Just Electricity
After decades of fighting off proposal after proposal for new gas-fired power plants where we organize, in 2010 CBE committed to changing the way California powers itself. To that end, our legal docket includes representing the California Environmental Justice Alliance (“CEJA”) in proceedings at the California Public Utilities Commission (“PUC”).
Order Instituting Rulemaking to Continue Electric Integrated Resource Planning and Related Procurement Processes, PUC proceedings R.20-05-003; R.25-06-019.
The PUC maintains a rolling proceeding to determine how much power the investor-owned utilities (and to a lesser degree, the Community Choice Aggregators) need to satisfy projected demand, and how to meet demand while emitting dramatically fewer greenhouse gases and air pollution, with a priority for emission reductions in our communities. Utilities must prepare Integrated Resource Plans (“IRPs”) that target GHG and criteria pollutant emission reductions while ensuring there is enough electricity to meet demand.
The PUC’s IRP proceeding implements several key laws, including SB 350, which requires planning for improved air quality and economic development in EJ communities as well as 50% renewables by 2030; SB 887, which requires planning for substantial reduction in reliance on nonpreferred resources by 2035; SB 100 and SB 1020, which mandate 100% clean and renewable energy by 2045, 95% by 2040, and 90% by 2035.
CBE’s legal staff have represented CEJA in IRP and its predecessor proceedings since 2012, along with co-counsel Deborah Behles and in partnership with Sierra Club and Earthjustice.
Order Instituting Rulemaking to Oversee the Resource Adequacy Program, Consider Program Reforms and Refinements, and Establish Forward Resource Adequacy Procurement Obligations, PUC proceeding R.23-10-011.
While the IRP proceeding plans for the energy system five years and further into the future, the PUC maintains a parallel proceeding, Resource Adequacy (“RA”) to ensure the utilities have contracts with power producers to deliver electricity when and where it is needed in the near-term. Historically, CBE identified the need for CEJA to intervene in the RA proceeding because the public had no information about RA contracts. The concern, which was well-founded, was that power plants in EJ communities were remaining online and operating because of RA contracts. After intervening, CBE with co-counsel Deborah Behles and in partnership with Sierra Club, engaged in the question of how to define a “reliable” grid – should we spend billions of ratepayer dollars to run polluting power plants in EJ communities in case of a one minute power shortage every ten years? Or is it more important to consider how local renewable resources, paired with energy storage, can help meet energy demand every hour of the day?
Order Instituting Rulemaking Regarding Building Decarbonization, PUC Proceeding R.19-01-011;
Application of Pacific Gas and Electric Company (U 39 M) on Behalf of the California Market Transformation Administrator (U-1399-E) for the Approval of the Initial Tranche of Statewide Energy Efficiency Market Transformation Initiatives, PUC Proceeding A.24-12-009
Getting gas out of people’s homes is a key step to achieving CBE’s climate and health goals, and we engage in policy and campaign work statewide and in specific cities to achieve that end while ensuring landlords do not use electrification upgrades as a pretext to evict our community members. California’s electricity rates, however, are high and climbing rapidly, so CBE focuses on ensuring that community members can both switch off gas appliances and afford their electric bills.
The PUC is entrusted with implementing SB 1477’s funds for electrification of space and water heating, and is establishing a framework for decarbonization of buildings in general. Representing CEJA and co-counseling with Deborah Behles, we are participating in this proceeding to ensure funding is directed equitably, and to environmental justice communities. After directing significant portions of SB 1477 funds to projects in our communities, the PUC turned to broader systemic questions, including the degree to which ratepayers subsidize new gas lines. Although it should be obvious that paying gas utilities a Line Extension Allowance (“LEA”) only adds fuel to the building decarbonization fire, industry feels strongly that ratepayers should continue to pay for new gas and electric service lines to buildings that have gas. After years of advocacy, the PUC acknowledged these would be “stranded assets” and voted to end the subsidies.
Securing affordable space heaters and cooktops for residents in EJ communities has required a decade of planning. In 2025, CBE supported CEJA (represented by Earthjustice) in intervening in the California Market Transformation Administrator effort to center portable room heat pumps (“RHPs”) and 120V, battery-equipped induction ranges and cooktops in the first round of PUC-supported technology.
In The Matter of Application of Southern California Gas Company (U-904 G) for Authority to Establish a Memorandum Account for the Angeles Link Project, PUC Proceeding A.22-02-007
Communities for a Better Env’t v. Southern California Gas Company, PUC Case (C.) 24-11-013
In The Matter of Application of Southern California Gas Company (U 904 G) for Authorization to Implement Revenue Requirement for Costs to Enable Commencement of Phase 2 Activities for Angeles Link, PUC Proceeding A.24-12-011
In the Matter of the Application of SOUTHERN CALIFORNIA GAS COMPANY (U904G) for Authorization to Recover Costs Recorded in Its Angeles Link Memorandum Account, PUC Proceeding A.25-06-011
California can and must transition from gas power to electricity generated by renewable resources. Yet entire industries are dedicated to diverting the transition so we substitute hydrogen gas for fossil gas. Concern over hydrogen projects prompted CBE to organize a year-long, statewide learning project with Gridworks, through which we developed clear principles around new hydrogen projects. CBE and its allies at the California Environmental Justice Alliance (CEJA) monitor new hydrogen projects in California for environmental justice concerns. When Southern California Gas Company (SoCalGas) filed its PUC application in 2022 to study a new hundreds-of-miles-long hydrogen transmission pipeline across the state, CEJA along with other organizations like Sierra Club and The Utility Reform Network stepped in. Although the PUC set clear parameters for SoCalGas’ study work, the gas utility declined to engage with the communities situated along studied pipeline routes despite repeated urging from CBE and other parties.
In November 2024, CBE filed a PUC complaint against SoCalGas for excluding impacted communities from its Phase 1 study process. SoCalGas then initiated two new proceedings, seeking to recover money from ratepayers for its Angeles Link efforts, and to secure PUC approval to advance the project.
Application of Pacific Gas & Electric Company (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff, and Green Tariff Shared Renewables Programs, and Related Matters, PUC Proceedings A.22-05-022 A.22-05-023, A.22-05-024
CBE’s communities have long identified the need for alternatives to rooftop solar that residents in environmental justice communities can access without owning their own homes, and without upgrades to their home electrical systems or roofs. The financial and energy benefits of rooftop solar are simply unattainable for many in our communities.
Beginning in 2014, CBE worked to establish the Solar on Multifamily Affordable Housing (SOMAH) program and advocated on CEJA’s behalf for alternatives to rooftop solar that work for EJ communities. After nearly a decade of programs, CEJA intervened in the community solar proceeding seeking to expand community solar and storage so we can safely retire polluting gas plants in low-income and disadvantaged communities, and bring access and bill savings to millions of households who are currently locked out of these benefits.
In partnership with Vote Solar and Natural Resources Defense Council, we advocate for programs that will allow our community members to secure these vital resources.
Order Instituting Rulemaking to Address Energy Utility Customer Bill Debt Accumulated During the COVID-19 Pandemic, PUC Proceeding R.21-02-014
Order Instituting Rulemaking to Establish a Framework and Processes for Assessing the Affordability of Utility Service, PUC Proceeding R.18-07-006
Order Instituting Rulemaking to Advance Demand Flexibility Through Electric Rates PUC Proceeding R.22-07-005
Even prior to the pandemic, environmental justice communities disproportionately bore both the pollution and energy burdens of our extractive energy system. In light of the pandemic and stay at home orders, California issued a moratorium on utility shutoffs. During the pandemic, utility debt rose to astronomical levels, and community members faced drastic electricity and gas bills. These same communities had disproportionately high COVID-19 infection and mortality rates, losing both the ability to go to work and, in many cases, the wage-earners who held those jobs.
While the shutoff moratorium was in place during the heart of the pandemic, CEJA (represented by CBE and Leadership Counsel for Justice and Accountability) were extremely concerned about community members, including those whose homes are sub-metered and who are incurring third-party debt to pay their bills. Together with the Greenlining Institute, we intervened in the COVID debt proceeding to advocate for elimination of debt, at a minimum for residential customers in environmental justice communities, but preferably for all customers.
Although we did not secure total debt forgiveness, our advocacy was extremely helpful in making incremental progress, ensuring there would be no wave of shutoffs when the statewide moratorium ended. The proceeding concluded in 2022, directing parties to the broader affordability proceeding, in which CEJA then intervened. In the broader Affordability proceeding, we presented significant evidence of how a Percentage of Income Payment could work.
This information was foundational in the subsequent AB205 implementation proceeding to establish a fixed charge that would lower bills for low-income ratepayers. Representing CEJA, CBE worked with expert Tyson Siegele to propose a non-invasive income evaluation tool, set a fixed charge at a level commensurate with that income, and evaluate to ensure bills would go down for low-income ratepayers.