Expert witness testimony and formal comments on behalf of large industrial energy consumers. Each entry opens a plain-English summary of the proceeding, our positions, and the public documents.
Direct, rebuttal, and supplemental rebuttal testimony of Sam Harper on behalf of CLECA in SCE's consolidated applications for a large power dynamic pricing rate — addressing rate design and implementation issues for large industrial customers under marginal-cost-based dynamic rates.
Comments on behalf of the ERCOT Steel Mills on the design of the new demand management service for large loads under PURA § 39.170 (SB 6) — supporting broad industrial participation, deployment in any grid emergency, and a clear program-participation rule that does not penalize loads for responding to transmission price signals.
Comments filed on behalf of CLECA in CARB's formal 45-day rulemaking to amend the California Cap-and-Invest Program, addressing allowance budget tightening, industrial allocation methodology, and cost impacts on large energy-intensive manufacturing facilities covered by the program.
Comments on behalf of the ERCOT Steel Mills through PUCT's rulemaking of new 16 TAC § 25.194 under PURA § 37.0561 (SB 6) — urging that the 75 MW threshold apply to additional (incremental) demand rather than total site demand, that ERCOT operational-standards authority be narrowed to its statutory scope, and that the rule include a good-cause exception.
Expert witness testimony on behalf of CLECA addressing utility affordability, industrial rate design, and proposed spending impacts on large California energy users in PG&E's 2026 GRC.
Point-by-point response on behalf of the ERCOT Steel Mills to PUCT staff's March 2026 draft report — supporting a CP-based approach without shoulder months, retention of the 15-minute measurement interval, and opposing a minimum demand charge, with data showing zero non-summer months exceeded 90% of system peak from 2020–2024.
Initial comments filed on behalf of the ERCOT Steel Mills in the large load interconnection standards rulemaking, articulating the interests of existing industrial load customers in the design of new interconnection requirements.
Supplemental comments on PUCT staff questions regarding the 4CP transmission cost recovery methodology, addressing equitable treatment of existing industrial loads and the implications of potential methodology changes for energy-intensive manufacturers.
Initial participation in PUCT's evaluation of transmission cost recovery methodology under SB 6, representing ERCOT Steel Mills interests in the review of the four coincident peak (4CP) cost allocation framework.
Joint testimony with Catherine Yap on behalf of CLECA in SCE's marginal cost, revenue allocation, and rate design proceeding — addressing marginal generation capacity costs, marginal energy costs, distribution capacity cost methodology, revenue allocation, and rate design for large industrial customers.
Expert witness testimony on behalf of a broad ratepayer coalition — the California Large Energy Consumers Association, Agricultural Energy Consumers Association, California Farm Bureau Federation, California Manufacturers & Technology Association, California Metals Coalition, Energy Users Forum, and Energy Producers and Users Coalition — in Southern California Edison's 2025 General Rate Case.
Expert witness testimony on behalf of CLECA in CPUC's consolidated demand response proceeding covering PG&E, SCE, and SDG&E demand response program applications for 2023–2027 — addressing program design, budgets, industrial customer participation rules, and qualifying capacity methodology for large industrial loads.
Each entry opens a summary of the proceeding and the positions we took, with links to the documents on the public record. Confidential client matters are not listed.