To: AVA Community Energy Board of Directors
From: Dave Shukla, Operations, Long Beach Alliance for Clean Energy Re: SB540 Grid Regionalization Item
4/16/2025
AVA Community Energy Board of Directors,
Our organization strenuously opposes SB540, and has concerns with your scheduled vote this evening on the SB540 grid regionalization item. Our concerns can be summarized as follows:
1. There is no Jobs Study. To date, there has not been a single analysis of the jobs impact of SB540 as written. Unlike with previous grid regionalization attempts, which consistently showed tens of thousands of job losses throughout California. So, AVA Board Members are being asked to support a bill without having any information on how many jobs that bill will cost their cities and constituencies.
2. SB540 abrogates CA legal authority. Section 345.5b of the Public Utilities Code is completely rewritten in a way that removes the “shall follow applicable state laws’ to “in lieu of applicable state laws”. Which laws can be skirted through such an unprecedented waiver of CA legislative authority? SB540 does not say! Perhaps all of our public health and environmental and climate laws – it’s up to the Regional Organization. Not Californians.
3. The PATHWAYS Initiative has had no outreach, none, to Environmental or Climate Justice organization in the state of California. This includes our organization, LB ACE. The bill language of SB540 is the first public unveiling of this latest strategy (4th time in 8 years) to privatize CAISO and enrich Transmission operators and Investor Owned Utilities. It is telling that PATHWAYS has neither had time nor interest in the justice implications of their proposal.
4. Gas and Coal Impacts. To date, the commissioned Brattle Group has done no analysis of how SB540 will impact gas generation in-state, including at the massive Once-Through-Cooled AES Alamitos plant on Studebaker Rd. in Long Beach. Should SB540 pass, it may be possible for fossil gas or coal to be counted as “preferred” or “least cost” options for electricity power production. Again, it’s up to the new Regional Organization. Under their own commissioned Brattle Study, coal consumption markedly increases in the (most likely) split market scenario.
5. We are concerned that the full weight of Californian opposition to SB540 has not been accurately presented to the AVA Board by Staff. Not only are there over 130 groups representing hundreds of thousands of Californians in opposition to SB540, but that opposition only continues to grow as details slowly emerge about this latest attempt to privatize CAISO. AVA’s CAC voted jus this past Monday to Oppose SB540. You should too.
In your role as Board Members of AVA Community Energy, you are being asked to make timely decisions on incredibly complex topics, and be on the hook if those decisions do not improve the lives of your constituents and ratepayers. SB540 trades genuine governance and legal authority for some proposed potential financial benefits, and is nothing more than a giveaway to transmission operators and investor-owned utilities that have no interest in the clean energy procurement and local economic development that CCAs like AVA were designed to achieve. Please oppose SB540.
Thanking you,
LB ACE.