CPUC Monitoring

WPTF also provides regulatory and legal advocacy on issues and proceeding at the California Public Utilities Commission (CPUC). CPUC advocacy is focused on supporting development of competitive electricity markets throughout the region and developing uniform operating rules to facilitate transactions among market participants. This work is not part done as under a dedicated committee per se, but rather, under the direction of the WPTF Board, individual members elect to fund the participation in specific proceeding.

Currently, these include

  •          Integrated Resource Planning,
  •          Implementation of the Renewable Portfolio Standard,
  •          Demand Response,
  •          SoCalGas Balancing/Aliso Canyon and
  •          SONGS

Given the variety of different proceedings, careful attention is paid to ensuring consistency among filings and adherence to WPTFs established and annually updated policy statement. WPTF counsel also works closely with WPTFs CAISO Committee leader to ensure that all necessary filings at FERC are accomplished on a timely and consistent basis. In addition, as new matters arise at the Commission, the Board is informed of these developments to determine the degree of involvement required.

WPTF CPUC advocacy has been instrumental in shaping the resource adequacy, long-term procurement plan (now the integrated resource planning) and RPS programs over the years by advocating on behalf of both generation and retail interests. For example, a recent IRP ruling showed a clear sensitivity as to whether in seeking to identify the exact resources needed to maintain reliability, it would be proper for the Commission to move from market-oriented solutions.

The fact this question is even being asked reflects years of WPTFs advocacy for market solutions over administrative fiats. On the strictly legal side, WPTF was successful in urging the Court of Appeals to annul the CPUCs Oakley decision that approved PG&Es request to acquire a new gas-fired power plant in Oakley, California.


Contact Person

He adds significant value to his clients due to the perspective gained from having spent a third of his career in management positions in the energy industry.  His background includes senior managerial positions in the utility, pipeline, gas marketing and independent power industries.  Before entering private practice, he served as Senior Vice President and General Counsel of LG&E Power Inc.  Prior to that position, he was the first President and Chief Operating Officer of the natural gas marketing company Cook Inlet Energy Supply (now Macquarie Cook).  During his tenure in marketing and gas supply positions at Southern California Gas Company, he conceived and implemented the nation's first large-volume spot market utility gas purchasing program and California's first natural gas transportation program.  As Senior Counsel for Pacific Lighting Corporation (now Sempra Energy), his legal efforts included a diverse domestic and international energy transactional practice.Dan Douglass coordinates all of WPTFs legal committees.  He specializes in energy law issues, providing regulatory and transactional counsel to sellers and end-users in the electricity and natural gas markets.  His particular specialty is representation of generation owners, energy service providers and large consumers of electricity and natural gas.  This includes assisting in the formation and representation of several influential regulatory advocacy organizations such as WPTF, the Direct Access Customer Coalition and the Alliance for Retail Energy Markets.  These organizations are quite active at the California Public Utilities Commission and have had notable successes in regulatory proceedings affecting competitive markets.  Prior to Douglass & Liddell, he was a partner with the national firm of Arter & Hadden, where he headed the firm's California energy practice.  As a sole practitioner, he developed green field power projects in Argentina and formed the Direct Access Alliance when restructuring was commencing in California.

Mr. Douglass holds a J.D. from the UCLA School of Law, and an M.B.A. from its Graduate School of Management.  His undergraduate degree in political science is also from UCLA.

Douglass & Liddell
21700 Oxnard Street, Suite 1030
Woodland Hills, CA 91367
Phone 818-961-3001
Fax: 818-961-3004
Mobile: 818-404-7535