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Public Comment Letter from Jessica Tovar

Ava Community Energy Board of Directors
June 18, 2025

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Public Comment Letter from Jessica Tovar
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June 18, 2025
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Ava Community Energy Board of Directors
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Text extracted from the CCA's file for reading and search. Open the original on avaenergy.org. That file is the official record.

Jessica Guadalupe Tovar
339 15th Street Suite 208
Oakland, CA 94612
[email protected]
Subject: Ava Community Energy - Oppose Harmful Policies and Advance Investments and Legislation that benefit Your Constituents
June 4, 2025
Dear Ava Community Energy Board Members, Community Advisory Committee Members and Alternates, We encourage Ava Community Energy to oppose increases of the Power Charge Indifference Adjustment (PCIA) proposed by the California Public Utilities Commission (CPUC), support state legislation that would protect the rights and authority of Community Choice Aggregators (CCA’s) and their constituents, and prioritize programs that create community benefits. Such benefits include producing local clean energy, creating clean energy jobs, reducing pollution, improving health, opportunities for new models of ownership and affordability of energy resources.

Oppose Policies that Harm Community Choice Agencies & Your Constituents The CPUC is considering a modification to how the PCIA is calculated that would drastically increase the PCIA fee charged to CCAs. Initially, the Investor Owned Utilities (IOUs) argued the PCIA was needed to compensate them for long-term energy contracts and a loss of customers due to CCAs. However, the IOUs aggressive and repeated advocacy for terms favorable to the corporate utilities have inflated the PCIA charge to CCAs far beyond the PCIA’s original purpose, thereby limiting CCA’s revenues for investments and unfairly punishing CCA customers. The CPUC’s current proposed PCIA modification would exacerbate this problem, threatening the very viability and sustainability of Ava Community Energy’s operations.

It is crucial that Ava Community Energy proactively engages with the CPUC to clearly demonstrate how these higher PCIA charges to CCAs negatively affect the affordability and expansion of renewable energy solutions. Direct advocacy at the CPUC level will help protect Ava’s ability to offer competitive rates and prevent undue financial burdens on local communities.

Support Legislation and Programs that Benefit Community Choice Agencies and Your Constituents
We urge Ava Community Energy to actively support and advocate for state legislation, such as SB 332 (Golden State Energy), and other related measures that support the long-term success of CCAs and their constituents. Such policies provide CCAs with autonomy and financial flexibility, allowing them to set independent rate structures, exist outside of PG&E’s predatory rates and surcharges, and reinvest funds in local communities. Legislation at the state level is important for ensuring that CCAs remain autonomous and capable of meeting local energy needs.

We strongly advocate for the continued prioritization and funding of Ava’s Local Development Business Plan programming. Community programs—including local renewable energy generation projects, affordability initiatives, energy efficiency programs, and resilience-building measures—must remain a priority, even during periods of market volatility or financial stress. These programs directly serve local community needs, contribute significantly to local climate resilience, and support community empowerment and environmental justice. We urge the Board to prioritize these essential programs, even in the face of financial challenges. Ava should explore alternative solutions and strategic financial management to uphold its commitment to the local community.

Establish and fund a new annual Community Based Organization Grant Fund for community non-profit organizations and their needs. This new fund should be independent of Ava Community Energy’s “Community Grants” program which has centered the agency’s marketing of specific programs.

This new program should be in collaboration with local community foundations (East Bay and San Joaquin) in providing funding for projects and programs that guide communities toward a healthier, resilient and sustainable clean energy future. 10% of the funds can help cover administrative costs for the community foundation to administer the grants, thereby not impacting the capacity of Ava Community Energy staff.

There is precedent for such a program at the San Diego Community Foundation that is funded by San Diego Community Power (SDCP). In 2024, the agency allocated $1.2M to the Community Clean Energy Grant Program to award grants to nonprofits within the agency territory for $25-$100K. Proposed projects or programs must be directly related to clean energy and advance one or more of the following focus areas:
● Increasing overall energy literacy of SDCP customers. ● Energy focused educational programming that encourages clean energy use, particularly for youth. ● Improvements in indoor and/or outdoor air quality related to electrification. ● Workforce development opportunities that support careers in the clean energy industry. ● Improved energy resilience to ensure communities can avoid, prepare for, minimize, adapt to, and recover from energy disruptions.

You can read more about the San Diego Community Foundation grant fund here.

To protect Ava Community Energy’s long-term viability and to uphold its mission of community-focused, local, clean energy, People’s Clean Power Alliance urges the Ava Board of Directors to:

1. Directly Engage with the CPUC and Oppose the PCIA Fee Increase . Proactive leadership in opposing the proposed higher fees will send a powerful message that Ava stands firmly against exploitative financial burdens imposed by PG&E.

2. Support Legislation that Empowers CCAs. Actively advocating for state legislation, such as SB 332 (The Golden State Energy Act), will strengthen Ava’s autonomy over rate-setting and protect it from continued financial vulnerability to PG&E’s policies. Ava’s support for such legislative measures is critical for its long-term financial security and effectiveness.

3. Prioritize the Local Development Business Plan Despite Financial Volatility. These programs directly serve the immediate and long-term resilience and energy affordability needs of Alameda County and San Joaquin residents. Maintaining these programs demonstrates Ava’s ongoing dedication to community empowerment and environmental justice.

4. Establish an Annual Community Based Organization Grant Fund that funds community non-profit organizations needs. This program should be done in collaboration with local community foundations in providing funding for projects and programs that guide communities toward a healthier, resilient and more sustainable clean energy future.

By committing to these actions, Ava Community Energy can continue to show responsible, community-driven energy leadership, ensuring long-term resilience, affordability, and sustainability for Alameda and San Joaquin Counties. This will not only help Ava withstand current and future challenges, but will also create affordability and other very needed community benefits for the communities that the agency serves. This will set a powerful precedent for CCAs and their communities across California.

Clean Power to the People,
Jessica Guadalupe Tovar, People’s Clean Power Alliance

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