Adrian Bankhead <[email protected]>
Thoughts on SB-540 to assist with the Board Discussion
INDIRA BALKISSOON <[email protected]> Tue, Apr 15, 2025 at 7:16 PM To: Adrian Bankhead <[email protected]>
Hello Adrian -
Ed suggested that I send this along as a public comment to assist with the Board’s discussion of SB-540 tomorrow.
Best regards,
Indira
Here are a summary of thoughts on SB-540 for your meeting tomorrow. The CAC vote: 5 not to sign support letter; 2 to sign support letter; and 1 abstention.
1. Governance - There is no clear description of the Governance structure that would be developed and based on research of other independent regional organizations (ROs) the issues of governance appear to be complex. It is important in developing our own RO that we evaluate and learn from other ROs, like PJM (Pennsylvania, New Jersey and Maryland ) Interconnection RTO. PJM consists of 13 states and the District of Columbia. PJM issues are related to an energy landscape similar to ours that is rapidly evolving. For example:
Significant tension between PJM’s regional authority and the sovereignty of individual states within its footprint.
PJM states are concerned about losing control over energy policy decisions that directly impact their constituents.
There are disputes over transmission planning and cost allocations.
There are interconnection challenges, the surge in renewable energy projects has overwhelmed PJM’s interconnection queue leading to significant delays.
There is strain on the grid due to expansion of data centers.
The governance of co-located loads, has been shown to have insufficiencies with in the PJM tariff.
Significant investments in infrastructure to accommodate the changing energy mix and increased demand. Determining who bears the costs?
Debates exist about the balance between regional transmission projects which benefit multiple states and local projects, which serve specific areas.
It is difficult to ensure fair and equitable cost allocation to avoid disproportionate burdens on certain states or ratepayers.
Lack of cost oversight
Ensuring resource adequacy is a growing challenge as traditional power plants retire and renewable energy sources become more prevalent
Maintaining transparency and fairness to ensure all participants have a level playing field.
Concerns about market manipulation and undue influence that erodes public trust.
If possible, these issues should be addressed before signing on to the SB-540 proposal.
2. Emissions - Emissions reductions appear to focus on California alone and not those of other western states.
Transferring emissions from California to other states does not reduce emissions overall in the West. SB-540 does not discuss the potential increases in GHG emissions in states that still rely heavily on coal. Nor is there discussion of mechanisms to prioritize the use of renewables and clean energy versus coal going into the future.
California’s only operating coal-fired power plant is located in San Bernardino. Yet there are 32 coal-fired power plants in the West with Wyoming, Montana, Utah and Arizona still relying heavily on coal plants.
Would SB-540 create a larger market for coal? We just saw the Colstrip coal plant in Montana, considered to be one of the dirtiest power plants in the country apply for a Presidential exemption from EPA’s Updated Mercury and Air Toxic Standards. The associated health risks from this can cause respiratory illnesses, heart disease, and other health problems.
More information is needed to define potential emissions impacts outside of California, if there is an increase in coal power plant use.
3. Local Organizations - There appears to be a lack of local organizations included in the SB-540 process. There appears 4/16/25, 9:58 AM Ava Community Energy Mail - Thoughts on SB-540 to assist with the Board Discussion https://mail.google.com/mail/u/0/?ik=703fa6ea73&view=pt&search=all&permmsgid=msg-f:1829523714753205424&simpl=msg-f:1829523714753205424 1/2 to be no representation from CARE/FERA customers, environmental justice organizations, local citizens, and local not-for-profit organizations. There were letters representing 73 indivisible California organizations and an additional letter representing 59 groups all opposing SB-540. Please include local customers, CARE/FERA, and local not-for-profits in developing SB-540. One of the Ava and the CAC is so important is because it provides an opportunity for these types of local organizations to provide input.
Best regards,
Indira Balkissoon
Ava CAC member North
4/16/25, 9:58 AM Ava Community Energy Mail - Thoughts on SB-540 to assist with the Board Discussion https://mail.google.com/mail/u/0/?ik=703fa6ea73&view=pt&search=all&permmsgid=msg-f:1829523714753205424&simpl=msg-f:1829523714753205424 2/2