Grid Justice Law

Energy litigation & regulatory advocacy · Western states & Hawai‘i

Energy matters.

For people and planet.

Grid Justice Law represents ratepayers, communities and clean energy advocates before utility commissions, lawmakers and courts. We fight to keep AI data centers and utility overreach from pushing their costs onto households and small businesses, and to open the grid to rooftop solar, storage and community microgrids.

Talk about a matter Bringing rates down

Rate affordability

Power bills have doubled. They don’t have to keep climbing.

Electricity has become one of the fastest-rising costs for western households. The increases come from choices regulators make: what utilities may build, how much they may earn on it, and who pays. Different choices can bring bills down.

Residential rate increases, 2015 to 2025

California’s three big utilities, compared with inflation over the same period

Source: Cal Advocates, Q4 2024 Electric Rates Report (Jan. 2015 – Feb. 2025)

What’s driving the increases

Share of recent California rate growth, by cause

50–60%Wildfire mitigation and liability. Now about 21% of PG&E’s revenue requirement.
25–30%Transmission and distribution spending, which earns utilities a guaranteed return
10–15%Rooftop solar incentives, the smallest of the three
2.27MCalifornia households behind on their electric bills, owing $769 on average (Dec. 2024)

What to do about it

Make data centers pay their own way

Require clean, self-supplied power and dedicated large-load tariffs, so the next wave of grid spending isn’t added to household bills.

Large-load tariffs, BYOG conditions, stranded-asset protection

Test big spending against cheaper options

Before ratepayers fund undergrounding or new transmission, commissions should compare it with microgrids, storage and local solar that can do the job for less.

Alternatives analysis in wildfire and transmission plans

Build storage and distributed energy at scale

Batteries and local resources cut peak demand and defer grid upgrades. Our modeling finds that about 50 GW of storage in California by 2035 could lower average rates by roughly a third.

Grid Justice Law analysis, Nov. 2025 (projection)

Lower the cost of utility capital

Challenge authorized returns that exceed what investors need, and finance suitable infrastructure through lower-cost public tools.

Cost of capital and general rate case intervention

Design rates that reward self-reliance

Oppose high fixed charges and export cuts that punish customers who conserve, add solar or share it with renters.

Rate design, net metering, community solar

Protect the households hit hardest

Expand bill assistance, stop shutoffs for families in arrears, and open clean energy programs to renters and low-income customers.

Low-income programs, energy burden, consumer protection

Households

Ask your utility whether you qualify for CARE or FERA discounts, and get quotes for solar with battery storage to see what it would save your household.

Cities and community groups

Rate cases are open to public participation, and California pays intervenor compensation to eligible parties. We can help you take part.

AI data centers

Why AI data centers could explode rates even more

A single hyperscale AI campus can draw as much power as a mid-sized city, around the clock. Utilities are racing to build the plants and power lines to serve them. Under today’s rules, much of that cost can be spread across every customer’s bill, and households keep paying even if the data center never shows up or leaves early.

Step 1

A developer requests huge new load

Hundreds of megawatts per site, often on aggressive timelines and with forecasts that may never materialize.

Step 2

The utility builds or buys capacity

New generation, substations and transmission, plus higher prices in capacity markets as demand tightens supply.

Step 3

Costs go into everyone’s rates

Infrastructure enters the rate base and earns the utility a return for decades, recovered from all customer classes.

Step 4

Ratepayers hold the risk

If the load shrinks, moves or never arrives, the stranded assets stay on household and small business bills.

9×

Jump in PJM capacity prices in one auction, from $28.92 to $269.92 per MW-day. Total cost rose from $2.2 billion to $14.7 billion, driven largely by projected data center demand.

PJM 2025/26 Base Residual Auction
$14–37

Added to a typical Virginia household’s monthly bill by 2040 from the generation and transmission needed for data center growth.

Virginia JLARC, Data Centers in Virginia (2024)
~10 GW

Of new data center load seeking service from PG&E alone, roughly the output of ten large nuclear reactors.

PG&E large-load pipeline, 2025

The fix: Bring Your Own Generation

If you build it, you power it.

Clean BYOG means data centers supply their own power from clean, additional resources, and stay ratepayer-neutral for anything they still draw from the grid.

It applies cost causation to the biggest new loads on the grid. The companies profiting from AI pay for the power it uses, instead of families and small businesses.

  • Self-supply with new clean power

    On-site or contracted generation and storage that is additional to the grid, not a claim on resources other customers already pay for.

  • A dedicated large-load tariff

    A separate customer class that pays the full cost of any grid service, upgrade or backup power it uses.

  • Stranded-asset protection

    Long-term contracts, minimum bills, collateral and exit fees, so households never inherit the cost of an abandoned campus.

  • Flexibility in emergencies

    Data centers curtail or switch to their own supply first during grid shortages, before any household loses power.

  • No secret contracts

    Special contracts and cost allocations filed in public dockets, open to review by ratepayer advocates.

Where pieces of BYOG are already law

Minnesota HF 16 · large-customer tariff, cost-shift ban, stranded-asset protection Texas SB 6 · large loads curtailed first in grid emergencies Utah SB 132 · direct supply contracts kept off other customers’ rates Ohio PUCO · data centers pay for most of the grid capacity they reserve

Why it has to be clean. Without that requirement, “bring your own generation” can mean private gas plants that sidestep state renewable standards, as Nevada regulators allowed in 2026. Clean BYOG protects ratepayers and the climate at the same time.

Facing a data center proposal? Talk to us

The principle behind every case

One rule of ratemaking, applied to everyone.

Cost causation is basic utility law: whoever causes a cost should pay for it. Regulators already enforce it hard against families with rooftop solar. Our work is making them apply the same standard to the largest new loads on the grid.

Rooftop solar customer Strict scrutiny

  • Export credits cut to avoided-cost levels over claimed “cost shifts”
  • Fixed charges and interconnection fees to recover grid costs
  • Upgrade costs assigned to the customer who triggers them

Hyperscale data center Often socialized

  • Transmission and generation built for new load, recovered from all customers
  • Special contracts filed as confidential, out of public view
  • Stranded-asset risk left with ratepayers if the load leaves

Same principle. Same rules. No exemptions for Big Tech.

Practice areas

Where we work

Utility commission proceedings, writs and appeals, legislation and local ordinances, across California, Hawai‘i and the western states.

AI data centers and Bring Your Own Generation

Large-load tariffs, special contracts, cost allocation, conditions of approval

Utilities across the West are planning gigawatts of new generation and transmission to serve AI data centers. Unless regulators act, the bill for that buildout lands on everyone else.

We advocate for clean BYOG: data centers supply their own power through clean, additional, ratepayer-neutral resources, and pay the full cost of any grid service they still need. Minnesota’s HF 16, with dedicated tariffs, cost-shift prohibitions and stranded-asset protections, is the model to beat.

What we do

  • Intervene in large-load tariff and rate cases
  • Challenge confidential special contracts
  • Draft ordinances, moratoria and conditions of approval
  • Energy and grid-cost support in CEQA and NEPA cases

Electricity affordability

Rate design, revenue requirements, fixed charges, energy burden

Residential rates in California have risen far faster than inflation, and Hawai‘i pays the highest rates in the country. Wildfire spending, transmission buildout and guaranteed utility returns drive most of the increase.

We press commissions to compare every major spending program against lower-cost distributed alternatives, and to design rates that don’t punish the customers who conserve and self-generate.

What we do

  • Rate design and general rate case intervention
  • Cost-benefit challenges to wildfire and transmission spending
  • Advocacy for renters and low-income households

Rooftop solar, storage and interconnection

Net metering, Rule 21, hosting capacity, upgrade cost sharing

California’s NEM 3.0 decision cut export compensation by roughly three quarters, and the rooftop solar market contracted sharply. Customers who try to connect solar and storage still face long delays, shifting technical requirements and upgrade charges that utility projects don’t.

We build the factual record to challenge that unequal treatment, now under the stronger judicial review available after Center for Biological Diversity v. CPUC (2025).

What we do

  • Interconnection rule reform
  • Fair compensation for exported energy
  • Applications for rehearing and writ petitions

Microgrids, wildfire and resilience

Community microgrids, PSPS alternatives, distribution planning

Undergrounding lines through fire country costs millions of dollars per mile. Solar-and-storage microgrids can protect remote communities at a fraction of that cost, and keep the lights on during shutoffs.

Projects such as PG&E’s Briceburg remote grid and the Blue Lake Rancheria microgrid show it works. We push planners to weigh these options before ratepayers fund the most expensive one.

What we do

  • Microgrid tariffs and approval rules
  • Alternatives analysis in wildfire mitigation plans
  • Resilience for critical facilities

Hawai‘i energy and food sovereignty

Island self-sufficiency, DER access, agrivoltaics

Hawai‘i imports roughly 90 percent of its energy and 90 percent of its food. One shipping disruption can threaten both. Rooftop solar, storage, community microgrids and farms that make their own power are the path to resilience.

We bring lessons from California proceedings to the Hawai‘i PUC and county councils, including the current debate over large AI data centers on the Big Island.

What we do

  • DER interconnection and compensation
  • County data center ordinances
  • Agrivoltaics and food-energy resilience hubs

Public trust and the duty to regulate

Atmospheric public trust doctrine, agency inaction

States hold the air, water and climate in trust for the public. When agencies decline to act on data center emissions, water use or grid impacts, the public trust doctrine can supply the obligation to act.

We develop these theories alongside cost causation and affordability claims, so each case rests on more than one leg.

What we do

  • Petitions to compel agency action
  • Public trust claims in western states
  • Policy research and amicus support

For co-counsel, communities and local governments

The firm that knows both the zoning hearing and the rate case.

Most data center fights split into land-use litigation and utility regulation, and few lawyers work both. We bridge the two.

Energy co-counsel in CEQA and NEPA cases

Energy, emissions, backup-generator and grid-reliability arguments, expert coordination, and remedies such as clean-power conditions.

land-use litigators, environmental NGOs

Utility commission intervention

Large-load tariffs, rate cases, resource plans and special contracts, with intervenor compensation where the state provides it.

community coalitions, cities, counties

Consulting and expert support

Cost-shift analyses, declarations, comment letters, model ordinances and conditions of approval.

litigators, councils drafting ordinances

Writs and appeals

Applications for rehearing and writ petitions framed for independent judicial review of commission statutory interpretation.

any party appealing a commission decision

Settlement design

Terms for 100% renewable supply, recycled cooling water and community benefit funds.

plaintiffs negotiating with developers

Policy and legislation

Bill analysis and drafting for BYOG, ratepayer protection and intervenor compensation statutes.

legislators, advocacy coalitions

On the docket

Current work

We appear as a party in proceedings where the rules for who pays are being written.

CPUC · R.26-04-009

Advanced Electric Rate Design rulemaking

Party representing distributed energy interests. Opening comments filed on the OIR, arguing that rate design must protect rooftop solar economics and hold data centers to the same cost causation standard.

CPUC · Intervenor compensation

Applications for rehearing

On behalf of the Green Power Institute, challenging compensation decisions that undervalue the work of public interest intervenors, starting with the microgrids proceeding (R.19-09-009).

Coming Jan. 2027 · SB 57

CPUC report on data center cost shifts

We will publish a response analysis when the Commission releases its report.

About the firm

Tam Hunt has spent his career on the side of distributed energy and the people who pay the bills. He has worked for years before the California Public Utilities Commission on interconnection, net metering, microgrids and cost allocation, including long work with the Green Power Institute.

He is the author of Solar: Why Our Energy Future Is So Bright, has written on AI safety for Scientific American, and serves on the board of the Hawai‘i EV Association.

Grid Justice Law is small by design. Research, docket tracking and first drafts are supported by AI tools under attorney supervision, which keeps costs low for public interest clients. Every filing is reviewed and signed by counsel.

Contact

Facing a data center, a rate hike or a blocked interconnection?

Tell us about the proceeding or the project. Please don’t send confidential details until we’ve confirmed there’s no conflict.

tam.hunt@gmail.com