California Extended Its Interconnection Enforcement Case Against PG&E and SCE to February 2027 While Four Other Items Reshaped the Rules Around Customer-Sited Storage

Item 32 on the California Public Utilities Commission’s October 29 voting agenda sits on the consent calendar under the heading Orders Extending Statutory Deadline. Its proposed outcome runs to a single line: extend the statutory deadline for completion of C.25-08-021 until February 28, 2027. The agenda records the order’s estimated cost as zero.

C.25-08-021 is the California Solar & Storage Association’s complaint against Pacific Gas and Electric and Southern California Edison.

The complaint. CalSSA filed on August 28, 2025 and asked the Commission to fine the two utilities a combined $10 million for repeatedly missing the Rule 21 review timelines that govern how fast a solar or storage application moves toward permission to operate.

In 2020 the Commission set the performance standard at 95% of projects completed within the required timeframes and ordered the utilities to file quarterly compliance reports.

Eighteen state legislators have since written to the Commission urging enforcement, citing CPUC data showing some timelines missed as often as 73% of the time.

February 28, 2027 falls eighteen months after the filing date.

The rest of the agenda. Item 23, in R.21-06-017, orders PG&E, SCE and San Diego Gas & Electric to retain a consultant to develop a common framework for orchestrating distributed energy resources. The same item adds a Load Flexibility Scenario as a fourth modeling scenario in distribution planning, beginning with the 2027 to 2028 cycle, with a joint Tier 3 advice letter due 60 days after the required workshop.

Item 51, in A.26-05-002, relating to A.25-04-006, would deny without prejudice SoCalGas’s proposed Microgrid Optional Tariff. The gas utility had sought authorization to build, own and operate behind-the-meter and off-grid microgrids for customers. The Commission signaled that outcome in a proposed decision at the end of September. The “without prejudice” qualifier leaves SoCalGas free to refile.

Two pending decisions. A proposed decision in R.19-09-009 grants the California Solar & Storage Association’s petition to modify D.20-06-017 in part and extends the suspension of the storage sizing limit for large net-energy-metering-paired storage until January 1, 2030. D.20-06-017 originally held a paired battery’s maximum output power to 150% of the NEM-eligible generator’s maximum output capacity, then lifted that limit on a trial basis in 2020. The trial has been extended twice since. The joint investor-owned utilities have told the Commission they support permanent removal, conditioned on customers funding any grid upgrades required to let paired storage charge from the grid above the original 150% level.

A second proposed decision in R.21-06-017 directs the three utilities to expand flexible service connections, which let a customer connect using available distribution capacity. It includes customer-managed power limits, updates the utilities’ Electric Rule 2 provisions, and establishes new data reporting obligations for flexible service connections.

Both remain proposed decisions awaiting a vote.

The dependency. What follows is interpretation. The four items above govern the entitlements attached to a customer-sited battery in California: how large it may be relative to its paired generator, what orchestration framework it will be dispatched under, what import limit its owner may contract to hold, and who is permitted to own the competing product. Each one is a question of what the asset is allowed to do once it is energized.

The date it is energized is set by the review queue that C.25-08-021 is about. A commercial storage project’s savings begin accruing at permission to operate, and every month of queue time is a month of the asset’s modeled life spent idle on a balance sheet. Recent industry figures put the span from application to permission to operate for commercial distributed projects at 16 to 26 months.

Flexible service connections make the dependency circular. The commercial argument for a customer-managed power limit is speed: a building that needs more amperage accepts a contractual import cap, enforced by on-site equipment, and connects faster than a conventional service upgrade would allow. That speed claim is a claim about the same utility interconnection function whose timeline compliance is the subject of the complaint. Writing flexible service connection terms into Electric Rule 2, the interconnection tariff, standardizes the product across PG&E, SCE and SDG&E. Delivery stays with the operation under complaint.

The gap between the two calendars. California’s regulatory stack for distributed storage is being built with specific, published dates. The consultant-led orchestration framework, the Load Flexibility workshop, the Tier 3 advice letter due within 60 days of it, the fourth modeling scenario arriving with the 2027 to 2028 planning cycle, the sizing limit suspension running to January 1, 2030. A developer can build a schedule around all of it.

Enforcement of the delivery timeline has one date, February 28, 2027, and it is the date by which the proceeding must be completed rather than the date any penalty attaches. Projects contracted in California during 2026 will be scheduled, permitted and queued across that entire window with the 2020 performance standard carrying the same practical weight it has carried since the quarterly reports began.

The entitlements attached to a California battery are being set on a published schedule. The date it turns on is not.

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