Loading...
HomeMy WebLinkAbout2020-10-01; Clean Energy Alliance Operational, Administrative and Regulatory Affairs Update; Haber, JasonTo the members of the: ,o)IT'f COUNCIL Date ~ CA ~ CC --1:_ Ctv,_1:_ACM ~DCM (3).1::._ October 1, 2020 Council Memorandum To: Honorable Mayor Hall an From: Via: Jason Haber, lntergovernm,...1.1,; __ ,airs Director Scott Chadwick, City Mana e {city of Carlsbad Memo.ID# 2020208 Re: Clean Energy Alliance Oper onal, Administrative and Regulatory Affairs Update This memorandum provides an update on the Clean Energy Alliance's operational, administrative and regulatory affairs activities, as presented in the attached Sept. 17, 2020, Clean Energy Alliance Staff Report. Among other things, the report provides an update on the Clean Energy Alliance launch schedule, which anticipates beginning service to customers in a two-phased approach; transitioning accounts from SDG&E to the Clean Energy Alliance in May and June 2021. The report also addresses two ongoing proceedings at the California Public Utilities Commission (CPUC) that have been discussed previously by the City Council, and which continue to present elements of uncertainty as they relate to the Clean Energy Alliance's financial proforma. These include the SDG&E PCIA (Power Charge Indifference Adjustment) Trigger Application (establishing a schedule and methodology for SDG&E to recover $8.92 million in under-collected 2020 exit fees) and the SDG&E ERRA (Energy Resources Recovery Account) Forecast Proceeding (setting SDG&E energy generatior:i rates and the PCIA for 2021). The CPUC is expected to issue rulings on these proceedings in mid-December, at which time the Clean Energy Alliance will be able to fully evaluate their impacts on the Alliance's community choice aggregation program. The report also includes information regarding SDG&E's Arrearage Management Plan advice letter, which presents for CPUC approval, SDG&E's debt forgiveness plan to protect SDG&E and Clean Energy Alliance customers at risk of disconnection for failure to make payments during and after the COVID-19 emergency. Next Steps The Clean Energy Alliance continuously monitors and reports monthly on operational, administrative and regulatory affairs activities. City staff will update the City Council once the anticipated CPUC rulings are incorporated into the Clean Energy Alliance's financial proforma. Attachment Clean Energy Alliance Operational, Administrative and Regulatory Affairs Update (Sept. 17, 2020) cc: Geoff Patnoe, Assistant City Manager Celia Brewer, City Attorney City Manager's Office Intergovernmental Affairs 1200 Carlsbad Village Dr. I Carlsbad, CA 92008 I 760-434-2820 t Clean Energy Alliance JOINT POWERS AUTHORITY DATE: TO: FROM: Staff Report September 17, 2020 Clean Energy Alliance Board of Direc_tors Barbara Boswell, Interim Chief Executive Officer ITEM 2: Clean Energy Alliance Operational, Administrative and Regulatory Affairs Update RECOMMENDATION: 1) Receive and File Community Choice Aggregation Update Report from Interim CEO. 2) Receive Community Choice Aggregation Regulatory Affairs Report from Special Counsel. BACKGROUND AND DISCUSSION: This report provides an update to the Clean Energy Alliance (CEA) Board regarding the status of the operational, administrative and regulatory affairs activities. OPERATIONAL UPDATE CEA is meeting its milestones for the implementation of its community choice aggregation (CCA) program and is on track to begin serving customers in May 2021/June 2021. (Attachment A -Clean Energy Alliance Timeline of Implementation Action Items). Interim Board Clerk Recruitment CEA Launch Schedule San Diego Gas & Electric (SDG&E) has been working over the past several years on their Customer Information System replacement program, known as Envision. They had committed to, and were on track, for a January 4, 2021 go live, despite the challenges of working remote in the COVID-19 · environment. With a January 2021 go live, SDG&E committed to supporting the CEA launch of May 2021. On Friday July 10, CEA staff, its regulatory attorney Ty Tosdal and data manager Calpine Energy Solutions participated in a call with San Diego Community Power and SDG&E regarding the recently approved California Public Utilities Commission (CPUC) Decision D. 20-06-003, which requires the Investor Owned Utilities (IOU) to adopt rules and policy changes designed to reduce the number of residential disconnections, provide assistance with debt forgiveness and offer extended payment plans. The decision is required to be implemented by the IOUs April 2021. This timing has presented a challenge to SDG&E to keep its go live date of January 4, 2021 while also meeting the requirements of the decision. SDG&E submitted a letter to the CPUC requesting an extension to September 30, 2021 for implementing the new procedures and policies required by the decision. This request was denied by the CPUC, resulting in SDG&E postponing implementation of its Envision project to April 2021. CEA and its consultants have been working diligently with SDG&E to develop a launch schedule that minimized impact to CEA while also minimizing the risk of incorrect bills being sent to customers. SDG&E has proposed a two-phased schedule with accounts transitioning to CEA in May and June 2021. May 2021 Phase 1 would include the transition of Solana Energy Alliance customers to CEA as well as customers who do not have complex billing plans in Carlsbad and Del Mar. Those customers who have been identified with complex billing plans would transition in June 2021. CEA is working with its Sept. 17, 2020 Item #2 Page 1 of 32 September 17, 2020 Operational & Regulatory Update Page 2 of 4 consultants, Pacific Energy Advisors and Calpine Energy Solutions to evaluate the impact of this two- phased approach from an operational and financial perspective. Preliminary analysis indicates that the proposed phasing does not have a material impact from a financial perspective. Staff anticipates providing the Board with an updated proforma reflecting this new phased approach, as well as updated rates related to the SDG&E ERRA Rate Proceeding at the November Board meeting. Once the final launch schedule has been agreed to by both CEA and SDG&E several regulatory actions would need to be taken, including providing proper notification to the CPUC Energy. Expansion of Clean Energy Alliance Staff has no update regarding CEA expansion. Regulatory Compliance Filings The Integrated Resource Plan (IRP) provides the CPUC with CEA's 10-year projected electricity load as part of the integrated resource planning process to ensure that California's electric sector meets its GHG reduction goals while maintaining reliability at the lowest possible costs. Although the IRP was originally due in April 2020, its due date has been extended to September 2020. The IRP was submitted September 1, 2020. Long-Term Renewable Procurement As a load serving entity, CEA will be required to procure 65% of its minimum state required renewable portfolio standards in contracts of 10-years or longer. To ensure compliance with this requirement, CEA's initial renewable energy solicitation is underway. The solicitation process, from beginning through final execution can be lengthy, particularly in light of the impacts of COVID-19 on the renewable development industry. The solicitation opened on July 1, 2020 with proposals due July 27, 2020. CEA's consultant, Pacific Energy Advisors, has been evaluating the responses to identify a short list of projects to move forward with negotiations. It is anticipated final contracts will be before the Board in late _2020/early 2021. Administrative and Operational Policies During the coming months as CEA prepares for its implementation and operation, policies will be brought to the Board for consideration in future Board meetings. The policies as proposed will be based on Government Code or regulatory requirements and best practices of successfully operational CCAs. / The policies and timeline as currently anticipated are: October 15 Board Meeting • Energy Risk Management Policy Introduction • Records Retention Policy November 19 Board Meeting • Energy Risk Management Policy Approval January 21 Board Meeting • Investment Policy Sept. 17, 2020 Item #2 Page 2 of 32 Contracts $50,000 -$100,000 entered into by Interim Chief Executive Officer VENDOR DESCRIPTION Tripepi Smith Communications and Marketing Services REGULATORY UPDATE September 17, 2020 Operational & Regulatory Update Page 3 of 4 AMOUNT $92,238.00 Attached is a regulatory report from Ty Tosdal, Special Counsel, providing a summary of key regulatory proceedings (Attachment B -Tosdal APC Energy Regulatory Update). FISCAL IMPACT There is no fiscal impact by this action. ATTACHMENTS: Attachment A -Clean Energy Alliance Timeline of Implementation Action Items Attachment B -Tosdal APC Regulatory Update Report Sept. 17, 2020 Item #2 Page 3 of 32 Timing 9/1/20 9/17/20 9/17/20 9/17/20 11/1/20 11/1/20 11/19/20 1/1/21 1/21/21 2/1/21 3/1/21 5/1/21 Attachment A aean Energy Alliance Tlmellne of Action Items CCA. Program Related Description Marketing/Customer Outreach Plan Development & Kickoff Records Retention Policy Bid Evaluation and Criteria Scoring System Award Scheduling Coordinator Services Introduce/Adopt Energy Risk Management Policy System Testing with SDG&E Set up Call O?nter/Scripting/lVR Recordings CEA Default Products/programs/renewable energy policies Create Customer Pre-and Post-Enrollment Notices Investment Policy Rate Setting Customer Noticing Launch-2 phases May & June 2021 Key: Board Actions/ Activity Staff/Consultant Activity Marketing/Customer Outreach CCA Launch / 3rdQtr '20 10/15 & 11/19 Sept. 17, 2020 4thQtr '20 lstQtr '21 September 17, 2020 Operational & Regulatory Update Page 4 of 4 Apr-21 May-21 Jun-21 Jul-21 Item #2 Page 4 of 32 Attachment B ENERGY REGULATORY UPDATE To: Barbara Boswell, CEO, Clean Energy Alliance From: Ty Tosdal, Regulatory Counsel, Tosdal APC Re: Energy Regulatory Update Date: September 11, 2020 T SDAL ENERGY & ENVIRONMENTAL LAW The energy regulatory update summarizes important decisions, orders, notices and other developments that have occurred at the California Public Utilities Commission ("Commission") and that may affect Clean Energy Alliance ("CEA"). The summary presented here describes high priority developments and is not an exhaustive list of the regulatory proceedings that are currently being monitored or the subject of active engagement by CEA. In addition to the proceedings discussed below, Tosdal APC monitors a number of other regulatory proceedings as well as related activity by San Diego Gas & Electric ("SDG&E") and other Investor-Owned Utilities ("IOUs"). 1. SDG&E Advice Letter 3602-E_2902-G (Arrearage Management Plan) SDG&E issued Advice Letter ("AL") 3602-E_2902-G on September 9, 2020, and it provides a detailed description of an Arrearage Management Plan ("AMP") that is designed to protect customers at risk of disconnection for failure to make payments. IOUs are required to adopt an AMP plan as a result of the disconnections decision that the Commission adopted earlier this year, D. 20-06-003. CalCCA and several individual CCA programs were involved in a workshop and negotiations with the IOUs regarding implementation prior to the issuance of the advice letter. SDG&E plans to track and recover all customer debt forgiven through the AMP program-including CCA customer debt related to commodity costs-and recover that debt on behalf of both the IOUs and the CCAs through the utilities' Public Purpose Program ("PPP") charge. This will include all debt forgiven through the AMP Plan for both bundled and unbundled customers, including CCA commodity-related debt forgiven. Notably, the collection and allocation payment method will apply only to CARE/FERA customers through the AMP program. As a result, SDG&E's Rule 27 will remain unchanged and at the conclusion of the COVID-19 measures in April 2021, SDG&E will continue to follow the payment allocation method outlined in Rule 27.- Please note that forgiveness of debt or arrearages for CCA customers will require that a CCA program notify the utility and participate in the AMP program. For unbundled customers to have CCA charges forgiven in the AMP Plan, the CCA must elect to participate in the AMP Plan. If the CCA does not elect to participate, SDG&E may only forgive the utility 1 Sept. 17, 2020 Item #2 Page 5 of 32 T SDAL ENERGY & ENVIRONMENTAL LAW charges through its AMP. Therefore, SDG&E requests that participating CCAs provide SDG&E reasonable notice that the CCA is electing to participate in the AMP. Pursuant to direction from the Energy Division that the AMP program be implemented before April 2021, SDG&E is proposing to implement its AMP program within 90 days of the Energy Division's letter, dated August 13, 2020, or no later than November 11, 2020, or within 45 days after approval of the advice letter, which could be November 12, 2020 at the earliest. Protests are due within 20 days of the advice letter being issued or no later than September 29, 2020. · 2. SDG&E PCIA Trigger Application (A.20-07-009) The Commission held a Prehearing Conference ("PHC") on August 27, 2020, where the relevant issues and schedule for the proceeding were discussed, as well as a motion to compel production of confidential documents. Given the current status of the proceeding, it is possible but unlikely that the $8.92 million balance in the PCIA trigger account will be collected this year, and more likely that it will be amortized over a longer period of time. A longer amortization schedule will reduce monthly rate shock by spreading recovery of the balance over a longer period of time. The next steps in the proceeding are the issuance of a scoping memo and a ruling on the motion. Related, at a recent Public Utilities Commission meeting, Commissioner Guzman Aceves mentioned that the PCIA cap and trigger mechanism that is currently in place may need to be revisited. No decision initiating a new proceeding or other action has been taken. IOU representatives have also made suggestions at various times to eliminate the cap and trigger mechanism. The proposed change would have major implications for CEA and other CCA programs. Further analysis and review are necessary to determine the impacts. 3. SDG&E ERRA Forecast Proceeding (A.20-04-014) CEA's counsel on the SDG&E ERRA Forecast have been working diligently to enter documents into the record regarding SDG&E's accounting, rate methodologies and related matters. The consultant, NewGen Strategies, has been contributing significantly to the effort. The next major step in the proceeding is briefing, and briefs are due on September 25, 2020. 2 Sept. 17, 2020 Item #2 Page 6 of 32