HomeMy WebLinkAbout2020-05-21; Clean Energy Alliance JPA; ; Operational, Administrative and Regulatory Affairs UpdateClean Energy Alliance
JOINT POWERS AUTHORITY
DATE:
TO:
FROM:
ITEM 1:
Staff Report
May 21, 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:
l. Receive and File Community Choice Aggregation Update Report from Interim CEO.
2. Receive and File 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. {Attachment A -Clean
Energy Alliance Timeline of Implementation Action Items)
CEA Financing Strategy
It had been anticipated that the CEA financing strategy for fiscal year 20/21 would be complete
and presented to the CEA Board at its May 21, 2020 meeting. Due to delays at the financial
institutions, update term sheets have not yet been provided to CEA staff. The financing option
evaluation is anticipated to be completed, with a recommendation to the CEA Board at its next
meeting, June 18, 2020.
CCA Registration Process
With the submittal of the $100,000 CCA bond and the SDG&E Service Agreement, CEA has now
completed all steps required with the California Public Utilities Commission {CPUC) for
registration as a CCA.
Expansion of Clean Energy Alliance
There has been no new activity related to expansion of CEA. At today's meeting the Board will
be considering developing an outreach strategy matrix that partners Board member, Alternates
and staff with potential new CEA member agencies.
May 21, 2020 Item #1 Page 1 of 8
Regulatory Compliance Filings
May 21, 2020
Community Choice Aggregation &
Regulatory Affairs Update
Page 2 of 4
CEA's Initial Renewable Portfolio Standards (RPS) Procurement Plan filed on April 1, 2020 was
approved by the CPUC on May 3, 2020. The 2020 RPS Procurement Plan filing, which was
originally due June 1, 2020, has been extended to a new due date of June 29, 2020. CEA's Initial
RPS Procurement Plan will need minor amendments to comply with CPUC Ruling 18-07-003,
which makes adjustments to the format and information requested in the RPS Procurement
Plan. This report preparation is included in the current Pacific Energy Advisors scope of work.
CEA's initial Year-Ahead Resource Adequacy (RA) Forecast, which informs the California Energy
Commission (CEC) and California Public Utility Commission (CPUC) of CEA's projected energy
load for 2021, was filed by the due date of April 20, 2020. In light of energy usage changes
related to impacts of COVID-19, an amendment to the Year-Ahead RA Forecast (Forecast) was
submitted on May 15, 2020, which adjusts the projected energy load. The Forecast will be
utilized by the CPUC to develop CEA's RA procurement requirements, which will need to be
contracted for by October 2020.
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.
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
SDG&E continues to be on track on its Envision project timeline for 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.
Long-Term Renewable Procurement
As a load serving entity CEA will be required to procure 65% of its minimum required renewable
portfolio standards in contracts of 10-years or longer. To ensure compliance with this
requirement, work has begun in developing specification for a long-term renewable solicitation.
The process of the solicitation process, from beginning through final execution can be lengthy,
and in light of the impacts of COVID-19 on the renewable development industry, the solicitation
is targeted to kick-off the end of June 2020.
REGULATORY UPDATE
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
May 21, 2020 Item #1 Page 2 of 8
There is no fiscal impact associated with this item.
ATTACHMENTS:
May 21, 2020
Community Choice Aggregation &
Regulatory Affairs Update
Page 3 of 4
Attachment A -Clean Energy Alliance Timeline of Implementation Action Items
Attachment B -Tosdal APC Energy Regulatory Update
May 21, 2020 Item #1 Page 3 of 8
Clean Energy Alliance
Timeline of Implementation Related Action Items
Date
Timin1 Completed Description
12/19/19 12/19/19 Appoint Interim Executive Olrector
12/19/19 & Approve & File Implementation Plan & Statement of
12/19/19 12/23/19 Intent
1/16/20 1/16/20 Direction on Banlcina. and Credit S~utions
Authorize RFP for Technical Consultant to Assist with
1/16/20 1/16/20 Re2ulatorv FilinRS
1/16/20 1/16/20 Authorize RFP for Data Mana,er/Call Center
1/16/20 1/16/20 CEA Public Outreach and MarketinR Kickoff
1/20/20 1/20/20 Issue RFP for Technical Consultant & Data Manaiter
2/20/20 2/20/20 Select Financial Institution & Approve Financing Plan
Select Technical Consultant to Assist with Regulatory
2/20/20 2/20/20 FilinRs
2/20/20 2/20/20 Select Data Manaller
2/20/20 2/20/20 Staff DeveloD & Submit Draft Customer Notice to CPUC
2/20/20 2/20/20 Develop Renewable Port'folio Standards Procurement Plan
2/20/20 2/20/20 Authorize Execution of service A2reement with SDG&E
4/20/20 4/23/20 Post CCA Bond with CPUC
4/20/20 4/23/20 Execute Service Aareement with S0G&E & Submit to CPUC
4/20/20 4/20/20 Year-Ahead Resource Adequacy Forecast Filing
6/1/20 File 2020 Renewable Portfolio Standards Procurement Plan
8/20/20 Aoorove lnteRrated Resource Plan
8/31/20 File lnteuated Resource Plan
May 21, 2020
Dec•19 Jan•20 Feb-20
May 21, 2020
Community Choice Aggregation &
Regulatory Affairs Update
Page 4 of 4
Attachment A
Mar-20 Aor-20 Mav-20 Jun•20 Jul-20 Au2-20
Item #1 Page 4 of 8
Attachment B
TOSDALAPC
ENERGY REGULATORY UPDATE
To: Barbara Boswell, CEO, Clean Energy Alliance
From: Ty Tosdal, Regulatory Counsel, Tosdal APC
Re: Energy Regulatory Update
Date: May 14, 2020
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. COVID-Related Developments
The Public Utilities Commission has taken a number of steps to assist customers
experiencing financial hardship as a result of the COVID-19 epidemic. These measures may
still be in place when CEA begins enrolling customers next year. For example, the Commission
approved Resolution M-4842 on April 16, 2020, requiring utilities to adopt emergency customer
protections that may remain in place until April 16, 2021, and issue advice letters describing
these measures.
Subsequently, on May 1, 2020, SDG&E issued Advice Letter 3516-E-A outlining the
following steps that it will be taking to assist customers:
• Waive deposits and late fees and implement payment plans for affected customers;
• Suspend disconnections for nonpayment;
• Support low-income customers through outreach efforts, increased assistance, and
suspension of removals from CARE and FERA programs; and
• Meet and confer with CCA programs to discuss roles and responsibilities.
Advice Letter 3516-E-A also states that SDG&E will issue pro rata payments to CCA programs
for customers who make partial payments on their bills.
1
May 21, 2020 Item #1 Page 5 of 8
TOSDALAPC
The Commission also issued a Proposed Decision on May 6, 2020, in a separate
proceeding, R. 18-07-005, regarding disconnections and reestablishment of service. The
Proposed Decision is designed to enact customer protections on a more permanent basis and
supplement the measures described in Resolution M-4842. The protections include:
• Cap on SDG&E disconnections of 3% through 2024;
• Prohibition on requiring new service or reestablishment deposits;
• Elimination of reconnection fees;
• No disconnection for any customer on a utility's low-income plan such as CARE or
Medical Baseline, has a household member under 12 months old, or anyone over
age 65. These customers will be offered one of several payment plans and must
participate within 2 billing cycles;
• Adopt an Arrearage Management Program (AMP);
• Adopt a Percentage of Income Payment Plan (PIPP); and
• No disconnections may occur when it is over 100 degrees or below 32 degrees.
Given the broad scope of these changes to existing· billing and disconnection practices,
adoption of the Proposed Decision in its current form are likely to have an adverse effect on
utility revenues and may also have an adverse effect on CCA program revenues. The
Commission is planning to vote on the Proposed Decision on June 11, 2020.
2. Power Charge Indifference Adjustment (R. 17-06-026)
Power Charge Indifference Adjustment ("PCIA") Working Group 3, which is co-chaired
by the California Community Choice Association ("CalCCA") and Southern California Edison
("SCE"), issued its Final Report ("Report") on February 21, 2020. The Report recommends that
the Commission adopt a process by which power and certain power attributes are allocated by
IOUs to Community Choice Aggregation ("CCA") programs to meet the goal of portfolio
Management, or "optimization" as the goal has also b~en characterized. Under the proposal,
power that remains available after the allocation process would be made available on the open
market to CCA programs or other buyers. Adoption of the proposal would permit CCA program
customers to realize the benefit of resources they currently pay for through PCIA charges, but
are unable to rely upon for their power needs because the contracts remain in the utility
portfolio.
Pacific Gas and Electric Company ("PG&E") and SDG&E filed independent proposals
that would leave greater control in the hands of the utilities to determine sales and allocations.
2
May 21, 2020 Item #1 Page 6 of 8
TOSDALAPC
Since the report of Working Group 3 was issued, there have been ongoing discussions by
various parties with the Commission and its staff regarding various aspects of the proposal and
proposals made by other parties. A proposed decision on IOU portfolio management is
anticipated in the third quarter of this year.
3. Resource Adequacy (R.17-09-020, R.19-11-009)
The Commission issued a proposed decision on March 26, 2020, in one of the operative
RA proceedings, R.17-09-020, rejecting a settlement proposal advanced by CalCCA and
SDG&E to adopt a residual central procurement model for local RA. The settlement proposal
would permit utilities and CCA programs to continue buying their own local RA and rely upon a
central buyer for any residual need. The Proposed Decision finds that the settlement proposal is
not reasonable in light of the whole record or supported by several affected parties, does not
present a fair compromise, and did not identify a central buyer.
Instead, the Proposed Decision adopts a hybrid central procurement model in PG&E and
SCE territories, and identifies these IOUs as the central buyers responsible for the purchase of
local RA. SDG&E, however, was exempted from central procurement because SDG&E's
transmission area is unique in that local RA requirements typically meet or exceed the system
requirements. A central buyer that procures all local capacity in the San Diego local areas
would leave no system or flexible capacity for CCA programs or other Load Serving Entities
("LSEs") to purchase. Since the Proposed Decision was issued, several parties including
CalCCA, individual CCA programs and IOUs have been engaged in formal ex parte
communications with Public Utilities Commissioners and their staffs. A final decision on central
procurement has been held over to the next Commission meeting on May 28, 2020.
4. Integrated Resource Planning (R.16-02-007)
Load forecasts for Load-Serving Entities ("LSEs") in California, including utilities and
CCA programs, were issued in the Integrated Resource Planning ("IRP") proceeding on April
15, 2020. CEA's adopted load forecast is as follows:
3
May 21, 2020 Item #1 Page 7 of 8
TOSDALAPC
CEA Load Forecast (GWh)
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Load
Forecast 144 929 932 938 947 955 964 974 983 992
The Commission also issued a Final Decision, D. 20-03-028, on March 28, 2020, that
adopts a reference portfolio for all LSEs, including CCA programs, to use in conjunction with the
preparation of their individual Integrated Resource Plans ("IRPs"). D. 20-03-028 was
controversial for maintaining the previous IRP cycle's Greenhouse Gas ("GhG") emissions
target of 46 Million Metric Tons ("MMT"). In addition, D. 20-03-028 extends the IRP filing
deadline to September 1, 2020.
5. SDG&E Seasonal Rates (A.19-09-014)
The Commission voted on April 16, 2020, to eliminate seasonal rates for SDG&E's tiered
residential customers, beginning on June 1, 2020. Winter rates for this class of customers will
increase by 4.1 percent and summer rates will decrease by 4.6 percent. The Final Decision
also provides that similar changes will be considered for residential Time-of-Use ("TOU")
customers in the next phase of the proceeding. Any additional changes to seasonal variation in
SDG&E's residential rates should be decided before CEA begins enrolling customers next year.
4
May 21, 2020 Item #1 Page 8 of 8
Clean Energy Alliance
JOINT POWERS AUTHORITY
Regular Board Meeting
May 21, 2020, 2 p.m.
Hosted by the City of Solana Beach
5/21/20 Cl [AN ENERGY ALLIANCE 1
Item 1: Administrative, Operational
and Regulatory Affairs Update
Barbara Boswell, Interim Chief Executive Officer
Ty Tosdal, Special Counsel Regulatory Affairs
5/21/20 CLEAN ENERGY ALLIANCE 2
Item 1: Administrative, Operational and
Regulatory Affairs Update
• Recommendation
0 1) Receive and File Community Choice Aggregation Update
Report from Interim Chief Financial Officer
0 2) Receive and File Community Choice Aggregation Regulatory
Affairs Report from Special Counsel
5/21/20 CLEAN ENERGY ALLIANCE 3
I
Item 1: Administrative, Operational and
Regulatory Affairs Update
Clean Energy Alliance
Tlmellne of Implementation Related Action Items
Date
Tlmln• Comoleted Deserio ti on
12/19/19 12/19/19 Annnlnt Interim Executive Director
12/19/19 & Approve & File Implementation Plan & Statement of
12/19/19 12/23/19 Intent
1/16/20 1/16/20 Direction on Banklno and Credit Solutions
Authorize RFP for Technical Consultant to Assist with
1/16/20 1/16/20 Re•ulato,y Flllnu
1/16/20 1/16/20 Authorize RFP for Data Mana•er/C.11 Center
1/16/20 1/16/20 CEA Public Outreach and Marketin• Kickoff
1/20/20 1/20/20 Issue RFP for Technical Consultant & Data Manaeer
2/20/20 2/20/20 Select Financitil Institution & Aoorove Financinll! Plan
Select Technical Consultant to Assist with Regulatory
2/20/20 2/20/20 Flllnu
2/20/20 2/20/20 Select Oata Manuer
2/20/20 2/20/20 Staff Oeveloo & Submit Draft Customer Notice to CPUC
2/20/20 2/20/20 Oeveloo Renewable Portfolio Standards Procurement Plan
2/20/20 2/20/20 Authorize f)(ecutlon of Service Ar1reement with S0G&E
4/20/20 4/23/20 Post CCA Bond with CPUC
4/20/20 4/23/20 Execute Service Aareement with SOG&E & Submit to CPUC
4/20120 4/20/20 Year-Ahead Resource Adeauatv Forecast Filin"
6/1/20 File 2020 Renewable Portfolio Standards Procurement Plan
8/20/20 Aocrove lntea:rated Resource Plan
8/31/20 FIie lnteRrated Resource Plan
Dec-19 Jan-20 Feb-20 Mar-20 Aor-20 Mav-20 Jun-20 Ju~20 Au•-20
• Implementation Tasks on
target
• CCA Registration Complete
• 2020 Renewable Portfolio
Standards Procu rement Plan
due 6/1/20
5/71/20 (LEAN ENER(,Y AlllAN( f 4
'
Item 1: Administrative, Operational and
Regulatory Affairs Update
• Regulatory Affairs Report -Ty Tosdal, Tosdal APC
S/21/20 CLEAN [ NI HGY /\I l lANCE 5