California Decision Aims to Accelerate Timelines for Electrification, EV Charging Projects

On September 12, the California Public Utilities Commission (CPUC) issued Decision 24-09-020, which sets timelines for the state’s three largest investor-owned utilities to complete customer energization projects. 

What is energization? Essentially, it’s the process of connecting electrification projects—such as electric vehicle charging equipment or clean heating and cooling systems—to the electric grid so that we can make use of our clean energy technologies. By setting timelines to complete energization projects, the CPUC decision recognizes that the state’s clean energy transition can’t happen without the timely integration of electrification projects to the grid.

This decision applies to California’s major investor-owned utilities (IOUs)—Pacific Gas & Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company—and requires them to accelerate energization as a means to meeting our clean energy goals. Specifically, to meet the ambitious goals of carbon neutrality in California by 2045¹ and net zero emissions in the U.S. by 2050,² utilities must accelerate energization processes, reduce delays, and improve communication with customers. 

IREC has been actively engaged in the decision’s proceedings and contributed to the decision’s results. This blog post digs into the CPUC’s decision requirements for energization timelines, how the decision sets out to implement current clean energy laws and goals, and why accelerating energization is crucial for our transition to clean energy. 

Complying with California’s Energization Laws and Rules 

The decision is an important measure to keep California on track to meeting its clean energy, electric vehicle, and climate targets. It also responds to several related pieces of legislation.

Senate Bill 410 and Assembly Bill 50

Due to concerns about slow energization processes and backlogs of energization requests, California legislators passed two laws last October to accelerate customer energization and help ensure that the state’s clean energy goals can be met on time. 

Senate Bill (SB) 410 addressed the need for customers to be “promptly energized” by requiring electrical distribution system upgrades, improved planning, faster service upgrades, minimized delays, and workforce enhancement. Because energization processes had been taking too long to complete, SB 410 required that the CPUC create timelines: one to show the IOU’s average time to complete a customer request, and the other to set a maximum time for IOUs to complete a customer’s new or upgraded electric service request for their property.

Similarly, California Assembly Bill (AB) 50 directed the CPUC to hold electrical corporations accountable for working through their backlog of energization requests. AB 50 states that IOUs that had failed to energize at least 35% of completed applications within a year, needed to demonstrate by the end of 2024 that they had completed 80% of applicable backlogged energization projects. The bill also required a streamlined process for customers to report project delays.

To further accelerate energization, AB 50 requires each IOU to evaluate and update its distribution planning process—the strategic planning process of identifying and managing updates and investments to ensure future customer demands will be met. The CPUC must also collect data on each IOU’s energization activities, which include the timely start of service and timely fulfillment of energization requests such as new service connections and increased capacity for existing connections.

Regulations for Cars, Trucks, and Fleets

This decision also supports California’s electric vehicle targets, which slow energization processes put in jeopardy. In 2020, California adopted the Advanced Clean Trucks Act (ACT) to reduce the ozone and greenhouse gas emissions from trucks on the road. The act requires medium- and heavy-duty vehicle manufacturers to increase sales of zero- or near-zero emissions vehicles. This essentially caps the annual number of fossil-fuel vehicle sales.

Energization delays have been particularly problematic for medium- and heavy-duty charger projects, which demand higher levels of power and are thus more likely to require grid upgrades. Energization of these projects can take many years, threatening the ACT timelines. 

Two years after the ACT, California passed Advanced Clean Cars II for light-duty vehicles and Advanced Clean Fleets (ACF) for truck fleets. Advanced Clean Cars II aims to make all new passenger vehicles zero emissions by 2035. Complimentary to ACT, Advanced Clean Fleets requires that fleet operators adopt increasing percentages of zero-emission vehicles each year, buy only zero-emissions trucks starting in 2024, and retire internal combustion engine vehicles after a certain age or mileage driven. 

As more clean energy vehicles take to the road each year, utilities must be able to make the infrastructure updates needed to charge them. The Rocky Mountain Institute notes that in order to comply with Advanced Clean Fleets, “utilities will need to work with fleets and public utility commissions to develop and implement grid upgrades.”³ In short, California needs energization processes that are efficient and timely if it’s going to meet its goals and stay in legal compliance.

Moreover, seventeen other states, including the District of Columbia, have to date adopted California’s ACT and ACF requirements.⁴ Other states that have adopted these targets, particularly the ACT, may encounter similar challenges with energization delays. California has the opportunity to lead the way and serve as a model of efficient energization.

Understanding the Decision’s Requirements for Public Utilities

The Commission recognizes the need for greater consistency and transparency regarding how long energization projects take to be completed, given the multiple investor-owned utilities and small, multi-jurisdictional utilities across the state. The decision requires that IOUs take the following actions:

• Accelerate energization of customers.

• Increase transparency around what steps of the energization process are in the utilities’ control and the time necessary for the large electric IOUs to complete the steps in customers’ energization project request(s).

• Clarify the process for customers to report energization delays to the California Public Utilities Commission.

• Plan and prioritize energization work to meet the new targets and timelines.

• Report on time periods that exceed the targets.

• Adopt remedial actions if the targets are exceeded.

Setting Energization Project Targets

The Commission is currently required to establish “reasonable average and maximum target energization periods.”⁵ The targets established in the decision seek to “enable customers seeking to electrify to have their requested new or upgraded services electrified more quickly.” IOUs must reduce timelines “for all customers seeking new or upgraded electric services, rather than specifically targeting certain customer or project types that are easier to accelerate.”

During the comment period between February and May of 2024, the CPUC heard arguments for establishing statewide targets vs. establishing IOU-specific targets for the energization of new or increased electric load. Ultimately, the decision settled on consistent statewide targets that will hold the IOUs to the same “goal posts,” allow for tracking and comparison, and increase transparency.

The table below shows the average targets and maximum targets for energization work that requires only new or upgraded equipment at the project site, not beyond.

Average targets were developed using data submitted by the IOUs, and maximum targets were set using the lowest average, with the intention of reducing project completion times overall. 

Further, the decision orders that “no more than 5% of customer requests for new or upgraded services shall exceed” the maximum target.

Upstream Capacity Project Timelines, Not Targets

When an energization project requires new or upgraded infrastructure beyond the project site, such as a new or upgraded circuit or substation, that work is designated as a separate project and gets labeled an “upstream capacity project.” 

While the CPUC believes that more timely completion of upstream capacity projects is important for meeting the state’s clean energy goals, it has decided not to set targets for these kinds of projects. Instead, it has set statewide maximum timelines that “set expectations for utility performance and planning when an energization request triggers upstream capacity work.” 

The Commission cites two reasons for being unable to set targets: first, the “unique differences for each upstream capacity upgrade project that complicate the Commission’s efforts to develop standardized average and maximum targets;” and second, “insufficient and inconsistent data” provided by the IOUs. They plan to revisit these timelines in Phase 2 of these proceedings.

The table below shows the maximum timeline in calendar days for upstream capacity projects.

If an energization project triggers an upstream capacity upgrade, the IOUs “are authorized to pause tracking the energization target tracking process,” and must notify the customer of the additional need and potential fees. The IOU must then begin separately tracking the time it takes to complete the upstream capacity project.

How the Decision Seeks to Improve Customer Communications

Just as important as timely energization is clear and thorough communication with customers regarding project requests. The CPUC decision states that “communications must improve, especially between steps, informing [customers] of targets, delays, application denials, outstanding issues, anticipated timing for completion, status updates,” and more.

One important step is a new requirement for each new customer to be assigned an account/project manager within 10 days of their application approval. This person will serve as a main point of contact and provide project transparency in the form of regular status updates, general information about the energization process, and details about project steps, targets, timelines, and reasons for any delays.

A New Process for Customers to Report Delays  

The decision adopts a new form for customers to use when reporting a project delay. If a customer’s request or project exceeds the maximum target, they can now submit the Energization Delay Reporting form, created by the CPUC and made available online and in print. These reports are designed not only to address the delays, but also to provide data and insights to the CPUC about the delay’s causes. The Commission seeks to gather “a full accounting of current scenarios an individual customer may face that create energization delays.”

New IOU Reporting Requirements

The Commission is required to establish annual energization data reporting processes and identify minimum energization reporting requirements for IOUs to submit. However, because IOUs have not historically been required to track energization project timelines, the CPUC has lacked transparency into how long the process takes. 

Here are the new IOU reporting requirements:

• The three largest IOUs will jointly create a new reporting template.
• IOUs will track time to complete energization steps within their control and outside their full control.
• At a minimum, the reporting must include:
  • the average, median, and standard deviation time between receiving an energization application and when the energization is completed; 
  • explanations for energization time periods that exceed the target maximum for energization projects; 
  • constraints and obstacles to each type of energization, including funding limitations, qualified staffing availability, or equipment availability; and 
  • any other information required by the Commission.
• Beginning in March 2025, IOUs will submit reports every six months for projects submitted on or after January 31, 2023.

What’s Next for Energization in California

This decision covers Phase 1 of this proceeding on energization timelines. In Phase 2, the CPUC expects to receive additional IOU data for upstream capacity project timelines and may establish firmer targets for that work. 

In the meantime, there will be a public workshop within 90 days of receiving the first IOU data report, which is due on March 31, 2025. That workshop will include a discussion of the data and the possible need for revising targets.

During the public comments period in this proceeding, IREC provided in-depth feedback and multiple recommendations for the Commission to be in legal compliance, adopt meaningful and ambitious targets, and create a reporting process that offers real transparency and insight into delays. 

Because we see the potential in this decision to truly accelerate energization and minimize delays, our next blog post will examine the areas where IREC hopes the Commission will move forward with mandates and expectations that move us toward a 100% clean energy future.

Sources

• https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/transportation-electrification/energization/fact-sheet-energization-091224.pdf
• https://www.cpuc.ca.gov/news-and-updates/all-news/cpuc-starts-work-to-establish-customer-energization-timelines-2024#:~:text=%E2%80%9CTimely%20energization%20is%20critical%20to,said%20CPUC%20President%20Alice%20Reynolds.

1. California Executive Order B-55-18
2. Executive Order on Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability
3. Understanding California’s Advanced Clean Truck Regulation
4. Adoption of California’s Clean Vehicle Standards by State
5. Public Utility Code § 934 (a)

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