March 17, 2025
From: Audrey Ichinose, People’s Clean Power (PCP),
California Alliance for Community Energy (CACE)
To: Board of Directors, CAC members, and Staff of AvaCommunity Energy Re: Ava support for SB 540/Pathways grid regionalization Thank you for taking this public comment.
Please DO NOT support Staff’s proposal. There are 3 important reasons not to do so:
1. First, with SB 540, CA takes many grave risks.
It would be yoked to western coal and oil drilling states with uncertain means of withdrawing, and faced with the possibility of Trump’s weaponizing FERC to punish CA and its clean energy leadership. CA would risk losing control over its RPS choices and its ability to achieve its clean energy goals.
2. Secondly, for these risks we would reap miniscule gains. According to the Brattle study of possible outcomes from SB 540, CA will be saving .16% of total customer bills in 2032 and will experience no change in renewables curtailment in the most realistic case scenarios.
3. Thirdly, contrary to Staff’s report, there is widespread uncertainty and doubt about this bill. The report cites only two opponents: Consumer Watchdog and former CPUC president Loretta Lynch. While neither of these “opponents” can be considered insignificant, in Ms. Lynch’s case, the report seems to trivialize her long experience with CAISO wholesale markets. The Staff report also fails to mention the 125 groups statewide that signed onto a letter of opposition (69 Indivisible California organizations and 56 environmental and social justice organizations).
It would behoove Ava CAC and Board members to listen to Senators’ questions at the recent March 12th informational hearing on the Pathways plan in the Senate Energy Committee. Among those expressing skepticism and the great need for more information were Senators Jerry McNerny from Pleasanton and Senator Aisha Wahab from Fremont.
For all of these reasons, it would not be advisable for Ava to submit a letter of support for SB 540.
Thank you.