USA – CALIFORNIA Law and Practice Contributed by: Nora Sheriff, Gwenneth O’Hara, Samir Hafez, Antonio Carrejo and Elisa Rivas, Buchalter
Revised Power Source Disclosure Programme (PSD)
time resources on behalf of customers of all load serving entities (LSEs) subject to the CPUC’s IRP procedure. In August 2024, the DWR was directed, as the CPE, to procure 10.6 GW of long
On 12 February 2025, the CEC approved amend- ments to the PSD regulations. These changes, driven by SB 1158, require retail electricity sup- pliers to track and report their power sources and associated greenhouse gas (GHG) emis- sions on an hourly basis by 2028. Long-Term Regional Transmission Planning and Cost Allocation Reform On 13 May 2024, FERC issued Order No 1920. This order established a comprehensive regula- tory framework requiring transmission providers to engage in long-term regional transmission planning over at least a 20-year horizon, and to develop cost-allocation methods for transmis- sion facilities selected through these processes. In California, this federal order directly governs CAISO’s planning activities and defines avenues for the CPUC and other state agencies in shap- ing future transmission development. Multi-Property Microgrid Tariff Rules On 18 November 2024, the CPUC adopted mul- ti-property microgrid tariffs, also referred to as community microgrid tariffs, for PG&E, SCE and SDG&E. These tariffs apply to community micro- grids that can be owned by private entities, Tribal or local governments, and CCAs. However, the incumbent IOU will continue to operate and con- trol the microgrid, and to own and maintain its existing electrical grid infrastructure within the microgrid’s boundary. Customers located within the microgrid will also remain customers of their IOU or CCA. These rules were developed following extensive stakeholder input, which included industry par- ticipants’ proposals for alternative tariff designs that allowed for non-IOU operation and control
lead-time emerging technologies. 1.6 Recent Changes in Law or Regulation
Over the past year (May 2024 to May 2025), Cali- fornia’s power industry has experienced several material changes in law and regulation, along- side significant ongoing policy developments. Resource Adequacy Slice of Day Construct Implementation The CPUC is actively implementing a new resource adequacy (RA) framework known as Slice of Day (SOD), slated to go into full effect in the 2025 compliance year. This marks a fun- damental shift in how RA is measured for com- pliance with the CPUC’s mandatory RA pro- gramme applicable to IOUs, CCAs and ESPs. Under this new construct, instead of relying on a single peak demand hour, the SOD construct requires LSEs to demonstrate that they have suf- ficient capacity to meet demand in every hour of a 24-hour period, each month. Enhanced Standards for Energy Storage Systems In March 2025, the CPUC adopted General Order (GO) 167-C to overhaul the operational and safe- ty standards applicable to electric generating assets. Crucially, these standards now explicitly apply to battery energy storage systems, and include new mandates for maintenance, opera- tion protocols, emergency response planning, incident reporting, and co-ordination with CAISO on outages.
336 CHAMBERS.COM
Powered by FlippingBook