California Public Utilities Commission: Confidential Data In, Public Records Out, On One Files.com Site

The California Public Utilities Commission regulates the investor-owned utilities that serve California: electric, natural gas, water, telecommunications, and passenger transportation. Inside it, the Energy Division oversees the state's ratepayer-funded energy efficiency programs, a combined budget of roughly a billion dollars a year. California has led the nation on energy efficiency for decades, and in 2025 it ranked first on the American Council for an Energy-Efficient Economy's state scorecard for the seventh time.

The Commission does not take savings claims on faith. The Energy Division manages and contracts every evaluation, measurement, and verification study used to prove what those programs saved, and it hires outside evaluation firms to do the work. That work is field-intensive primary research: evaluators call and visit the homes and businesses that participated in the programs, and California law specifically protects the confidentiality of those participants.

“Every dang lightbulb, every dang TV, every fridge, every washer-dryer, every hot water heater, literally everywhere.”

That structure is where the problem was always going to come from. The data behind every study is produced by firms the Commission does not employ, on contracts that make the raw data state property. Getting it into state hands, governing access by contract, and eventually putting finished records in front of the public is file exchange. The Division needed one governed site for confidential intake and public release. And a state agency is not free to do file exchange however it likes.

Data the State Owns, Produced by Firms It Does Not Employ

Every evaluation contract obliges the firm to hand over the raw data it developed while evaluating the programs, and ownership passes to the Commission. The deliverables are heavy: datasets run to multiple gigabytes, and a single evaluation folder on the Commission's site exceeds 80 GB.

Custody was only the first of three obligations pulling in different directions. Much of the material is confidential, covering the households and businesses that took part in the research, so an evaluation firm can be shown only what its own contract entitles it to. The end product runs the other way entirely: finished evaluation reports and their datasets are public records, published for anyone in California to download.

The constraint sitting over all of it was the envelope around a state agency.

“Because we're the state of California, we're very restricted on who we can share stuff with.”

The consumer sharing tools a private company defaults to were off the table. When the team surveyed cloud file storage options in 2014, handling files larger than a gigabyte was one of its explicit test points, and a 2.5 GB file-size ceiling was enough to knock an option out of testing. On top of that, the evaluator population is seasonal: each new evaluation cycle brings new firms whose people need access, alongside folders most of them must never see. The agency owed the public its data and owed its research participants confidentiality, and it had no sanctioned way to move files with outsiders at all.

What the Division needed was a single exchange point that could do all of it: admit an outside firm to exactly the folders its contract covers and nothing else, open confidential folders case by case, move files in the tens of gigabytes, and still hand the general public a plain download link. The Energy Division selected Files.com to be that exchange point.

One Folder Tree, From Single-Folder Contractors to Public Links

Files.com became the single governed home for the whole lifecycle of an evaluation: raw data in from the contractors, confidential analysis held in the middle, and the finished public record going out the other side.

Keeping every party in its lane is the work of Files.com groups and folder-level permissions applied across a multi-level folder hierarchy. Each evaluator group has a private folder for its own work and a shared folder others can read. Confidential folders sit apart from both, opened case by case to named individuals or groups. At the tightest end, an outside party can be admitted to exactly one folder with no visibility of its parents or siblings. As far as that user can tell, the folder is the entire site.

The same structure absorbs turnover. Contractor onboarding happens through group membership, so when a new cycle brings a new firm, its people are added to a group and the folder permissions come with them. When the cycle ends, they are removed the same way.

Files move at whatever grain the sender needs. Commission staff and evaluators work in the web interface day to day, and firms transferring multi-gigabyte datasets connect over SFTP and FTP against the same folders and the same permissions.

The public end runs on Files.com Share Links. When a report and its dataset are finished, the Division creates a link and publishes it on the CPUC's public website, where anyone can follow it and download the record with no account and no request process.

A Decade of Growth, Run by the Program's Own Analysts

With the whole lifecycle on one site, the Energy Division turned an exchange it had no sanctioned way to perform into the standing infrastructure of its evaluation program.

The data underneath has grown the way a regulator's data grows: from about a terabyte in 2016 to several terabytes a decade later, much of it held under a seven-year retention mandate and kept longer still against public-records requests. Files.com absorbed that growth without the Commission standing up any infrastructure behind it. Day to day, the site is administered by a senior regulatory analyst inside the Energy Division, not by a dedicated IT operation.

Both Ends of the Transparency Spectrum

Today, a decade in, the most restricted material the program produces and the most public sit on the same Files.com site. An evaluator uploads raw survey data into the one folder their firm can see. An analyst opens a confidential folder to exactly the people a study requires. Anyone in California follows a link on the Commission's website and downloads the finished report. A government body barred from consumer sharing tools did not need one system for confidential intake and another for public release. One permissioned platform serves both ends.