Under City of South Lake Tahoe v. California Tahoe Regional Planning Agency (9th Cir. 1980) 625 F.2d 231, 233 and its progeny, a state’s political subdivisions lack standing to challenge a state statute on constitutional grounds in federal court.  That rule applies to as-applied as well as facial challenges to state statutes.  Also, since the PUC is an arm of the State of California, it is entitled to sovereign immunity from suit in federal court.

No. 17-56693, 2019 U.S. App. LEXIS 27369 (9th Cir. Sep. 11, 2019)