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Public comment letter from Ayla Paz (2nd letter)

Ava Community Energy Board of Directors
April 16, 2025

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Public comment letter from Ayla Paz (2nd letter)
Meeting
April 16, 2025
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Ava Community Energy Board of Directors
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Jessica Tovar
339 15th Street #208 Oakland, CA 94612
[email protected]
415-766-7766
Subject: Urgent concern over (Ava Community Energy’s Support of SB 540) Dear Ava Community Energy Board of Directors, Community Advisory Committee, and Ava staff, The People’s Clean Power Alliance, as well as the undersigned organizations below, urge Ava Community Energy Board members to vote AGAINST supporting SB 540, the California “Pathways” grid regionalization measure. We were concerned to learn at the March 18th CAC meeting that Ava Community Energy staff recommended the Board and CAC support the bill. It is extremely disconcerting to us that the Ava board would consider supporting a proposal that not only exposes California’s renewable energy market to our current federal administration, but that also distracts from local clean energy investments, and harms smaller, more local renewable energy producers.

SB 540 proposes that California participate in a broader Western regional energy organization, with the promise that by doing so, energy market participants will save money, increase grid reliability, and reduce the risk of power outages. However, these promises are dependent on actions that would be out of the control of California. PCPA believes that these are false promises that do not outweigh the risks of the Pathways Initiative. Areas of concern about SB 540 include:
● Exposing California to federal administration oversight: There are very real concerns raised over how the Pathways Initiative would reduce the state’s control over the western energy market and expose California to rules made by the federal government. The current federal administration has already overstepped federal authority, killed clean energy investments, and gutted many regulatory measures, especially with regards to the environment. In Trump’s first presidency, his Department of Energy ordered grid operators to buy coal and nuclear power. His “drill, baby drill” motto is a good indication of how a FERC-regulated energy organization will make energy decisions. By putting California in the line of fire of a dangerous and authoritarian federal administration, we would be putting the nation’s top state leader in renewable energy investments at risk of being annihilated.
● Losing CAISO Protections: California’s Independent System Operator was specifically carved out, separately from a regional energy organization, to ensure certain mandates are in place to protect the people of California. These were: reducing costs, protecting the public’s health and environment, and maximizing energy availability. SB540 has no such protections. ● Uncertain benefits for California: The estimated saving of $7 million to $32 million for the Ava is an estimate. Actual cost savings are highly dependent on how many entities join the regional organizational market, and the overall size of the market’s footprint. Ava’s budget is $1 billion, and projected savings will be somewhere between 0.7% and 3.2% of said budget. ● Distracting from local clean energy investments: Ava’s initial mandate under its Joint Power Agreement (JPA) was to promote the development and usage of state, regional, and local renewable energy production. Ava’s mission and goals are to focus on local investments in a robust clean energy economy. SB 540’s proposed Western regional energy market goes completely against that mandate. Procuring power from other states is in direct defiance of Ava’s goals, and flies in the face of the agency’s commitment to local clean energy investments.

Loretta Lynch, the former president of the CPUC, presented on this topic recently, and expressed a variety of concerns on the Pathways initiative. Her presentation can be found at this:
https://www.youtube.com/watch?v=_EAbwTq3fbg.

For all of these reasons, it would not be advisable for Ava to submit a letter of support for SB 540 and certainly not rush into doing so.

Thank you.

Clean Power to the People,
People’s Clean Power Alliance
San Francisco Bay Physicians for Social Responsibility
350 Bay Area Action
Center for Biological Diversity
Green the Church
Oil and Gas Action Network
Friends of the Public Bank East Bay
Reclaim Our Power Utility Justice Campaign
CODEPINK Bay Area
Collective Resilience
Bay Area-System Change not Climate Change
Long Beach Alliance for Clean Energy

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