CAISO is asking the California Public Utilities Commission to consider issuing a new procurement order to meet the state’s electricity reliability needs from 2028 to 2032, citing significant forecasted load growth in those years. 

New resources could be needed over the period in addition to existing procurement orders and load-serving entity resources, CAISO said in its filing. 

The California Energy Commission’s most recent demand forecast shows more load growth in those years than prior forecasts, CAISO said. CPUC’s existing procurement orders provide resource requirements up to 2028. 

Without explicit new procurement orders, LSEs might not schedule new development projects with sufficient lead time, risking capacity shortfalls when options to cure shortfalls may be limited, CAISO said.  

“This outcome not only creates reliability concerns but could also result in a tight resource adequacy market and high RA prices in nearer-term years where new development is not an option,” CAISO said. 

CAISO asked CPUC to conduct a near-term needs assessment for 2028-2032, which could lead to a new procurement order issued as soon as the end of 2025, and develop a comprehensive Reliable and Clean Power Procurement Program (RCPPP) framework over a longer period. 

CPUC’s RCPPP proposal, published in April 2025, will develop long-term procurement requirements to allow LSEs to plan and implement their procurement of reliable and clean electric resources, the proposal says. CAISO supports the RCPPP goal to shift procurement away from emergency-based or “just in time” orders to more proactive procurement approaches, the ISO said in its filing. 

CAISO is concerned about relying on the state’s RA program to meet demand from 2028-2032. In previous CPUC decisions, the agency set planning reserve margin (PRM) levels and thus RA requirements below levels needed to meet a 0.1 loss-of-load expectation (LOLE) because of the risk of project delays and tight supply conditions, CAISO said in the filing. 

Concerns about tight supply conditions persist, so CPUC should seek to minimize risks of supply shortfalls that result in the CPUC setting binding RA requirements below levels needed to meet a 0.1 LOLE reliability target, CAISO said. 

CAISO’s Cluster 14 interconnection queue contains significant potential new capacity, which could come online between 2028 and 2032 if CPUC determines new resources are needed, the ISO said. Many of these projects do not currently have power purchase agreements. 

In 2021, Cluster 14 had 373 interconnection requests for a total of about 150,000 MW of proposed generating capacity, CAISO said in a 2021 staff proposal. In total, CAISO’s generator interconnection queue contains 246,000 MW of potential generating capacity. 

CAISO’s 2024 peak demand was 48,323 MW. Even with robust procurement in the future, the potential generation available in the region exceeds demand by a significant margin, CAISO said in the proposal.