Distribution Resources Plans: Guidance



In August 2014, the CPUC opened a Rulemaking  to set policies to guide the utilities in their development of Distribution Resources Plans (DRPs), pursuant to AB 327 (P.U. Code section 769). The purpose of the DRPs is to integrate Distributed Energy Resources (DERs), a variety of small, decentralized grid-connected technologies, into all utility system planning, operations, and investment.


Draft Guidance

On November 17, 2014, the CPUC issued a Ruling, attaching “Draft Guidance for the Distribution Resources Plans” as preliminary direction for developing Distribution Resources Plans (DRPs). The electric utilities are required to file their DRPs with the CPUC by July 1, 2015. The CPUC’s Draft Guidance set forth a New Framework for Distribution Planning as necessary to mitigate greenhouse gas emissions, and enable mass adoption of Distributed Energy Resources (DERs).


Purpose and Scope:

  • Suggests the jurisdictional scope of the proceeding should be low-voltage distribution (4kV-16 kV or lower) and at sizes of 20 MW or less
  • Identifies where the DRP overlaps with other CPUC proceedings


 CPUC Oversight:

  • Identifies the need for on-going CPUC coordination among utilities, CAISO, the Energy Commission  
  • Requires Small and Multi-Jurisdictional Utilities (CASMU) to file DRPs per the California statute


 Plan Requirements and Definitions:

  • Development of Integration Capacity and Locational Value Analysis tools
  • Development of demonstration projects
  • Provision of data access
  • Identification of safety considerations
  • Description of barriers to DER deployment
  • Explanation of how the DRP filings will be coordinated with the utilities’ general rate cases


 Final Guidance

On February 6, 2015, the CPUC issued a Ruling attaching the final detailed Guidance for the utilities' Distribution Resources Plan filings on July 1, 2015.  



Public Advocates Office’s Position

Public Advocates Office supports the state’s goals to move the utilities toward full integration of Distributed Energy Resources (DER) into their distribution system planning, operations, and investment in order to optimize ratepayers' investment in smart grid technologies and to achieve greater climate and other benefits. Public Advocates Office advocates for Distribution Resource Plans that are cost-effective and employ strategies to ensure reliable electric service at the lowest possible cost and maximum benefits for ratepayers. The CPUC should establish criteria, benchmarks, and accountability mechanisms to evaluate the success and effectiveness of DER integration in achieving its climate objectives. 

Public Advocates Office recommended that the CPUC should adopt criteria that:

  • Maximizes the benefits of DER integration to all ratepayers.
  • Minimizes the costs of  DER integration to all ratepayers.
  • Reduces greenhouse gas emissions.
  • Promotes advances in DER technologies. 
  • Reduces the impact of DER integration to the utilities’ traditional grid systems.    
  • Reduces ratepayers’ investment in transmission and distribution systems.
  • Ensures safe and reliable service.
  •  Reduces utilities’ power generation and overall operating costs.
  • Reduces ratepayers’ electric bills.
  • Ensures the safety of the utilities’ personnel, DER owners, and the general public.


 Public Advocates Office also recommended that the CPUC develop a uniform set of modeling methodologies, assumptions, and definitions to appropriately quantify the value of various Distributed Energy Resources in order to comply with Public Utilities Code 769, including: 

  • Consider the costs and benefits associated with the implementation of DERs.
  • Assure costs are just and reasonable.
  • Prioritize holistic coordination of existing CPUC programs that are cost-effective and yield net benefits to ratepayers within a short time-frame.    


See Public Advocates Office’s September 5, 2014 Opening Comments

See Public Advocates Office’s October 6, 2014 Reply Comments



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