Regulatory Update: California Public Utilities Commission Issues Order for Oversight of Energy Efficiency Portfolios

The California Public Utilities Commission (CPUC) has initiated a rulemaking process to oversee energy efficiency portfolios, policies, programs, and evaluation. Small Business Utility Advocates (SBUA) has submitted Reply Comments on the Proposed Decision, addressing concerns regarding the Potential and Goals (P&G) study and the need for flexibility in incorporating new policies and external factors.

Key Takeaways:

• The CPUC has issued an Order Instituting Rulemaking for Oversight of Energy Efficiency Portfolios, Policies, Programs, and Evaluation, Rulemaking 25-04-010.
• SBUA supports San Diego Gas & Electric Company's (SDG&E) recommendation to re-evaluate established energy efficiency goals prior to the next P&G cycle.
• SBUA agrees with the Guidehouse practice of including only existing and future policies with a high degree of certainty of adoption in the P&G study.
• The P&G study must remain flexible enough to incorporate new policies and external factors that may significantly influence energy efficiency outcomes.
• SBUA emphasizes the need for accurate accounting of potential impacts on programs from new policies and external factors.
• SDG&E provides examples of California Assembly Bill 130 and recent federal legislation that were enacted after the foundational research phase of the P&G study.

Statistics:

• The CPUC has issued an Order Instituting Rulemaking for Oversight of Energy Efficiency Portfolios, Policies, Programs, and Evaluation, Rulemaking 25-04-010 (filed April 24, 2025).
• SBUA submitted Reply Comments on August 19, 2025.
• The Proposed Decision was dated July 25, 2025.
• SDG&E's comments on the Proposed Decision are dated July 25, 2025, and page 3 includes a discussion on the potential impacts of future policies.

Sources:

• "REPLY COMMENTS OF SMALL BUSINESS UTILITY ADVOCATES ON PROPOSED DECISION ADOPTING ENERGY EFFICIENCY GOALS FOR 2026-2037" (August 19, 2025)
• California Public Utilities Commission's Rules of Practice and Procedure
• "Comments on Proposed Decision" by San Diego Gas & Electric Company (July 25, 2025)