On November 21, 2024, Pacific Gas & Electric Company (PG&E) filed an application at the California Public Utilities Commission (CPUC or Commission) seeking approval of a new Electric Rule No. 30 (Electric Rule 30) to address the interconnection of non-residential customers requesting retail electric service at transmission-level voltages between 50 kilovolts (kV) and 230 kV, otherwise known as transmission-level customers.[1]  PG&E’s current electric rules are intended for distribution-level interconnections.[2]  As such, when a customer applies for transmission-level retail electric service, PG&E and the customer negotiate unique interconnection terms, and PG&E is required to make an “exceptional case”[3] filing with the Commission for approval of the negotiated agreement.  PG&E states that creating a uniform tariff (proposed Electric Rule 30) will streamline both the negotiation process and the approval process, resulting in faster interconnection timelines.

According to PG&E, there has been a significant increase in transmission-level service requests at 50 kV and above.  Between 2014 and 2022, PG&E interconnected 16 customers at transmission-level voltages with a total load of 145 megawatts (MW).  Since 2023, however, PG&E received 34 applications for transmission-level interconnection service with an estimated total load of 4,400 MW, which is a 3,000% increase in transmission-level demand.  More than half of the applications for new transmission-level retail service are from data centers. PG&E has also received a number of transmission-level service requests from universities, manufacturing, industrial, and electric vehicle-charging customers. PG&E proposes new Electric Rule 30 to address these particular customers and implement a more efficient and transparent approach.

Electric Rule 30 Overview[4]

Electric Rule 30 includes provisions that address design and construction specifications, ownership of facilities, the installation of facilities to provide service to new transmission-level retail electric service customers, including both overhead and underground facilities, and customer’s responsibilities for PG&E facilities.

One of the key elements of Electric Rule 30 is that customers must provide an advance payment for the actual cost of electric facilities (with the exception of transmission network upgrades) that will be constructed to interconnect their new facilities. PG&E states that this arrangement will protect customers from having to bear the initial cost of these facilities.  These payments will only be refunded if and when the new customer’s load materializes and provides revenues sufficient to support refunds. Electric Rule 30 does not require the customer to provide an advance or pay actual costs for network upgrades, because according to PG&E these upgrades, if required, generally benefit all transmission customers once they are operational.

Electric Rule 30 also addresses situations where there are joint customers planning to use the transmission facilities, a customer’s failure to take service, reduction of excess facilities, the refund process, and the option for a customer to build certain facilities.  There is a section of the rule pertaining to special circumstances such as relocation or rearrangement of existing facilities, removal of existing facilities, termination of service, and the option for a customer to provide a loan to PG&E to prefund transmission network upgrades to expedite work when possible.

In regard to the interconnection process, PG&E notes that it is conducting a pilot program in Alameda and Santa Clara Counties to adopt a cluster study process for new transmission-level retail electric customers.  The new cluster study approach aims to identify: (1) upgrades needed to serve potential new transmission-level retail electric customers; and (2) opportunities for these potential new customers to share costs for new facilities that could be used by multiple customers. Electric Rule 30 rules and requirements would apply to transmission-level interconnections and projects emerging from the cluster study process.

Electric Line Extension Subsidies

One open question presented in PG&E’s application is whether the Commission’s elimination of subsidies for electric line extensions in all new building projects that use gas and/or propane in addition to electricity would apply to transmission-level electric service. In D.23-12-037, the Commission eliminated all such subsidies, but allowed for non-residential customer exemptions in certain circumstances that are in line with California’s climate goals amongst other criteria.  PG&E points out in its application that it is not clear whether this decision applies to transmission-level retail customers, given that Electric Rule 30 did not exist when D.23-12-037 was adopted by the Commission. PG&E also points out that the decision eliminating electric line extension subsidies also allowed the electric utilities to propose categorical exemptions.  PG&E did not take a formal position in its application on whether transmission-level customers should be exempt, but states that it believes there may be good reasons for exempting these customers generally.

Next Steps

Responses and protests to PG&E’s application are due on Monday, December 23, 2024.  PG&E will have an opportunity to reply to the responses, and the assigned Judge will set a time for a prehearing conference sometime thereafter.  The schedule contemplated in PG&E’s application would result in a final decision in February 2026, but that schedule is subject to modification through the Commission’s Scoping Ruling.

PG&E states that it intends to file a motion for interim implementation of Electric Rule 30 approximately 60 days after filing the application, which would fall on or around January 21, 2025. The motion for interim implementation will include the draft form agreements that PG&E plans to use for Electric Rule 30, if the interim implementation request is granted.

[1] A.24-11-007, Application of Pacific Gas and Electric Company (U39E) for Approval of Electric Rule No. 30 for Transmission-Level Retail Electric Service (Nov. 21, 2024).

[2] See PG&E Electric Rule No. 15 (Distribution Line Extensions); PG&E Electric Rule No. 16 (Service Extensions).

[3] An exceptional case filing refers to a situation where a party requests deviation from standard rules, procedures, or requirements of CPUC regulations, often when adhering to the usual requirements would not be feasible or the case warrants special consideration.

[4] This is not an exhaustive summary of proposed PG&E Electric Rule 30. For additional information or advice, please contact Stoel Rives.