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Integrated Resource Planning (R.20-05-003)
Filing Requirements Overview for
June 3, 2024, IRP Procurement Compliance Filing & Data Request
May 3, 2024
1. Background:
In accordance with Decision (D.) 20-12-044 Ordering Paragraph 1, all load-serving entities (LSEs) who fall
within the Commission’s authority for Integrated Resource Plan (IRP) proceeding with procurement
obligations included in D.19-11-016 who did not opt-out of providing capacity for their customers, and
who have projects counting towards D.19-11-016 compliance that were not online by December 1,
2023, shall make compliance filings using RDTv3 on June 3, 2024. As June 1, 2024, is a Saturday, this
filing will be required by 5pm PT on Monday, June 3, 2024. Additionally, in accordance with D.21-06-035
Ordering Paragraph 3:
“All load-serving entities named in Table 6 of this order, plus the individual electric service providers
who will receive their individual allocations confidentially from Commission staff, shall procure the
September net qualifying capacity amounts given in Table 6, and shall file and serve on the service list of
this proceeding or any successor proceeding compliance filings according to the schedule given in Table
7 of this order.”
Finally, in accordance with D.23-02-040, Ordering Paragraph (OP) 5: “Beginning after the August 1, 2023,
procurement information compliance filings, all load serving entities subject to our integrated resource
planning oversight shall continue making procurement data filings on December 1 and June 1 of each
year to be assessed for compliance unless and until the Commission sets different requirements. The
need for backstop procurement as discussed in Decisions 20-12-044 and 21-06-035 shall continue to be
evaluated each year after receipt and analysis of the procurement data filed on December 1.”
This Filing Requirements Overview is aimed to assist LSEs meet all of these requirements.
For purposes of keeping CPUC’s project status information up-to-date, LSEs are also required to provide
information on the following project types. LSEs that are not required to make a D.19-11-016, D.21-06-
035, or D.23-02-040 compliance filing may still be required to submit an RDTv3 due to the following
request:
• LSEs should include any projects planned, in review, or in development as of 5/1/2024, or online
after 11/1/2023, in the LA Basin local capacity area, even if not pursuant to either IRP
procurement order.
The template, Resource Data Template version 3 (RDTv3), is posted on the CPUC IRP Procurement Track
website along with instruction documents. Each LSE should fully and accurately complete the RDTv3 in a
way that adheres to the compliance requirements explained in this document and RDTv3 User Guide.
RDTv3 indicates a major version. Minor version changes have and will occur and so the RDT versions
have both a minor version number and a date. At the time of this publication the latest version is
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RDTv3_4_2 (05/03/2024), available on the IRP Procurement Track Website. LSEs should use the latest
version of the RDTv3 posted to the CPUC’s website.
The June 3, 2024, IRP Procurement Compliance Filing & Data Request (and associated RDTv3 template)
does not replace the similar Procurement Status Data Request, issued most recently via email to LSEs on
October 10, 2022 (and correction guidance issued 12/7/2023). The IRP Procurement Compliance Filing &
Data Request, and not the Procurement Status Data Request, will serve as the compliance check on
individual LSE’s compliance with IRP orders. While the templates involved are similar, they must each be
submitted using their own instructions. The instructions for any fields that do appear on both templates
should be the same and can be found in the RDTv3 User Guide.
Further, Commission staff has posted responses to Frequently Asked Questions (FAQ) about D.21-06-
035 on the CPUC IRP website (IRP Procurement Track page), that are referred to in this Filing
Requirements Overview. At the time of publication of this document, the latest D.21-06-035 FAQ
document is version 1/4/2023. Please note that many of these FAQs are also applicable to D.23-02-040
procurement.
2. Purpose:
This document guides LSEs and provides an overview of this data request and the compliance
obligations, as well as instructs LSEs on how to file their RDTv3 and supporting documents with the
CPUC. This document is intended to provide an overview of the filing requirements for D.19-11-016,
D.21-06-035, and D.23-02-040 to assist LSEs with preparing their filings. This document is not intended
to review all requirements. LSEs have an obligation to review this document in concert with all relevant
Decisions, staff’s responses to FAQ, and any other relevant Commission materials.
3. General Instructions:
A. All LSEs who fall within the Commission’s authority for the Integrated Resource Plan (IRP)
proceeding with procurement obligations included in D.19-11-016 who did not opt-out of
providing capacity for their customers, and have projects that were counting towards D.19-
11-016 compliance and not online as of December 1, 2023, are required to file updated
procurement related data to satisfy the requirements of D.19-11-016, and D.20-12-044,
which includes data entry in the NQC Validation Tool. Please see the detailed instructions in
section 4. Projects pursuant to D.19-11-016 only that came online by the previous filing
(December 1, 2023) or earlier and have associated milestone 3 documentation submitted do
not need to be included in the filing or RDT. Projects pursuant to D.19-11-016 that did not
come online as of December 1, 2023, did not have milestone 3 documentation submitted by
the previous filing, or also will be partially used toward another IRP order should still be
submitted.
B. All LSEs that have fulfilled their D.19-11-016 compliance obligations by December 1, 2024
with fully online projects do not need to report on D.19-11-016 compliance in the June 3,
2024 filing.
C. All LSEs who fall within the Commission’s authority for the IRP proceeding and were given a
procurement obligation for D.21-06-035 or D.23-02-040 are also required to file
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procurement data and supplemental documentation pursuant to the requirements set in
D.21-06-035 and D.23-02-040. Please see the detailed instructions in sections 4 and 5.
D. Staff notes Resolution E-5080, adopted Aug 6, 2020, authorizes Commission staff to cite
LSEs "for non-compliance with mandatory filing deadlines and reporting requirements of the
Integrated Resource Planning (IRP) proceeding." Further, Section 3.2 of the IRP Citation
program states: “Specified Violation” also means the failure, absent an extension formally
approved by the Commission’s Executive Director or Deputy Executive Director, to submit
other supporting data clearly and reasonably requested by Commission Staff that is
reasonably related to the implementation of the Commission’s Integrated Resource
Planning Program.”
E. Additionally, LSEs should also include any projects planned, in review, or in development as
at 5/1/2024, or online after 11/1/2023, in the LA Basin local capacity area, even if not
pursuant to either IRP procurement order. Please see the detailed instructions in section 6.
F. For purposes of determining contract status for D.19-11-016, D.21-06-035, and D.23-02-040
projects, use June 1, 2024, as the cutoff date.
G. LSEs should review “RDTv3 User Guide” as Commission staff-provided comprehensive
instructions. LSEs should also review the “Draft NQC Validation Tool” instructions.
a. Similar to previous rounds, comprehensive error checking will be conducted, after
submissions are received, based on the rules and relationships spelled out in the
User Guide using RDT Error Checking, Aggregation and Reallocation Tool (RECART)
version 3 (RECARTv3).
b. Staff developed an error checking macro as part of RDTv3, based on the rules and
relationships spelled out in the user guide. LSEs need to trace the errors identified
by the macro and correct them before submitting. Macro runs are required for
submittal. If an LSE has not run the macro, their submittal may not be accepted.
LSEs are required to correct errors wherever possible, but an error-free report sheet
may not be possible under certain conditions. LSEs may advise staff when making
their filings if any errors cannot be corrected.
H. LSEs must fill out the new NQC Validation Tool and the MTR NQC Summary sheets in the
RDT. Instructions are included in the RDT user guide .
I. LSEs do not need to fill out the following for this filing:
a. Unique_contract sheet columns: “csp_resource_category”; “csp_annual_2024”;
“csp_annual_2026”; “csp_annual_2030”; “csp_annual_2035”.
b. Sheets: ‘Calcs’, ‘Reliability’, and ‘CSPReportSheet’
J. Please provide compliance filing documents at each filing as soon as they are available (I.e.
even if it is for a future year).
a. Providing the documents before the compliance deadline will allow IRP Staff to be
able to review the document in advance and notify LSEs of issues that need to be
resolved.
4. Detailed Instructions on IRP D.19-11-016, D.20-12-044, D.21-06-035, and D.23-02-040
Requirements:
Per Ordering Paragraph (OP) 1 in D. 20-12-044, all LSEs with procurement obligations in D.19-11-016
who did not opt out of providing capacity for customers must submit compliance filings for backstop
procurement on February 1 and August 1 of 2021, 2022, and 2023, in a format developed and
disseminated by the CPUC for the publicly-available portion, containing information about progress
toward achieving the electric capacity procurement requirements for 2021, 2022, and 2023. This same
backstop process was adopted in D.21-06-035 and D.23-02-040. LSEs should follow all applicable
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instructions here for reporting their D.21-06-035 and D.23-02-040 resources as well. Section 5 below
details additional instructions that are only applicable to D.21-06-035 and D.23-02-040.
In addition to the RDTv3, self-providing LSEs must also submit information addressing Milestone 1,
Milestone 2, and Milestone 3 for 2021, 2022, and 2023 in the compliance filing, as detailed in D.20-12-
044.
LSEs are not required to re-submit supplemental documentation already provided to the CPUC in a
previous compliance report, unless those materials have been amended or modified. Since August 1,
2023, was the required due date for D.19-11-016 resources, only D.19-11-016 resources that were not
online as of the last filing, did not have associated milestone 3 documentation, or will be partially
used for another IRP order need to be included in this filing.
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Crosswalk Table of Context Requirements
LSEs must include a table of contents cover page with their submittal that covers the following:
document name, applicable resource, milestone requirement this document meets (e.g., site control or
online status), applicable tranche or tranches, location of document in filing. LSEs submitting a
remediation plan should include it in their table of contents. The crosswalk table is required to include
the document location for all past MTR project milestones filed in prior filings. Below is a table LSEs may
use for this cover page. The LSE Unique Contract ID column must match the RDT.
Please submit all supplemental documentation in a searchable format. Please provide supporting
documents in separate folders by project. Please keep the document and folder names succinct to
prevent file path length issues.
LSE Name IRP June 3, 2024, Procurement Report Crosswalk Table Format Requirements (sample format
and information below)
Document
Name
LSE Unique
Contract ID
Milestone
Requirement
Met and/or
NP Contract
Validation
Decision &
Tranche(s)
Compliance
Filing Date
Location
LSEname_deve
loper_ABCsola
r_PPA
ABCsolar
Milestone 1 –
executed
contract, NP
Contract
validation
D.19-11-016, 1
& 2
February 1,
2023
Compliance
Filing
Folder Name,
Pg 17 of PDF,
NP validation
on page 2 of
PPA.
LSEname_deve
loper_ABCstor
age_PPA
ABCstorage
Milestone 2 –
Notice to
Proceed
D.21-06-035,
2023
August 1, 2023
Folder Name,
3rd PDF in
zipfile labeled:
“ABCStorage_
NTP”
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LSEname_deve
loper_DEFstor
age_PPA
DEFstorage
NP Contract
Validation –
Namplate
value
D.21-06-035,
2023
December 1,
2023
Folder Name,
3rd PDF in
zipfile labeled:
“ABCStorage_
NTP”, page 4,
• For compliance with Milestone 1, self-providing LSEs must provide:
o executed contracts for new construction,
▪ Executed contracts should state the nameplate value of the resource (with pg #
this value can be found included in the table above). If nameplate values are not
included in the contract, LSEs may submit a signed attestation that includes the
nameplate value of the resource.
▪ Executed contracts should also include a project timeline. LSEs should note if
the project timeline is instead included with other documentation.
o signed interconnection agreements,
o and provide evidence of site control with signed land leases or title deeds (either
accepted).
• For compliance with Milestone 2, LSEs must provide a "Notice to Proceed" or similar contractual
evidence of construction commencement. Additionally, LSEs meeting part of their obligation
with imports, demand response or sale of excess generation must submit executed contracts for
these resources.
o If the LSE does not have the “Notice to Proceed” documentation, they may submit what
similar evidence they are able to provide that serves a similar purpose (i.e., updates on
construction milestones).
o Imports may not be more than 20% of an LSE’s total obligation for D.19-11-016.
o LSEs procuring demand response resources must provide load impact protocols when
available. If applicable, the LSE should also submit progress on rule 21 permits for DR
contracts involving BTM storage. LSEs must provide NQC via Load Impact Protocols,
contracted NQC, or an estimated NQC. LSEs should be sure to indicate via the
“NQC_reporting_source,” column if the provided NQC is an estimate.
• For Milestone 3, LSEs must provide evidence of online status and commercial operation. Please
provide a copy of the commercial operations date (COD) notice you received. If that is not
available (i.e., in the case of an existing resource), LSEs should provide where to find the
resource on the CAISO Master Generating Capability list.
• LSEs must either have a contract that states their contracted nameplate capacity (MW), per
contract, or include a signed attestation that confirms the contracted nameplate capacity.
o This information must be included in the crosswalk table as shown in example
“DEFstorage”
o In column “Milestone Requirement Met and/or NP Contract Validation” please specify if
the NQC or Nameplate value is what is shown in the contract
• At the time of this filing, all milestones should be met for all D.19-11-016 procurement and for
the 2023 and 2024 requirements of D.21-06-035.Remediation Plan: When an LSE is notified of
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delay or contract failure, please include a remediation plan that describes the source of the
delay, possible remediation that will be taken by the LSE, whether the LSE has notified the CPUC
previously of the delay, and what substitute resources the LSE may be able to procure.
• Any instructions included in this Filing Requirements Overview, the RDTv3 User Guide, or the
RDTv3, supersede previous instructions and should be followed. Some previous staff
instructions and responses to FAQs are no longer applicable.
• Please note that staff previously instructed LSEs to create multiple lines in the unique contracts
sheet in the data template if a project met multiple tranches. This is no longer necessary due to
the drop-down list for the tranche column containing all possible combinations. Please only
include one line for each project in the unique contracts tab. If the contract has an NQC value
that changes from year to year, please include that additional information in a note. When
something fundamental about the contract changes (e.g., the resource’s nameplate is
expanded), please enter them as separate contracts (in separate rows). For more details, please
read section 8 of the RDTv3_UserGuide. For the NQC validation tool, LSEs should follow the
guidance that instructs LSEs to have separate rows for each instance where a single contract is
being used for a distinct MTR “tranche."
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5. Additional Instructions for D.21-06-035 and D.23-02-040:
LSEs are also required to include and provide information in the RDTv3 for any projects intended to
meet D.21-06-035 (the Mid-Term Reliability, MTR, Procurement Decision) and D.23-02-040 (the
Supplemental MTR Procurement Decision). LSEs should include information for all applicable columns in
the RDTv3. Information on these resources should be filed in the same RDT and LSEs should follow all
instructions above regarding milestone reporting and the table of contents cover pages. The following
constitutes additional instructions to follow for D.21-06-035 and D.23-02-040 resources.
Please note:
• Projects pursuant to multiple orders should include a note indicating how much capacity the LSE
intends to apply toward each order.
• LSEs must also fill out the NQC Validation Tool sheet for D.21-06-035 and D.23-02-040
resources. No other resources should be reported in this worksheet. Please see the RDT User
Guide for instructions on how to fill out this tab. New columns have been added to this
workbook to collect the NQC of resources pursuant to D.23-02-040 (Supplemental MTR
Procurement).
o The NQC Validation Tool has been further modified to capture Zero emissions
generation, generation paired with storage, or demand response requirement aka
“Diablo Canyon Replacement” resources. Please see the RDT User Guide for instructions
on how to enter these resources. These resources are now required to be entered into
the NQC Validation Tool.
• Long-Lead Procurement NQC should be reported in the column pertaining to its applicable
tranche ELCC. Please indicate this resource is meeting your LLT requirements by selecting
“firm_ZE” or “long_duration_energy_storage” in the “d2106035_procurement_cat” column.
Please note that this is a change from some previous RDT versions.
• Please note that the “d2106035_procurement_cat” column option “ZE_gen_paired_dr” refers to
the Zero emissions generation, generation paired with storage, or demand response aka “Diablo
Canyon Replacement” requirement. The “ZE_gen_paired_dr” option should not be used for any
resources that are not pursuant to that requirement. If an LSE is showing a a zero emission
resource being used toward their general requirement, they can select general, and they should
not select “ZE_gen_paired_dr” unless it is intended to specifically count towards the “Zero
emissions generation, generation paired with storage, or demand response” requirement.
Instructions by Resource Procurement Category:
Zero emissions generation, generation paired with storage, or demand response requirement: Per D.21-
06-035 OP 6, LSEs are collectively required to procure 2,500 MW of zero emissions generation,
generation paired with storage, or demand response resources that meet certain requirements by 2025.
• OP 6 states:
“This zero-emitting capacity shall have the following characteristics: (a) Be from a generation
resource, a generation resource paired with storage (physically or contractually), or a demand
response resource; (b) Be available every day from 5 p.m. to 10 p.m. (the beginning of hour
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ending 1800 through the end of hour ending 2200), Pacific Time, at a minimum; and (c) Be able
to deliver at least 5 megawatt-hours of energy during each of these daily periods for every
megawatt of incremental capacity claimed.”
• LSEs must attach an engineering assessment to their supplemental documentation to address
these requirements. Staff will not provide or require a precise format for these assessments but
instead outline the minimum qualifications of these assessments. Staff reserve the right to ask
LSEs for additional information if insufficient detail is provided in the attached assessment.
These assessments and additional documentation, if required, as well as the compliance table
provided below, must be submitted via one filing prior to the required online date for this
procurement category. As this procurement category is required online by June 1, 2025, these
materials must be provided no later than the December 1, 2024, filing. These materials should
be provided as soon as they are available.
• It is understandable that different portions of an LSE’s portfolio for this procurement category
will have different online dates and can be used toward an LSE’s annual requirements prior to
the ability to show an engineering assessment for a paired resource. However, procurement will
not count toward the Zero emissions generation, generation paired with storage, or demand
response requirement until the LSE is able to submit the required engineering assessment and
demonstrate how the resources will be paired.
o Engineering assessments must meet the annual P50 standard set in FAQ 1.4.13 which
states:
“Staff expects that the resource (or combination of paired generation and storage
resources) should have, on an annual basis, at least 50% probability of being “able to
deliver at least 5 MWh during each of these daily periods for every MW of incremental
capacity claimed” (OP 6). If the probability is lower than 50%, then the resource does
not comply with the decision and is ineligible. Staff expresses this standard as: the
resource's annual P50 during the 5-hour period from 5 p.m. to 10 p.m. Pacific Time
must be at least 1,825 MWh (5 x 365) for every MW of incremental net qualifying
capacity claimed by the LSE to meet this procurement requirement.”
o Engineering assessments should be in accordance with standard industry practice, per FAQ
1.4.13 which states:
“Staff expects that the assessment should use standard practices in renewables and
storage project financing (for example, taking into account battery charging restrictions,
round trip losses, and with the probabilistic assessment considering standard sources of
uncertainty including interannual resource variability). Staff expects that the only
atypical aspect of this is the daily 5-hour window focus of this category of the
procurement order.”
o The engineering assessment must clearly state how the storage resource will be paired with
the generating resource, if using paired resources. If only a portion of one or both resources
is being used toward this requirement, that must be specified.
o The LSE should include the location of the engineering assessment in the table of contents
cover page.
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o The LSE may provide additional information if it is necessary for Staff to assess compliance
of their resource or paired resources with OP6 and all of D.21-06-035.
o If an energy-only resource is being paired with a storage resource, the LSE must meet the
P50 assessment within the CAISO footprint. This is staff’s expectation of how an LSE would
need to manage the use of a resource that is not deliverable in this situation. The LSE would
need to show via the engineering assessment that sufficient energy will be provided
specifically in CAISO to charge the battery prior to 5pm for 5 hours of discharge. The energy-
only solar’s capacity would not count directly at all towards the LSE’s procurement
requirement, since per FAQ 1.1.2 resources must be deliverable. (Staff notes that even if the
solar was deliverable, it follows from the P50 standard set in FAQ 1.4.13 that is highly
unlikely to contribute materially to reliability between 5p.m. and 10 p.m. other than by
charging the storage earlier in the day; so it is likely that just the ELCC of the storage that is
able to be counted towards an LSE’s procurement requirement for this category anyway).
o LSEs must review all requirements in D.21-06-035 and D.23-02-040, as well as staff’s
responses to FAQ (particularly FAQ 1.4.13) to ensure they are complying with all
requirements.
o To streamline review of compliance with these requirements, LSEs should complete the
following table for each paired resource being shown towards their required procurement
for this category. The engineering assessment/s should be source document/s for item D.
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Name of Paired Resource Being Shown for Compliance with D.21-06-035 OP6: ABC solar and
storage
Item
Value
Source Documents
(including relevant
page numbers)
and/or Working
A. Generator nameplate capacity (MW)
B. Storage nameplate capacity (MW)
C. Storage duration (MWh)
D. Annual P50 of combined resource during the 5-
hour period from 5 p.m. to 10 p.m. Pacific Time
(MWh)
E. Reliability capacity being shown for counting
towards the LSE’s required procurement for
this category (NQC MW)
F. Eligibility test: Is D / E >= 1,825? (Yes/No)
(If No, then the paired resource is ineligible)
Not applicable
Long Lead-Time Resources:
• Long Duration Energy Storage – Contracts for long duration energy storage must note that
the storage resource is able to discharge for at least eight hours at full nameplate value, per
D.21-06-035, OP 2(a). Hybrid or paired resources can be used for this requirement as long as
the storage portion of resource meets the above requirement, per FAQ 1.3.1. Additionally,
per FAQ 1.3.1, if a hybrid resource is used, an engineering assessment must be submitted
that demonstrates compliance with this requirement. The LSE should include the page
number that an assessment of the resource’s discharge capabilities can be found in the
table of contents cover page. An engineering assessment is not required if the resource is
not hybrid.
• Firm Zero Emission – Resources meeting the 1,000 MW NQC firm zero emission requirement
must have an 80% capacity factor, per D.21-06-035, OP 2 (b). This will be based on
forecasted capacity factor based on the latest available design. LSEs should provide an
engineering assessment to demonstrate that their resource meets the capacity factor
requirement. Per instruction in section 4, LSEs must re-submit materials that have been
modified or amended. LSEs should re-submit this assessment if substantive changes are
made to the resource design that lower the capacity factor below the requirements for firm
zero emission resource procurement. The LSE should include the page number that an
assessment of the resource’s capacity factor can be found in the table of contents cover
page.
• Bridge Resources: Please be sure to review D.21-06-035, D.22-02-004, D.23-02-040, and
staff’s responses to FAQ for all requirements regarding bridge resources. Bridge Resources
should be explained and described in the LSE’s remediation plan document. Bridge
resources must also follow all the same requirements as other MTR compliant resources
including instructions for entering into the RDT and backstop / milestone documentation
submission.
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Substituting Delayed D.19-11-016 Capacity for D.21-06-035 Procurement: If an LSE submitted a resource
for D.19-11-016 that was put in the baseline for D.21-06-035 and that resource has not yet come online,
the LSE may follow the instructions provided in the “Instructions and Template for LSEs Substituting
Delayed Excess D.19-11-016 Procurement Capacity for D.21-06-035 Mid-Term Reliability (MTR)
Procurement” document to count their resource toward D.21-06-035 instead. This requires that: (1) the
resource will come online during the D.21-06-035 compliance period and that (2) The LSE has met their
D.19-11-016 obligations with other resources. All requirements put forth in the referenced
documentation must be met before or at the time of the filing. Additional information is also provided in
FAQ 5.4.7.
Emergency/ Summer Reliability Resources: In some circumstances, IOUs have submitted advice letters
and received approval for resource procurement to meet summer reliability requirements. If the IOU
seeks to change the use of the resource such that it now will be used to meet some of their MTR
obligations, Staff expects the IOU may need to make a filing identifying the change in the designation of
the resource from being a summer reliability resources to being an MTR resource, and the resulting
change in CAM treatment.
6. Detailed Instruction on Project Progress Tracking Requests:
For purposes of keeping our project status information up-to-date, LSEs are also required to provide
information on the following project types:
• LSEs should include any projects with contract statuses planned, development, or review as of
5/1/2024, as well as any projects that came online after 11/1/2023 in the LA Basin local capacity
area, even if not pursuant to either IRP procurement order.
o LSEs should use the sub-area column
o LSEs should complete all applicable columns in the RDTv3 for these projects.
o LSEs should not include any supplemental documentation for these projects, unless they
are also pursuant to a procurement order.
7. Submission Date:
As June 1, 2024, is a Saturday, each LSE must submit a completed RDTv3 along with supporting materials
to the CPUC by 5 PM PT on Monday, June 3, 2024.
8. Submission Instructions:
a. Informal Provision: Please submit all materials to irpdatarequest@cpuc.ca.gov through the
CPUC FTP website. The LSE should file the RDTv3 utilizing the instructions in this document
and “RDTv3 User Guide”. LSEs may consider some contractual information confidential and
wish to file accordingly. In that case, LSEs need to submit two versions of their RDTv3s
(confidential and public). Filers who do not already have a CPUC secure FTP account should
follow the instructions on the secure FTP site. From within the secure FTP application, users
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can send secure emails to CPUC staff with large attachments. This mechanism allows filers
to transmit their complete filing to CPUC staff including any portions deemed confidential.
Before submitting, please change the RDTv3 file name using the following naming
convention. The file name must contain the 5 elements below, in the order provided. Use an
underscore to separate each element. All letters should be in lower-case.
1. The LSE's abbreviation, provided in the Resource Data Template’s workbook in the
“lse_names" tab
2. “rdtv3”
3. “38mmt”
4. Confidential vs. Public: written as “confidential” or “public”
5. Version number, written as the letter "v", followed by a number. If you have to re-
submit a file for any reason, increase this number by 1.
b. Formal Filing: Parties should also read carefully and follow Rule 1.5 through 1.14 of the
Commission’s Rules of Practice and Procedure when preparing and submitting their filings,
available here:
http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M209/K618/209618807.PDF
Below is a summary of the basic steps, in anticipation of the likely needs of many LSEs in this
proceeding. This guidance is not intended to modify, in any way, the requirements set forth in
the Commission’s Rules of Practice and Procedure, which are considered authoritative.
• E-filing
· When making the formal filing, LSEs are encouraged to utilize the Commission’s
electronic e-filing system and select the document type “compliance filing.”
· When e-filed, documents must be PDF/A compliant (see Rule 1.13).
· All materials should be e-filed, including PDF/A compliant versions of public
spreadsheet materials, EIA forms, etc.
· Filers should include the verification required by Rule 1.11.
· Filers should also include a certificate of service (service requirements are discussed
further below).
· If a document is larger than 50 pages or 3.5 megabytes, the filer should instead file
and serve a “notice of availability” with a link to the materials housed on its own web
site in a publicly accessible format (see Rule 1.9(d)).
· The filing deadline is June 3, 2024, before 5 p.m PT.
Version: 05/03/2024
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• Confidential Materials
· The LSE should file the RDTv3 utilizing the instructions in this document and “RDTv3
User Guide”. LSEs will likely consider certain contractual information confidential and
wish to file accordingly.
· Along with the confidential version of its materials, the LSE will need to separately
file a “motion to file under seal” detailing the justification for keeping the material
confidential, following the guidance in the Commission’s decision D.06-06-066 for these
purposes (see Rule 11.4; there is also detailed guidance contained on the following page
on the Commission’s Practitioner Page web site: https://www.cpuc.ca.gov/about-
cpuc/divisions/administrative-law-judges/practitioners-page , look for link titled: “Filing
Confidential Documents Under Seal (Rev. Nov 2013)).
· The confidential version of the LSE’s materials may be submitted under seal in hard
copy form, or if the material exceeds 3.5 megabytes, may be submitted on an archival
DVD directly to the Docket Office. For more detailed guidance on this issue, also see the
Practitioner’s Page at https://www.cpuc.ca.gov/about-cpuc/divisions/administrative-
law-judges/practitioners-page , look for link titled: “Mixed Media Filings: Cutting Edge
Filing Techniques to Accommodate Multiple & Voluminous Media Formats.”
· LSEs should also ensure that confidential materials are delivered to Commission
staff electronically immediately, regardless of the formal filing status, so that staff can
begin analysis (see further details below).
• Service of Materials
· All public versions of filed materials should be served on all members of the
“service list” of this proceeding (See Rule 1.13).
· The service list can be downloaded from the docket card for this proceeding or
from the Commission’s service list webpage, by clicking on “download comma-delimited
file.”
· Email service is generally preferred, but has some limitations:
· Some email servers will not accept or deliver messages to groups of more than 100
addresses. Thus, serving the whole service list may require dividing up distribution into
smaller groups of recipients.
· Document size is also limited if serving by email, and thus a notice of availability
with a public web site link is preferred for large documents and underlying materials.
Such an approach will also make spreadsheet materials more accessible and useful.
· Service should be performed on the same day as filing (June 3, 2024), before 5 p.m.
