University of San Diego

San Diego Journal of Climate & Energy Law

Library of Congress Authority File


This Article focuses on the CPUC RA program’s role in helping to keep the lights (and air conditioning) on while advancing California’s continued mission to decarbonize the grid, even in the face of extreme climate-change induced weather events. It explains how the existing RA program creates risks of overestimating the availability of some capacity, including solar, wind, and energy storage resources, to meet demand in the increasingly critical evening hours. These risks are attributable to the program’s original design, which assumed that all resources will be available to meet load in all hours. This Article outlines the major CPUC regulatory developments since August 2020, aimed at reforming the foundation of RA to better plan and account for the availability limitations inherent in the rapidly shifting electricity resource mix that is necessary to meet California’s ambitious clean energy goals. In sum, this Article demonstrates how the pathway to a zero-carbon future in California is inextricably linked to the successful development and implementation of a reformed RA capacity paradigm that properly ensures procurement of resources capable of meeting both gross peak demand and energy requirements across all hours. Absent these key features, reliability will suffer, and accelerated decarbonization will almost certainly face major roadblocks.

Part II provides background on RA in California. Part III describes some of the main components of California’s existing RA program. Part IV explains the main factors underlying the critical need for RA reform in California, including how integration of renewables and energy storage uniquely affects the existing structure. Part V introduces the future of RA in California: the CPUC’s newly reformed “24-hour slice of day” RA framework that will be implemented beginning with a test year in 2024 and will pave the way for a fully decarbonized, reliable grid. Finally, Part VI briefly concludes.