Sam Wong advises clients on the development, financing, and regulation of energy projects across the United States. With experience counseling utilities, independent power producers, and investors, he guides clients through complex regulatory frameworks, litigation, and transactional matters at the intersection of federal and state energy laws, environmental compliance, and emerging carbon markets. Click here to read Sam's full bio.

As data centers and other large load customers seek to connect to California’s power grid, the California Public Utilities Commission (Commission) is rethinking how—and when—those customers should be refunded for costly transmission infrastructure upgrades.

Historically, distribution-level interconnection customers paid up front and received swift refunds under PG&E’s Base Annual Revenue Calculation (BARC) methodology. But the

December 9, 2025 Update: Following the D.C. Circuit’s September ruling, parties opted not to seek panel rehearing or en banc review. The deadline to petition the U.S. Supreme Court for certiorari expired on December 8, 2025, without any petitions for cert filed, thereby ending the potential for appeals of the decision.

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On September 9