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Home My WebLink About2019-11-05; Clean Energy Alliance JPA; ; Review Proposed Implementation Timeline, Overview of Implementation Plan and Statement for Intent and Confirm Implementation Plan AssumptionsTO: CLEAN ENERGY ALLIANCE STAFF REPORT Clean Energy Alliance Board of Directors ITEM9: REVIEW PROPOSED IMPLEMENTATION TIMELINE, OVERVIEW OF IMPLEMENTATION PLAN & STATEMENT OF INTENT AND CONFIRM IMPLEMENTATION PLAN ASSUMPTIONS DATE: November 5, 2019 RECOMMENDATION: That the Board review the proposed Clean Energy Alliance (CEA) Implementation Timeline - Action Items (First Six Months) and overview of the CEA Implementation Plan and Statement of Intent and confirm that the plan's underlying assumptions are consistent with those identified in the CEA Joint Powers Agreement: • Default energy product from a minimum 50% renewable sources; • Offer a voluntary 100% renewable energy service at a premium above the default service rate; • Default rates that are set to provide a minimum target of 2% discount below San Diego Gas & Electric comparable service offerings. BACKGROUND AND DISCUSSION: Staff is presenting a proposed implementation timeline for action items to be completed during CEA's first six months (Attachment 1} and an overview ofthe CEA Implementation Plan and Statement of Intent. The Board is asked to confirm the underlying assumptions being used to develop the draft CEA Implementation Plan, which will be presented to the Board at its next meeting. IMPLEMENTATION TIMELINE There are several tasks that CEA will have to accomplish over the next six months in order to meet the goal of a 2021 launch. Staff has completed the attached timeline of pertinent action items to ensure all tasks are being completed on time and in compliance with regulatory requirements. These are high level tasks that do not include the detail of necessary steps that must be taken to accomplish the task. These are grouped into three general categories: • Administrative • Implementation Plan Related • Regulatory Compliance Administrative tasks include actions specific to the operations of the JPA, such as appointment of interim staff and adoption of policies and procedures. Implementation Plan Related tasks include actions specific to meeting the requirements established by California Public Utilities Commission (CPUC) Resolution E-4907 for the Clean Energy Alliance to begin serving customers in 2021. They include preparation, approval and filing of the Implementation Plan, creating and submitting a draft customer notice, filing the financial security (CCA bond) requirement and execution of the San Diego Gas & Electric Service Agreement. Regulatory Compliance tasks include actions such as preparation and filing of an initial Renewable Portfolio Standards Procurement Plan and participation in the year-ahead Resource Adequacy process. Staff will continually monitor and update the timeline to ensure CEA meets all needed milestones and compliance obligations to begin serving customers in 2021. CEA IMPLEMENTATION PLAN Public Utilities Code Section 366.2(c)(3) (Code) establishes the requirements related to the filing of an Implementation Plan (Plan) for a community choice aggregation program. The Plan is a regulatory compliance document that: • Must be considered and adopted at a noticed Public Hearing; • Must contain the following sections: o Organization structure, operations & funding o Ratesetting o Methods for entering and terminating agreements with other entities o Rights & responsibilities of program participants o Termination of program o Energy suppliers Code Section 366.2(c)(3) also requires a Statement of Intent that addresses: • Universal access • Reliability • Equitable treatment of customer classes • Compliance with requirements of state law or commission concerning greenhouse gas emission performance standards The Statement of Intent will be included as part of the Implementation Plan that is presented to the Board for consideration. In addition to the statutory requirements, the Plan will discuss the goals and purpose of the Clean Energy Alliance, such as CEA's renewable energy standards and rate discount targets, as identified in the JPA documents, including: • Offering an energy mix for its default service that provides a cleaner power portfolio than that of San Diego Gas & Electric (SDG&E) and from a minimum 50% renewable sources; • Offering a voluntary opt-up service at 100% renewable content that customers may elect to participate in; • Achieving -and sustaining -the Climate Action Plan goals of the Member Agencies; and • Setting rates with a target generation rate at least 2 percent below that of SDG&E's base product generation rate. To meet these goals, the Plan assumes an energy mix for its default service that is a minimum 50% renewable energy sourced, increasing to the goal of 100% by no later than 2035, at an assumed target rate 2% below that offered by SDG&E for its base energy product. The Plan will be written to meet all the requirements to be certified, while providing the Board the greatest flexibility as it considers program design and options in establishing its CCA program to meet the program goals. The Plan should be considered a statutory requirement and not a detailed business plan, that sets program targets and goals but does not lock the Board in to specific details that have not been fully reviewed or analyzed for feasibility. Pursuant to CPUC Resolution E-4907 the Implementation Plan must be submitted to the CPUC no later than January 1, 2020 for CEA to be eligible to serve customers in 2021. The CPUC has 90 days to review and certify that the Implementation Plan meets the requirements set forth in the Code, unless the CPUC staff responds with questions or requests additional information. The Plan being developed is modeled after implementation plans that have successfully been through the CPUC review and certification process, and as result, questions from CPUC staff are not anticipated. At this time, staff is seeking confirmation of the Plan assumptions and will be bringing the draft Plan for Board review at its next Board meeting, with the public hearing for adoption to be scheduled in December 2019. Attachment: 1. Clean Energy Alliance Implementation Timeline -Action Items (First Six Months) 1 11/5/2019 2 11/5/2019 3 11/5/2019 4 11/5/2019 5 11/5/2019 6 11/5/2019 7 11/5/2019 8 11/5/2019 9 11/5/2019 10 11/19/2019 11 11/19/2019 12 12/19/2019 13 12/31/2019 14 1/16/2020 15 1/16/2020 16 1/16/2020 17 1/16/2020 18 2/20/2020 19 2/20/2020 20 2/20/2020 21 3/19/2020 22 3/19/2020 23 4/23/2020 Key: Clean Energy Alliance Implementation Timeline -Action Items First Six Months Nov-19 Dec-19 Authorize RFP for Executive Director Appoint Board Treasurer/CFO Appoint Board Secretary Appoint Board General Counsel Appoint CEA Regulatory Counsel Approve Conflict of Interest Policy Determine Meeting Schedule & Locations Board Direction on Staffing Board Confirm Default RPS and Rate Discount Board Approve Cost Reimbursement Agreement for Member Agency Support Draft Implementation Plan & Statement of Intent Appoint Executive Director Approve & File Implementation Plan & Statement of Intent Approve FY 19/20 Budget Select Financial Institution & Approve Financing Plan Select Technical Consultant to Assist with Regulatory Filings Select Data Manager Develop Draft Customer Notice for Submittal to CPUC Secure CEA Website Domain (by 12/1/19); create website; create CEA logo Develop RPS Procurement Plan Post CCA Bond with CPUC Execute Service Agreement with SDG&E Resource Adequacy Compliance Filing Administrative Implementation Plan Related Regulatory Compliance Attachment 1 Jan-20 Feb-20 Mar-20 Apr-20 Item 9: Review Proposed Implementation Timeline, Overview of Implementation Plan & Statement of Intent and Confirm Implementation Plan Assumptions Dan King Clean Energy Alliance Board Meeting November 5, 2019 Item 9: Review Proposed Implementation Timeline ... RECOMMENDED ACTION: That the Board review the proposed Clean Energy Alliance (CEA) Implementation Timeline -Action Items (First Six Months) and overview of the CEA Implementation Plan and Statement of Intent and confirm that the plan's underlying assumptions are consistent with those identified in the CEA Joint Powers Agreement. 11/14/2019 18 Item 9: Review Proposed Implementation Timeline ... IP PLAN PURPOSE: • Regulatory formality submitted to CPUC • Specific items to be included • Public Utilities Code Section 366.2(c)(3) • Approval at a Public Hearing • Modeled on Successfully Certified Implementation Plans • Intentionally flexible • Provide Board greatest flexibility and discretion to develop program over next 18 months Item 9: Review Proposed Implementation Timeline ... REQUIRED CONTENT: • Organization structure, operations & funding • Rate setting process • Methods for entering and terminating agreements with other entities • Rights & responsibilities of program participants • Energy suppliers 11/14/2019 19 Item 9: Review Proposed Implementation Timeline ... STATEMENT OF INTENT: • Required by Public Utilities Code Section 366.2 • Address commitment to: • Universal Access • Reliability • Equitable treatment of customer classes • Compliance with requirements of state law or CPUC concerning Greenhouse Gas Emission performance standards Item 9: Review Proposed Implementation Timeline ... PRIORITIES/GOALS OF CLEAN ENERGY ALLIANCE: • Default energy product from a minimum 50% renewable sources 11/14/2019 • Voluntary 100% renewable energy product at premium above default rate • Default rates that are set to provide a minimum target of 2% discount below San Diego Gas & Electric comparable service offerings. 20 I 11/14/2019 Item 9: Review Proposed Implementation Timeline ... SCHEDULE: • Must be filed by January 1, 2020 to serve customers in 2021 • CPUC has 90 days to certify Implementation Plan meets requirements in Public Utilities Code or respond with questions • Within same 90 days CEA is required to: • Submit a draft Customer Notice • Submit CCA Bond & SDG&E Service Agreement • Prepare & file Initial Renewable Portfolio Standards Procurement Plan • CEA registered as a CCA Item 9: Review Proposed Implementation Timeline ... NEXT STEPS: • Draft IP and Statement of Intent presented to Board at November 19, 2019 Board Meeting • Final IP and Statement of Intent approved by Board at December 19, 2019 Board Meeting • IP submitted to CPUC by December 31, 2019 21 Task# Tlmlnor l 11/5/19 2 11/5/19 3 11/5/19 4 11/5/19 5 11/5/19 6 11/5/19 7 11/5/19 8 11/5/19 9 11/5/19 10 11/19/19 11 11/19/19 12 12/19/19 13 12/31/19 14 1/16/20 15 1/16/20 16 1/16/20 17 1/16/20 18 2/20/20 19 2/20/20 20 2/20/20 21 3/19/20 22 3/19/20 23 4/23/20 Key: Oean Energy Alliance TimeUne of Action Items First Sil Months Descrfmlnn Nov-19 Authorize RFP for Exea.Jtive Director Anrrint Interim Board Treasurer/CFO 1A0Doint Interim Board Secretarv Appoint Board General Counsel .a.n~nt CEA Soedal Resi:ulatorv counsel Approve Conflict al Interest Polley De term lne Meetlrc Schedule & Locations Board Direction on Staffin• • If needed Board Confirm lmplementatlon Plan Assumptions Board Approve Cost Reimbursement Aareement for Member 1>11.eoo, Sunoort Draft lmDlementation Plan & Statement of Intent Appoint Interim E>cecutl"" Director Approve & File Implementation Plan & Statement of Intent Approve FY 19/20 Bu<feet Select Financial Institution & Approve Flnanci~ Plan Select Technical Consultant to Assist with Reaulatory Flllrcs Select Data Manaeer DeYeloo Draft OJstorner Notice for Submittal to CPUC Secure CU Website Domain (by 12/1/19); create website; aeate CEA 1010 Develoo RPS Procurement Plan Post <XA Bond with CPUC ExeaJte Service A&reement with SDG&f Resource A""""aCV Compliance Fllln1 Administrative Im ementatlon Plan Related Re ulat Com lance 11/14/2019 Dec-19 Ja~20 Feb-20 Mor-20 --20 22