The Legal Division supports the General Counsel in her role as attorney to the Commission.  The General Counsel, working with the legal staff, represents and appears for the People of the State of California and the Commission in all actions and proceedings involving any questions under the Public Utilities Code or under any order or act of the commission. 

The Division provides legal advice for a variety of clients:  the Commission, Administrative Law Judge Division, Energy Division, Water Division, Public Advocates Office, Communications Division, Safety and Enforcement Division, Consumer Protection and Enforcement Division, Rail Safety Division, the Office of Governmental Affairs and handles Public Record Act Requests and Subpoenas. 

The Legal Division is committed to providing high quality, timely legal services to all of its clients.

We advocate on behalf of and advise the Public Utilities Commission and its staff for the ultimate benefit of all Californians, striving to ensure that:

  • Commission decisions and processes comply with the law, and
  • regulated entities provide the public with safe, reliable and environmentally sustainable services at reasonable rates.

The Legal Division is a diverse, respectful, and collaborative team of lawyers and support staff providing high quality legal services to the Commission and its staff.  We do challenging and creative legal work, ensure fully-informed and well-reasoned decisions based on the record and advocate effectively in all forums.

JUSTICE - We strive to achieve fair processes and just results.

PROFESSIONALISM - We provide high quality legal services to all of our clients, creatively and in a timely manner, treating all people and interests with respect.

TEAMWORK - We – attorneys, support staff and managers – foster a supportive work environment and work cooperatively within Legal Division and with other divisions and agencies.

JOB SATISFACTION - We enjoy our work, encourage professional growth and initiative, and are recognized and respected for our contributions and accomplishments.  

Legal Division is organized into the following sections:

The Section handles all Cal Advocates and safety and enforcement matters.  As is true with all of the advocacy sections, this section can handle any of the industry areas, with an emphasis on energy and transportation.  Areas of primary responsibility are as follows:  Long-Term Procurement Planning (LTPP), Resource Adequacy (RA), Renewable Portfolio Standard (RPS), Energy Efficiency (EE), Energy Resources Recovery Accounts (ERRA), Net Energy Metering (NEM), Energy Storage (ES), Distributed Resource Plans (DRP), Water-Energy Nexus, and Utility Procurement Applications.  Principal Clients are Public Advocates Office (Cal Advocates), Safety and Enforcement Division (SED), and the Consumer Protection and Enforcement Division (CPED).

Chris Clay, Assistant General Counsel

Advocacy II Section

The Section handles all Public Advocates Office and enforcement matters. As is true with all of the advocacy sections, this section can handle any of the industry areas, with an emphasis on ratemaking and energy and water.  Areas of primary responsibility are as follows: Public Advocates Office - energy rate case litigation; Public Advocates Office – gas matters; Public Advocates Office - water utility rate case litigation; Public Advocates Office - telecommunication cases; SED and non-SED Enforcement.  Principal Clients are Public Advocates Office, SED, CPED.

Amy Yip-Kikugawa, Assistant General Counsel

Advocacy III Section

The Section handles advocacy, safety and enforcement matters, with a particular emphasis on wildfire safety, cost recovery and securitization, electric de-energization matters, emergency response planning, and transportation enforcement matters.  Principal Clients are Public Advocates Office, SED, and CPED. 

Charlyn Hook, Assistant General Counsel

Federal Advisory Section

The Section handles all federal district court and subsequent federal appellate court challenges to Commission decisions. This Section also handles federal advisory work, federal agency matters, including representation of the Commission and the utilities’ ratepayers before the Federal Energy Regulatory Commission (FERC) and the Federal Communications Commission (FCC), and if warranted, federal appellate court challenges to the federal agency decisions.  The section also advises on state proceedings that may have federal issues.   Principal Clients are the Commission and Energy and Communications Divisions.

Christofer Nolan, Assistant General Counsel

Government Law Advisory Section

The Section handles various administrative law matters, including but not limited to conflicts of interest, Public Record Act requests, employment law, and contract administration.  Along with the State and Federal Advisory Section, this section also handles questions that arise under the Commission’s Rules of Practice and Procedure and the Bagley-Keene Open Meeting Act.

Laura Gasser, Assistant General Counsel

State Advisory I Section

The Section handles state advisory matters, rehearings and state court litigation, involving state appellate courts (California Supreme Court and California Courts of Appeal).  As is true with all of the advisory sections, this section can handle any of the industry areas, with an emphasis on energy and transportation.  Areas of primary responsibility are as follows: Applications for Rehearing of Commission Decisions (all industry areas), State Appellate Court Challenges to Commission Decisions (all industry areas) and state advisory work.  Principal Clients are the Commission, the Executive Division, ALJ Division and all of the advisory industry divisions.

Vacant, Assistant General Counsel 

State Advisory II Section

The Section handles state advisory matters, rehearings and state court litigation, involving state appellate courts (California Supreme Court and California Courts of Appeal) and Superior court.  As is true with all of the advisory sections, this section can handle any of the industry areas, with an emphasis on telecommunications.  Areas of primary responsibility are as follows: State Advisory work, Applications for Rehearing of Commission Decisions (all industry areas), State Appellate Court Challenges to Commission Decisions (all industry areas), Superior Court.  Principal Clients are the Commission, the Executive Division, ALJ Division and all of the advisory industry divisions.

Jonathan Koltz, Assistant General Counsel

State and Federal Advisory Section

The Section handles both state and federal advisory matters, including federal agency work representing the Commission on behalf of ratepayers before the Federal Energy Regulatory Commission (FERC) and in related court challenges.  State advisory areas of primary responsibility include the following:  Wildfire Mitigation Safety and Costs, Public Safety Power Shutoffs, Water, Gas and Oil Pipelines, and Energy Reliability. Principal Clients are the Commission, the Executive Division, ALJ Division and the advisory industry divisions. 

Candace J. Morey, Assistant General Counsel

State and Federal Advisory and Special Projects Section

The Section handles both state and federal advisory matters, as well as special projects that may arise, or be assigned by the General Counsel.  As is true with all of the advisory sections, this section can handle any of the industry areas. Areas of primary responsibility are as follows: State and federal legislation, Superior Court litigation, Safety Advisory, CEQA/NEPA, administrative law and advisory work. Principal Clients are the Commission, the Executive Division, ALJ Division and all of the advisory industry divisions. 

Aaron Bloom, Assistant General Counsel