs strive to be highly responsive and transparent in their efforts to provide clean, affordable energy to our customers.
CalCCA Policies
Procurement and Reliability
- Protect CCAs’ procurement autonomy
- Protect CCAs’ right to self-procure their customers’ portions of system reliability needs
- Encourage results-oriented policymaking over prescriptive procurement mandates
Local Control
- Protect the authority of the CCA Board of Directors as the primary governing body of a CCA
- Develop roles for state agencies that are complementary to rather than competitive with the CCA Boards of Directors
Non-Bypassable Charges
- Prevent new non-bypassable charges (“NBCs”) and phase out or eliminate existing NBCs
- Ensure that NBC inputs and methodologies are transparent and developed through public processes that allow for full stakeholder input
- Foster market certainty by maximizing year-to-year consistency and/or predictability of all NBCs
Customer Indifference and Legacy Costs
- Protect indifference of all ratepayers to load migration between LSEs
- Increase the transparency and certainty of PCIA charges, and phase out unreasonable PCIA charges over a time period that addresses stranded costs
- Reform IOU procurement practices to minimize stranded load and mitigate CCA charges
Grid Edge
- Protect CCAs’ right to develop and administer energy efficiency and integrated distributed energy resources
- Protect CCA customers’ right to select, install, and operate energy efficiency and behind-the-meter distributed energy resources
- Foster and develop integrated distributed energy resources as non-wires alternatives to expanding distribution infrastructure and centralized generation
The Broader Landscape
- Support further CCA growth and formation
- Build energy market structures and regulatory paradigms that benefit all California ratepayers and facilitate affordability, reliability, decarbonization, and social equity
Utilities Restructuring
- Support refocusing the utilities’ electric business on the safe management of wires infrastructure
- Support options for local governments to expand their electricity program offerings, including the option to serve as sole retail provider and provider of last resort and support local jurisdictions’ existing right to establish publicly-owned utilities
- Encourage establishment of a statewide public agency to serve bundled utility customers without a public power option until such time as a local agency option becomes available
- Support the operation of investor-owned utility distribution systems as transparent neutral, open-access platforms which facilitate the deployment of distributed energy resources and other demand-side management strategies
- Promote optimization and rebalancing of IOUs’ portfolio
Key Legislation
AB 117 – Enacted in 2002 in response to the California Electricity Crisis, AB 117 outlined the steps that must be taken to form a CCA, and laid out how CCAs would be regulated and coexist with the local investor-owned utility (IOU). Among many points, AB 117 mandated that a CCA become the default provider for residents and businesses in its service territory.
SB 790 – Created a code of conduct which IOUs must adhere to in regards to CCAs operating in their service area. Specifically, it prohibited utilities from marketing against CCAs except through a separate marketing division separated by a ‘firewall’ from the other operations of the utility. It was passed in response to several IOUs efforts to stem CCA growth.
Recent Regulatory Filings
November 2023
Opening Comments on OIR around Overseeing the RA program (11-08-23)
Reply Brief and Comments around SCE ERRA Requirement (11-02-23)
Comments on Fall Update around 2024 ERRA Forecast (11-01-23)
October 2023
SCE Response to CalCCA DRs 7.02 and 7.03 (10-27-23)
Reply Brief around PGE ERRA forecast proceeding (10-23-23)
Comments on RA Modeling and Program Design WG Discussion Paper (10-20-23)
Comments on Billing, Payment, and Credit Enhancements Issue (10-17-23)
Public Version of Opening Brief Around PGE ERRA Forecast (10-13-23)
Motion for Leave to Submit Confidential Version of Opening Brief Under Seal (10-13-23)
Comments on IPE 2023 Straw Proposal (10-12-23)
Response to SCE’s Petition for Modification of D.23-06-006 around OIR on PCIA (10-11-23)
Comments on Price Formation Enhancement WG session 5 (10-11-23)
Exhibit 02 Compilation of PG&E’s responses to CalCCA data requests 6.04 and 6.06-6.12 (10-06-23)
Reply Brief around the OIR to Advance Demand Flexibility Through Electric Rates (10-06-23)
Petition for Writ of Review around CPUC Resolution E-5258 and Decision 23-08-052 (10-05-23)
September 2023
Exhibit 04 Select Passages of Prepared Testimony from PGE 2024 ERRA Forecast Case (09-26-23)
Exhibit 02 SCE REsponses to Certain Data Requests Issued in Lieu of Cross Examination (09-26-23)
Prepared direct testimony of Brian Shuey in PGE’s 202e ERRA Compliance Proceeding (09-22-23)
Exhibit 03 PGE 2023 ERRA Forecast Chapter 11 (09-26-23)
Select Passages of Prepared Testimony from PGE’s 2024 ERRA Forecast Case A.22-05-029 (09-26-23)
Selects Passages of Prepared Testimony from PGE’s 2023 ERRA Forecast Case A.22-05-012 (09-26-23)
Opening Brief on Phase 1 Track 2 Issues (09-18-23)
Comments on March 29, 2023 Scoping Order (09-18-23)
Joint Case Management Statement around Application of SCE for its 2024 ERRA Forecasting (09-15-23)
Comments on Generator Deliverability Methodology Review Straw Proposal (09-12-23)
Response to West-Wide Governance Pathways Initiative (09-11-23)
Prepared direct testimony of Brian Shuey in PGE’s 2024 ERRA Forecast Proceeding (09-06-23)
August 2023
Comments on ED Price Machine Proposal (08-28-23)
Exhibit around Stipulated PGE DR Responses (08-25-23)
Cross Exhibits Toy 15 PG&E Response to CalCCA Data Request 1.51 (08-25-23)
Cross Exhibits Toy 14 Assigned Commissioner’s Scoping Memo and Ruling (08-25-23)
Reply Comments Regarding Fixed Generation Costs (08-23-23)
Comments in Response to ALJ Order Regarding Fixed Generation Costs (08-16-23)
Comments on IPE Track 2 (08-15-23)
Comments on EDAM BAA Participation Rules Track A1 (08-14-23)
Scoping Memo Question 4.b. Proposal (08-14-23)
Protest to PGE ERRA Trigger Application (08-10-23)
July 2023
Comments on ALJ’s Ruling on the Implementation Pathway for Income-Graduated Fixed Charges (07-31-23)
Reply Brief around SB 520 discussing POLR (07-31-23)
Application for Rehearing of D.26-03-029 around the RA Program Reforms (07-26-23)
Comments on DAME Revised Draft Tariff Language (07-25-23)
Comments on CPM Enhancements Track 2 Straw Proposal (07-24-23)
Opening Brief around OIR to Implement SB520 and Address Other Matters Related to POLR (07-10-23)
June 2023
Comments on EDAM BAA Participation Rules WS (06-28-23)
Comments on Generator Deliverability Issue Paper (06-22-23)
Final Informal Comments on Draft 2023 I&A Document (06-21-23)
Final Comments on RA Workshop (06-20-23)
Comments on DAME Draft Tariff Language (06-16-23)
Comments Rejecting the PD’s Restrictions on LSE Expansion around OIR to Oversee the RA Program (06-14-23)
May 2023
Comments on Summer Reliability Workshop (05-31-21)
Application for Rehearing of Resolution E-5258 (05-30-23)
Reply Comments around Alternatives to the PCIA (05-30-23)
Comments on PD around OIR to Review Revise and Consider Alternatives to the PCIA (05-24-23)
Comments on the May 4 Workshop on Clean Energy Interconnection – Bulk Grid (05-23-23)
Comments on Subscriber PTO Model Draft Final Proposal (05-02-23)
April 2023
Comments on the ALJ’s Ruling on the Next Steps for the Arrearage Management Plan Program (04-26-23)
Final Comments on 2022-23 Draft Transmission Plan (04-25-23)
Comments on IPE 2023 Track 1 Final Proposal (04-24-23)
Comments on Revised DAME Final Proposal (04-24-23)
Comments on EDAM ISO BAA Workshop (04-19-23)
Final Comments on Resolution E-5258 Effective Dates for the Expansions of CCCE and EBCE (04-17-23)
March 2023
Comments on DAME Feb 27 and Mar 7-8 Workshops (03-30-23)
Reply Comments on the PD around P2 RA Reform Track (03-28-23)
Comments on IPE 2023 Issue Paper and Straw Proposal (03-27-23)
Comments on the 2024 and 2028 Local Capacity Requirements Technical Study Draft Results (03-23-23)
Joint Conference Statement CalCCA, SCE et al. (03-21-23)
Final Protest of PG&E AL 6870-E Around Diablo Canyon Decommissioning (03-21-23)
Reply Comments on the Assigned Comissioner’s Amended Scoping Memo and Ruling around RA (03-03-23)
February 2023
Informal Comments on PG&E M&C around Diablo Canyon Power Plant (02-10-23)
January 2023
Reply Comments on ALJ’s Ruling Regarding Phase 2 around OIR to Revise GO 156 (01-30-23)
Comments on the January 13, 2023 workshop on Energy Data Modernization and Analytics (01-27-23)
Opening Brief around OIR to Advance Demand Flexibility Through Electric Rates (01-23-23)
Comments on ALJ’s Ruling Regarding Phase 2 around OIR to Revise General Order 156 (10-13-23)
Protest to PG&E Advice 6794-E (01-09-23)
Protest of SCE Advice 4922-E (01-09-23)
Protest to PG&E Advice 6794-E (01-09-23)
CAISO Comments on Generatory Deliverability Challenges(01-04023)
CalCCA, PG&E, et al. Joint Status Conference Statement (01-04-23)
December 2022
Comments on DAME Draft Final Proposal (12-21-22)
Comments on CPM Enhancements T1 Revised Draft Final Proposal (12-20-22)
Reply Comments on OIR to Implement AB 843 – The BioEnergy Market Adjusting Tariff Program (12-13-22)
Response to PGE Scheduling Letter re A.22-09-018 (12-12-22)
Comments on Assigned Commissioner’s Phase 1 Scoping Memo and Ruling (12-02-22)
Comments on Individual IRP Filings around OIR to Continue EIRP (12-02-22)
November 2022
Comments on OIR to Implement AB843 – the Bioenergy Market Adjusting Tariff Program (11-28-22)
Comments on EDAM Market Draft Final Proposal (11-22-22)
Comments on EDAM Market Governance Review Straw Proposal (11-18-22)
Comments on WEIM RSE Phase 2 Revised Final Proposal (11-15-22)
Comments on Energy Storage Enhancement Final Proposal (11-15-22)
October 2022
Direct Testimony of Brian Shuey in PGE’s 2021 ERRA Compliance Proceeding (10-31-22)
Joint Motion to Seal Portions of Evidentiary Record and Report of PG&E (10-13-22)
Comments on CPM Enhancements Track 1 Draft Final Proposal (10-07-22)
Exhibit CalCCA-02 PG&E’s Data Responses to CalCCA 6.01-6.04 (10-06-22)
Joint Report on Informal Status Conference – CalCCA, PG&E, Cal Advocates, etc.(10-05-22)
Addendum to 9-26 Comments on EDAM Revised Straw Proposal (10-4-22)
Comments on IPE Final Proposal (10-04-22)
Comments EDAM Revised Straw Proposal (10-04-22)
September 2022
Motion to Shorten Response Time to PFM of D.22-03-034 around RA Requirements (09-30-22)
Comments on the Proposed Amendments to the Load Management Standards (09-27-22)
Protest of SCE’s Tier 2 Advice Letter Regarding CCA FSR Reports Prior to Mass Enrollment (09-20-22)
Comments on ESE Draft Final Proposal (09-09-22)
Direct Testimony of Brian Shuey in PGE’s 2023 ERRA Forecast Proceeding (09-07-22)
August 2022
Comments on CPM Enhancements T1 Straw Proposal (08-18-22)
Comments on OIR to Advance Demand Flexibility through Electricity Rates (08-15-22)
Comments on WEIM GRC Straw Proposal (08-15-22)
Comments on Price Formation Enhancements Issue Paper (08-09-22)
Comments on TPP Enhancements Issue Paper (08-05-22)
Comments on ESE Addendum Second Revised Straw Proposal (08-03-22)
July 2022
Comments on Proposed Draft Program Guidelines – Demand Side Support Program around AB205 (07-29-22)
Comments on WEIM Resource Sufficiency Evaluation Enhancements Phase 2 Straw Proposal (07-25-22)
Comments on the Proposed Revisions to the Load Management Standards (07-21-22)
Comments on 2022-2023 Transmission Planning Process Update (07-20-22)
Comments on the Proposed Approach by the CAISO for Accessing Out-of-State Wind Resources (07-11-22)
June 2022
Comments on IPE Phase 2 Revised Straw Proposal at CAISO (06-28-22)
Energy Index MPB Calculation Proposal around the PCIA (06-13-22)
Comments on Market Offer Process around RPS Program (06-06-22)
May 2022
Comments on the CEC Staff Workshop on Summer and Midterm Reliability (05-27-22)
Comments on the IEPR Commissioner Workshop on the California Planning Library (05-17-22)
April 2022
Comments on Draft 2023 Flexible Capacity Needs Assessment (04-28-22)
Comments on ALJ’s Ruling Regarding Market Price Benchmarks around the PCIA (04-28-22)
Comments on the Proposed Revisions to the LMS Rulemaking (04-20-22)
Comments on Energy Storage Enhancements Revised Straw Proposal (04-04-22)
March 2022
Comments on the ALJ’s Ruling Seeking Comments on the Future of RA Working Group Report (03-24-22)
Comments on CAISO Day-Ahead Market Enhancements Workshop (03-16-22)
Comments on CAISO Draft 2022-2023 Study Plan (03-14-22)
Comments on LCR WG Final Report and LOLE Ruling (03-14-22)
Reply Comments on PD around Go 156 Supplier Diversity Program (03-07-22)
Comments on PD Revising GO 156 Supplier Diversity Program (03-01-22)
February 2022
CalCCA and PGEs’ Local Capacity Requirement Final Working Group Report (02-28-22)
Final CalCCA Informal Comments on LCR Working Group (02-24-22)
Comments on the Draft 2021-2022 Transmission Plan Feb 7, 2022 Stakeholder Call Discussion (02-22-22)
Comments on Phase 2 of Resource Adequacy Program Workshop and Proposals (02-14-22)
Comments on DAME Workshop – CAISO (02-07-22)
Comments on Proposed Amendments to Load Management Standards (02-07-22)
Comments on Transmission Development Forum (02-04-22)
January 2022
Comments on Central Procurement Entity Implementation Draft Final Proposal (01-20-22)
Reply Comments on the PD Adopting the 2021 Preferred System Plan (01-19-22)
Comments on the 2021 Preferred System Plan (01- 14-22)
Final Comments on CAISO Energy Storage Enhancements Straw Proposal (01-12-22)
Comments on EIM RSE Draft Final Proposal (01-10-22)
Joint CA LSEs Comments on Transmission Service Draft Final Proposal (01-07-22)
Reply Comments on ALJ Ruling Regarding PCIA Forecasting Data Access (01-06-22)
Comments on Interconnection Process Enhancements Straw Proposal to CAISO (01-05 -22)
Comments on Assigned Commissioner’s Scoping Memo and Ruling around RA Reform (01-04-22)
Comments on PD on 2021 RPS Procurement Plans (12-30-21)
December 2021
Comments on PD on 2021 RPS Procurement Plans (12-30-21)
Comments on the Draft 2021 IEPR (12-21-21)
Phase 1 Proposals in Response to the Assigned Commissioner’s Scoping Memo and Ruling (12-13-21)
Opening Comments on ALJ Ruling Regarding PCIA Forecasting Data Access (12-09-21)
Comments on Draft Resolution E-5183 (12-06-21)
Comments on Central Procurement Entity Issue Paper/Straw Proposal (12-06-21)
Comments to CAISO Nov Transmission Planning Process Workshop (12-03-21)
November 2021
Final Comments to CAISO RMR Clarifications Final Proposal (11-22-21)
Protest of SCE AL 4620-E (11-17-21)
Reply Comments on Phase 2 PD Directing PG&E, SCE, SDG&E to Take Actions to Prepare for Potential Extreme Weather in the Summers of 2022-23 (11-16-21)11 17 21 R.21-02-014 CalCCA Protest of SCE AL 4620-E, et al
Informal Comments on RA Track 3B.2 (11-10-21)
Comments on the PD P2 Directing Preparations for Summers 2022-23 (11-10-21)
Reply Comments on OIR to Oversee RA Program to Prioritize the Reform Track (11-10-21)
October 2021
Reply Comments Against Possible Natural Gas Procurement Mandate (10-28-21)
Comments on CAISO Resource Adequacy Enhancements Straw Proposal (10-26-21)
Response to Joint Utilities Supplemental AL on CBOs (10-18-21)
Comments to CAISO RMR Clarifications Straw Proposal (10-13-21)
Comments on the Transmission Planning Process (10-12-21)
Reply Comments on Ruling ALJ’s Proposed PSP (10-12-21)
Reply Comments on ERRA-PCIA Ruling (10-08-21)
RA Track 3B.2 Workshops Resource Counting Questions (10-08-21)
Comments on Proposed COVID Debt Relief JU Small Business Pilot (10-05-21)
Comments on Joint Utilities Small Business Pilot (10-05-21)
Comments to CAISO MIC Enhancements Draft Final Proposal (10-04-21)
Comments on Midterm Reliability Modeling Workshop (10-04-21)
Opening Comments on Data-Related PCIA Issues (10-01-21)
September 2021
Joint CA LSE’s Comments on Issue Paper External Load Rights (09-30-21)
Reply Comments on PD Authorizing Percentage of Income Payment Plan Pilot Programs (09-27-21)
Comments on ALJ’s Ruling Seeking Comments on Proposed Preferred System Plan (09-27-21)
Reply Brief around the Amended Scoping Memo and Ruling for Phase 2 (09-27-21)
Reply Comments in Response to Request of Comments on Market Price Benchmark Issue Date (09-22-21)
Comments on the PD Authorizing Percentage of Income Payment Pilot Programs (09-22-21)
Protest to Joint IOU RPS VAMO Advice Letter (09-13-21)
Protest to PG&E AL 6306-E Methodology PCIA-eligible RA Capacity Bundled Portfolio Plan (09-13-21)
Protest to SCE AL 4570-E Methodology Justifying PCIA-eligible RA Bundled Portfolio Plan (09-13-21)
Comments on ALJ Ruling Requesting Comments on MPB Issue Date (09-13-21)
Protest to SDG&E’s Tier 2 AL Determining PCIA-eligible RA in its Bundled Procurement Plan (09-13-21)
Comments EIM Resource Sufficiency Straw Proposal and August 23, 2021 Workshop (09-08-21)
Comments on Draft CEC Preliminary 2022 Summer Supply Stack Analysis (09-07-21)
August 2021
Final Comments to Clarifications to RMR Designation Process Issue Paper (08-31-21)
Brief on Scoped Issue 7, Allocation of Payments on Arrearages for CCA Customers (08-27-21)
Comments on CAISO Straw Proposal around Maximum Import Capability Enhancements (08-25-21)
Final Comments CAISO DAME Second Revised Straw Proposal (08-18-21)
Comments on 21-SIT-01 SB 100 Resource Build: Transmission Work Shop (08-11-21)
Final Comments on CAISO Transmission Planning Workshop (08-10-21)
Final Comments on Energy Storage Enhancements Working Group (08-10-21)
Final Joint CA LSEs Comments on External Load Workshop (08-03-21)
July 2021
Comments on IEPR Workshop on Summer 2021 Reliability (07-23-21)
June 2021
Comments on Track 3B.2 PD in Relation to Resource Adequacy Programs (06-30-21)
Application for Rehearing of the Decision in Relation to Revising Phase 2 of the PCIA (06-23-21)
Comments on RAAIM Exemption Options for Demand Response Resources (06-23-21)
Hybrid Aggregate Capability Constraint Final Proposal Comments (06-14-21)
EIM Governance Review Straw Proposal Comments (06-10-21)
Comments on PD and Alternate PD Requiring Procurement to Address Mid-term Reliability (06-10-21)
Reply Comments on PD around OIR to Oversee RA Program (06-10-21)
Comments on the PD Recommending Against Further Direct Access Expansion (06-03-21)
May 2021
MIC Straw Proposal Comments (05-24-21)
Comments on CAISO Energy Storage White Paper (05-19-21)
Reply Comments on OIR to Implement SB 520 and Address Other Matters Related to POLR (05-10-21)
Reply Comments on Phase 3 of the Decision on PCIA Cap and Portfolio Optimization PD (05-03-21)
April 2021
Reply Brief around OIR to Address Customer Bill Debt Accumulated During COVID-19 (04-30-21)
Comments on PD around OIR to Review, Revise, and Consider Alternatives to PCIA (04-26-21)
Comments on OIR to Revise GO 156 – Supplier Diversity Program (04-12-21)
Stakeholder Comments to CAISO – Summer Readiness Final Proposal (04-02-21)
Comments on MIC Enhancements Issue Paper (04-02-21)
March 2021
Comments on Track 3B.2 Proposals around OIR regarding Resource Adequacy Program (03-12-21)
February 2021
CalCCA Protest to PG&E’s Advice Letter 6078-E (02-18-21)
Reply Brief around OIR to Ensure Reliable Service During an Extreme Weather Event in 2021 (02-12-21)
Reply Comments on Amended Scoping Memo and Ruling in PCIA Proceeding (02-05-21)
Reply Comments on Ruling for Moratorium Approach in Emergency Disaster Relief Program OIR (02-05-21)
Motion for Party Status in OIR regarding Emergency Disaster Relief Program (02-04-21)
Comments on Market Enhancements for Summer 2021 (02-03-21)
Response to the IOUs’ Resubmitted FSR Advice Letters (02-02-21)
January 2021
Comments on Sixth Revised Straw Proposal – RA Enhancements Phase 2A (01-29-21)
Comments on Draft Resolution M-4849 (01-22-21)
Comments on Assigned Commissioner’s Amended Scoping Memo and Ruling (01-22-21)
Comments on January 12 Load and Export Scheduling Workshop (01-20-21)
Comments on Track 3B.2 Proposals (01-15-21)
SDCP CEA and CCA Opening Comments on Alternative PD (01-07-21)
Motion for Party Status by CCA (01-05-21)
December 2020
Reply Comments to Law Judge Kline’s Proposed Decision on SCE 2021 ERRA and PCIA (12-15-20)
Reply Comments in Extreme Weather Event OIR (12-10-20)
Letter Extending CalCCA FSR Posting Deadline in Resolution E-5059 (12-08-20)
CalCCA Comments Letter on DR E-5114 (12-07-20)
Joint Comments on SDGE U 902 E under the PCIA Account Trigger Mechanism (12-03-20)
Request for Extension of Posting Requirement in Resolution E-5059 (12-02-20)
November 2020
Protest to the IOUs’ FSR Compliance Advice Letters (11-30-20)
CalCCA CAISO RA Enhancement Comments (11-30-20)
Joint Comment on SDGE November Update Application (11-18-20)
October 2020
Comments on CAISO Hybrid Resources Revised Final Proposal (10-30-20)
Reply Comments on CAISO’s Business Practice Manual (BPM) Change Proposed Revision (10-20-20)
Joint Opening Brief of CalCCA and SoCal CCAs in SDG&E PCIA Trigger Application Proceeding (10-20-20)
Comments on CAISO RA Enhancements (10-1-20)
September 2020
CCA Integrated Resource Plans (IRPs)
Protest to PG&E AMP Advice Letter in response to Decision 20-06-003 (9-29-20)
CalCCA and DACC Response to the Joint IOU Advice Letters in Response to Decision 20-03-19 (9-21-20)
Comments on PD Granting CalCCA PFM of Decision 19-11-016 in IRP Proceeding (9-14-20)
Comments on the proposed competitive neutrality rules submitted by PG&E (9-11-20)
Response to Line Loss PFM in PCIA Proceeding (9-8-20)
August 2020
Comments on CAISO Hybrid Resources Draft Final Proposal (8-26-20)
Protest to Expedited Application of SDG&E Application Under the PCIA Trigger Mechanism (8-13-20)
Comments on Draft Resolution E-5059 (8-13-20)
CalCCA and Edison’s Track 3 Proposal in RA Proceeding (8-7-20)
Informal Comments on LCR Compensation Mechanism (8-3-20)
July 2020
Comments on Draft Resolution E-5080 (7-27-20)
Reply Comments on PD For Working Group #2 (Prepayment) in PCIA Proceeding (7-27-20)
Comments on Backstop Procurement and Cost Allocation Mechanisms in IRP Proceeding (7-22-20)
2022 Building Standards Comment Letter to CEC (7-16-2020)
Comments on Three-Year Planning Schedule in IRP Proceeding (7-6-20)
Amicus curiae brief in support of Protect Our Communities’ appeal of CPUC PCIA decision (7-6-20)
June 2020
Comments on CAISO Resource Adequacy Enhancements Working Group (6-24-20)
CalCCA Comments on OIR in IRP Proceeding (6-15-20)
Comments on PD in Confidentiality Proceeding (6-9-20)
Comments on Resource Adequacy Import Requirements PD (6-8-20)
Response to PGE Advice Letter 5827-E (6-4-20)
May 2020
Reply Comments on PD in De-Energization OIR (5-26-20)
Comments on CAISO Hybrid Resources Initiative Second Revised Straw Proposal (5-20-20)
Comments on PD in De-Energization OIR (5-18-20)
Petition for Modification of Decision 19-11-016 in IRP Proceeding (5-14-20)
April 2020
Reply Comments on Resource Adequacy Central Procurement Entity PD (4-20-20)
Joint Response to Motions for Evidentiary Hearings in PCIA Working Group 3 (4-17-20)
Reply Comments on Request for Comments in RPS Proceeding (4-17-20)
Comments on Resource Adequacy Central Procurement Entity PD (4-15-20)
Comments on Limited Rehearing of Decision 19-10-021 (4-6-20)
Track 2 Reply Comments in Resource Adequacy Proceeding (4-2-20)
March 2020
Comments on Request for Comments in RPS Proceeding (3-30-20)
Reply Comments on the Final Report of PCIA Working Group 3 (3-27-20)
Reply Comments on PD considering PCIA working group proposals (3-23-20)
Comments on Track 2 Proposals in RA Proceeding (3-23-20)
Late-Filed Track 2 Proposal in RA Proceeding (3-18-20)
Motion for Leave to Late-Filed Track 2 Proposal in RA Proceeding (3-18-20)
Opening Comments on PD considering PCIA working group proposals (3-17-20)
Motion for Late Acceptance of Opening Comments in PCIA Proceeding (3-17-20)
Reply Comments on RSP PD in IRP Proceeding (3-17-20)
Opening Comments on the Final Report of PCIA Working Group 3 (3-13-20)
Comments on RSP PD in IRP Proceeding (3-12-20)
Reply Comments on Track 1 Proposals in RA Proceeding (3-11-20)
Reply to Responses to CalCCA’s Petition for Modification of D06-06-066 (3-9-20)
Track 1 Comments in Resource Adequacy Proceeding (3-6-20)
February 2020
Comments on Proposed Additional De-Energization Guidelines (2-26-20)
Final Report of PCIA Working Group 3 Co-Chairs (2-21-20)
Opening Comments on Proposed Additional De-Energization Guidelines (2-19-20)
CalCCA Letter of Support to CPUC for GRID Alternatives PFM of D1806027 (2-11-20)
January 2020
Post-Workshop Reply Comments in Direct Access Proceeding (1-27-20)
Comments on Third Straw Proposal – CAISO Resource Adequacy Enhancemants (1-27-20)
Petition for Modification of D.06-06-066 (1-21-20)
Post-Workshop Comments in Direct Access Proceeding (1-21-20)
Comments on CAISO Hybrid Resources Revised Straw Proposal (1-14-20)
Reply comments on Final Working Group 2 Report (Prepayment) by SDG&E, DACC, and AREM (1-13-20)
Comments on IOU post-event reports in De-Energization Proceeding (1-7-20)
Reply Comments on Reference System Portfolio Ruling in IRP Proceeding (1-6-20)
Joint Motion WG 3 to Amend Scoping Memo in PCIA Proceeding (1-3-20)
December 2019
Comments on ALJ Ruling on Proposed Reference System Portfolio and Related Policy Actions (12-17-19)
Comments on AB 1110 Revised Draft Regulations(12-10-19)
Opening Comments on OIR to Oversee RA Program (12-3-19)
November 2019
Comments on PCIA PrePayment Proposal (11-14-19)
October 2019
Comments on Revised Proposed Decision in IRP Proceeding (10-31-19)
Petition for Modification of Decision 19-06-026 in Resource Adequacy Proceeding (10-30-19)
Comments to CAISO on Resource Adequacy Enhancements Second Revised Straw Proposal (10-30-19)
Informal Comments on IRP Resource-to-Busbar Mapping (10-29-19)
Response to ALJ’s Ruling Issuing Staff Reports in Disconnections Proceeding (10-28-19)
Application for Rehearing of Decision 19-10-021 in RA Proceeding (10-24-19)
Motion for Stay of Decision 19-10-021 in RA Proceeding (10-24-19)
Motion to Shorten Time of CPUC Response to Motion for Stay (10.24.19)
Comments to CAISO on Hybrid Resources Straw Proposal (10-21-19)
Responses to Comments in De-energization Rulemaking (10-15-19)
Joint Reply Comments on Motion for Adoption of Settlement Agreement (10-15-19)
Comments on Filing Requirements for 2020 IRPs (10-14-19)
Response to Joint Parties’ Motion on Determining the Capacity Value of Hybrid Resources (10-11-19)
Reply Comments on PD Requiring Electric System Reliability Procurement for 2021-2023 (10-8-19)
Reply Comments on on Electric System Reliability Procurement PD in IRP Proceeding (10-7-19)
Comments on Electric System Reliability Procurement PD in IRP Proceeding (10-2-19)
Reply Comments on PD on WG 1 Issues 1-7 and 11 in PCIA Proceeding (10-1-19)
September 2019
Comments on PD on WG 1 Issues in PCIA Proceeding (9-26-19)
Comments on PD on RA Import Rules in Resource Adequacy Proceeding (9-26-19)
Notice Of Availability Of Second Progress Report Of WG 3 Co-Chairs in PCIA Proceeding (9-26-19)
Proposal in Response to Scoping Memo in De-Energization Proceeding (9-17-19)
Opening Comments in Affordability of Utility Service Proceeding (9-10-19)
August 2019
Joint Motion for Adoption of Settlement Agreement in RA Proceeding (8-30-19)
Reply Comments on IRP Procurement Track Ruling (8-12-19)
Notice of Settlement Conference in RA Proceeding (8-9-19)
Comments on Informal Workshop Reports in RA Proceeding (8-2-19)
July 2019
Reply Comments on Working Group Report in PCIA Proceeding, Questions 8-12 (7-26-19)
Comments on WG One Report on Questions 8-12 in PCIA Proceeding (7-26-19)
Opening Comments on Assigned Commissioner/ALJ Ruling in IRP Proceeding (7-22-19)
Comments on Working Group Report in PCIA Proceeding, Questions 8-12 (7-19-19)
Comments on RA Import Ruling (7-19-19)
CalCCA Comments on RA Import Rules (7-19-19)
Informal Report on Track 2 Workshops 3 and 4 in RA Proceeding (7-17-19)
Motion of Amended Ruling and Extension of Time in IRP Proceeding (7-1-19)
Joint Motion To Amend Scoping Memo in PCIA Proceeding (7-1-19)
June 2019
Progress Report Of WG 3 in PCIA Proceeding (6-24-19)
Response to AReM Petition for Modification of Decision D19-02-022 (6-24-19)
CalCCA Comments on SDG&E/AReM/DACC Suggested Approach to PCIA Prepayment (6-21-19)
Comments on Track 3 Proposed Decision in RA Proceeding (6-13-19)
Post-Workshop Reply Comments in Utility Service Affordability OIR (6-4-19)
May 2019
Reply Comments on Proposed Decision in Direct Access/SB 237 OIR (5-28-19)
CalCCA Comments on Proposed Decision in Direct Access/SB 237 OIR (5-20-19)
Attachment C – in Direct Access/SB 237 OIR (5-20-19)
CalCCA Comments on Draft Resolution E-4998 (5-14-19)
Post-Workshop Comments in Utility Service Affordability OIR (5-13-19)
Notice of Ex Parte Meeting in PCIA Proceeding (5-6-19)
April 2019
Amended Reply Comments on Proposed Decision in IRP Proceeding (4-17-19)
Integrated Resource Planning PD Reply Comments (4-15-19)
CalCCA Reply Comments in Direct Access Proceeding (4-10-19)
Integrated Resource Planning PD Comments (4-8-19)
CalCCA Opening Comments in Direct Access Proceeding (4-5-19)
March 2019
Comments on Track 3 Workshop and Proposals in RA Proceeding (3-22-19)
Comments on Draft Resolution E-4990 (3-4-19)
February 2019
Reply to Response of IOUs’ Motion in PCIA Proceeding (2-19-19)
CalCCA Protest to PGE Advice Letter 5473-E (2-14-19)
Joint Motion of PGE and CalCCA for Workshop Time Extension (2-14-19)
January 2019
IRP – Comments of Joint CCAs on PSP (1-31-19)
Reply Comments on Reliability Ruling (1-14-19)
Comments on Draft Resolution E-49771 (1.11.19)
December 2018
Reply Comments on Proposed Decision in RA Proceeding (12-17-18)
Comments on Proposed Decision in RA Proceeding (12-11-18)
Reply Comments on PD in Tree Mortality Proceeding (12-3-18)
PCIA – Prehearing Conference Statement (12-02-18)
November 2018
Reply in IRP Framework Proceeding (11-30-18)
Opening Comments on Proposed Decision in Tree Mortality Proceeding (11-28-18)
PCIA Application for Rehearing (11-19-18)
Comments on Confidential Treatment in IRP Framework Proceeding (11-16-18)
October 2018
Comments on Assembly Bill 1110 Implementation Plan (10-25-18)
Reply Comments to ALJ Ruling in RA Proceeding (10-24-18)
Response to ALJ Ruling in RA Proceeding (10-17-18)
September 2018
Comments in RA Proceeding (9-14-18)
Reply Comments in PCIA Proceeding (9-13-18)
Comments in IRP Proceeding (9-12-18)
Comments on Alternate Proposed Decision in PCIA Proceeding (9-6-18)
Protest of IOU Advice Letters – Financial Security Requirements (9-4-18)
August 2018
Reply Brief in Tree Mortality Proceeding (8-31-18)
Comments on PCIA Proposed Decision (8-21-18)
Closing Brief in Tree Mortality Proceeding (8-13-18)
Comments on Affordability OIR (8-13-2018)
Comments on Disconnections/Energy Access OIR (8-9-18)
Responsive Comments in RA Proceeding (08-08-18)
July 2018
Protest to PG&E Advice Letter 5322-E (7-19-18)
Direct Testimony in Resource Adequacy Proceeding (7-10-18)
June 2018
Additional Brief in PCIA Proceeding (6-25-18)
CalCCA Reply Brief in PCIA Proceeding (6-15-18)
CalCCA Comments on Green Book (6-11-18)
CalCCA PCIA Opening Brief (6-01-18)
May 2018
CalCCA Tree Mortality NBC Reply Comments (5-18-18)
CalCCA Comments on SB 350 GHG Target Methodology (5-14-18)
CalCCA Comments on the Energy Division Staff Proposal (5-11-18)
CalCCA Reply Comments on Proposed Decision Establishing Reentry fees and Financial Security Requirements for CCAs (5-01-18)
April 2018
CalCCA Reply Comments on GHG Emissions Accounting Methods (4-30-18)
CalCCA_PCIA Rebuttal Testimony (4-23-18)
CalCCA Comments on GHG Emissions Accounting Methods (4-20-18)
CalCCA PCIA Opening Testimony (4-2-18) (zip file)
Exhibit 3-A Sutherland Testimony
Exhibit 3-B Abramson Testimony
Exhibit 3-D Schoenblum Testimony
March 2018
AL_3939-G_5235-E CalCCA Protest_PGE proposed revisions to billing services (3-12-18)
CalCCA Response to Petition for Modification of the Code of Conduct (3-1-18)
January 2018
CCA Parties’ Comments on RA Scoping Memo (1-30-18)
CalCCA Reply Comments on IRP Proposed Decision (1-22-18)
CalCCA Reply Comments – Draft Resolution E-4907 (1-18-18)