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SB 254 requires WMPs to align with GRC cycles; utilities warn of forecasting, stakeholder and coordination challenges

Office of Energy Infrastructure Safety · December 18, 2025
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Summary

Energy Safety told utilities WMP submissions will be aligned with each utility's general rate case cycle and move to a four-year planning cadence; utilities raised concerns about long forecasting windows, suggested cumulative targets and bridge plans, and urged coordination with the CPUC.

Nicole Dunlap of the Office of Energy Infrastructure Safety introduced the WMP submission cadence change required by SB 254: WMPs must align with each electrical corporation's general rate case (GRC) or ramp filing cycles, the WMP cycle will extend to four years, and annual WMP updates will no longer be required.

"It puts each electrical corporation on their own WMP cycle as opposed to historically all WMPs have been submitted in the same year," Dunlap said when describing the regulatory change and its immediate implications for filing schedules and longer-term forecasting.

Utility speakers described practical challenges. Jay Landon of PG&E said under a strict reading of SB 254 his company would…

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