Regulatory filings 2019 – present

We influence energy regulation on the national and state levels by providing decision-makers with information, analysis, and proven solutions. To advance forward-looking energy policies, the Clean Coalition is in the trenches shaping regulatory processes that result in decisions that can make or break our nation’s clean energy future. Below is a list of filings and related documents that the Clean Coalition has officially submitted in 2019 and 2020. For the previous decade of Clean Coalition filings, see this page.

2026

CPUC: Flexible Service Connections with Power Control Systems — Reply Comments on Proposed Decision | 23 January 2026
Clean Coalition’s reply comments support the need to include secondary distribution upgrades as an eligible upstream capacity ugprade for which a customer may request a flexible service connection, request the Commission mandate guidance for how engineering review will be conducted if behind-the-meter solar is deployed, maintain that the utilities should enable customers to access limited load profiles prior to submitting full applications, advocate for the creation of an energizations Unit Cost Guide for Rules 15/16, and urge the Commission to require customer benefits from a flexible service connection rather than ratepayer benefits.

CPUC: Flexible Service Connections with Power Control Systems — Comments on Proposed Decision | 16 January 2026
Clean Coalition supports the Proposed Decision, but our comments recommends that SDG&E also be required to develop a standard offer flexible service connection alongside SCE and PG&E. We also note that the proposal for at least three seasonal capacity limit values and two daily capacity limit values per day risks shifting customer demand to off-peak periods when the fossil content of energy is high and instead recommend three daily values to shift customer consumption to the middle of the day (when solar energy is abundant).

CPUC: Track 3 – Flexible Connections — Reply Comments on Commissioner Ruling with Questions on Flexible Connections | 2 January 2026
Clean Coalition’s reply comments concurs with the Interstate Renewable Energy Council that the CPUC should work on a roadmap to utilize low-cost scalable solutions for flexible connection rather than waiting until utility-owned DERMS are fully deployed and capable of dynamic signalling. We note that SCE’s ideal solution involves dynamic hosting capacity, which is not realistic given SCE’s difficulties keeping the ICA maps up-to-date on a monthly basis (including 1/3 of feeders not included in the dataset being modeled) and underscore that the responses by SCE and SDG&E on the potential value of distribution deferral demonstrate that flexible connections are a viable solution so long as the program design is streamlined and compensation is sufficient to draw customer interest.

2025

CPUC: Track 3 – Flexible Connections — Opening Comments on Commissioner Ruling with Questions on Flexible Connections | 19 December 2025
Clean Coalition comments introduce Energy Tetris to demonstrate the importance of flexible connections as both a temporary and permanent solution. We address the need for flexible connections for both polyphase and single phase customers and underscore the potential value that flexible connections can create during abnormal grid conditions by working to prevent any grid emergency from occurring.

PURA: Renewable Energy Tariff Successor Study Program — Comments Responding to Questions from Commissioner | 12 December 2025
Clean Coalition comments support an option for front-of-meter storage (including storage that is not co-located with generation projects), suggest that the program cap should be 150 MW, and identify a parking canopy incentive as an effective method for achieving multiple policy objectives simultaneously. We also urge PURA to design a program focused on promoting infill deployments to preserve pristine natural lands and utilize the built environment.

CPUC: NEM Interconnection Application Fees — Protest of PG&E Advice Letter 7760-E | 3 December 2025
The Clean Coalition’s protest vehemently objects to PG&E’s proposal to increase NEM application fees for projects over 30 kW from $145 to $2,000. We argue that the fee is exorbitant and the proposed increase goes far beyond the scope of what the CPUC envisioned could be requested via an Advice Letter and the proper venue is a full rulemaking. Furthermore, we note that the greatest cost increases are from PG&E’s administrative costs, not customer-driven costs from complicated projects, as suggested.

CPUC: Rule 21 Interconnection — Opening Comments on Order Instituting Rulemaking | 20 October 2025
Clean Coalition’s comments emphasize the importance of updating the cost-causer model used to allocate costs for distribution upgrades with a process that enables a more equitable sharing of costs. We also identify the ambiguity surrounding the Electrical Independence Test process as a barrier to DER deployment that should be clarified.

PURA: Renewable Energy Tariff Successor Study Program — Comments on Study | 10 September 2025
Clean Coalition advocates for a Feed-In Tariff with Market Responsive Pricing as an ideal tool to enable the widespread deployment of renewable energy technologies, especially solar and solar+storage. Our comments clearly lay out a FIT structure that addresses the FIT rate, specific adders, tactics to streamlined interconnection, how to adjust the price based on market conditions, and co-benefits from FIT projects.

CPUC: Demand Flexibility Rate Design — Comments on Proposed Decision Guidelines for Demand Flexibility Rate Design Proposals | 19 August 2025
Clean Coalition’s reply comments advocate that the CPUC should require a technology-neutral demand flexibility rate that includes compensation for exports. We support keeping the proceeding open to ensure that data sharing from the IOUs to CCAs is smooth and streamlined, support a locational Marginal Distribution Capacity Cost, and request clarification on the term DLAP (which should be “default” not “distribution” Load Aggregation Point).

CPUC: PG&E Motion to Increase 2025 and 2026 Energization Cost Caps — Reply Comments on Proposed Decision Adopting Increased 2025 and 2026 Energization Caps | 19 August 2025
Clean Coalition’s reply comments continue to urge rejection of the PD, in this case by supporting comments from Cal Advocates and The Utility Reform Network (TURN). We note that PG&E’s proposal is insufficient to complete the needed work at a pace that will completely eliminate the energization backlog in two years, criticize the inclusion of future customer loads to justify small impacts on customer rates, and reiterate that the overreliance on contractor labor is due to a lack of planning over the last decade and should not be rewarded, and lament PG&E’s failure to transparently produce the needed evidence on ratepayer impacts to allow the CPUC to make an informed decision.

FERC: SDG&E FERC Order 2023 WDAT Compliance Filing — Answer to Motion for Expedited Consideration of SDCP & CEA | 18 August 2025
Clean Coalition’s answer strongly supports the Motion by San Diego Community Power (SDCP) and Clean Energy Alliance (CEA) for an expedited ruling by FERC on SDG&E’s Order 2023 compliance filing. We argue that the Motion clearly demonstrates the urgent need for action by FERC, that the premature closing of the WDAT Independent Study Process perpetuates the existing Local RA shortfall, that SDG&E’s unique consolidated GIP necessitates a direct ruling, and that FERC has already ruled on compliance filings for other RTOs and IOUs (so SDG&E should be next).

CPUC: PG&E Motion to Increase 2025 and 2026 Energization Cost Caps — Comments on Proposed Decision Adopting Increased 2025 and 2026 Energization Caps | 14 August 2025
Clean Coalition’s comments urge a rejection of the Proposed Decision (PD), noting that the PD rewards PG&E for years of inaction and potentially incentivizes future backlogs (to enable subsequent requests for higher Cost Caps). We lambast the CPUC’s allowance of high-priced contract labor that is triple the cost of PG&E’s internal labor and raise concern about the lack of up-front guardrails that prevent overspending by the utility.

CPUC: SOMAH, RESBCT — Comments on ALJ Ruling Seeking Comments on SB 355 Implementation | 18 July 2025
Clean Coalition’s response strongly supports expanding the Solar on Multi-Family Affordable Housing (SOMAH) program with the intention of reaching and eclipsing the 300 MW program statutory requirement. We advocate expanding program eligibility to include master metered sites, arguing that these sites represent a huge opportunity to bring renewable energy to low-income Californians and accelerate the transition to electrification to legacy sites.

CPUC: Microgrids & Energy Storage — Petition for Modification of CALSSA requesting permanent extension of storage sizing limit expemtions | 14 July 2025
Clean Coalition’s reponse strongly supports CALSSA’s PFM as necessary to enable customer-sited resilience and promoting reliability benefits that are aligned with grid needs and CPUC policy. We argue that the existing storage sizing limit exemption has caused no problems and that oversized storage is essential for true renewables-driven resilience.

CPUC: Data Working Group — Comments on Data Working Group | 13 June 2025
Clean Coalition’s comments advocate for the creation of a Microgrid Clearinhouse that will collect important data for microgrids (load data, system size, climate zone, interconnection issues, etc…) to streamline the process of deploying a microgrid and ensure that performance validation occurs once a system is online. We also support a reduction in the stringency of the existing 15/15 rule (which limits the availability of load data in the name of data privacy), agree on the need for data collection on front-of-meter DER and energy efficiency/electrification programs, and note that data must be properly organized (cleaned and formatted) to be of value.

CPUC: Microgrid Incentive Program — Protest of Draft Resolution | 11 June 2025
Clean Coalition’s protest supports the desire to increase accessibility of the MIP for local and tribal governments but opposes shifting 100% of the risk to the Community Microgrid developers. We note that the 100% letter-of-credit forces a developer to be financially responsible for circustances outside of its control, such as a potential elimination/reduction of the ITC, interconnection issues, supply chain shortages, natural disasters, pandemics, etc… We also urge the CPUC to include force majeure provisions, which are common in contracts across multiple different industries, including the energy industry.

CEC: Non Energy Benefits and Social Costs — Comments on Scoping Workshop | 22 May 2025
Clean Coalition’s Joint Comments (authored by the Center for Biological Diversity) urge the CEC to include all Non-Energy Impacts (NEIs) in the scope of the proceeding and clarify that the affordability benefits of including NEIs in planning are significant. The comments conclude by providing an example of the opportunity cost of considering NEIs – such as early planning for a Microgrid in LA before the recent fires due to the need for resilience – and considers the hidden costs of “avoiding” NEIs in rates.

CPUC: Avoided Cost Calculator — Opening Comments on Guidelines for the 2026 ACC | 12 May 2025 
Clean Coalition’s comments support the inclusion of equity considerations (such as the Societal Cost Test) in the Avoided Cost Calculator (ACC), encourages the CPUC to include front-of-meter resources in the ACC, supports greater geographic granularity, and promotes transparency in the decision-making process.

CEC: EV Charging with Solar Microgrids EPIC Grant — EPIC Grant Scoping Workshop | 1 April 2025
Clean Coalition’s comments support the CEC’s efforts to study the value creation opportunities from pairing electric vehicle (EV) charging with Solar Microgrids. We argue that the flexibility enabled by a Solar Microgrid can help avoid or defer infrastructure upgrades, potentially saving the ratepayers billions of dollars, and urge the CEC to separate the results of this grant funding opportunity from any preconceived notions about DER deferral due created by lackcluster CPUC pilots like the Distribution Investment Deferral Framework. To conclude, our comments address the most important lessons learned that can come from this grant project deployment, including how to streamline the request/approval process for receiving a flexible connection, compensation mechanisms for DER services, and clearly laying out the full value stack.

CPUC: Track 3, Smart Inverter Operationalization — Reply Comments on ALJ Ruling | 27 March 2025
Clean Coalition’s reply comments note the widespread belief amongst parties that maximizing use of the existing grid and avoiding future infrastructure projects can save the ratepayers billions of dollars and argue that flexible connection service agreements (FSCAs) can provide sustained value by deferring grid upgrades. We urge the CPUC not to conflate the potential of FSCAs to create value with that of previous badly-designed DER deferral programs and note that the true benefit of avoiding an infrastructure project includes avoiding the total cost – the rate of return, operations & maintanence costs, and capital costs – not just capital costs. Finally, we address the important opportunity to use FSCAs in ways that benefit disadvantaged communities and argue that CCAs and IOUs should have a level playing field when it comes to issuing flexibility offerings.

CPUC: Track 3, Smart Inverter Operationalization — Opening Comments on ALJ Ruling | 13 March 2025 
Clean Coalition’s comments urge the CPUC to develop an overarching framework for flexibility based on two umbrella issues: streamlined interconnection/energization and maximizing ratepayer savings through distributed grid services. We provide a list of 5 connection-related use cases and 7 related to grid services. In addition, we emphasize the importance of having actionable and accurate ICA maps to ensure that finding locations to site a project can be done efficiently without relying on complicated and costly utility studies.

CPUC: Flexible Service Connections with Power Control Systems — Opening Comments on ALJ Ruling | 13 March 2025
Clean Coalition’s comments strongly support the development of a framework that enables flexible service connection agreements (FSCAs) to connect load to the grid before a costly grid upgrade can be completed. We raise the success that Australia has had with their dyanmic operating envelope framework, which has roughly doubled the amount of energy a residential solar+storage system can export to the grid. Our comments support aligning flexibility with actual grid needs with as much granularity as possible, urge the CPUC to prioritize accurate/actionable ICA maps, and profer that flexibility should be permitted on constrained and unconstrained feeders.

CPUC: Energy Generation in Priority Communities — Reply Comments on Order Instituting Rulemaking | 11 March 2025
Clean Coalition’s reply comments support the need to fully value the benefits and costs of programs that support renewable energy deployments in disadvantaged communities. We argue that the proceeding should prioritize SOMAH by expanding eligibility to master metered properties and promote the deployment of microgrids at SOMAH properties.

CPUC: Rule 21 Interconnection — Letting raising outstanding issues for successor proceeding | 20 February 2025 
The Joint Parties (GPI, Clean Coalition, 350 Bay Area, and Quantum Energy) raise concerns with the premature closure of the Rule 21 interconnection proceeding, which has left numerous issues unresolved and no clear venue or timeline on how to address them or and other types of reform. We urge the CPUC to create a new interconnection proceeding to address the implementation of previous CPUC orders and developing other broad reforms, clarify coordination with other proceedings, and institute reforms to prevent future schedule delays that have plagued previous interconnection proceedings. The letter concludes with a detailed list of 14 subjects that a successor proceeding should address that will help put California on the path to achieve its clean energy goals.

CPUC: PG&E’s Motion to Revise 2025 and 2026 Energization Cost Caps — Reply Brief | 31 January 2025
Clean Coalition’s Reply Brief urges the CPUC to reject PG&E’s request for more than $2 billion in additional funding over the next two years to address the massive backlog of incomplete energizations. PG&E’s proposal relies entirely on third-party labor to conduct grid upgrades at more than triple the cost of internal labor. We agree with The Utility Reform network (TURN) that PG&E’s proposed plan – effectively a bailout – makes no attempt to minimize costs, leaving the ratepayers to foot the bill once again. If approved, PG&E will make no attempt to hire or train any internal staff to reduce labor costs and will make a profit on the entire needlessly inflated expenditure (e.g., via a rate of return on $2 billion of extra spending), which is unacceptable. We highlight the fact that PG&E has only completed one internal review of the departments related to energizations in the last 10 years and made no effort to increase internal staffing levels as the backlog grew to massive proportions as two reasons the CPUC should reject the PG&E proposal and/or withdraw PG&E’s ability to receive a rate of return on this funding.

CEC: Non-Energy Impacts  — Comments on Scope of the NEI Proceeding | 10 January 2025
These Joint Comments underscore the needy to clarify the scope of the proceeding and specify which non-energy impacts will be considered in the Energy Commission’s analysis. We specify that outcomes of this proceeding should be the full inclusion of non-energy impacts in resource planning and investment decision making, a plan to include non-energy impacts in all Energy Commission reports (such as the Integrated Energy Policy Report and the 2025 and 2026 California Energy Resource and Reliability Outlook Reports), and a process to facilitate continuous refinement of the methods used to calculate non-energy impacts as additional granularity becomes possible. Lastly, we suggest that the Energy Commission should coordinate with the Disadvantaged Communities Advisory Group to ensure community voices are heard.

CPUC: Future of the Grid Study — Reply Comments on Future of the Grid Study | 10 January 2025
Clean Coalition’s reply comments explain why a crucial step in the transition to a distribution system operator (DSO) should be requiring the investor-owned utilities (IOUs) to divest from all transmission assets. The higher rate of return that the utilities receive for investing in transmission versus distribution infrastructure means the IOUs are inherently motivated to maximize transmission spending. Divesting from all transmission assets will narrow the focus of the IOUs to maintaining and operating the distribution system to earn revenue, lowering total grid costs for the ratepayers by prioritizing the optimization of the distribution grid before over investing on transmission.

CPUC: Customer-Sited Meter Socket Adapter (Rule 31) — Response to PG&E Advice Letter 7453-E | 9 January 2025
Clean Coalition’s response highlights the benefits of customer-owned meter socket adapters in avoiding costly grid upgrades and providing site-level resilience. We support PG&E’s intention to formalize a procedure for the expedient deployment of customer-sited meter socket adapters as Rule 31 but urge the CPUC to mandate two additional actions before approving PG&E’s Advice Letter. First, the meter socket adapters must be available for all customer classes not just single-meter residential properties since the technology works in the same way regardless of facility type. Second, we advocate that the CPUC should require SCE and SDG&E to work with PG&E to ensure that customer-sited meter socket adapters can be deployed throughout the IOU service territories via the same streamlined process.

2008 – 2024 regulatory filings

See this page for the previous decade of Clean Coalition regulatory filings