Submitted for Board consideration:
___________________________________
Gregory Wade
Chief Executive Officer
ATTACHMENTS:
A. Public Hearing Notice
B. Resolution No. 2025-045
PUBLIC HEARING NOTICE
CLEAN ENERGY ALLIANCE
The Board of Directors of Clean Energy Alliance (CEA) will conduct a public hearing to consider adopting a resolution amending the Wholesale Market Access Tariff (WMAT) rate, effective January 1, 2026.
The proposed amended WMAT rate is: $.11759 per kWh
DATE OF HEARING: Thursday, November 20, 2025
TIME OF HEARING: 2:00 p.m. or as soon thereafter as the matter may be heard
PLACE OF HEARING: Leucadia Wastewater District, Board Room 1960 La Costa Ave
Carlsbad, CA 92009
All interested persons are invited to attend the meeting and comment on adopting a Resolution Amending Rates for Clean Energy Alliance. Members of the public unable to attend the public hearing may submit their comments and recommendations in writing to Clean Energy Alliance, via email to [email protected], which must be received no later than 12 p.m. on Thursday, November 20, 2025 to ensure consideration by the Board.
_____________________________ DATED: November 3, 2025
Ana Marie Alarcon, CMC
Clerk to the Board
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Published: Friday, November 7, 2025 Published: San Diego Union Tribune Friday, November 14, 2025
Posted: Monday November 7, 2025 Leucadia Wastewater Board Room Attachment A
CLEAN ENERGY ALLIANCE
RESOLUTION NO. 2025-045
A RESOLUTION OF THE BOARD OF DIRECTORS OF THE CLEAN ENERGY
ALLIANCE AMENDING RATE SCHEDULE UPDATING THE WHOLESALE
MARKET ACCESS TARIFF RATE EFFECTIVE JANUARY 1, 2026
WHEREAS, the Clean Energy Alliance (CEA) is a joint powers agency formed on November 4, 2019, under the Joint Exercise of Power Act, California Government Code section 6500 et seq.,
WHEREAS, Section 4.6 of the Joint Powers Authority (JPA) Agreement establishes the specific responsibility of the CEA Board of Directors to adopt retail rates for power; and WHEREAS, the CEA Board adopted the Wholesale Market Access Tariff (WMAT) Rate at its October 31, 2024 Board meeting effective January 1, 2025; and WHEREAS, at its July 31, 2025 Regular Board Meeting, the CEA Board adopted Resolution No. 2025-035 amending the WMAT Rate effective August 1, 2025; and WHEREAS, the WMAT rate is to be reviewed each year and if appropriate, updated, for the following calendar year; and
WHEREAS, the WMAT Terms and Conditions establishes the methodology for calculating the WMAT rate; and
WHEREAS, the updated WMAT Rate was calculated using the approved methodology to generate sufficient revenue to cover the costs of serving WMAT customers; WHEREAS, the Public Hearing Notice was published in the San Diego Union Tribune on November 7 and November 14, 2025 and posted on November 7, 2025.
NOW, THEREFORE, BE IT RESOLVED, by the Board of Directors of the Clean Energy Alliance, as follows:
Section 1. The Board of Directors of the Clean Energy Alliance hereby approves CEA the updated WMAT Rate at $.11759 per kWh.
Section 2. Rate to be effective January 1, 2026.
Attachment B
CEA No. Resolution 2025-045
WMAT Rate Increase
The foregoing Resolution was passed and adopted this 20th day of November 2025, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
APPROVED:
________________________________________
Katie Melendez, Chair
ATTEST:
_______________________________
Ana Marie Alarcon, Clerk to the Board
Staff Report
DATE: November 20, 2025
TO: Clean Energy Alliance Board of Directors
FROM: Gregory Wade, Chief Executive Officer
ITEM 6: Receive Regulatory Update from Keyes & Fox
RECOMMENDATION:
Receive the Regulatory Update from Keyes & Fox.
BACKGROUND AND DISCUSSION:
Clean Energy Alliance (CEA) contracts with Keyes & Fox for Regulatory Advocacy related activities. Each month Keyes & Fox provides an update to the CEA Board on key items of interest. This month’s update will focus on San Diego Gas & Electric’s (SDG&E’s) October revisions to their 2026 Energy Resource Recovery Account (ERRA) forecast for Power Charge Indifference Adjustments (PCIA) and bundled generation rates.
FISCAL IMPACT:
There is no fiscal impact from this action.
Submitted for Board consideration:
___________________________________
Gregory Wade
Chief Executive Officer
ATTACHMENTS:
A. Keyes & Fox Regulatory Report
1 Clean Energy Alliance
Regulatory Monitoring Report
To: Clean Energy Alliance (CEA) Board of Directors
From:
Tim Lindl, Partner, Keyes & Fox LLP
Jacob Schlesinger, Partner, Keyes & Fox LLP
Jason Hoyle, Director of Research, EQ Research LLC
Subject: Monthly Regulatory Memo
Date: November 10, 2025
Keyes & Fox LLP and EQ Research LLC are pleased to provide CEA’s Board of Directors with this informational memo describing recent developments in key California regulatory and compliance-related updates from the California Public Utilities Commission (CPUC). Additional information is available in CEA’s Digest of Regulatory Updates.
IRP Rulemaking (R.25-06-019)
• On October 28, the CPUC issued the Assigned Commissioner's Scoping Ruling setting May 5, 2026 as the IRP filing deadline. IRP filing requirements will be issued in a ruling expected in mid-November. A decision about the need for additional mid-term reliability procurement between 2029 and 2032 is expected by February.
• The scope for this proceeding also includes development of the Preferred System Plan portfolio for use in the 2027/2028 Transmission Planning Process recommendation to the CAISO, implementation of the Reliable and Clean Power Procurement Program (RCPPP) if a framework for the program is adopted in R.20-05-003, and coordination with Division of Water Resources on centralized Long-Lead Time resource procurement.
Updates to IOU Bundled Procurement Plans are due April 1, 2026.
Resource Adequacy Rulemaking (R.25-10-003)
• Comments on the October 15 Order Instituting Rulemaking (OIR) were filed on November 4. Several parties recommended improving and expediting the coordination between the IRP and RA proceedings, particularly in relation to the RCPPP (when/if approved) and GHG emission accounting. CalCCA’s Comments emphasized RA transactability under the slice-of-day framework, and PG&E’s Comments acknowledged the issue but recommended it be moved to Track 1.B after the Energy Division Staff Report is available The proceeding may also consider updates to the 2028 and 2029 planning reserve margin, accreditation methodologies for long-duration energy storage, and evaluation of transactability issues within the slice-of-day framework.
• Reply comments on the OIR are due November 14. Following a prehearing conference on November 17, a scoping memo is expected in December, and party proposals will likely be due in late January.
SDG&E EE Portfolio (A.25-04-014)
• On November 3, the ALJ issued a Ruling amending the procedural schedule for consideration of SDG&E’s proposal to withdraw from its role administering the regional energy efficiency programs in its region. The Ruling postpones an interim decision addressing legal issues in favor of reviewing testimony on factual and policy issues before preparing a comprehensive proposed decision in Summer 2026. The ruling accelerates deadlines as compared to the initial Scoping Memo by about a month. Parties’ opening testimony is now due January 15, rebuttal testimony is now due February 18, and the deadline to request an evidentiary hearing is now March 11.
High Distributed Energy Resource Future (R.21-06-017)
• On October 31, SDG&E submitted Part 2 of its Draft Electrification Impact Study that lists grid needs and identified planning solutions related to increased building and transportation electrification. Under the base Attachment A
2 case scenario, SDG&E expects peak load of 6,204 MW by 2030 and 7,007 MW by 2040 which will require an estimated $3 billion in distribution system investments. Increased demand flexibility is expected to reduce peak load to 6,086 MW by 2030 and 6,814 MW by 2040 at an estimated distribution system cost of $2.3 billion.
• On October 31, the CPUC issued Draft Resolution E-5413 (SCE AL 5567-E, SDG&E AL 4676-E, PG&E AL 7630-E) that would adopt the large IOUs’ joint proposal to use a uniform pending loads framework to identify locations with high load growth and distribution capacity constraints. On November 3, the CPUC issued Draft Resolution E-5414 (SDG&E AL 4675-E, SCE AL 5566-E, PG&E AL 7631) that would adopt the large IOUs’ joint proposal to establish a scenario planning framework in the distribution planning process. The scenario planning framework consists of three scenarios: Low, Base, and High, based on a range of factors including the categories of pending loads included, the use of pending loads, and changes in assumptions. Both resolutions are scheduled to be heard at the December 4 Commission meeting.
Staff Report
DATE: November 20, 2025
TO: Clean Energy Alliance Board of Directors
FROM: Gregory Wade, Chief Executive Officer
ITEM 7: Review Options for Customer Electricity Rate Relief RECOMMENDATION:
That the Clean Energy Alliance (CEA) Board of Directors (Board) receive a report on CEA customer rate options and financial impacts resulting from San Diego Gas & Electric’s (SDG&E’s) 2026 Energy Resource Recovery Account (ERRA) Forecast for Power Charge Indifference Adjustment (PCIA) rates and provide direction to staff.
BACKGROUND AND DISCUSSION:
At the Board Meeting on October 30, 2025, staff presented preliminary 2026 PCIA rates and preliminary SDG&E bundled rates. While those rates will not be finalized until the end of December 2025, the preliminary rates show a dramatic increase in PCIA rates for all CEA vintage years. SDG&E’s generation rates are also projected to increase, but not enough to offset the overall impact that is expected to be borne by CEA’s customers through payment of the PCIA. The Board directed staff to look at options and impacts that would reduce the financial burden and impact on CEA’s customers created by SDG&E’s PCIA rates.
The second Core Guiding Principle of CEA’s adopted Strategic Plan is to Build & Maintain Financial Stability. Among the key Financial Stability strategic goals is to achieve an Investment Grade Credit rating from one or more of the industry rating agencies. Achieving such a rating is a best practice for most electricity providers as it provides comfort to energy suppliers that an independent third-party believes that the rated entity is financially stable, creditworthy, and able to withstand the volatility that is inherent in energy markets. The result is that rated entities are able to avoid substantial collateral requirements and enjoy lower prices that can translate into lower customer rates. There are multiple measures that agencies use to assess the rating that they assign to electricity providers. The most common and well-known is Days Liquidity on Hand (DLOH), which measures how many days of cash (and available credit) an entity has on hand compared to its average daily level of expenses. While there are no hard numbers to point to, rating agencies generally require DLOH to be at least 150-180 days on a sustained basis. Many CCAs maintain DLOH levels well above those general guidelines.
Based on the current customer electricity rates, CEA’s current forecasted financial performance and the fiscal year-ending DLOH for the following 5 years are summarized below. Using 180 days as the required target, it is estimated that CEA could hope to target an investment grade rating sometime in late in Calendar Year (CY) 2027 or early in CY 2028 as shown in Table 1.
November 20, 2025
Rate Relief Options
Table 1
Estimated Rate Comparison Based on Preliminary SDG&E 2026 Rates Based on CEA’s current electricity rates combined with the preliminary 2026 PCIA rates, it is estimated that CEA’s customers will be paying a premium in 2026 as compared to the preliminary bundled SDG&E rates. As an example, for the rate class with the most residential customers (TOU-DR1) and using the average usage of 361 kWh per month, the average monthly bill for each CEA Vintage Year is shown in Table 2. Also shown is the premium that each City/Vintage Year would pay relative to SDG&E’s bundled rate.
Table 2
Options Considered for Customer Financial Relief
As directed by the Board, staff have evaluated several options which are shown below along with the estimated financial impact and other long-term implications for consideration by the Board.
1. Electricity Rate Reduction – 3% Reduction starting February 1, 2026 As shown in Table 3, adoption of a 3% rate reduction would reduce CEA’s revenues by approximately $12 to $12.5 million per year. Based on the assumed DLOH target necessary to seek and obtain an investment grade credit rating, adoption of this rate decrease would likely push this timeline out by approximately a year to sometime between late CY 2028 to early in CY 2029.
Total Year FY26 Total Year FY27 Total Year FY28 Total Year FY29 Total Year FY30 Change in Net Position $ 37,588,214 $ 41,193,206 $ 81,184,311 $ 90,603,516 $ 90,112,218 DLOH 65 101 199 256 349
November 20, 2025
Rate Relief Options
Table 3
2. Electricity Rate Reduction – 5% Reduction starting February 1, 2026 As shown in Table 4, adoption of a 5% rate reduction would reduce revenues by approximately $20 to $22.5 million per year. In terms of an investment grade credit rating, adoption of this rate decrease would likely push the timeframe for CEA to seek and receive a credit rating by approximately 18 months to late in CY 2029.
Table 4
It is important to note that, in both of these options, typical residential customers would still pay a slight premium over an average SDG&E bundled residential customer as shown in Table 5 below.
Table 5 SDG&E VY 2017 VY 2020 VY 2022 VY 2023
No Rate Change $ 180.46 $ 190.42 $ 189.57 $ 188.09 $ 185.73 3% Rate Decrease $ 180.46 $ 188.49 $ 187.64 $ 186.16 $ 183.80 5% Rate Decrease $ 180.46 $ 187.20 $ 186.35 $ 184.87 $ 182.51
3. CARE/FERA Credit
As directed by the Board, staff also looked at providing a bill credit to California Alternate Rates for Energy (CARE) and Family Electric Rate Assistance (FERA) customers. There are approximately 52,000 such customers in CEA’s territory. Unfortunately, SDG&E’s billing system does not currently provide the ability to pass a credit to the customer if the credit results in a negative bill amount that would otherwise be owed to CEA. Additionally, providing this type of credit to CARE/FERA customers may be in tension with CEA’s Joint Powers Authority (JPA) Agreement provision regarding the use and allocation of discretionary revenues. For these reasons, this credit option is not recommended.
4. Adjust CEA’s Base Product Rate (Clean Impact) to be at Parity with SDG&E’s Bundled Rate New CEA customers are automatically enrolled in CEA’s default product, Clean Impact Plus, which is 50% Renewable and 75% Carbon Free. Each customer has the option to “Opt Down” to the base product, Clean Impact (50% Renewable), at any time by making a voluntary election. If a customer does elect to Opt Down, the electricity rate is reduced by $0.001 (one-tenth of a cent) per kWh. As of today, very few customers have chosen to Opt Down to the Clean Impact product. Currently, the number of customers in each product category is as follows:
Total Year FY26 Total Year FY27 Total Year FY28 Total Year FY29 Total Year FY30 Change in Net Position $ 33,787,049 $ 29,115,842 $ 68,963,157 $ 78,196,765 $ 77,498,841 DLOH 62 86 169 211 291
Total Year FY26 Total Year FY27 Total Year FY28 Total Year FY29 Total Year FY30 Change in Net Position $ 31,252,939 $ 21,064,265 $ 60,815,721 $ 69,925,598 $ 69,089,924 DLOH 61 76 149 181 253
November 20, 2025
Rate Relief Options
Product Product Content Customers
Clean Impact (Base) 50% Renewable 748
Clean Impact Plus (Default) 50% Renewable75% Carbon Free 253,081 Green Impact (Premium) 100% Renewable 1,469
Total 255,298
The objective for this option would be to reduce the electricity rate for the Clean Impact product for all vintages so that even the highest CEA PCIA rate vintage (Vintage Year 2017) would be at parity to SDG&E’s bundled rate for a one-year period.
Using the same TOU-DR1 Rate Class, the result would be that, instead of the average customer paying approximately $5 to $10 per month more than SDG&E, the average CEA customer who opts down to Clean Impact would pay either the same (for Vintage Year 2017) or less (for all other vintages) than if they were on SDG&E’s bundled service for that one-year period. The savings would range from parity (2017 Vintage Year) to up to $4.69 per month (2023 Vintage Year). It is estimated that the earliest that such a rate change could take effect is February 1, 2026, following final publication of SDG&E’s rates and the required CEA public notice period and rate hearing. So, the estimates below are based on a 12-month period beginning on February 1, 2026. If the Board elected to adopt this option, monthly charges and rates for customers would be as shown in Table 6 below.
Table 6
If this option is adopted by the Board, the per-kWh electricity rate for Clean Impact for TOU-DR1 rate class customers would be set at a rate so that the total rate paid for electricity (including generation, delivery and PCIA) would be equal or better than what each customer would have paid had they been or chosen to opt out to become an SDG&E bundled customer (i.e. “Parity” or better).
Using an estimate that 30,000 residential customers might Opt Down with this CEA rate/product offering, Table 7 shows the projected Change in Net Position and the DLOH for this option.
November 20, 2025
Rate Relief Options
Table 7
The objective with this option would be to apply this rate relief to CEA’s residential customers for 12 months in CY 2026 and to monitor SDG&E’s 2027 ERRA Forecast for projected PCIA rate impacts. Staff would assess these impacts and present them to the Board at the end of 2026.
Staff have been coordinating with Calpine, CEA’s data and billing services provider, to determine the procedural and logistical steps and timelines necessary for implementation of this rate relief option. This information will be presented to the Board at the November 20th Board Meeting. It should also be noted that the analysis conducted thus far for this option applies only to residential customers as they are the customers for whom rate relief would provide the most meaningful benefit. Should the Board wish to consider applying this rate relief option to any non-residential customer classes, that direction should be provided by the Board.
Summary of Options
In Table 8 below is a summary of the financial impact of the several options presented above.
Table 8
Staff Recommendation
Having considered the above options, staff recommends that the Board direct staff to continue to work with Calpine to develop a process to achieve the Clean Impact Residential Rate Relief option outlined in Option 4 and to return to the Board at its January 2026 Regular Board meeting to hold a Public Hearing implementing the residential rate relief at the earliest possible date in 2026.
November 20, 2025
Rate Relief Options
Submitted for Board consideration:
___________________________________
Gregory Wade
Chief Executive Officer
ATTACHMENTS:
None.