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A December 3 CPUC Vote Could Get Commercial EV Chargers and Batteries Connected Before Grid Upgrades Finish. What Southern California Site Owners Should Know

November 9, 2026 · Burge Energy · 6 min read

If your EV charging grid connection is stuck behind a utility upgrade, a proposal now before California regulators is worth your attention. On October 20, 2026, a California Public Utilities Commission (CPUC) commissioner issued a proposed decision that would direct Southern California Edison (SCE), San Diego Gas & Electric (SDG&E) and Pacific Gas and Electric (PG&E) to expand Flexible Service Connections, which let a site energize with operating limits instead of waiting for full capacity. The earliest the Commission could vote is its December 3, 2026 business meeting.

Status: proposed, not adopted. A proposed decision has no legal effect unless the full Commission approves it, and it can be revised or held before then.

A second proposed decision, mailed October 26, 2026, is also eligible for the December 3 meeting. It affects owners pairing a large battery with net metered solar, including adding one to an existing system. Both are covered below.

What the CPUC is proposing on flexible connections

The proposal is in the CPUC's grid modernization rulemaking (R.21-06-017, Agenda ID 24599). As written, it would:

  • Require the three large utilities to evaluate whether a flexible connection could defer or avoid an upgrade before they move ahead with a ratepayer funded upgrade. Participation stays voluntary for the customer.
  • Extend the Flexible Service Connection Standard Offer, already required of SCE and PG&E, to SDG&E.
  • Require SCE and SDG&E to offer "variable operating envelope" connections modeled on PG&E's Flex Connect, where the allowed load can change with grid conditions.
  • Allow customers on a temporary, bridging connection to move to a longer term, non-bridging version within a set period.
  • Require utilities to give customers the information needed to decide, including upgrade schedules, expected curtailment and equipment needs.

The proposal also says utilities may not exclude customers from evaluation solely by customer class or size unless they show those customers have no realistic chance of deferring or avoiding an upgrade. It would update Electric Rule 2 so that the limit on a customer's power control system is based on demand load rather than connected load, with the utilities filing those tariff changes in an advice letter within 45 days of adoption.

How an EV charging grid connection works under today's rules

The flexible option is not brand new. In Decision 26-02-025, adopted February 5, 2026, the CPUC required SCE and PG&E to offer a Standard Offer for Flexible Service Connections. Under that decision, a new or expanding customer waiting on a grid upgrade can receive firm but limited capacity on a Limited Load Profile, a schedule of allowed power levels by season and time of day, until the constraint is resolved. The decision did not require SDG&E to offer it at the time.

Key mechanics from the February decision:

  • The customer controls its own load. A power control system certified to UL 3141 receives safe harbor treatment.
  • The utility checks compliance with advanced meter data, and telemetry is not required.
  • Taking the Standard Offer does not change the customer's place in the energization queue.

SCE's Flexible Service Connection fact sheet describes these arrangements as bridging solutions, not permanent replacements for full service, and names large commercial and industrial customers and fleet charging facilities among those who may benefit most. SCE makes the final eligibility call based on engineering analysis, and the connection neither speeds up nor delays the required grid upgrade.

PG&E's Flex Connect pilot shows the variable version the proposal would bring to SCE and SDG&E. PG&E's own example is a site that requests 2 MW for DC fast chargers but would otherwise be limited to 0.5 MW year round because of constraints in a small number of hours. Under the pilot, it can typically draw the full 2 MW. PG&E sends the site an hourly power limit forecast a day ahead, and the site's chargers adjust automatically.

A second December 3 item: battery sizing for net metered solar

The second proposal (R.19-09-009, Agenda ID 24607) concerns a long standing rule for storage paired with a net energy metering (NEM) generator. Under that rule, storage devices larger than 10 kilowatts (AC) are limited to 150% of the NEM generator's maximum output. The CPUC temporarily removed that limit in 2020, and Executive Director letters have extended the waiver since. The current extension runs until 30 days after the Commission acts on this petition.

The proposed decision would extend the temporary removal to January 1, 2030, and would keep existing metering requirements. Its ordering paragraphs also refer to cost responsibility for grid upgrades for oversized systems that charge or discharge from the grid, while its discussion says that question needs more analysis, so watch whether the final text resolves this. It would deny the request to remove the limit permanently, finding the record insufficient for now. The proposal does not limit the waiver by customer class.

If you are on a Net Billing Tariff system, ask your utility whether the same limit applies to you. For a commercial owner with an older NEM solar system who wants a battery sized for demand charge management or backup, rather than matched to the size of the solar array, this keeps that design path open while the waiver lasts.

What this means for your project

Neither proposal is final, and the text can change before or at the vote. Owners planning EV charging, fleet charging or battery projects in SCE or SDG&E territory can still prepare now:

  • Ask the capacity question early. Before you finalize charger counts, request the utility's preliminary capacity review for the site. SCE's fact sheet points applicants to its Preliminary Capacity Assessment and to a service application that includes load profiles and flexible load details.
  • Say you are open to a flexible connection. SCE's fact sheet says your application can state that you are willing to operate under a Flexible Service Connection if constraints exist. It does not guarantee eligibility, but it keeps the option on the table.
  • Plan for load management hardware. Budget and space for a power control system and charger software that can hold a site to a set power level. UL 3141 certification matters under the current Standard Offer.
  • Check your operations. Flexible connections work best when charging can shift by hour or season. Map when vehicles actually need to charge before you agree to a load profile.
  • Size storage with the deadline in view. If you are adding a battery to existing NEM solar, ask how the January 1, 2030 sunset in the proposal would affect your design, metering and interconnection paperwork.
  • Watch December 3. Burge Energy will track the outcome. If the Commission adopts, holds or revises either item, the timelines above may shift.

How Burge Energy can help

Burge Energy designs and builds commercial solar, battery storage and EV charging systems for new and existing buildings across Orange County and Southern California. We can review your site's electrical service, help you prepare the utility service application, design charging and storage around realistic load limits, and coordinate with the utility through energization. Burge has been building in Southern California since 1977, and we are licensed (CSLB) and covered for solar, storage and EV charging work. Learn more about Burge Energy, review current incentives, or Request an Energy Assessment.

Sources

Incentive eligibility depends on project specifics. Confirm with your tax advisor and the program administrator before relying on any figure here. Tariff and interconnection terms also depend on your site, so confirm timelines with your utility. This article is general information, not legal, tax or financial advice, and it is current as of November 9, 2026.

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