Distribution Resources Plan:
Utility Plans


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.  

On February 6, 2015, the CPUC issued a Ruling attaching the final detailed Guidance for the utilities' Distribution Resources Plan (DRP) filings on July 1, 2015.  In these Plans, the utilities are also required to propose 5 demonstration and deployment projects. 


Utilities' Proposed DRP Plans

On July 1, 2015, the utilities submitted their DRP Applications requesting CPUC approval:  

The utilities submitted DRP plans using a common format as required by the CPUC's Guidance Ruling. The utilities addressed the development of a consistent method for calculating the integration capacity of a distribution line at the feeder level.  The proposed DRP plans address:

  •  Ability of utilities to quickly assess whether the existing feeder can accommodate the Distributed Energy Resources   
  • Scenarios for projecting DER growth in the utilities’ service areas.       
  • One-time issues:
    • Identification of barriers to DER integration 
    • A summary of existing tariffs and contracts 
    • A summary of safety concerns related DERs 
    • A policy on data sharing    

CPUC Distribution Resources Plan (DRP) Roadmap

On January 27, 2016, the CPUC issued a Scoping Ruling in response to stakeholder comments on its November 2015 Staff Proposal. The Ruling sets a roadmap for implementation of DRP pilot programs across 3 concurrent Tracks. Follow the links below to learn more about each Track.  

  • Track 1:  Methodological Issues -This track will address Integration Capacity Analysis, Locational Net Benefits Analysis, and authorization for demonstration projects related to computer simulations.  


  • Track 2:  Demonstration and Pilot Projects - This track will address the design and authorization of demonstration projects related to Locational Benefits, Distribution Operation sand High Penetration of Distributed Energy Resources.     


  • Track 3:  Policy Issues This track will address the numerous policy issues that stakeholders in the DRP proceeding.  


 Public Advocates Office (the Office) Position

 The 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. However, the CPUC should determine the reasonableness of demonstration and deployment in a separate ratesetting phase where assertions are subject to evidentiary hearing, given the millions of dollars in cost to ratepayers.



The CPUC's Ruling to create a Roadmap with 3 Tracks adopted several of the Office's recommendations, including:

  • To delineate tracks to address ratesetting and policy issues separately.
  • Addition of issues of ownership and utility business incentives for Distributed Energy Resources.
  • Splitting off the smaller utilities in order to review California large utilities separately.    

The Office also advocated that the DRP proceeding should address key foundational issues:

  • Identify appropriately whether utility investment for grid modernization is due to upgrades for DRP or for previously authorized smart grid projects.     
  • Identify what grid modernization investments can be deferred due to integration of Distributed Energy Resources.     
  • Consider DRP issues in the context of the Integrated Distribubted Energy Resources (IDER) proceeding.     
  • Include metrics of success in order to evaluate demonstration project success, keeping IDER pilots separate in order to provide distinct and useful metrics.    


 See the Office's November 20, 2015 Comments on the CPUC Staff Straw Proposal.


Utility DRP Plans

The CPUC should require the the following modifications to the utilities' Plans: 

  • Integration Capacity: Modify the analysis to reflect the impact of smart inverter technology.
  • Locational Value: Modify the analysis assumptions for over-generation to reflect the fact that both conventional and renewable resources can contribute to over-generation conditions at night.
  • Safety: Require IOUs to rectify deficiencies in their DRP safety sections to comply with the CPUC’s Guidance.

The CPUC should create Stakeholder groups to gather robust data: 

  • Hold a Grid Architecture Workshop to allow stakeholders an opportunity to comment and develop solid grid architectural principles.
  • Create a Tariff Working Group to develop guidelines for incorporating locational value methodology into both demand and supply side tariffs.
    • Identify combinations of DER packages which can be developed as tariffs in other proceedings, including the Integrated Demand Side Resources, Interconnection/Rule 21, and Net Energy Metering (NEM 2.0).
  • Form a Data Access working group to discuss data access to address long-term data access challenges.
  • DER procurement policy and mechanism development which IOUs will be ready to implement by 2018 (Phase 2b).
  • Form a Distributed Resource Procurement Review Group (DPRG) in order to periodically update non-market participants on utilities' application of the distribution deferral framework.  


See the Office's August 31, 2015 Protest to the utilities' DRP Plans.    



Proceeding Docket

See the CPUC Proceeding docket.  

Subscribe here to receive updates to the proceeding.  



Other Resources

The Office DRP Portal

CPUC Distribution Resources Plan webpage 


 Related the Office pages:  

 The Office Energy Efficiency webpage 

The Office Energy Storage webpage 

The Office Alternative-Fueled Vehicles webpage  

The Office Demand Response webpage