HomeMy WebLinkAbout2020-04-16; Clean Energy Alliance JPA; ; Operational, Administrative and Regulatory Affairs UpdateClean Energy Alliance
JOINT POWERS AUTHORITY
DATE:
TO:
FROM:
ITEM 1:
Staff Report
April 16, 2020
Clean Energy Alliance Board of Directors
Barbara Boswell, Interim Chief Executive Officer
Ty Tosdal, Special Counsel, Tosdal APC
Operational, Administrative and Regulatory Affairs Update
RECOMMENDATION:
1. Receive 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.
CCA Implementation Plan & Statement of Intent Certification and CCA Registration
A significant step towards implementing CEA was achieved on March 16, 2020, with the
certification of CEA's Implementation Plan and Statement of Intent by the California Public
Utilities Commission (CPUC) (Attached). Certification
At the February 20, 2020 meeting the Board approved executing the San Diego Gas & Electric
(SDG&E) CCA Service Agreement, which has been submitted to SDG&E and we are awaiting the
executed copy. The SDG&E Service Agreement will be summitted to the CPUC along with the
CCA bond payment. These last two steps are the final requirements for CCA registration and are
expected to be completed within the next week.
Meeting with CPUC Energy Division
At its February 20, 2020 meeting the Board appointed Board Member Kristi Becker to represent
CEA at a meeting with the CPUC Energy Division, who were to be joined by Barbara Boswell and
Ty Tosdal, Special Counsel and staff representatives. The purpose of the meeting was to
provide an overview of CEA, an update of its implementation plans and goals for the program at
launch and to provide an opportunity for the CPUC staff to ask the group question regarding
CEA and the transition of Solana Energy Alliance customers to CEA in anticipation of CPUC
April 16, 2020 Item #1 Page 1 of 6
April 16, 2020
Community Choice Aggregation &
Regulatory Affairs Update
Page 2 of 4
certifying the CEA Implementation Plan. The meeting had been scheduled to be in held in
person at the CPUC office in San Francisco on March 11, 2020. Due to the early concerns
regarding COVID 19 and travel, the meeting was rescheduled as a conference call. Board
Member Becker, Interim CEO Barbara Boswell, Special Counsel Ty Tosdal, City of Del Mar
Environmental Sustainability and Special Projects Manager Clement Brown and City of Carlsbad
Intergovernmental Affairs Director Jason Haber participated in the call with the CPUC Energy
Division. CEA representatives addressed questions the Energy Division had regarding regulatory
compliance filings required of both CEA and SEA and indicated to Energy Division the
commitment of both CCA programs to meet the various regulatory compliance requirements.
The CPUC subsequently certified the Implementation Plan.
Expansion of Clean Energy Alliance
Greg Wade and Jason Haber participated in a South Orange County Community Choice Alliance
workshop regarding lessons learned and potential opportunities with neighboring cities on
February 20, 2020.
The cities of Escondido, San Marcos and Vista have engaged EES Consulting to complete a CCA
feasibility study which is targeted to be complete by the end of the calendar year.
Staff is also keeping communication lines open with the County of San Diego and Oceanside
regarding their efforts in evaluating CCA in their areas.
Regulatory Compliance Filings
Clean Energy Alliance is in compliance with all required regulatory compliance filings to date,
including the most recent filing of the initial Renewable Portfolio Standards (RPS) Procurement
Plan. The plan is a compliance filing and is separate and distinct from CEA's overall
procurement strategy and decision-making process, which the Board will ultimately decide.
The RPS plan reflects the CEA is aware of, and plans to comply with, California's renewable
energy requirements.
The Year-Ahead Resource Adequacy forecast, which informs the California Energy Commission
(CEC} and California Public Utility Commission (CPUC) of CEA's projected energy load for 2021.
The CEC and CPUC utilize the forecast to develop the Resource Adequacy requirements that
CEA will need to procure. The forecast is in progress and is on track to meet the April 20, 2020
filing deadline. CEA staff and its consultants have been working cooperatively with SDG&E to
ensure the forecasts are coordinated regarding SDG&E's assumptions related to the departing
load. Should revisions need to be made to the initial forecast, CEA has until May 15, 2020 to
make those revisions.
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.
April 16, 2020 Item #1 Page 2 of 6
April 16, 2020
Community Choice Aggregation &
Regulatory Affairs Update
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The IRP was originally due in April 2020, was pushed out to July 2020, and has now been further
pushed out to September 2020.
Coordination with San Diego Gas & Electric
CEA staff and consultants continue to meet with and work collaboratively with SDG&E to
ensure a smooth CCA implementation. The most recent meeting took place March 27, 2020,
topics included a discussion to satisfy SDG&E's "Meet and Confer" requirement related to the
Year-Ahead Resource Adequacy forecast as well as an update of SDG&E's bill system
replacement project, known as Envision. Attendees included various SDG&E staff, Barbara
Boswell, Ty Tosdal and Pacific Energy Advisors.
SDG&E updated CEA regarding its energy load forecast assumptions related to the CEA
customer leaving SDG&E service that SDG&E will be applying to the 2021 load forecast. SDG&E
intends to issue a Request for Offers to handle the excess resource adequacy SDG&E may have
due to the departed load. CEA will need to engage the services of a transactions attorney to
execute the agreements and documents necessary for CEA to take advantage of SDG&E's
request for offers.
SDG&E also informed CEA that SDG&E is tracking on its project timeline towards a go live date
of January 4, 2021. The on-going testing, including end-to-end testing for CCA and transition of
customers will further confirm the operational and application readiness of the systems.
REGULATORY UPDATE
A regulatory update will be provided to the Board by Ty Tosdal, Tosdal Law APC, highlighting
current CPUC proceedings of interest to CEA.
FISCAL IMPACT
There is no fiscal impact associated with this item.
ATTACHMENTS:
Clean Energy Alliance Timeline of Implementation Action Items
California Public Utilities Commission Letter Certifying Clean Energy Alliance Implementation
Plan and Statement of Intent
April 16, 2020 Item #1 Page 3 of 6
Timi ..
12/19/19
12/19/19
1/16/20
1/16/20
1/16/20
1/16/20
1/20/20
2/20/20
2/20/20
2/20/20
2/20/20
2/20/20
2/20/20
4{J.0/20
4{J.0/20
4{J.0/20
8/1fJf1D
8/31/1.0
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TlmallMcl•• ... •••don ........ Actian .....
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eam.....i Daafptlon
12/19/19 Appoint Interim Executive Director
12/19/19 & Appr0\11! & File Implementation Plan & Statement of
12/23/19 Intent
1/16/20 Direction on Banking and Credit Solutions
Authorize RFP for Technical Consultant to Assist with
1/16/20 Regulatory Filings
1/16/20 Authorize RFP for Data Manager/Call Center
1/16/20 CEA Public Outreach and Marketi~ Kickoff
1/20/20 Issue RFP for Technical Consultant & Data Manager
2/20/20 Select Financial Institution & Approve Financing Plan
Select Technical Consultant to Assist with Regulatory
2/20/20 Filires
2/20/20 Select Data Manager
2/20/20 Staff Develop & Submit Draft Customer Notice to CPUC
2/20/20 Develop Renewable Portfolio Standards Procurement Plan
2/20/20 Authorize Execution of Service ARreement with SDG&E
Post CCA 8and with <J>UC
Execute Senna, Al!reement with SOG&E & Submit to CPUC
Year-Ahead Resource Adequacy Forecast Fili~
Anrv,we ln-.ated Resaurce Plan
Fie lnr-ated Rescx.-ce Plan
Administrative
Implementation Plan Related
Regulatory Complia nce
April 16, 2020
DIN>-19
April 16, 2020
Community Choice Aggregation &
Regulatory Affairs Update
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Item #1 Page 4 of 6
STATE OF CALIFORNIA Gavin Newsom, Governor
PUBLIC UTILITIES COMMISSION
505 YAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
March 16, 2020
Barbara Boswell
Interim Chief Executive Officer
Clean Energy Alliance
1200 Carlsbad Village Drive
Carlsbad, CA 92008
RE: Letter Certifying Clean Energy Alliance's Implementation Plan and Statement of
Intent
Dear Ms. Boswell:
The California Public Utilities Commission's Energy Division has reviewed Clean Energy
Alliance's Implementation Plan and Statement of Intent, which was submitted to us on
December 23, 2019 to begin service to the cities of Del Mar, Carlsbad and Solana Beach,
effective May 1, 2021.
Pursuant to Public Utilities Code Section 366.2 (c)(7), within 90 days after the Community
Choice Aggregator (CCA) establishing load aggregation files an Implementation Plan, the
California Public Utilities Commission is required to certify that it has received the
Implementation Plan, including any additional information necessary to determine a cost-
recovery mechanism.
Public Utilities Code Section 366.2 (c)(3) requires a CCA Implementation Plan to contain all of
the following:
A) An organizational structure of the program, its operations, and its funding.
B) Rate setting and other costs to participants.
C) Provisions for disclosure and due process in setting rates and allocating costs among
participants.
D) The methods for entering and terminating agreements with other entities.
E) The rights and responsibilities of program participants, including, but not limited to,
consumer protection procedures, credit issues, and shutoff procedures.
F) Details regarding the termination of the program.
G) A description of the third parties that will be supplying electricity under the program,
including, but not limited to, information about financial, technical and operational
capabilities.
Pursuant to Public Utilities Code Section 366.2 (c)(4), a CCA is also to prepare and provide for
all of the following:
April 16, 2020 Item #1 Page 5 of 6
A) A statement of intent; and
B) Provision(s) that provide for:
1) Universal access;
2) Reliability;
3) Equitable treatment of all classes of customers; and
4) Compliance with any legal requirements concerning aggregated service.
Toe California Public Utilities Commission hereby certifies that the Implementation Plan and
Statement of Intent submitted by Clean Energy Alliance contains the information required by
Public Utilities Code Section 366.2 ( c ). Should there be any modification to the Implementation
Plan, including but not limited to the start date, anticipated load and phase-in schedule, Clean
Energy Alliance shall submit an updated Implementation Plan to the California Public Utilities
Commission in the same manner it submitted the original plan.
Pursuant to P.U. Code Section 366.2 (c)(7), the California Public Utilities Commission is
required to provide Clean Energy Alliance with "its findings regarding any cost recovery that
must be paid by customers of the community choice aggregator to prevent a shifting of costs as
provided for in P.U. Code Section 366.2 subdivisions (d), (e) and (f)." Toe costs referenced in
P.U. Code Section 366.2 subdivisions (d), (e) and (f) are recovered via separate charges for: (1)
Power Charge Indifference Adjustment (per kWh); (2) DWR Bond Charge (per kWh); and (3)
Competition Transition Charge (CTC) (per kWh). By this letter, the California Public Utilities
Commission informs Clean Energy Alliance that these costs are identified on each of San Diego
Gas & Electric's customer-class-specific tariff sheets, in the "Special Conditions" section, sub-
section "Billing," in the section labeled "Direct Access (DA) and Community Choice
Aggregation (CCA) customers" and in the column labeled "Community Choice Aggregation
Cost Responsibility Surcharge (CCA CRS)."
Sincerely,
Edward Randolph
Deputy Executive Director for Energy and Climate Policy/
Director, Energy Division
cc:
Megan Caulson, SDG&E (SDGETariffs,,l,semprautilities.com) and USPS)
Mitchell Shapson (Mitchell.Shapson(wcpuc.ca.gov)
Dina Mackin (Dina.Mackin@cpuc.ca.gov)
Barbara Boswell (Barbara'°a1BA YSHORECGI.COM)
April 16, 2020 Item #1 Page 6 of 6