CPUC · California

PG&E 2027 General Rate Case

A general rate case is where a utility's spending plans become customers' rates. PG&E's test-year 2027 GRC arrives with California industrial electricity rates already among the highest in the country — and with the state trying to retain manufacturing investment.

What we filed

The opening testimony of Sam Harper and John Holler (February 2026) took the following positions:

  • The Commission should recognize the seriousness of current electric rate unaffordability, evaluate PG&E's revenue requirement on a basis that accounts for accounting and procedural adjustments, and approve spending only if it results in declining electric rates across the entire 2027–2030 GRC period under all reasonable load-growth scenarios.
  • The Commission should evaluate PG&E's risk management programs using risk-neutral cost-benefit ratios as the primary analytical reference, and require PG&E to justify any program tranche with a ratio below 1 through explicit findings of safety necessity, legal obligation, or clearly articulated non-quantifiable benefits.
  • The testimony also assessed the sequencing and prioritization of load-growth investments and the reasonableness of PG&E's use of two-way balancing and memorandum accounts.

In June 2026, CLECA joined EPUC and the Indicated Shippers in a joint response opposing PG&E's motion for interim rate recovery.

Why it matters

For an energy-intensive manufacturer, electricity is a raw material: when California rates rise faster than competitors' rates in Texas or overseas, the arithmetic of where to locate the next production line shifts accordingly. Affordability arguments in a GRC are about whether the state's industrial base can continue to justify investment.

Facing a related regulatory or commercial question? Harper Advisory works with a focused number of large industrial energy users across ERCOT, CAISO, PJM, and other US markets.

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This summary is drawn from documents on the public record and is provided for general information. It is not legal advice, and it does not disclose any confidential client matter.