This redefinition of DAC status not only departs from the Commission’s directive but also undermines the meaningful identification of communities that may already be disadvantaged in the distribution planning process. Compounding this issue, the Joint Utilities’ reliance on load growth as a proxy for infrastructure need poses a distinct equity concern. DACs often have lower load growth forecasts precisely because of historical underinvestment in them. In turn, DACs’ energy consumption is low, but they spend more on energy relative to their income than higher income households. Focusing on load growth may continue resulting in underinvestment in energy efficiency, distribution upgrades, and other investments that create a cycle of perverse disincentives for DACs.
4. Tribal Community Status (Yes/No):
D.24-10-030 requires the Joint Utilities to indicate whether the equipment/facility serves a Tribal community. The Joint Utilities’ proposals do not ensure this metric will be reported for each circuit. While PG&E/SCE at least include “Tribal community” as one of the customer group categories in their regression analysis, SDG&E’s approach offers no separate identification of Tribal-serving circuits. For SDG&E, tribal communities are subsumed under the broad “DAC circuit” definition if they happen to overlap with other priority factors.9 This
means that the unique needs of Tribal communities could be masked. The omission of a clear, standalone Tribal indicator in the final metrics is a failure to carry out Metric 4 from D.24-10- 030, as listed above.
The Commission explicitly requested information identifying whether a circuit serves a Tribal land or community. This information cannot be determined from SDG&E’s combined DAC label, nor from PG&E/SCE’s regressions unless one digs into underlying data. This is a clear inconsistency with the directive in D.23-10-030.
5. Medical Baseline Enrollment (Percent of Customers):
D.24-10-030 requires tracking the percentage of customers on Medical Baseline on each circuit. The Joint Utilities do not plan to report this percentage as a separate metric. PG&E/SCE again only use Medical Baseline customer counts as an input to their regressions, and even note that there “may not be sufficient statistical variation” in Medical Baseline data to produce a meaningful metric under the Commission’s request.10 Instead, SCE and PG&E note that their methodology would determine whether there is a significant metric for this customer group, but fails to provide granular data. SDG&E similarly does not report a Medical Baseline percentage.
Instead, a single Medical Baseline customer would just contribute to labeling the circuit as a “DAC” by SDG&E’s method.
By failing to explicitly report the proportion of Medical Baseline customers per circuit, the Joint Utilities are omitting Metric 5 as outlined in D.24-10-030. This omission is contrary to
9 See Equity Metrics Advice Letters at 3.
10 Equity Metrics Advice Letters at 6.
Protest of the Joint CCAs to the
Joint Utilities’ Equity Metrics Advice Letters
the Commission’s expressed requirement to consider the needs of customers with medical equipment (often critically dependent on reliable power).
In summary, none of the Joint Utilities proposed metrics directly correspond to the five equity metrics the Commission explicitly required to be included and reported. Instead of providing the straightforward transparency envisioned in D.24-10-030, the Joint Utilities propose to roll some of these factors into composite metrics and drop others entirely. D.24-10-030’s equity tracking mandate was aimed at shedding light on how distribution planning impacts vulnerable groups. By diverting to different metrics, the Joint Utilities risk obscuring that light.
The relief requested (approval of these alternative metrics in lieu of the metrics set forth in D.24- 10-030) is therefore inconsistent with both the letter of D.24-10-030 (which listed those five metrics to include) and its intent (to provide clear, granular equity data).11 The Commission should require the Joint Utilities to include and report the metrics in D.24-10-030, not replace them with unproven substitutes.
B. The Equity Metrics Advice Letters Contain Omissions in the Analysis and Data that Undermine Equity.
The Joint Utilities’ proposed metrics focus largely on internal planning indicators such as regression outputs and load growth proxies, omitting critical data that would reflect actual outcomes experienced by DACs. This is a material omission that fails to support the Commission’s commitment to ensure equitable access to distribution service for historically at-risk communities. While the Decision did not expressly mandate metrics for reliability, resilience, or climate adaptation, these factors are central to equitable service and must be included to ensure metrics are meaningful. Further, the Commission’s five metrics adequately encompass these factors in a way that the Joint Utilities’ alterations do not encompass.
Metrics that only reflect planning inputs or correlations are not sufficient for evaluating equity in service delivery or infrastructure investment. DACs often suffer more frequent and/or longer outages and may be less able to cope with disasters, yet the proposed metrics provide no insight into these issues. By ignoring reliability and climate adaptation considerations entirely, the Joint Utilities are leaving out factors that are essential to evaluating whether the grid is equitably serving all communities. This omission directly undermines the Commission’s goal of equity, reliability, and resilience.
Additionally, the metrics proposed by PG&E and SCE use a regression analysis between the metric (grid access and project initiation) and the number of customers within CARE/FERA, DAC, Tribal, and Medical Baseline customer groups. Under this approach, the proposed metrics are narrowly scoped to evaluate grid access and project initiation within these historically at-risk
11 In effect, the Joint Utilities are proposing new metrics, and this type of request by the Joint Utilities is inappropriate for advice letters. See General Rule 7.4.2 (5), which provides, as another grounds for protesting an advice letter, the fact that “[t]he relief requested in the advice letter requires consideration in a formal hearing, or is otherwise inappropriate for the advice letter process.” Protest of the Joint CCAs to the
Joint Utilities’ Equity Metrics Advice Letters
customer groups, based on number of customers, rather than comparison between at-risk customer groups and non-at-risk customer groups. At best, the metrics proposed by PG&E and SCE would limit the actions they could take to address inequitable access to distribution services, and at worst, these metrics would result in misleading conclusions, leading to actions that could further inequitable treatment of disadvantaged communities.
While SDG&E’s proposed metrics do a better job comparing DAC customers to non-DAC customers, SDG&E rolls the five customer groups proposed by CPUC into one binary designation of DAC vs. non-DAC. This erases the granularity intended by the CPUC’s proposed metrics, which can lead to misinterpretation of the data produced.
Lastly, the Joint Utilities do not clearly describe how they will use the proposed equity metrics to implement equitable distribution planning.
In short, failing to include any metric on service reliability, outage frequency/duration, or resilience measures is a material gap in the analysis. Additionally, the metrics proposed by the Joint Utilities, particularly those proposed by PG&E and SCE, can produce invalid or misleading results when evaluating the equitable treatment and outcomes in distribution planning and service for historically at-risk communities. For these reasons, the Joint CCAs further protest the Equity Metrics Advice Letters on the grounds that, as described in General Rule 7.4.2 (3), “[t]he data in the advice letter[s] contain material…omissions.”
NOTICES
The Joint CCAs request that they be added to the service list for the Equity Metrics Advice Letters, and that they be notified of the issuance of a draft resolution addressing the Equity Metrics Advice Letters. Contact information for the Joint CCAs is as follows:
Jessica Melms
BRAUN BLAISING & WYNNE, P.C.
555 Capitol Mall, Suite 570
Sacramento, CA 95814
(916) 326-5814
[email protected]
///
Protest of the Joint CCAs to the
Joint Utilities’ Equity Metrics Advice Letters
CONCLUSION
For the foregoing reasons, the Joint CCAs urge the Commission to reject Advice Letters 7530-E, 5498-E, and 4617-E as submitted, or at minimum to require substantial modifications to ensure compliance with D.24-10-030. The Joint Utilities’ proposed metrics do not satisfy the Commission’s explicit requirements in D.24-10-030 and require modifications.
The Joint CCAs thank the Commission for its consideration of this protest.
Respectfully,
/s/ Jessica Melms
Jessica Melms
Scott Blaising
BRAUN BLAISING & WYNNE P.C.
[email protected]
Attorneys for the Joint CCAs
Copy (via e-mail): Leuwam Tesfai, Energy Division ([email protected]) Connor Flanigan, SCE ([email protected])
Adam Smith, SCE ([email protected])
Sidney Bob Dietz II, PG&E ([email protected])
Greg Anderson, SDG&E ([email protected])
Service List: R.21-06-017
Comments on Discussion paper and Mar 03 discussion
Initiative: Demand and distributed energy market integration Comment period
Mar 04, 2025, 04:00 pm - Mar 28, 2025, 05:00 pm
Submitting organizations
California Community Choice Association
California Community Choice Association
Submitted on 03/28/2025, 03:53 pm
Contact
Shawn-Dai Linderman ([email protected])
1. Please provide your organization’s feedback on the approach to the Working Group’s goals, process, evolution of the Discussion paper, and Stakeholder Recommendations (pg. 2-5) in the DDEMI Discussion Paper. Any suggestions to improve the Working Group process or deliverables?
The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the Demand and Distributed Energy Market Integration (DDEMI) Working Group and Discussion Paper. As described in detail in the sections below, CalCCA recommends, in summary, that the California Independent System Operator Corporation (CAISO):
Prioritize: (1) improving the simplicity and accuracy of performance evaluation methodologies; (2) enhancing the economic-based demand response participation models through a modified proxy demand resource (PDR) model that considers exports; and (3) exploring distributed energy resource (DER) participation in wholesale markets and pathways for advancing demand flexibility;
Provide an educational session early on in the working group process to help newer market participants learn about market participation options and related issues being explored in this initiative; and
Seek to minimize implementation barriers and complexity associated with the performance evaluation methodologies while ensuring accurate performance calculations.
2. Please provide your organization’s feedback on the overarching themes/areas and the associated scope items for problem statement formulation. Are there any additional themes/areas or individual scope items which should be explored further? The CAISO should prioritize the following three themes within this initiative:
1. Performance Evaluation Methodologies: The current baseline methodologies create a high barrier to entry for smaller load-serving entities and program operators, including community choice aggregators. Simplifying and improving the accuracy of the baseline methodologies can help promote market diversity and competition, and accelerate the integration of clean resources. This supports state policy goals and overall market efficiency. DERs will play a key role in the state’s portfolio and address local reliability and community needs. CalCCA supports exploring the items advanced by stakeholders, including: (1) modifying the control group settlement methodology; (2) moving the baseline methodologies to the business practice manuals; (3) using device-level measurement; and (4) creating alternative baseline methodologies.
2. Economic-based Demand Response Participation Models: The PDR model used for economic demand response participation will benefit from a holistic review to ensure it accurately reflects resource capabilities and minimizes barriers to participation. CalCCA supports evaluating a modified PDR (mPDR) model to more accurately reflect the capabilities of PDR resources that can export. The mPDR model has the potential to better account for the full capabilities of behind-the-meter (BTM) resources with storage. CalCCA also recommends that within this holistic assessment of economic Demand Response (DR) participation models, the CAISO should: (1) clearly document how to use the Demand Response Registration System Application Program Interface to increase the ability of market participants to develop their own processes that use it; (2) maintain clear data requirements to allow market participants to prepare for upcoming changes; and (3) enable easier maintenance of accurate registration records.
3. Distributed Energy Resource Participation: The current participation models for BTM storage should be re-evaluated to ensure they fully account for battery capabilities. CalCCA supports exploring BTM storage participation in the wholesale markets, as described in the discussion paper. The CAISO should also explore microgrid participation in the wholesale markets?and the resource adequacy (RA) program (including obtaining a net qualifying capacity, must-offer obligations, etc.).
3. Please provide your feedback on any specific topics that require further information/reference in order to facilitate substantive stakeholder conversation.
Early in the working group process, the CAISO should host an educational session on its existing DR and DER market participation models to help newer market participants learn about pathways for market participation and related issues. CalCCA proposes the following topics be addressed in this session:
Differences between supply-side and load-modifying participation pathway requirements; Existing supply-side market participation models for DR and DER; Registration requirements and maintenance of DR and DER registrations; Participation requirements, data requirements, and existing baseline methodologies; and California Public Utilities Commission and CAISO jurisdictional responsibilities and rules for obtaining RA credit for each participation model.
4. What feedback do you have on the challenges shared by Stakeholder presentations regarding service level load measurement & validation needed for control groups? Do the M&V and Performance Evaluation Methodology (PEM) options available today address the needs of diverse technologies? Are there additional technical challenges (e.g., technology-specific curtailment, control group validation, energy storage baselines) that should be considered in the working group?
CalCCA appreciates the stakeholder presentations on performance evaluation methodologies from Leap, Pacific Gas and Electric Company (PG&E), and Nostromo Energy. As described in section 2, above, CalCCA supports exploring improvements to the baselines, focused on increasing simplicity and accuracy. The Leap and PG&E presentations demonstrate that accuracy and participation benefits can be realized through the control group methodology. This methodology is not widely used due to implementation barriers, including difficulty accessing non-participant meter data.[1] Modifications to the baseline methodologies should seek to minimize implementation barriers and complexity such that market participants can leverage the baseline methodology that most accurately measures the performance of their resources. [1] See PG&E presentation:
https://stakeholdercenter.caiso.com/InitiativeDocuments/Presentation-PGE-Settlement-Methodology -Mar-03-2025.pdf; and Leap presentation:
https://stakeholdercenter.caiso.com/InitiativeDocuments/Presentation-Leap-Prescriptive-Baselines-Mar-03-2025.pdf.
5. What topic(s) would your organization be interested in presenting (what is the problem/issue seeking to be addressed)? Which stakeholders would it impact? CalCCA has no particular topics to be presented at this time but may be interested in presenting on issues as the initiative progresses.
APRIL FILINGS
ADVICE LETTER
SUMMARY
ENERGY UTILITY
Company name/CPUC Utility No.:
Utility type:
Phone #:
EXPLANATION OF UTILITY TYPE
ELC GAS
PLC HEAT
MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Advice Letter (AL) #:
WATER
E-mail:
E-mail Disposition Notice to:
Contact Person:
ELC = Electric
PLC = Pipeline
GAS = Gas
HEAT = Heat WATER = Water
(Date Submitted / Received Stamp by CPUC)
Subject of AL:
Tier Designation:
Keywords (choose from CPUC listing):
AL Type: Monthly Quarterly Annual One-Time Other:
If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:
Does AL replace a withdrawn or rejected AL? If so, identify the prior AL:
Summarize differences between the AL and the prior withdrawn or rejected AL:
Confidential treatment requested? Yes No
If yes, specification of confidential information:
Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information:
Resolution required? Yes No
Requested effective date: No. of tariff sheets:
Estimated system annual revenue effect (%):
Estimated system average rate effect (%):
When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).
Tariff schedules affected:
Service affected and changes proposed1:
Pending advice letters that revise the same tariff sheets:
1Discuss in AL if more space is needed.
Marin Clean Energy (MCE)
✔ 415-464-6664
[email protected]
[email protected]
Amulya Yerrapotu
86-E 2
2026 Budget Request and Marketing, Education and Outreach Plan for the Disadvantaged Communities Green Tariff Program
COMPLIANCE
✔
D.24-05-065,
N/A
✔
N/A
✔
5/1/25 0
N/A
N/A
N/A
N/A
N/A
Clear Form
California Public Utilities Commission
Energy Division Tariff Unit Email:
[email protected]
Protests and correspondence regarding this AL are to be sent via email and are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:
Contact Name:
Title:
Utility/Entity Name:
Telephone (xxx) xxx-xxxx:
Facsimile (xxx) xxx-xxxx:
Email:
Contact Name:
Title:
Utility/Entity Name:
Telephone (xxx) xxx-xxxx:
Facsimile (xxx) xxx-xxxx:
Email:
CPUC
Energy Division Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102
Policy Analyst
Marin Clean Energy
Amulya Yerrapotu
(925) 378-6729
[email protected]
MCE Regulatory
Regulatory Account
Marin Clean Energy
N/A
N/A
[email protected]
Clear Form
ENERGY Advice Letter Keywords
Affiliate Direct Access Preliminary Statement
Agreements Disconnect Service Procurement
Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates
Balancing Account Energy Charge Refunds
Baseline Energy Efficiency Reliability
Bilingual Establish Service Re-MAT/Bio-MAT
Billings Expand Service Area Revenue Allocation
Bioenergy Forms Rule 21
Brokerage Fees Franchise Fee / User Tax Rules
CARE G.O. 131-D Section 851
CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map
Cogeneration Increase Rates Service Outage
Compliance Interruptible Service Solar
Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage
Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges
Contracts Line Extensions Tariffs
Core Memorandum Account Taxes
Credit Metered Energy Efficiency Text Changes
Curtailable Service Metering Transformer
Customer Charge Mobile Home Parks Transition Cost
Customer Owned Generation Name Change Transmission Lines Decrease Rates Non-Core Transportation Electrification
Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding
Demand Side Management Oil Pipelines Voltage Discount
Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service
Depreciation Power Lines
Clear Form
MCE Advice Letter 79-E
1 April 1, 2025
California Public Utilities Commission
Energy Division
Attention: Tariff Unit
505 Van Ness Avenue, 4th Floor
San Francisco, CA 94102-3298
MCE Advice Letter 86-E
RE: 2026 Budget Request and Marketing, Education and Outreach Plan for the Disadvantaged Communities Green Tariff Program
Pursuant to Ordering Paragraphs (“OP”) 2 and 4 of Resolution E-4999,1 OP 3 of Resolution E-5125,2 and OPs 2 and 3 of D.24-05-065,3 Marin Clean Energy (“MCE”) hereby submits this Tier 2 Advice Letter (“AL”) to submit the program budget request and marketing, education and outreach (“ME&O”) plan for the Disadvantaged Communities Green Tariff (“DAC-GT) program for the program year (“PY”) 2026.
TIER DESIGNATION
This AL has a Tier 2 designation pursuant to OP 3 of Resolution E-5125.
EFFECTIVE DATE
Pursuant to G.O. 96-B, MCE requests that this Tier 2 AL become effective on May 1, 2025, which is 30 calendar days from the date of this filing.
BACKGROUND
On June 21, 2018, the California Public Utilities Commission (“Commission” or “CPUC”) approved D.18-06-027, adopting two new community solar programs to promote the use of 1 OP 2 and 4 of Resolution E-4999 specifically directed Pacific Gas and Electric Company, Southern California Edison and San Diego Gas & Electric Company to submit annual program budget estimates and ME&O plans to the Commission by February 1 of each year. MCE’s implementation Advice Letter, MCE AL 42-E/E-A/E-B was approved in Resolution E-5124, which brought MCE under the same program rules and reporting structure applicable to the IOUs. 2 OP 3 of Resolution E-5125 directed that DAC-GT and CS-GT Annual Budget Advice Letters are to be submitted as Tier 2 ALs to allow for additional review and oversight. 3 OP 2 of D.24-05-065 discontinues the CS-GT program and directs program administrators to transfer remaining capacity, customers, and programs into the DAC-GT program. OP 3 of D.24-05-065 makes several modifications to the DAC-GT program, which are reflected in this budget submission.
MCE Advice Letter 86-E
2 renewable generation among residential customers in disadvantaged communities (“DACs”),4as directed by the California Legislature in Assembly Bill (“AB”) 327 (Perea), Stats. 2013, ch 611.
The DAC-GT and the CS-GT programs offer 100% solar energy to eligible customers and provide a 20% discount on the electric portion of the utility bill.
D.18-06-027 allows Community Choice Aggregators (“CCAs”) to develop their own DAC-GT and CS-GT programs, and states that CCAs that elect to offer DAC-GT and CS-GT must abide by all rules and requirements adopted in that decision.5 Pursuant to OP 17 of D.18-06-027, MCE filed its Implementation AL (MCE AL 42-E) on May 7, 2020. The Commission approved AL 42-E in Resolution E-5124, issued April 15, 2021.
Resolution E-4999 from May 2019 approved the investor-owned utilities’ (“IOUs”) implementation ALs for the DAC-GT and CS-GT programs and established the budgeting procedures and timelines for the programs. The Resolution sets the deadline for submitting annual DAC-GT and CS-GT program budget requests and ME&O plans for the upcoming PY by February 1 st of each year.6 Furthermore, the Resolution specifies that Program Administrators must reconcile prior year budget forecasts and expenditures in their annual budget requests.7 On December 4, 2023, MCE, as a part of the Joint CCAs, requested a two-month extension of the budget AL until April 1, 2023. On January 11, 2024, MCE, as a part of the Joint CCAs, amended the extension request to align with the IOUs, requesting an extension until May 1, 2024, or 30 days after the issuance of the Final Decision in proceeding A.22-05-022, whichever is later. On January 24, 2024, the Joint CCAs’ extension request was granted. The Final Decision in proceeding A.22- 05-022 was issued on June 7, 2024.8
On May 30, 2024, the CPUC approved D.24-05-065, discontinuing the CS-GT program and approving a number of modifications to the DAC-GT program. The DAC-GT program modifications pertaining to CCA program administrators include: modifying project siting requirements, increasing program capacity, allowing the voluntarily inclusion of storage in projects, ordering the cost containment cap to be updated, changing the budget advice letter deadline to April 1st, and removing the Green-e certification requirement.
On September 27, 2024, MCE submitted its updated tariff documents for the DAC-GT program.
On November 15, 2024, the CPUC approved MCE’s revised DAC-GT tariff with an effective date of October 27, 2024.
Per D.18-06-027, the budget requirements outlined in Resolution E-4999 apply to participating CCAs as well. The submission and approval of this budget AL is the prerequisite to having the 4 DACs are defined under Resolution E-5212 as communities that are identified in version 3.0 or any subsequent version of CalEnviroScreen as among the top 25 percent of census tracts statewide, plus the census tracts in the highest five percent of CalEnviroScreen’s Pollution Burden that do not have an overall CalEnviroScreen score because of unreliable socioeconomic or health data. Resolution E-5212 also expands program eligibility to include California Indian Country. 5 D.18-06-027, p. 104, OP 17.
6 Resolution E-4999, OP 2.
7 Resolution E-4999, OP 4.
8 D.24-05-065
MCE Advice Letter 86-E
3 DAC-GT and CS-GT budgets included in the IOUs’ Energy Resource Recovery Account (“ERRA”) Forecast in June each year. The ERRA Forecast in turn enables cost recovery of the programs. Therefore, MCE is submitting this advice letter to ensure timely cost recovery for its programs.
PURPOSE
MCE hereby submits the budget request for PY 2026 for the DAC-GT program. Per Resolution E-4999, the budget request includes both the budget reconciliation for the previous PY (i.e., PY 2024) and the budget forecast for the upcoming PY (i.e., PY 2026). Additionally, MCE includes two corrections for inadvertent errors in last year’s budget AL (MCE AL 79-E). Because D.24-05- 065 closed the CS-GT program for future procurement and MCE has not already procured a project for the CS-GT program, MCE does not include CS-GT in the PY 2026 budget forecast. However, MCE continues to include CS-GT program costs in the PY 2024 budget reconciliation until the point of program closure upon issuance of D.24-05-065. In summary, MCE requests a total budget of $1,972,742 for the DAC-GT program for PY 2026, including corrections from MCE AL 79-E and PY 2024 DAC-GT and CS-GT reconciliation costs. Additional details can be found in Appendix A.
Once the Commission approves MCE’s budget request, PG&E will be responsible for including the total budget request for MCE’s DAC-GT program in the 2026 ERRA Forecast filing.9 Once PG&E receives approval of its ERRA Forecast from the Commission, PG&E will set aside the requested MCE budget in a sub-account of its DAC-GT balancing account. PG&E will then transfer program funds to MCE as determined in Resolution E-5124.10 In addition to the budget request, MCE submits its updated ME&O plan for PY 2026 as Appendix B.
CONCLUSION
MCE respectfully requests the Commission approve the budgets proposed herein and direct PG&E to transfer funds sufficient to meet MCE’s approved annual budgets per the funding mechanisms set forth in Resolution E-5124. MCE also requests approval of its ME&O plan for 2026.
NOTICE
A copy of this AL is being served on the official Commission service lists for Rulemaking R.14- 07-002 and Application A.22-05-022.
For changes to this service list, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at [email protected].
9 D.22-01-023, p. 28, OP 3. Modifies the due date for PG&E to file this annual Application to May 15, 2023. Because D.24-05-065 was not voted on until May 30, 2024, pushing this advice letter filing to July 8 th, 2024 PG&E may need to include an updated budget in its October ERRA forecast update. 10 Resolution E-5124, p. 10.
MCE Advice Letter 86-E
4 PROTESTS
Anyone wishing to protest this advice letter filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests must be submitted to:
CPUC, Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102
Email: [email protected]
In addition, protests and all other correspondence regarding this advice letter shall be sent electronically to the attention of:
Amulya Yerrapotu
Policy Analyst
Marin Clean Energy
1125 Tamalpais Ave
San Rafael, CA 94901
Email: [email protected]
There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and shall be submitted expeditiously.
CORRESPONDENCE
For questions, please contact Amulya Yerrapotu at (925) 378-6729 or by electronic mail at [email protected].
/s/ Amulya Yerrapotu
Amulya Yerrapotu
Policy Analyst
MARIN CLEAN ENERGY
1125 Tamalpais Avenue
San Rafael, CA 94901
Telephone: (925) 378-6729
Email: [email protected]
Appendices
Appendix A: PY 2026 Budget Request
Appendix B: PY 2026 ME&O Plan
MCE Advice Letter 86-E
5 cc: Service List for R.14-07-002 and A.22-05-022
A-1
Budget Forecast for the Disadvantaged Communities Green Tariff Program for Program Year 2026
Proposed by Marin Clean Energy
A-2
TABLE OF CONTENTS
1. BACKGROUND 3
2. BUDGET FORECAST FOR PY 2026 4
3. BUDGET CAPS 6
4. BUDGET RECONCILIATION FOR PY 2024 6
5. CORRECTION OF MCE AL 79-E 2023 ACTUAL BILL DISCOUNT COSTS 8
6. 2026 BUDGET REQUEST 8
7. PROGRAM CAPACITY AND ENROLLMENT NUMBERS 8
TABLE OF FIGURES
Table 1: MCE Budget Forecast for PY 2026 4
Table 2: MCE Budget Reconciliation for PY 2024 8
Table 3: MCE Budget Request for PY 2026 9
Table 4: Program Capacity and Enrollment Count for DAC-GT and CS-GT for PY 2024 9 Table 5: Forecasted Program Capacity and Enrollment Count for DAC-GT and CS-GT for PY 2026 9
A-3
1. BACKGROUND
MCE is a program administrator (PA) of the Disadvantaged Communities (DAC) Green Tariff (DAC-GT) and Community Solar Green Tariff (CS-GT) programs. Per Resolution E-4999, annual program budgets must be presented by program and include the following budget line items:1
1. Generation cost delta, if any;2
2. 20 percent bill discount for participating customers;
3. Program administration costs: 3
a. Program management;
b. Information technology (IT);
c. Billing operations;
d. Regulatory compliance;
e. Procurement;
4. Marketing, education and outreach (ME&O) costs:
a. Labor costs;
b. Outreach and material costs;
c. Local CBO/ sponsor costs (for CS-GT only).
In this program budget, MCE includes both the budget reconciliation for the previous program year (PY) (i.e., PY 2024) and the budget forecast for the upcoming PY (i.e., PY 2026). As D.24- 05-065 closes the CS-GT program for future procurement and MCE has not already procured a CS-GT project, MCE does not include CS-GT program costs for PY 2026, and only includes CS-GT costs in the budget reconciliation for PY 2024 until program closure.
Additionally, MCE includes a correction for an inadvertent error in calculating the actual program costs in last year’s budget advice letter (AL) (MCE AL 79-E).
In addition to budget reconciliation and forecast, annual program budget submissions must also include details on program capacity and customer enrollment numbers for both programs. More specifically, MCE reports on:
1. Existing solar generation capacity at previous PY’s close (i.e., December 31, 2024); 1 A detailed description of each budget line item can be found in MCE’s Implementation Plan, submitted in Appendix A to MCE Advice Letter 42-E filed on May 7, 2020. 2 Resolution E-4999 establishes that above market generation costs should include net renewable resource costs in excess of the otherwise applicable class average generation rate that will be used to calculate the customers’ bills. In conversations with the CPUC’s Energy Division after the release of the Resolution, it was clarified that this budget line item is intended to cover both a potential higher, as well as lower, cost of the DAC-GT/ CS-GT resources than the otherwise applicable class average generation rate. Hence, the term is updated to state the “Delta of generation costs between the DAC-GT/ CS-GT resources and the otherwise applicable class average generation rate.” 3 Resolution E-5124 established that PG&E can charge “CCA Integration Costs” to the programs; i.e. costs that incur to PG&E to enable CCAs to administer the programs (e.g., billing support functions). To date, CCAs have been including CCA integration costs on their budget ALs. On March 2, 2023, PG&E submitted Advice Letter 6872-E requesting that the CPUC approve a tariff modification to allow PG&E to record these CCA integration costs directly to PG&E’s subaccount, instead of the CCAs seeking cost recovery. Therefore, MCE does not include the CCA integration cost in its 2025 budget forecast. However, MCE still includes the CCA integration cost in the calculation of its administration cost cap, per Resolution E-5124.
A-4
2. Forecasted solar generation capacity under contract for procurement in the upcoming PY;
3. Customers served at previous PY’s close (i.e., December 31, 2024); and
4. Forecasted customer enrollment for the upcoming PY.
Finally, MCE will submit the following workpapers to the California Public Utilities Commission’s (CPUC or Commission) Energy Division staff directly:
1. Calculation of the generation cost delta;
2. Calculation of the 20% bill discount to participating customers.
2. BUDGET FORECAST FOR PY 2026
For PY 2026, MCE forecasts a total budget of $2,902,368 for the DAC-GT program. This budget forecast accounts for the program modifications established in D.24-05-065, including discontinuing the CS-GT program and rolling unused capacity into the DAC-GT program, increasing DAC-GT program capacity, and removing the Green-e certification requirement. A detailed budget forecast for each program by budget line item can be found in the table below.
Table 1: MCE Budget Forecast for PY 2026
MCE provides a brief description of each of the budget line items below.
Generation Cost Delta
To date, MCE has been using interim solar generation resources to support the DAC-GT program while it is procuring a dedicated solar facility for the program. On June 20, 2022, the Commission Tab Category DAC-GT
1 Generation Cost Delta $ 921,536
2 20% Bill Discount $ 1,679,692
Program Administration
3a Program Management $ 115,280
3b Information Technology $ 13,635
3c Billing Operations $ 100,065
3d Regulatory Compliance $ 18,678
3e Procurement $ 14,620
Subtotal Program Administration $ 262,278
Marketing, Education & Outreach
4a Labor Costs $ 10,382
4b Outreach and Material Costs $ 28,480
Subtotal ME&O $ 38,862
Total $ 2,902,368
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granted MCE’s request to approve its dedicated DAC-GT power purchase agreement (PPA).4 On November 11, 2024, the Commission approved MCE’s first request to amend its dedicated DAC-GT PPA. On June 19, 2024, the Commission approved MCE’s second request to amend its dedicated DAC-GT PPA. The new dedicated solar generation facility is expected to come online in early 2026.
Decision 24-05-065 approves a 50% expansion of MCE’s DAC-GT program capacity. Decision 24-05-065 also rolls any unused CS-GT capacity into MCE’s DAC-GT program. MCE’s DAC-GT program now has a total capacity of 8.249 MW. MCE plans to enroll new customers using an interim resource as it works to procure a resource to serve the remaining program capacity. MCE anticipates using the existing DAC-GT interim resource for this purpose.
As such, the DAC-GT generation cost delta budget forecast for the first three months of 2026 is based on the PPA price of the current interim solar generation resource, compared to the costs of serving customers under MCE’s residential base tariff, the “Light Green” tariff. For the remainder of 2026, after the new dedicated solar resource comes online, the DAC-GT generation cost delta for customers enrolled under the original DAC-GT capacity is based on the PPA price of the new dedicated solar generation resource. The DAC-GT generation cost delta for customers enrolled under the expanded DAC-GT capacity continues to be based on the PPA price of the current interim solar generation resource.
20 Percent Bill Discount
As set forth in Resolution E-5124, MCE calculates the 20% bill discount on both the generation and transmission and distribution (T&D) portion of the electric bill for participating customers.
The bill discount is then fully included on the generation portion of customer bills, i.e., the discount reduces the electric generation costs of a customer’s bill only.5 MCE then recovers these program
costs via this budget AL filing.
In PY 2026, MCE expects to have approximately 5,805 customers enrolled in the DAC-GT program. D.24-05-065 expands MCE’s DAC-GT program capacity by 3.609 MW. MCE estimates that it will be able to serve 2,540 customers with this new capacity, in addition to the existing 3,265 customers currently served by existing program capacity. MCE plans to enroll customers using an interim resource as it works to procure a new resource to serve the remaining program capacity.
The PY 2026 forecast for the 20 percent bill discount is based on the actual average monthly bill discount provided to participating customers in 2024, with a 25% increase to account for forecasted increases in electricity rates. Future customers enrolled under the expanded capacity are assumed to have the same usage as existing customers.
Program Administration Costs
Program administration includes program development, management, budgeting, and reporting.
IT costs include the costs to develop program tools and updating existing systems to accommodate program enrollment and billing. Billing operations cover costs for ongoing billing operations and customer support, including the costs of MCE’s third-party billing provider. While D.24-05-065 4 See Disposition of MCE AL 63-E, MCE Disadvantaged Communities Green Tariff Program 2022 Power Purchase Agreement Approval.
5 Resolution E-5124, p. 12.
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directs PG&E to provide a cost estimate for implementing an automated billing solution, it is uncertain whether such a solution will be implemented. As such, for the time being, MCE assumes that billing costs will remain as they are now. Regulatory Compliance covers costs for regulatory compliance and related program filings with the Commission. Procurement covers the costs to develop and manage the solicitations for solar resources under the program, ongoing contract management, as well as annual renewable energy credit (REC) retirement and compliance functions. D.24-05-065 removes the Green-e certification requirement, instead ordering program administrators to independently track the retirement of RECs. MCE estimates those costs in the procurement forecast.
Marketing, Education and Outreach (ME&O)
ME&O budgets are split in two categories – (1) MCE labor costs; and (2) MCE direct costs for outreach and material.
3. BUDGET CAPS
Resolution E-4999 establishes a cap of 10% of the total budget for program administration costs and a cap of 4% of the total budget for ME&O costs, to apply beginning with each administrator’s third program year.6 Subsequently, in recognition that these programs may exceed the established caps because of their relatively small size, the time it takes to launch, and other factors, the Commission permitted PAs whose budgets exceed the established caps to submit a rationale supporting the exceedance in their Annual Budget Advice Letters (ABAL).7 The ABAL was elevated from Tier 1 to Tier 2 to allow for additional review of this and other ABAL components.8 The 2026 budget forecast summarized above in Table 1 results in DAC-GT program administration budgets of 9% and ME&O budgets of 1%. As such, MCE does not require an adjustment to the program administration budget cap for DAC-GT for PY 2026.
4. BUDGET RECONCILIATION FOR PY 2024
MCE submitted a budget forecast for PY 2024 as a part of its 2024 Budget Request and Marketing, Education, and Outreach Plan in AL 69-E on April 3, 2023. The table below shows the forecasted and actual costs for PY 2024 per budget line item, as well as the true-up amount that will be carried forward to future program years.
6 Resolution E-4999, p. 27.
7 Resolution E-5125, p. 7.
8 Id.
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Table 2: MCE Budget Reconciliation for PY 2024
Tab Category
Forecast Actual
True-up (Actual -
Forecast) Forecast Actual
True-up (Actual -
Forecast)
1 Generation Cost Delta $ 988,083 $ 561,365 $ (426,718) $ - - $ $ - 2 20% Bill Discount $ 280,035 $ 755,851 $ 475,816 $ - - $ $ - Program Administration
3a Program Management $ 84,050 $ 12,281 $ (71,769) $ 97,150 $ 12,281 $ (84,869) 3b Information Technology $ 30,537 $ 6,240 $ (24,297) $ 19,009 $ 6,240 $ (12,769) 3c Billing Operations $ 76,735 $ 90,991 $ 14,256 $ 34,422 $ 6,141 $ (28,281) 3d Regulatory Compliance $ 7,860 $ 22,365 $ 14,505 $ 7,860 $ 12,991 $ 5,131 3e Procurement $ 26,815 $ 28,100 $ 1,285 $ 31,093 $ 786 $ (30,307) 3f CCA Integration Costs $ - - $ $ - $ - - $ $ -
Subtotal Program Administration $ 225,997 $ 159,976 $ (66,021) $ 189,534 $ 38,439 $ (151,096) Marketing, Education & Outreach
4a Labor Costs $ 21,615 $ 3,220 $ (18,395) $ 59,605 $ 2,260 $ (57,345) 4b Outreach and Material Costs $ 20,000 $ 15,969 $ (4,031) $ - 26,000 $ $ (26,000) Subtotal ME&O $ 41,615 $ 19,189 $ (22,426) $ 85,605 $ 2,260 $ (83,345) Total $ 1,535,730 $ 1,496,382 $ (39,348) $ 275,139 $ 40,698 $ (234,441)
DAC-GT CS-GT
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5. CORRECTION OF MCE AL 79-E 2023 ACTUAL BILL DISCOUNT COSTS While preparing its 2025 Budget Advice Letter, MCE discovered and corrected an inadvertent error in the calculation of the 2023 Actual Bill Discount Cost for the DAC-GT program. MCE AL 79-E incorrectly reported the 2023 Actual Bill Discount Cost as $1,489,780. After correcting the error, MCE’s 2023 Actual Bill Discount Cost is $833,942. The difference in the actual bill discount costs amounts to $655,837.
MCE submits this correction to MCE AL 79-E as a separate line item in its 2026 Budget Request in Section 6.
As the calculation for the 2025 Forecast Bill Discount Cost is based on the 2023 Actual Bill Discount Cost, MCE AL 79-E also overestimates the 2025 Bill Discount Forecast. By design of the DAC-GT program, any unused funds due to this inadvertent overestimation will be returned in next year’s budget advice letter when the Actual 2025 Bill Discount Cost is reconciled with the 2025 Forecast Bill Discount Cost.
6. 2026 BUDGET REQUEST
Based on the budget forecast for PY 2026 presented in Section 2, the budget reconciliation for PY 2024 presented in section 4, and the corrections to MCE AL 79-E presented in Section 5, MCE is requesting a total budget of $1,972,742 for the DAC-GT and CS-GT programs in this budget AL.
Table 3: MCE Budget Request for PY 2026
7. PROGRAM CAPACITY AND ENROLLMENT NUMBERS
MCE reports existing program capacity and customer enrollment numbers as of December 31, 2024, in Table 4 below. In PY 2024, enrolled customers were served with an interim solar resource, as discussed above.
Table 4: Program Capacity and Enrollment Count for DAC-GT and CS-GT for PY 2024 Category DAC-GT CS-GT
Existing program capacity (MW) 4.646 0
Participating customers (#) 3,265 0
DAC-GT CS-GT Total
Budget Carry-over from PY 2024 $ (39,348) $ (234,441) $ (273,789) Budget Forecast for PY 2026 $ - 2,902,368 $ $ 2,902,368 Correction to MCE AL 79-E $ (655,837) - $ $ (655,837)
TOTAL $ 2,207,183 $ (234,441) $ 1,972,742
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In Table 5, MCE reports forecasted capacity and customer enrollment for PY 2026. As noted above, MCE estimates that the dedicated project to serve existing DAC-GT will come online in early 2026. MCE plans to solicit a new project to serve the expanded DAC-GT capacity granted in D.24-05-065, but does not anticipate this project will come online during PY 2026. MCE plans to enroll additional customers under the expanded capacity using an interim resource until a new resource can be procured.
Table 5: Forecasted Program Capacity and Enrollment Count for DAC-GT and CS-GT for PY 2026
Category DAC-GT
Existing program capacity (MW) 4.646
Additional program capacity to be procured (MW) 3.609
Total program capacity (MW) 8.249
Estimated customer enrollment (#) 5,805
Marketing, Education and Outreach Plan for the Disadvantaged Communities Green Tariff Programs for Program Year 2026 Proposed by Marin Clean Energy
TABLE OF CONTENTS
1. PURPOSE AND GOALS .......................................................................................................... 1
2. GUIDING PRINCIPLES .......................................................................................................... 1
3. TARGET AUDIENCE ............................................................................................................. 1
4. ME&O TACTICS AND STRATEGIES ...................................................................................... 3
5. METRICS TRACKING .......................................................................................................... 3
TABLE OF FIGURES
Figure 1. Qualifying Neighborhoods in MCE Service Area for DAC-GT Auto-Enrollment 2 1 1. PURPOSE AND GOALS
MCE will develop and implement a targeted customer marketing, education, and outreach (ME&O) campaign under the Disadvantaged Communities Green Tariff (DAC-GT) program to ensure potential customers in disadvantaged communities (DACs) are aware of the benefits from the program.
MCE will develop and implement a targeted customer marketing, education, and outreach (ME&O) campaign for the DAC-GT program. Eligible customers for DAC-GT will be identified and automatically enrolled in the program by MCE. Hence, no customer recruitment for program participation is required.
MCE’s ME&O strategy for the DAC-GT program has three main goals:
1. Notify DAC-GT customers that their account has been automatically enrolled in the program;
2. Provide information (i.e., FAQs) about the program; and
3. Notify DAC-GT customers if they no longer meet eligibility criteria for the program (i.e., moved, installed solar, or no longer enrolled in CARE or FERA) and provide instructions on how to continue their program participation (if applicable).
2. GUIDING PRINCIPLES
MCE is committed to developing diverse and culturally appropriate communication strategies to ensure that stakeholders can participate in decisions and actions that impact their communities. As such, MCE commits to the following guiding principles throughout the ME&O engagement process for the DAC-GT program. MCE aims to:
● Achieve diverse and meaningful engagement that reflects the demographics of DAC communities in MCE’s service area to ensure equitable outreach across race, income and age barriers;
3. TARGET AUDIENCE
For the DAC-GT program, in 2021 MCE automatically enrolled eligible customers that live in one of the top 10% of DAC census tracts statewide that are in MCE’s service area, as defined by CalEnviroScreen 3.0. Priority was given to customers who made an effort to pay, as defined by at least 4 full or partial payments in the preceding 8 months. With the expanded capacity of the DAC-GT program, MCE will enroll additional customers as identified by CalEnviroScreen 4.0 in the following order:
1. Customers who live in one of the top 25% of DAC census tracts and are enrolled in the Arrearage Management Program (category 1);
2 2. Customers who live in one of the top 25% of DAC census tracts and are in arrears (category 2); and
3. All other customers who live in one of the top 25% of DAC census tracts (category 3).
If there is insufficient program capacity to enroll all customers in a category under the DAC-GT program, customers from the eligible category will be selected for program enrollment using the categories listed above. MCE will monitor program attrition on a monthly basis and enroll additional customers from the waitlist as appropriate.
Figure 1 below shows the list of eligible census tracts for DAC-GT auto-enrollment.
Figure 1. Qualifying Neighborhoods in MCE Service Area for DAC-GT Auto-Enrollment 75% CalEnviroScreen 4.0 Score
Census Tract California
County ZIP
Nearby City
(to help approximate
location only)
6013305000 Contra Costa 94509 Antioch
6013306002 Contra Costa 94509 Antioch
6013306003 Contra Costa 94509 Antioch
6013307102 Contra Costa 94509 Antioch
6013306002 Contra Costa 94509 Antioch
6013327000 Contra Costa 94520 Concord
6013336201 Contra Costa 94520 Concord
6013309000 Contra Costa 94565 Pittsburg
6013310000 Contra Costa 94565 Pittsburg
6013311000 Contra Costa 94565 Pittsburg
6013312000 Contra Costa 94565 Pittsburg
6013314102 Contra Costa 94565 Pittsburg
6013314103 Contra Costa 94565 Pittsburg
6013314104 Contra Costa 94565 Pittsburg
6013314200 Contra Costa 94565 Pittsburg
6013314103 Contra Costa 94565 Pittsburg
6013314102 Contra Costa 94565 Pittsburg
6013365002 Contra Costa 94801 Richmond
6013375000 Contra Costa 94801 Richmond
6013376000 Contra Costa 94801 Richmond
6013377000 Contra Costa 94801 Richmond
6013379000 Contra Costa 94804 Richmond
6013380000 Contra Costa 94804 Richmond
6013381000 Contra Costa 94804 Richmond
6013382000 Contra Costa 94804 Richmond
6013358000 Contra Costa 94572 Rodeo
3 6013366002 Contra Costa 94806 San Pablo
6013368001 Contra Costa 94806 San Pablo
6013368002 Contra Costa 94806 San Pablo
6013369001 Contra Costa 94806 San Pablo
6013392200 Contra Costa 94806 San Pablo
6095250701 Solano 94590 Vallejo
6095250801 Solano 94592 Vallejo
6095250900 Solano 94590 Vallejo
6095251000 Solano 94590 Vallejo
6095251600 Solano 94590 Vallejo
6095251802 Solano 94589 Vallejo
6095251803 Solano 94589 Vallejo
6095251901 Solano 94589 Vallejo
4. ME&O TACTICS AND STRATEGIES
MCE will continue to use the communications and media content originally developed to promote DAC-GT, including direct mailers, email, and a webpage.
5. METRICS TRACKING
MCE uses multiple tactics for ME&O. Accordingly, a variety of metrics will be used to evaluate the effectiveness of each effort. The primary measure of effectiveness is the number of customers reached, which can be measured by the:
● Number of customers enrolled based on auto-enrollment criteria; ● Number of customers found to be ineligible for the program based on eligibility criteria; ● Number of customers opting to cancel program participation; and ● Number of customers to be enrolled from the waitlist based on the capacity provided through the total sum of all aforementioned attributes.