Board of Directors
Chair: Alice Dowdin Calvillo
Vice Chair: Greg Janda
City of Auburn
Alice Dowdin Calvillo
Sandra Amara, Alternate
City of Colfax
Sean Lomen
Kim Douglass, Alternate
County of El Dorado
Lori Parlin
Brian Veerkamp, Alternate
City of Grass Valley
Tom Ivy
Jan Arbuckle, Alternate
City of Lincoln
Richard Pearl
John Reedy, Alternate
Town of Loomis
David Ring
Danny Cartwright, Alternate
Nevada City
Gary Petersen
Lou Ceci, Alternate
County of Placer
Anthony DeMattei
Suzanne Jones
Bonnie Gore, Alternate
City of Placerville
Ryan Carter
David Yarbrough, Alternate
City of Rocklin
Greg Janda
David Bass, Alternate
Pioneer Community Energy
Board of Directors
July 10, 2025
SPECIAL MEETING
2:45 PM
Pioneer Community Energy Board Room
2510 Warren Drive, Suite B, Rocklin, CA 95677
REMOTE LOCATION:
Nevada City – City Hall, Wetherall Conference Room
317 Broad Street, Nevada City, CA 95959
This special meeting will convene in person at the address printed above, be accessible on the Zoom platform at the following link:
https://us06web.zoom.us/j/89020017279;
and live streamed for viewing on the Pioneer website:
https://pioneercommunityenergy.org/about-us/meetings-and-agendas/.
Members of the public may participate in person or by remote audio/visual access.
Those who participated remotely and wish to comment should be prepared to use the Zoom platform via computer or telephone. Public comment will be opened for each agenda item in sequence.
How to Participate Using Zoom
You can join the meeting using the following link:
https://us06web.zoom.us/j/89020017279.
When you join the meeting, you will be muted by default. To inform the Clerk that you would like to make a public comment, you will use the “Raise Hand” feature.
Public Comment via Computer or Smartphone
If you would like to make a comment, you will use the “Raise Your Hand” feature.
Please note that you should only raise your hand during the item to which you will comment. Instructions for using the “Raise Hand” feature when using a computer or mobile device can be found at the link:
https://support.zoom.us/hc/en-us/articles/205566129-Raising-your-hand-in-a-webinar Public Comment via telephone (Audio Only Option)
1. Dial 1 (699) 900-6833
2. When asked for the meeting ID, enter 890 2001 7279#
3. When asked for your participant ID, press # to continue.
You will be muted by default. To inform the Clerk that you would like to make a comment, during each agenda item, dial *9 to “Raise your hand.” When it is your turn to speak, the Clerk will identify you by the last three digits of your phone number; at that time, dial *6 to unmute yourself and state your name and comment for the record. Please note that you should only raise your hand during the item to which you will comment.
Plf)NEER
COMMUNITY ENERGY
I. GENERAL ADMINISTRATIVE FUNCTION – PART 1
A. CALL TO ORDER
1. Roll Call
B. PRESENTATIONS BY THE PUBLIC ON MATTERS NOT ON THE AGENDA WITHIN THE
JURISDICTION OF THE BOARD
Persons may address the Board on items not on this agenda. Please limit comments to 3 minutes per person. According to State Law (the Brown Act), items must first be noticed on the agenda before any discussion or action. The Board is prohibited from discussing issues not on the agenda brought to them at this time.
C. ADJOURN TO CLOSED SESSION
Conference with Real Property Negotiator - Government Code §54956.8 Property: 2540 Warren Drive, Suite C, Rocklin, California, 95677.
Agency Negotiator: Brad Koehn, Director of Finance & Administration.
Negotiating Parties: Tricorp Group, Inc. and Pioneer Community Energy.
Under Negotiation: Price and Terms of Payment.
D. RECONVENE OPEN SESSION
1. Roll Call
E. PUBLIC REPORT OF CLOSED SESSION
F. AGENDA REVIEW
II. CONSENT AGENDA
1) APPROVAL OF THE CONSENT AGENDA
All items on the Consent Agenda have been recommended for approval by the Chief Executive Officer.
All Consent items will be approved by a single vote. Anyone may ask to address Consent items prior to the Board acting, and the item may be moved for discussion. a) ADMINISTRATION
Approve the minutes of the June 19, 2025 regular meeting. (ECKERT) b) FINANCE & ADMINISTRATION
Receive Fiscal Year 2024-25 Draft Monthly Financial Reports through May 2025. (KOEHN) c) PROCUREMENT
Adopt Resolution approving Amendment to Resolution 2025-11 to authorize the Chief Executive Officer to execute individual Power Purchase Agreements, contracts, or confirmations not exceeding
1.5% of Pioneer’s annual procurement budget as a maximum annual notional amount, together witha maximum 20-year term. (KANG)
III. REGULAR AGENDA
2) PRESENTATION
Dr. Ahmad Faruqui (DISCUSSION-ECKERT)
Recommendation: Receive a presentation from our guest speaker, Dr. Ahmad Faruqui, on a variety of topics impacting California’s electricity markets.
3) COMMUNICATIONS/PROCUREMENT
Update on Expansion Efforts and Planning for October 2027 Service Launch (DISCUSSION-KANG/STASSI-VANACORE)
Recommendation: Receive an update on expansion efforts and an overview of planning for an October 2027 service launch.
4) PROCUREMENT
Update on Power Markets and Energy Procurement (DISCUSSION-KANG) Recommendation: Receive an update on power markets and energy procurement. 5) ADMINISTRATION
Adopt Resolution Honoring the Memory of Dan Karleskint (ACTION-ECKERT) Recommendation: Adopt Resolution honoring the memory of Director Dan Karleskint for his contributions to the success of Pioneer Community Energy and his outstanding service to the community.
IV. GENERAL ADMINISTRATIVE FUNCTION – PART 2
A. BOARD MEMBER COMMUNICATIONS
B. CHIEF EXECUTIVE OFFICER COMMUNICATIONS
C. ITEMS FOR INFORMATION
1. Glossary of Terms
D. ADJOURNMENT
Upcoming Meeting of the Board:
September 18, 2025
Accommodations
Pioneer Community Energy is committed to ensuring that persons with disabilities are provided with the resources to participate fully in its public meetings. If you are hearing impaired, we have listening devices available. If you require additional disability-related modifications or accommodations, including auxiliary aids or services, please contact the Clerk of the Board. If requested, the agenda shall be provided in appropriate alternative formats for persons with disabilities. All requests must be in writing and must be received by the Clerk five business days prior to the scheduled meeting for which you are requesting accommodation. Requests received after such time will be accommodated only if time permits.
Affidavit of Posting
I, Teresa Willock, Board Secretary, declare under penalty of perjury that the foregoing agenda for the July 10, 2025 special meeting of the Pioneer Community Energy Governing Board was posted and available for public review on July 8, 2025 at the offices of Pioneer Community Energy, 2510 Warren Drive, Suite B, Rocklin, CA 95677; at remote location Nevada City – City Hall, Wetherall Conference Room, 317 Broad Street, Nevada City, CA 95959; and, was on the Pioneer website at: https://pioneercommunityenergy.org/about-us/meetings-and-agendas/.
All public materials related to an item on this agenda submitted to the Governing Board after distribution of the agenda packet are also made available for public inspection on Pioneer’s website at:
https://pioneercommunityenergy.org/about-us/meetings-and-agendas/. Any document provided at the meeting by staff or by the public will be provided by the Board Clerk upon request by phone at (916) 758-8946, or by email at: [email protected].
DRAFT
PIONEER COMMUNITY ENERGY
GOVERNING BOARD
MINUTES
June 19, 2025
REGULAR MEETING
Entry No. 1
Heard General Administrative Functions – Part I
Call to Order
Pioneer Community Energy Governing Board met in regular session at 3:00 PM on June 19, 2025. The Members convened in person and the meeting was accessible to the public at Pioneer Community Energy, 2510 Warren Drive, Suite B, Rocklin, California 95677; the meeting was accessible for viewer participation on the Zoom platform at the following link: https://us06web.zoom.us/j/89020017279; and, was live streamed for viewing on the Pioneer website:
https://pioneercommunityenergy.org/about-us/meetings-and-agendas/.
Roll Call
Present: City of Auburn (Dowdin Calvillo), County of El Dorado (Parlin), City of Grass Valley (Ivy), City of Lincoln (Pearl), Town of Loomis (Ring), Nevada City (Petersen), City of Placerville (Carter), City of Rocklin (Janda).
Absent: City of Colfax (Lomen), County of Placer (DeMattei), County of Placer (Jones).
Chair Dowdin Calvillo presided over the meeting.
Agenda Review
Reviewed and made no revision to the meeting agenda.
Chair Dowdin Calvillo requested for the July 17, 2025 Board of Directors meeting to be rescheduled for July 10, 2025; and, the Board of Directors agreed by consensus.
Public Comment
There were no comments from members of the public on items not listed on this agenda.
Entry No. 2
Acted on the Consent Agenda as follows:
Approved the minutes of the May 15, 2025 regular meeting as amended.
Received Fiscal Year 2024-25 Draft Monthly Financial Reports through April 2025.
Adopted Resolution 2025-19 approving and authorizing the Chief Executive Officer to execute Amendment No. 2 with Greenlite Lighting Corp. USA, authorizing an additional $500,000 for LED Discount Lighting Program Services resulting in a not-to-exceed amount of $1,112,400.
Adopted Resolution 2025-20 approving and authorizing the Chief Executive Officer to execute a five-year Agreement with Hall Energy Law PC for Commercial Legal Support in an amount not to exceed $600,000.
Adopted Resolution 2025-21 approving and authorizing the Chief Executive Officer to execute a two-year Agreement with Pacific Energy Advisors, Inc., for Technical Support in an amount not to exceed $1,040,572.
ITEM 1a
DRAFT – June 19, 2025 – page 2
Adopted Resolution 2025-22 approving and authorizing the Chief Executive Officer to execute an Amendment authorizing an additional $224,875 to an Agreement with cQuant.IO Inc., for Portfolio Optimization and Slice-of-Day Compliance Requirements support in an amount not to exceed $454,875.
Adopted Resolution 2025-23 authorizing the Chief Executive Officer to execute an agreement with Maher Accountancy for Accounting Services for a contract amount of $207,200 for a term of one year.
Adopted Resolution 2025-24 authorizing the Chief Executive Officer to execute an Amendment to the Agreement with Colantuono Highsmith Whatley, PC for an increase of $200,000 for a total contract amount not to exceed $350,000.
Adopted Resolution 2025-25 approving the job descriptions for the Customer Care Specialist and the Community Outreach Specialist.
MOTION: Parlin/Pearl. Vote: 8:0:3.
Ayes: Carter, Dowdin Calvillo, Ivy, Janda, Parlin, Pearl, Petersen, Ring.
Absent: DeMattei, Jones, Lomen.
Entry No. 3
California Independent System Operator – Summer Readiness Received presentation from the California Independent System Operator (CAISO) on Summer Readiness.
Chair Dowdin Calvillo expressed appreciation for the work in this area accomplished by CAISO.
Staff provided clarification regarding “Slice-of-Day” to be the requirements set for Community Choice Associations and reporting by Pioneer on what is in Pioneer’s portfolio to meet those requirements.
Nat Brown, CAISO Senior Customer Readiness Trainer, provided clarification that the management of emergency situations, reliability, and handling increased loads is in advance and not reactive; expecting growth on demand, reducing load to manage higher loads, and, the added ability to do more with programs such as GridGen and micro powerplants introduced.
Director Jones joined the meeting following this presentation.
Entry No. 4
Recommended Fiscal Year 2025-26 Budget
Adopted Resolution 2025-26 approving the recommended Fiscal Year 2025-26 Budget.
Staff confirmed no changes to the budget had been made since the previous meeting and that the five-year forecast only reflects the current load territory. Further clarified that the increased cost of power was expected; and, the budget is balanced.
Chair Dowdin Calvillo expressed appreciation for staff.
MOTION: Petersen/Jones. Vote: 9:0:2.
Ayes: Carter, Dowdin Calvillo, Ivy, Janda, Jones, Parlin, Pearl, Petersen, Ring.
Absent: DeMattei, Lomen.
Entry No. 5
Cash Reserves Policy
Adopt Resolution increasing the days of liquidity target and updating the Cash Reserves Policy.
DRAFT – June 19, 2025 – page 3
Staff recommended increasing the cash liquidity to 270 days and that the amount exceeding the reserves target may be returned to customers via bill credits.
Discussion regarding if number of days is set too high, it may bring suspicion; so, better to plan ahead and move ahead cautiously.
Director Janda supported growing the target with incremental raises to reach the set days of liquidity comfortably; then, set higher if not able to reach that amount.
MOTION: Janda.
Moved to increase the days of liquidity target to 240 days.
Motion failed with no second to the motion received.
Chair Dowdin Calvillo voiced her support to raise the liquidity target to 270.
Director Ivy was comfortable with a liquidity target of 270; and, inquired if Pioneer can expect better rates and continue to grow.
Chief Executive Director Eckert suggested a liquidity target of 260+; and, informed the Board about the Power Charge Indifference Adjustment (PCIA) going down in 2026 and is expected to be better in 2027 and 2028; and, the inverse relationship between PCIA and power market is also going down.
Chair Dowdin Calvillo asked the Board if they would be comfortable moving the cash liquidity target from the current 240 days to 255 or 260 days.
MOTION: Ivy.
Moved to increase the days of liquidity target but to separate the customer bill credits from the liquidity target.
Motion failed with no second to the motion received.
Continued discussion regarding the days of liquidity target.
Director Carter voiced his support for 270 days of liquidity and that it seems to be safer heading into expansion; and suggested the liquidity target be an annual consideration.
Chief Executive Officer Eckert confirmed to the Board that the annual Rates discussion includes the Reserves rate.
Director Parlin expressed that 240 days of liquidity is realistic; and is cautious going into expansion.
Director Ring voiced his support for 270 days of liquidity; and, suggested that this be discussed along with the annual budget. Then, corrections could be made as needed.
Director Pearl voiced his support for 270 days of liquidity; and, commented that it was modest stretch but wondered how Standard & Poor’s views it.
Director Petersen voiced his support for 270 days of liquidity then revisit if necessary; and, commented that an “A” rating is important, but we are about to double our members and load; an “A” rating should not be the driver.
DRAFT – June 19, 2025 – page 4
Director Janda suggested setting 240 days of liquidity for 8-9 months; then, set a range of 240-270 prior to offering customer bill credits.
MOTION: Dowdin Calvillo.
Adopt Resolution increasing the cash liquidity target to 270 days with permissive language regarding customer bill credits.
Adopted Resolution 2025-27 increasing the days of liquidity target and updating the Cash Reserves Policy as amended.
MOTION: Dowdin Calvillo/Pearl. Vote: 7:2:2.
ROLL CALL: Carter, Dowdin Calvillo, Ivy, Jones, Pearl, Petersen, Ring.
Noes: Janda, Parlin.
Absent: DeMattei, Lomen.
Director Petersen excused himself from the meeting at 4:36 PM.
Entry No. 6
Printing Services Agreement
Adopted Resolution 2025-28 authorizing the Chief Executive Officer to execute an agreement with Sierra Office Systems and Products, Inc. dba API-Marketing for Printing and Mail Services for an amount not to exceed $500,000 for a one-year term with an option to extend up to two additional one-year terms.
MOTION: Parlin/Jones. Vote: 8:0:3.
ROLL CALL: Carter, Dowdin Calvillo, Ivy, Janda, Jones, Parlin, Pearl, Ring.
Absent: DeMattei, Lomen, Petersen.
Entry No. 7
Overview of the Microgrid Incentive Program
Received an overview of Pacific Gas & Electric’s Microgrid Incentive Program and an update on Pioneer Community Energy’s participation in that program.
Staff clarified that Pioneer is only a facilitator for member agencies contacting the developers.
Director Parlin informed the Board that PG&E had installed a microgrid in Georgetown for resilience during Public Safety Power Shutoff (PSPS) events only and now there are not too many PSPS events; and, suggested Pioneer could use this program to get more started in the rural areas and bring about goodwill with customers in El Dorado County.
Entry No. 8
Item 7, Update on Power Markets and Energy Procurement, will be continued to a future meeting.
Entry No. 9
Heard General Administrative Function – Part II
Board Member Communications
There were no items to report.
Chief Executive Officer Communications
Chief Executive Officer Eckert introduced Linda Praseudsuk, Senior Finance Analyst, as our newest team member; and, announced the addition of Brooke Sardella to the Communications Division through the summer internship program.
DRAFT – June 19, 2025 – page 5
Chief Executive Officer Eckert announced that Pioneer received certification from the California Public Utilities Commission (CPUC) authorizing our expansion into thirteen new communities with service beginning in October 2027.
Chief Executive Officer Eckert informed the Board that we are nearing the conclusion of our annual cash-out for NEM accounts that over-generated in the past year with approximately 9,000 customers receiving cash-outs totaling $1.2 million and more than 2,600 customers receiving a bill credit due to their cash-out being less than $25.00.
Items for Information
Received the Glossary of Terms.
Adjournment
The meeting adjourned at 5:01 PM.
Staff Report – Item 1b
To: The Governing Board
From: Eric Acedo, Sr. Financial Analyst
Item 1b: Receive Fiscal Year 2024-25 Draft Monthly Financial Reports Through May 2025 Date: 7/10/2025
RECOMMENDATION
Receive Fiscal Year 2024-25 Draft Monthly Financial Reports through May 2025.
BACKGROUND
The Year-To-Date (YTD) financial reports are produced by Maher Accountancy for Board member and management review. Although these reports are unaudited, they provide the most up-to-date financial data for Pioneer Community Energy. The mPOWER program accepted its last application August 2021 and mPOWER activity is now limited to administering the outstanding mPOWER Bonds. Financials for the mPOWER program will be included in the audited year-end reports. For May 2025, the financial reporting package includes the following reports for the CCA Fund only:
Statement of Net Position (Balance Sheet) – Accounting of Assets, Liabilities and Net Position as of the reporting period end date for the CCA program. Statement of Revenues, Expenses, and Changes in Net Position (P&L) – Accounting of all revenues, expenses, and changes in net position on a YTD basis through the reporting period end date for the CCA program.
Budgetary Comparison Schedule (Budget to Actuals) – Comparison of budget to actuals on a YTD basis through the reporting period end date for the CCA program.
STRATEGIC PLAN
Strategic Priority: Be Fiscally Strong and Resilient
FISCAL IMPACT
The YTD change in net position through eleven months of the fiscal year is $43.4 million.
ATTACHMENTS
1. Financial Reports through May 31, 2025
Plf)NEER
COMMUNITY ENERGY
1 ACCOUNTANTS’ COMPILATION REPORT
Management
Pioneer Community Energy
Management is responsible for the accompanying financial statements of the CCA Fund of Pioneer Community Energy (a California Joint Powers Authority) which comprise the statement of net position as of May 31, 2025, and the related statement of revenues, expenses, and changes in net position for the eleven months then ended in accordance with accounting principles generally accepted in the United States of America. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the accompanying statements nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, we do not express an opinion, conclusion, nor provide any assurance on these financial statements.
Management has elected to omit substantially all of the disclosures and the statement of cash flows required by accounting principles generally accepted in the United States of America in these interim financial statements. Pioneer Community Energy’s annual audited financial statements include the note disclosures and statement of cash flows omitted from these interim statements. If the omitted disclosures and the statement of cash flows were included in these financial statements, they might influence the user’s conclusions about Pioneer Community Energy’s financial position, results of operations, and cash flows. Accordingly, these financial statements are not designed for those who are not informed about such matters.
We are not independent with respect to Pioneer Community Energy because we performed certain accounting services that impaired our independence.
Maher Accountancy
San Rafael, CA
July 2, 2025
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com MAHER
ACCOUNTANCY
CCA Program
ASSETS
Current assets
Cash and cash equivalents 39,484,297 $
Investments 122,198,540
Accounts receivable, net of allowance 17,207,569
Accrued revenue 8,462,705
Other receivables 668,454
Interest receivable 540,000
Prepaid expenses 7,443,239
Deposits 1,016,692
Total current assets 197,021,496
Noncurrent assets
Capital assets, net of depreciation and amortization 1,114,856 Deposits 792,401
Total noncurrent assets 1,907,257
Total assets 198,928,753
LIABILITIES
Current liabilities
Accrued cost of electricity 14,698,091
Accounts payable 728,026
Other accrued liabilities 491,085
Lease liability 124,704
Note payable 875,227
Interest payable 5,482
Deposits 1,470,000
Total current liabilities 18,392,615
Noncurrent liabilities
Lease liability 779,373
Note payable 778,331
Supplier security deposits 282,000
Total noncurrent liabilities 1,839,704
Total liabilities 20,232,319
NET POSITION
Net investment in capital assets 210,779
Unrestricted net position 178,485,655
Total net position 178,696,434 $
PIONEER COMMUNITY ENERGY
STATEMENT OF NET POSITION
As of May 31, 2025
CCA PROGRAM
See accountants' compilation report. 2
CCA Program
OPERATING REVENUES
Electricity sales, net 210,677,950 $
Other income 13,056
Total operating revenues 210,691,006
OPERATING EXPENSES
Cost of electricity 161,612,275
Contract services 5,672,768
Staff compensation 3,744,107
Other operating expenses 1,604,537
Depreciation and amortization 172,249
Total operating expenses 172,805,936
Operating income (loss) 37,885,070
NONOPERATING REVENUES (EXPENSES)
Investment income 5,743,088
Interest and financing expense (149,443)
Nonoperating revenues (expenses), net 5,593,645
NET POSITION
Change in net position 43,478,715
Net position at beginning of period 135,217,719
Net position at end of period 178,696,434 $
Eleven Months Ended May 31, 2025
AND CHANGES IN NET POSITION
STATEMENT OF REVENUES, EXPENSES
CCA PROGRAM
PIONEER COMMUNITY ENERGY
See accountants' compilation report. 3
Participation Rates – May 2025
Participation Rate March 2025 April 2025 May 2025 May 2024 AUBURN INC 85.35% 85.52% 85.61% 85.54% COLFAX INC 87.67% 87.86% 87.96% 88.08% GRASS VALLEY INC 96.42% 96.52% 96.59% 97.71% LINCOLN INC 82.60% 82.65% 82.73% 82.84% LOOMIS INC 86.91% 87.03% 87.13% 87.56% NEVADA CITY INC 97.70% 97.87% 97.75% 98.39% PLACERVILLE INC 85.27% 85.61% 85.47% 85.66% ROCKLIN INC 90.05% 90.26% 90.15% 90.69% UNINC EL DORADO CO 79.51% 79.68% 79.74% 79.99% UNINC PLACER CO 84.66% 84.67% 84.74% 84.81% Grand Total 84.13% 84.25% 84.29% 84.56%
COMMUNITY ENERGY
Total Pioneer Customers(# of Accounts)
175,000 174,486
173,961
174,000 173,534
173,000 172,000 171,000 170,000 169,181 169,000 I 168,000 167,000 166,000 May2024 March2025 April2025 May 2025
1 ACCOUNTANTS’ COMPILATION REPORT
Board of Directors
Pioneer Community Energy
Management is responsible for the accompanying special purpose budgetary comparison schedule for the CCA Program of Pioneer Community Energy, a California Joint Powers Authority, for the eleven months ended May 31, 2025, and for determining that the budgetary basis of accounting is an acceptable financial reporting framework. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the accompanying statement nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, we do not express an opinion, a conclusion, nor provide any assurance on this special purpose budgetary comparison statement.
The special purpose statement is prepared in accordance with the budgetary basis of accounting, which is a basis of accounting other than accounting principles generally accepted in the United States of America. This report is intended for the information of the Board of Directors of Pioneer Community Energy.
Management has elected to omit substantially all of the note disclosures required by accounting principles generally accepted in the United States of America in these interim financial statements.
Pioneer Community Energy’s annual audited financial statements include the note disclosures omitted from these interim statements. If the omitted disclosures were included in these financial statements, they might influence the user’s conclusions about Pioneer Community Energy’s financial position, results of operations, and cash flows. Accordingly, these financial statements are not designed for those who are not informed about such matters.
We are not independent with respect to Pioneer Community Energy because we performed certain accounting services that impaired our independence.
Maher Accountancy
San Rafael, CA
July 2, 2025
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com MAHER
ACCOUNTANCY
2024/25 YTD
Amended
Budget
2024/25 YTD
Actual
2024/25 YTD
Variance
(Under) Over
2024/25
YTD
Actual/
Budget %
2024/25
Amended Budget
2024/25
Amended
Budget
Remaining
ENERGY REVENUES
Energy Sales $ 214,529,000 $ 213,498,163 $ (1,030,837) 100% $ 235,801,000 $ 22,302,837 Green100 Sales 182,000 62,862 (119,138) 35% 200,000 137,138 Congestion Revenue Rights and Battery Optimization 9,238,095 10,669,688 1,431,592 115% 10,000,000 (669,688) Less Uncollectible Accounts (2,898,000) (2,883,074) 14,926 99% (3,186,000) (302,926) Total Operating Revenues 221,051,095 221,347,639 296,543 242,815,000 21,467,361
ENERGY EXPENSES
Power Supply 187,823,258 172,281,963 (15,541,295) 92% 208,976,000 36,694,038 OPERATING MARGIN 49,065,676 33,227,837 15,837,839 33,839,000 (15,226,676)
OPERATING EXPENSES
Administration
Compensation 740,913 642,766 (98,146) 87% 816,385 173,619 Contract services 291,798 155,863 (135,935) 53% 318,325 162,462 Operating expenses 921,121 702,420 (218,701) 76% 941,796 239,376 Total Administration expenses 1,953,832 1,501,050 (452,782) 77% 2,076,506 575,456 Finance
Compensation 980,153 860,650 (119,502) 88% 1,061,050 200,400 Contract services 544,988 323,370 (221,618) 59% 591,000 267,630 Operating expenses 334,225 240,477 (93,748) 72% 357,700 117,223 Total Finance expenses 1,859,365 1,424,497 (434,869) 77% 2,009,750 585,253 Power Procurement
Compensation 954,162 663,313 (290,849) 70% 1,027,592 364,279 Contract services 2,947,852 1,865,880 (1,081,972) 63% 3,143,538 1,277,658 Operating expenses 257,089 193,439 (63,650) 75% 291,500 98,061 Total Power Procurement expenses 4,159,103 2,722,632 (1,436,470) 65% 4,462,630 1,739,998 Customer Care
Compensation 437,752 430,599 (7,152) 98% 489,002 58,403 Contract services 2,693,333 2,660,733 (32,600) 99% 2,920,000 259,267 Operating expenses 196,854 141,535 (55,319) 72% 214,750 73,215 Total Customer Care expenses 3,327,939 3,232,868 (95,072) 97% 3,623,752 390,884 Marketing & Communications
Compensation 680,117 525,716 (154,401) 77% 741,946 216,230 Contract services 388,875 78,228 (310,647) 20% 420,000 341,772 Operating expenses 579,571 152,512 (427,059) 26% 646,350 493,838 Total Marketing expenses 1,648,563 756,456 (892,107) 46% 1,808,296 1,051,840 Legislative & Regulatory
Compensation 500,984 418,420 (82,563) 84% 553,670 135,250 Contract services 349,140 211,664 (137,476) 61% 377,807 166,143 Operating expenses 7,608 9,278 1,669 122% 8,300 (978)
Total Legislative expenses 857,732 639,363 (218,369) 75% 939,777 300,414 Programs
Compensation 268,900 185,777 (83,122) 69% 293,345 107,568 Contract services 1,279,506 - (1,279,506) 0% 1,456,341 1,456,341 Operating expenses 1,750,655 475,653 (1,275,002) 27% 1,909,805 1,434,152 Total Programs expenses 3,299,061 661,430 (2,637,630) 20% 3,659,491 2,998,061 Total Operating Expenses 17,105,595 10,938,295 (6,167,300) 64% 18,580,202 7,641,907
NON-OPERATING REVENUES (EXPENSES)
Investment gains (losses) 2,153,250 5,743,088 3,589,838 2,871,000 (2,872,088) Miscellaneous income - 13,056 13,056 - (13,056)
Term Loan Debt Service (870,833) (836,796) 34,038 96% (950,000) (113,204) Additional Term Loan Principal (2,100,000) (2,100,000) - (2,100,000) - Line/Letter of Credit Fees (750,000) (262,209) 487,791 35% (750,000) (487,791) Financial Security Requirement (800,000) - 800,000 0% (800,000) (800,000) Nonoperating revenues (expenses), net (2,367,583) 2,557,139 4,924,722 (1,729,000) (4,286,139) Total Expenses and Non-Operating Activity 207,296,436 180,663,119 (26,633,317) 229,285,202 48,622,084 Contribution to/(from) Reserves 13,754,659 $ 40,684,520 $ 26,929,861 $ 13,529,798 $ (27,154,722) $
BUDGETARY COMPARISON SCHEDULE
Eleven Months Ended May 31, 2025
PIONEER COMMUNITY ENERGY
CCA PROGRAM
397934.1 Page 1 of 2
Staff Report – Item 1c
To: The Governing Board
From: Sam Kang, Chief Operating Officer
Item 1c: Adopt Resolution Approving Amendment to Resolution 2025-11 and the Energy Risk Management Policy to Authorize the Chief Executive Officer to Execute Individual Power Purchase Agreements, Contracts, or Confirmations not Exceeding 1.5% of Pioneer’s Annual Procurement Budget as a Maximum Annual Notional Amount, together with a Maximum 20-year term
Date: 7/10/2025
RECOMMENDATION
Adopt Resolution approving Amendment to Resolution 2025-11 to Authorize the Chief Executive Officer (“CEO”) to execute individual Power Purchase Agreements (“PPAs”), Contracts, or Confirmations not exceeding 1.5% of Pioneer’s annual procurement budget as a maximum annual notional amount, together with a maximum 20- year term.
BACKGROUND
As a load-serving entity, Pioneer Community Energy (“Pioneer”) procures energy for its customers in its ordinary course of business. In establishing guidelines for signatory authority for those contracts, the Pioneer Board most recently approved Resolution 2025-11 that authorized the CEO or designee to execute long-term (more than five years) power purchase agreements, contracts, and confirmations after receiving the advice and recommendation from the Energy Procurement Review Committee (“EPRC”), and subject to the written approval of: 1) General Counsel, and 2) Pioneer’s outside counsel specializing in power transactions and power contract law.
Since 2021, when the Pioneer Board delegated similar authority to the CEO for PPAs of five years or more, Pioneer has been actively developing programs with extremely low notional values that still require the advice and recommendation of the EPRC, which has become inefficient due to the process. This topic was discussed in the EPRC on October 9, 2024, as it was also considering a contract with a program vendor, and the EPRC directed staff to bring their recommendation of the modification as presented herein to the Board for approval.
ANALYSIS & DISCUSSION
New programs with low notional values are constantly being introduced to Pioneer’s Board for approval, but the corresponding contracts that need to be executed with the program vendor still have to go through the approval process and receive the advice and recommendation of the EPRC. Some examples include Participate Energy, Ice Energy, and the recently approved feed-in tariff. The programs may generate energy, renewable energy certificates, and/or resource adequacy (“RA”), or may also lower RA requirements through load shifting. The expected range of notional values for potential projects and programs on an annual basis together with their percentage of the annual budget are in the following tables under the current procurement budget and expansion procurement budget.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: X Agenda Date: 5/15/2025
All potential resource types known are listed here to capture and illustrate potential capacity up to approximately
1.5% of the budget.
To facilitate more efficient approvals of PPAs with extremely small notional values, it is recommended that the Board authorize the Chief Executive Officer or designee to execute individual Power Purchase Agreements, contracts, or confirmations not exceeding 1.5% of Pioneer’s annual procurement budget as a maximum annual notional amount, together with a maximum 20-year term, without the need for EPRC advice and consideration.
The proposed resolution would grant such authority and update Pioneer’s Energy Risk Management Policy accordingly.
STRATEGIC PLAN
The recommendation supports the Operational Optimization goal.
FISCAL IMPACT
None.
ATTACHMENTS
1. Resolution to Approve Amendment to Resolution 2025-11 and the Energy Risk Management Policy to Authorize the Chief Executive Officer to Execute Individual Power Purchase Agreements, Contracts, or Confirmations not Exceeding 1.5% of Pioneer’s Annual Procurement Budget as a Maximum Annual Notional Amount, together with a Maximum 20-year term
For Exception with Expansion Annual Budget $ 450,000,000 Project MW Annual MWh $/MWh Annual Notional % of Annual Procurement Budget Biomass Brownfield 6 48,000 $135 $6,480,000 1.44%
Biomass Greenfield 4 32,000 $200 $6,400,000 1.42%
Standalone Solar 40 120,000 $55 $6,600,000 1.47%
Solar + BESS 10 53,180 $134 $7,126,120 1.58%
Wind 30 71,220 $90 $6,409,800 1.42%
Hydro 10 73,000 $85 $6,205,000 1.38%
Project MW Annual MWh $/kW-mo Annual Notional
Standalone BESS 30 43,800 19.00 $ $6,840,000 1.52%
Ice Energy 50 731,600 11.00 $ $6,600,000 1.47%
For Exception Annual Budget $ 225,000,000
Project MW Annual MWh $/MWh Annual Notional % of Annual Procurement Budget Biomass Brownfield 3 24,000 $135 $3,240,000 1.44%
Biomass Greenfield 2 16,000 $200 $3,200,000 1.42%
Standalone Solar 20 60,000 $55 $3,300,000 1.47%
Solar + BESS 5 26,590 $134 $3,563,060 1.58%
Wind 15 35,610 $90 $3,204,900 1.42%
Hydro 5 36,500 $85 $3,102,500 1.38%
Project MW Annual MWh $/kW-mo Annual Notional
Standalone BESS 15 21,900 19.00 $ $3,420,000 1.52%
Ice Energy 25 365,800 11.00 $ $3,300,000 1.47%
1c 7/10/2025
I
f t t t
I I I I
I I I I
397935.1
Before the Governing Board of
Pioneer Community Energy
Resolution No.: ____________
The following Resolution was duly passed by the Governing Board of Pioneer Community Energy at a regular meeting held July 10, 2025, by the following vote on roll call:
Ayes:
Noes:
Absent:
Signed and approved by me after its passage.
______________________________
Chair of the Governing Board
Attest:
_______________________
Secretary
WHEREAS, this Resolution approving modification of Resolution 2025-11 to authorize the Chief Executive Officer or designee to execute individual Power Purchase Agreements, contracts, or confirmations not exceeding 1.5% of Pioneer’s annual procurement budget as a maximum annual notional amount, together with a maximum 20-year term has been brought before the Governing Board; and
WHEREAS, Resolution 2025-11 authorizes the CEO or designee to execute long-term (more than five years) power purchase agreements, contracts, and confirmations after receiving the advice and recommendation from the Energy Procurement Review Committee (EPRC), and subject to the written approval of: 1) General Counsel, and 2) Pioneer’s outside counsel specializing in power transactions and power contract law; and WHEREAS, the process to sign contracts associated with new programs with extremely low notional values has become inefficient because they still require the EPRC to consider and provide advice pursuant to Resolution 2025-11; and
In the matter of: APPROVE AMENDMENT TO
RESOLUTION 2025-11 TO AUTHORIZE THE CHIEF
EXECUTIVE OFFICER TO EXECUTE INDIVIDUAL
POWER PURCHASE AGREEMENTS, CONTRACTS,
OR CONFIRMATIONS NOT EXCEEDING 1.5% OF
PIONEER’S ANNUAL PROCUREMENT BUDGET AS
A MAXIMUM ANNUAL NOTIONAL AMOUNT,
TOGETHER WITH A MAXIMUM 20-YEAR TERM
2 397935.1
WHEREAS, The expected range of notional values for potential programs at 3 MW capacity on an annual basis is generally less than 1.5% of Pioneer’s annual procurement budget; and WHEREAS, this topic was discussed in the EPRC on October 9, 2024, and the EPRC directed staff to bring their recommendation of the modification as presented in this Resolution to the Board for approval.
BE IT RESOLVED, the Governing Board of Pioneer Community Energy, State of California, hereby finds, declares, and resolves as follows:
1. The above recitals are true and correct.
2. The Governing Board hereby approves the modification of Resolution 2025-11 to authorize the Chief Executive Officer or designee to execute individual Power Purchase Agreements, contracts, or confirmations not exceeding 1.5% of Pioneer’s annual procurement budget as a maximum annual notional amount, together with a maximum 20-year term.
3. The Energy Risk Management Policy is hereby approved with the revisions indicated in the Policy attached hereto.
4. This Resolution shall take effect immediately upon its adoption.
Exhibits:
A. Resolution 2025-11
B. Energy Risk Management Policy
Resolution 2025-__
July 10, 2025
Before the Governing Board of
Pioneer Community Energy
In the matter of: RESOLUTION ESTABLISHING AD
HOC ENERGY PROCUREMENT REVIEW
COMMITTEE, REVISING AUTHORITY FOR
EXECUTING LONG-TERM POWER PROCUREMENT
CONTRACTS, AND AMENDING THE ENERGY RISK
MANAGEMENT POLICY
Resolution No.: 2025-11
The following Resolution was duly passed by the Governing Board of Pioneer Community Energy at a regular meeting held March 20, 2025, by the following vote on roll call:
Ayes: Carter, DeMattei, Dowdin Calvillo, Ivy, Janda, Jones, Lomen, Parlin, Petersen, Reedy, Ring.
Noes: None.
Absent: None.
Signed and approved by me after its passage. cw~~
Chair of the Governing Board
Attest:
WHEREAS, Pioneer Community Energy ("Pioneer") has established a Community Choice Aggregation (CCA) Program to provide economic, environmental and social benefits to the residents, business and communities within its jurisdiction; and WHEREAS, the CCA Program has statutory authority to procure electrical power under Public Utilities Code Sections 331.1 and 366.2; and
WHEREAS, Pioneer procures power products for the purpose of ensuring safe, reliable and affordable electric generation services to its customers; and WHEREAS, to mitigate and manage risks associated with the procurement of power products, the Pioneer Board has adopted an Energy Risk Management Policy, which is subject to annual review and update; and
WHEREAS, the execution of contracts, agreements and confirmations for the procurement of electric power resources require a purchasing decision and execution of related contracts, agreements and confirmations within a limited period of time; and WHEREAS, pursuant to its Energy Risk Management Policy and Resolution 2019-1, the Chief Executive Officer ("CEO") or the CEO's designee is authorized to execute electric power purchase agreements, contracts, and confirmations, subject to approval of General Counsel, or the approval of outside counsel specializing in power transactions and power contracts, as may 392144.1
Resolution 2025-11
March 20, 2025
be determined appropriate and delegated by General Counsel, for any term, as long as the delivery period concludes five years or less from the date of execution of the contract; and WHEREAS, pursuant to its Energy Risk Management Policy and Resolutions 2019-3 and 2021-1, the CEO or CEO's designee is authorized to execute long-term (five years or more) purchase agreements, contracts, and confirmations, subject to the written approval of: 1) General Counsel, 2) Pioneer's outside counsel specializing in power transactions and power contract law, and 3) Pioneer's Energy Procurement Review Committee; and WHEREAS, decisions concerning long-term energy contracts requires consideration of sensitive market data that have independent economic value from not being generally known and which would cause economic damage to Pioneer and its customers if it were to become known; and
WHEREAS, in light of Pioneer's efforts at expansion and approval, subject to certain conditions, to do so, Pioneer will be exploring additional long-term power procurement contracts in the coming year.
NOW THEREFORE, BE IT RESOLVED, by the Governing Board of Pioneer Community Energy as follows:
1. The above recitals are true and correct.
2. Establishment of Energy Procurement Review Committee. 2 392144.1
a. The Energy Procurement Review Committee, as previously existing prior to the date of this Resolution, is hereby disestablished and Resolutions 2019-3 and 2021-1 are hereby repealed.
b. An ad hoc advisory subcommittee is hereby established to be comprised of the following Board members:
Board Member
Ryan Carter
Alice Dowdin Calvillo (Vice-Chair)
Greg Janda
Sean Lomen
Gary Petersen (Chair)
Member Agency
Placerville
Auburn
Rocklin
Colfax
Nevada City
c. This subcommittee shall be advisory to the CEO or the CEO's designee and shall be referred to as the Energy Procurement Review Committee. It shall be charged with providing advice and recommendations to the CEO or the CEO's designee on long-term (five years or more) Power Procurement Contracts, purchase agreements, contracts, and confirmations contemplated for the current calendar year. This subcommittee shall have such support from General Counsel and Pioneer staff as the CEO shall direct.
d. This subcommittee shall make its recommendations to the CEO or CEO's designee from time to time as the CEO deems necessary but no later than the date of the first regular meeting of the Pioneer Governing Board in January 2026 and upon provision of its recommendations to the CEO or CEO's designee, this subcommittee shall automatically be disestablished.
Resolution 2025-11
March 20, 2025
e. As a temporary, ad hoc committee advisory to the CEO and comprised of less than a quorum of the Governing Board, the Energy Procurement Review Committee may, but need not, comply with the Brown Act as authorized by Government Code section 54952, subdivision (b).
3. Authorization for CEO to Enter Into Long-Term Power Procurement Contracts and Revisions to Energy Risk Management Policy.
a. The CEO or CEO's designee is hereby authorized to execute long-term (five years or more) Power Procurement Contracts, purchase agreements, contracts, and confirmations after receiving the advice and recommendation from the Energy Procurement Review Committee, and subject to the written approval of:
1) General Counsel, and 2) Pioneer's outside counsel specializing in power transactions and power contract law.
b. The Energy Risk Management Policy is hereby approved with the revisions indicated in the Policy attached hereto.
4. This Resolution shall take effect immediately upon its adoption.
Exhibit A: Energy Risk Management Policy
3 392144.1
392143.1
ENERGY RISK
MANAGEMENT
POLICY
Revised: October 19, 2023
Revised: March 20, 2025
PICf)NEER
COMMUNITY ENERGY
392143.1 2
Table of Contents
Contents
Table of Contents.............................................................................................................................. 2 Section 1: POLICY OVERVIEW.................................................................................................................. 4
1.1 Background and Purpose .................................................................................................................................. 4
1.2 Scope................................................................................................................................................................. 4
1.3 Energy Risk Management Objective ................................................................................................................. 5
1.4 Policy Administration........................................................................................................................................ 5 Section 2: STRATEGY/GOALS AND RISK EXPOSURES................................................................ 6
2.1 Strategy/Policy Goals........................................................................................................................................ 6 a) Current Board-approved Procurement Strategy.............................................................................................. 6 b) Long-term Business Viability Goals .................................................................................................................. 6
2.2 Risk Exposures................................................................................................................................................... 7
2.2.1 Customer Opt-Out Risk .................................................................................................................................. 7
2.2.2 Market Risk .................................................................................................................................................... 7
2.2.3 Regulatory Risk............................................................................................................................................... 8
2.2.4 Volumetric Risk .............................................................................................................................................. 8
2.2.5 Model Risk...................................................................................................................................................... 9
2.2.6 Operational Risk............................................................................................................................................. 9
2.2.7 Counterparty Credit Risk................................................................................................................................ 9
2.2.8 Liquidity Risk ................................................................................................................................................ 10
2.3 Risk Measurement Methodology.................................................................................................................... 10 Section 3: BUSINESS PRACTICES......................................................................................................... 11
3.1 General Conduct ............................................................................................................................................ 11
3.2 Trading for Personal Accounts........................................................................................................................ 11
3.3 Adherence to Statutory Requirements........................................................................................................... 11
3.4 Transaction Type, Regions and Markets......................................................................................................... 12
3.5 Counterparty Suitability .................................................................................................................................. 13
3.6 System of Record ............................................................................................................................................ 13
3.7 Transaction Valuation ..................................................................................................................................... 13 392143.1 3
3.8 Stress Testing .................................................................................................................................................. 13
3.9 Trading Practices............................................................................................................................................. 13
3.10 Policy Compliance ......................................................................................................................................... 14 Section 4: ORG. STRUCTURE AND RESPONSIBILITIES ........................................................... 15
4.1 Risk Management Organizational Structure................................................................................................... 15
4.2 Governing Board ............................................................................................................................................. 15
4.3 Risk Oversight Committee (“ROC”)................................................................................................................. 15
4.4 Energy Procurement Review Committee (“EPRC”)......................................................................................... 16
4.5 Segregation of Duties...................................................................................................................................... 16
4.5.1 Front Office .................................................................................................................................................. 16
4.5.2 Middle Office................................................................................................................................................ 17
4.5.3 Back Office ................................................................................................................................................... 17 Section 5: DELEGATION OF AUTHORITY.......................................................................................... 19
5.1 Hedging Tolerances......................................................................................................................................... 19
5.1.1 Energy Procurement Tolerances.................................................................................................................. 19
5.1.2 Renewable Portfolio Standard..................................................................................................................... 20
5.1.3 Resource Adequacy...................................................................................................................................... 20
5.2 Monitoring, Reporting and Instances of Exceeding Risk Limits...................................................................... 20 Section 6: CREDIT POLICY........................................................................................................................ 21
6.1 Counterparty Credit Risk................................................................................................................................. 21
6.2 Counterparty Concentration........................................................................................................................... 21
6.3 Credit Review Exceptions................................................................................................................................ 22
6.4 Credit Exposure and Monitoring..................................................................................................................... 22 Section 7: POSITION TRACKING AND MANAGEMENT REPORTING .................................. 23 Section 8: POLICY REVISION PROCESS............................................................................................ 24
8.1 Acknowledgement of Policy............................................................................................................................ 24
8.2 Policy Interpretations...................................................................................................................................... 24 Appendix A: AUTHORIZED TRANSACTION TYPES, REGIONS AND MARKETS ............. 25 Appendix B: NEW TRANSACTION APPROVAL FORM.................................................................. 26 Appendix C: DEFINITIONS........................................................................................................................ 27 392143.1 4
Section 1: POLICY OVERVIEW
1.1 Background and Purpose
Pioneer Community Energy (“Pioneer”) is a public joint powers agency located within the geographic boundaries of El Dorado, Nevada, and Placer Counties.
Member agencies of Pioneer include the Unincorporated Counties of Placer and El Dorado, as well as the Cities of Auburn, Colfax, Grass Valley, Lincoln, Nevada City, Placerville, and Rocklin and the Town of Loomis.
Mission Statement: Pioneer is a locally owned provider of electricity – powering the communities we serve with competitive rates, reliable service, and a choice in energy options.
Pioneer will give its members an opportunity to procure electricity supplies and implement local programs that meet the goals of the local communities. Electricity procured to serve customers will continue to be delivered through Pacific Gas & Electrics’ (“PG&E”) transmission and distribution system.
Providing retail electric generation service to customers enrolled in the CCA program exposes Pioneer to risks such as customer opt-out risk, market risk, regulatory risk, volumetric risk, model risk, operational risk, counterparty credit risk and reputation risk.
This Energy Risk Management Policy (“Policy”) establishes Pioneer’s Energy Risk Management Program (“Program”) including risk management functions and procedures to manage the risks associated with power procurement activities.
The ultimate purpose of this Policy is to help Pioneer manage its risks by specifying management responsibilities, organizational structures, risk management standards, and operating controls and limits necessary to properly identify and manage Pioneer’s exposure to risk.
1.2 Scope
Unless otherwise explicitly stated in this Policy, or other policies approved by the Board, this Policy applies to all power procurement and related business activities that may impact the risk profile of Pioneer. This Policy documents the framework by which management and staff will:
• Identify and quantify risk
• Develop and execute procurement strategies
• Create a framework of controls and oversight
392143.1 5
• Monitor, measure, and report on the effectiveness of the Program
1.3 Energy Risk Management Objective
The objective of the Energy Risk Management Policy is to provide a framework for conducting procurement activities that will manage risks to support Pioneer meeting the goals listed in Section 2.1.
Pursuant to this Policy, Pioneer will identify and measure the magnitude of the risks to which it is exposed and contribute to the potential for not meeting identified goals.
1.4 Policy Administration
This Policy document shall be reviewed and approved by Pioneer’s Governing Board (“Board”) biennially.
392143.1 6
Section 2: STRATEGY/GOALS AND RISK EXPOSURES
2.1 Strategy/Policy Goals
a) Current Board-approved Procurement Strategy
The current Board approved Energy Procurement Strategy is to meet the State’s minimum renewable energy targets while procuring the remaining energy needs with less expensive power whether system power or other power sources to maintain competitive rates.
b) Long-term Business Viability Goals
To help ensure Pioneer’s long-term viability, this Program outlines the following business goals. Pioneer will establish metrics for modeling and measuring risk exposures for tracking performance relative to these goals. • Pioneer will target to maintain competitive retail rates compared to PG&E after adjusting for the Power Charge Indifference Adjustment (PCIA) and Franchise Fee.
• Pioneer will fund financial reserves with the following objectives:
o Establish long-term business sustainability
o Build collateral for power procurement activities
o Establish an investment grade credit rating
o Develop a source of funds for investment in generation and other local programs
o Stabilize rates and dampen year-to-year variability in procurement costs 0%
20%
40%
60%
80%
100%
120%
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
CA Renewable Portfolio Standards
Portfolio Composition Requirements
CA RPS Min % Non-Specified Power %
I I I I I I I I ■ ■
392143.1 7
The goals outlined above are incorporated into the financial models that are used in modeling and measuring risk exposures. It is important to note that the goals listed above are not intended to be a comprehensive list of goals for Pioneer.
2.2 Risk Exposures
The Program faces a range of risks during ongoing operations:
a) Customer Opt-Out risk
b) Market risk
c) Regulatory risk
d) Volumetric risk
e) Model risk
f) Operational risk
g) Counterparty credit risk
h) Liquidity risk
2.2.1 Customer Opt-Out Risk
Customer opt-out risk is the primary risk the CCA faces. Customer opt-out risk includes any condition or event that creates the potential for significant reductions in the CCA’s customer base, thereby increasing the potential for the CCA to not meet its Policy goals. A CCA faces other risks, but the ultimate concern is often how these other risks will affect customer opt-outs. This Policy addresses this paramount risk and secondary risk types listed below. These risks are not all inclusive but are identified as the risk factors driving the success of the CCA.
The most relevant measures of the success of this Policy include:
• Retail rate competitiveness with PG&E
• Financial reserve level
2.2.2 Market Risk
For this Policy, risk exposure is assessed on all the transactions (energy, environmental attributes, capacity, etc.) executed by Pioneer, as well as the risk exposure of open positions and the impacts of these uncertainties on the CCA’s load obligations. The following are components of Pioneer’s energy risk that will be monitored, assessed, and managed.
Market risk is the uncertainty of Pioneer’s financial performance due to variable commodity market prices (market price risk) and uncertain price relationships (basis risk). Variability in market prices creates uncertainty in Pioneer’s procurement costs and can materially impact Pioneer’s financial position. Market risk is managed by:
392143.1 8
• Regular measurement
• An active hedging program
• Execution of approved procurement and Congestion Revenue Right strategies • The limit structure set forth in this Policy
2.2.3 Regulatory Risk
CCAs remain a comparatively new legal entity in the state of California and are subject to an evolving legal and regulatory landscape. Additionally, Pioneer is in direct competition with PG&E, which face the risk of stranded investments in generating assets and power purchase agreements procured in the past to serve now departing CCA loads. That stranded investment risk is passed on to Pioneer’s customers through the PCIA which impacts Pioneer’s competitiveness. The competitive and regulatory landscape results in retail rate competitiveness risks that are unique to CCAs. Regulatory risk is managed by:
• Monitoring and analyzing legislative and regulatory proceedings impacting CCAs • Monitoring and reporting of actual and projected financial results including stressed financial results assuming a range of market and retail rate scenarios (both Pioneer and PG&E)
• Structuring procurement strategies with the objective function of maintaining a favorable retail rate savings relative to PG&E
• Actively participating in and representing CCA customer interests during regulatory and legislative proceedings
2.2.4 Volumetric Risk
Volumetric risk is the uncertainty of Pioneer’s financial performance due to variability in the quantity of retail load served by Pioneer. Load variability can be the result of customer opt-outs, temperature deviation from normal, unforeseen adoption of behind the meter generation by Pioneer customers, as well as local, state, and national economic conditions. Volumetric risk is managed by:
• Quantifying the variability of PG&E generation and PCIA rates • Quantifying variability in procurement costs
• Monitoring and adjusting for non-regulatory factors driving volumetric uncertainty (e.g. weather)
• Implement robust short- and long-term load and generation supply forecast methodologies, including regular monitoring of forecast accuracy through time and refining such forecasts, including by incorporating Pioneer’s actual load data into forecasts as such data becomes available
• Adopting a formal procurement strategy
• Implement a key accounts program and maintain strong relationships with local communities
392143.1 9
• Monitoring trends in customer onsite generation, economic shifts, electric vehicle adoption, and other factors that affect electric consumption
2.2.5 Model Risk
Model risk is the uncertainty of Pioneer’s financial performance due to potentially inaccurate or incomplete characterization of a transaction or power supply portfolio elements due to fundamental deficiencies in models and/or information systems.
Model risk is managed by:
• Developing industry standard financial risk assessment models • Reviewing model outputs as part of risk control framework • Conducting ongoing Pioneer staff education and participation in CCA industry forums
• Updating and improving models as additional information and expertise are acquired
2.2.6 Operational Risk
Operational risk is the uncertainty of Pioneer’s financial performance due to weaknesses in the quality, scope, content, or execution of human resources, technical resources, and/or operating procedures within Pioneer. Operational risk can also be exacerbated by fraudulent actions by employees or third parties or inadequate or ineffective controls. Operational risk is managed by:
• Ensuring adequate controls set forth in this Policy
• Conducting routine oversight of procurement activity
• Perform timely and effective reporting by management
• Training staff to reinforcing a culture of compliance to ERM policies • Conducting Ongoing and timely internal and external audits • Separate internal operations between Front, Middle and Back Office responsibilities as set forth herein
• Provide training to Board members to enhance oversight
2.2.7 Counterparty Credit Risk
Counterparty credit risk is the potential that a Counterparty will fail to perform or meet its obligations in accordance with terms agreed under contract. Pioneer’s exposure to counterparty credit risk is controlled by the limit controls set forth in the Credit Policy described in Section 6.
392143.1 10
2.2.8 Liquidity Risk
Pioneer manages liquidity risk through adherence to its loan and power purchase agreement credit covenants, limiting commitments to provide cash security consistent with its Credit Guidelines, ensuring it has adequate loan facilities, prudent cash and investment management, and adherence to its Reserve Policy.
Pioneer monitors its liquidity (defined as unrestricted cash, investments, and unused bank lines of credit) no less than weekly. Pioneer utilizes scenario and sensitivity analyses while preparing budget, rate, and pro forma analyses to identify potential financial outcomes and ensure sufficient liquidity under adverse conditions.
2.3 Risk Measurement Methodology
A vital element in Pioneer’s Energy Risk Management Policy is the regular identification, measurement, and communication of risk. Pioneer will routinely evaluate industry accepted benchmarks of quantified risk measurements to determine the applicability of such benchmark to Pioneer operations and performance. To effectively communicate risk, all risk management activities must be monitored frequently using risk measurement methodologies that quantify the risks associated with Pioneer’s energy procurement and performance relative to goals.
Risk measurement is the comparison of Pioneer’s projected retail rates to those of PG&E under expected and stressed scenarios. The rate comparison will be adjusted for actual and projected PCIA and Franchise Fee charges. Risk measurement methodologies shall be re-evaluated on a periodic basis to ensure Pioneer adjusts its methods to reflect the evolving regulatory and competitive landscape. The implementation of these methods shall be overseen and ratified by the Risk Oversight Committee (“ROC”).
392143.1 11
Section 3: BUSINESS PRACTICES
3.1 General Conduct
It is the policy of Pioneer that all personnel, including the Board, management, and agents, adhere to standards of integrity, ethics, conflicts of interest, compliance with statutory law and regulations and other applicable Pioneer standards of personal conduct while employed by or affiliated with Pioneer.
3.2 Trading for Personal Accounts
All Pioneer Directors, management, employees and agents participating in any transaction or activity within the coverage of this Policy are obligated to give notice in writing to Pioneer of any interest such person has in any counterparty that seeks to do business with Pioneer, and to identify any real or potential conflict of interest such person has or may have regarding any contract or transaction with Pioneer.
Conflicts of Interest shall be identified and defined as set forth in the Pioneer Conflict of Interest Code, as amended from time to time by the Board, which incorporates the Political Reform Act requirements for all employees advising Pioneer.
If there is any doubt as to whether a prohibited condition exists, then it is the employee’s responsibility to discuss the possible prohibited condition with her/his manager or supervisor.
3.3 Adherence to Statutory Requirements
Compliance is required with rules promulgated by the state of California, California Public Utilities Commission, California Energy Commission, Federal Energy Regulatory Commission (FERC), Commodity Futures Trading Commission (CFTC), and other regulatory agencies.
In addition to statutory requirements, the goals of the Energy Risk Policy are to comply with Governing Board's approved policies and objectives including the Strategic Plan, the Integrated Resource Plan ("IRP"), the Procurement Plan and Cash Reserve Policy including retail rate stability and competitiveness and the accumulation of financial reserves.
Congress, FERC, and CFTC have enacted laws, regulations and rules that prohibit, among other things, any action or course of conduct that actually or potentially operates as a fraud or deceit upon any person in connection with the purchase or sale of electric energy or transmission services. These laws also prohibit any person or entity from making any untrue statement of fact or omitting to state a material fact where the omission would make a statement misleading. Violation of these laws can lead to both civil and criminal actions against the individual involved, as well as 392143.1 12
Pioneer. This Policy is intended to comply with these laws, regulations, and rules and to avoid improper conduct on the part of anyone employed by Pioneer. These procedures may be modified from time to time by legal requirements, auditor recommendations, ROC requests and other considerations.
In the event of an investigation or inquiry by a regulatory agency, Pioneer may provide legal counsel to employees. However, Pioneer, with the consent of the Board, will not appoint legal counsel to an employee if Pioneer determines that the employee was not acting in good faith within the scope of employment.
3.4 Transaction Type, Regions, and Markets
Authorized transaction types, regions and markets are listed in Appendix A to this Policy. These transaction types, regions and markets are and shall continue to be focused on supporting Pioneer’s financial policies, including approved procurement strategies. New or non-standard transaction types may provide Pioneer with additional flexibility and opportunity but may also introduce new risks. Therefore, transaction types, regions and markets not included in Appendix A, or transactions within already approved transaction types that are substantially different from any prior transaction executed by Pioneer, must be approved by the ROC prior to execution using the process defined below.
When seeking approval for a new or non-standard transaction type, region, and/or market, a New Transaction Approval Form, as shown in Appendix B, should be drafted describing all significant elements of the proposed transaction. The proposal write-up should, at a minimum, include:
• A description of the benefit to Pioneer, including the purpose, function and expected cost impact (i.e., decrease costs, manage volatility, control variances, etc.);
• Identification of the in-house or external expertise that will manage and support the new or non- standard transaction type;
• Assessment of the transaction’s risks, including any material legal, tax or regulatory issues;
• How the exposures to the risks above will be managed; • Proposed valuation methodology (including pricing model, where appropriate); • Proposed reporting requirements, including any changes to existing procedures and system requirements necessary to support the new transaction type; • Proposed accounting methodology.
It is the responsibility of Pioneer’s Executive Director to ensure that relevant departments have reviewed the proposed transaction and that material issues are resolved prior to submittal to the ROC for approval. If approved, Appendix A to the Policy will be updated to reflect the new transaction type. 392143.1 13
3.5 Counterparty Suitability
Pioneer’s counterparty credit limits and approval processes will govern counterparty suitability for all transactions executed by Pioneer, consistent with the credit policies described in Section 6. Credit limits should be approved prior to execution of contracts.
3.6 System of Record
Pioneer will maintain a set of records for all transactions executed in association with Pioneer procurement activities. The records will be maintained in US dollars and transactions will be separately recorded and categorized by type of transaction.
This system of record shall be auditable.
3.7 Transaction Valuation
Transaction valuation and reporting of positions shall be based on objective, market-observed prices. Open positions should be valued (mark-to-market), based on consistent valuation methods and data sources. Whenever possible, mark-to-market valuations should be based on independent, publicly available market information and data sources.
3.8 Stress Testing
Stress testing shall also be used to examine the performance of the Pioneer portfolio under adverse conditions. Stress testing is used to understand the potential variability in Pioneer’s projected procurement costs, and resulting retail rate impacts and competitive positioning, associated with low probability events.
3.9 Trading Practices
It is the expressed intent of this Policy to prohibit the acquisition of risk beyond that encountered in the efficient optimization of Pioneer’s generation portfolio and execution of procurement strategies. As such, speculative transactions are prohibited. During developing operating plans and conducting procurement activities, Pioneer recognizes that expertise must be employed by staff, and it is not the intent of this Policy to restrain the legitimate application of analysis and market expertise in executing procurement strategies intended to minimize costs and risks within the constraints of this Policy. If any questions arise as to whether a transaction constitutes speculation, the ROC shall review the transaction(s) to determine whether the transaction would constitute speculation and document its findings.
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3.10 Policy Compliance
Pioneer’s Director of Finance and Administration will provide a quarterly report monitoring compliance with the limits established by this Policy. 392143.1 15
Section 4: ORG. STRUCTURE AND RESPONSIBILITIES
4.1 Risk Management Organizational Structure
Pioneer’s Energy Risk Management Policy ensures proper segregation of responsibility for policy approval, valuation and reporting, and trading.
4.2 Governing Board
Pioneer’s Board has the responsibility to review and approve this Policy. With approval, the Board assumes responsibility for understanding the risks Pioneer is exposed to due to CCA Program activity and how the policies outlined in this document help Pioneer manage the associated risks. The Board is also responsible to:
• Determine Pioneer’s strategic direction
• Understand the procurement strategy employed
• Approve risk exposures beyond the Executive Director’s authority
4.3 Risk Oversight Committee (“ROC”)
The ROC shall include the following voting members: Executive Director, Director of Finance and Administration, and General Counsel or their designees in case of their absence. The Technical Procurement Advisor (which may be an outside consultant or as otherwise selected by the Executive Director) shall be a non-voting member of the ROC. The Executive Director shall act as the chair of the ROC.
The ROC shall meet quarterly or as otherwise called to order by the Executive Director. The Executive Director shall make reports and seek approval for any substantive changes to this Policy from the Board.
The ROC shall from time to time adopt and bring current risk management guidelines defining in detail the internal controls, strategies, and processes for managing market risks incurred through or attendant upon wholesale trading, retail marketing, long-term contracting, CRR trading and load and generation scheduling.
The ROC shall specify the categories of transactions permitted and set risk limits for wholesale trading. The ROC shall receive and review information and reports regarding risk management, wholesale trading transactions, and the administration of supply contracts.
The ROC maintains the authority and responsibility to:
• Approve and ensure that all procurement strategies are consistent with this Policy;
• Determine if changes in procurement strategies are warranted; 392143.1 16
• Approve new transaction types, regions, markets and delivery points; • Understand financial and risk models;
• Understand counterparty credit review models and methods for setting and monitoring credit limits;
• Receive and review reports as described in this Policy; • Meet to review actual and projected financial results and potential risks; • Escalate to the Board with any risks beyond the Executive Director’s authority; • Review summaries of limit violations;
• Review the effectiveness of Pioneer's energy risk measurement methods; • Maintain this Policy; and
• Monitor regulatory and legislative activities.
4.4 Energy Procurement Review Committee (“EPRC”)
The EPRC is authorized to review and advise the Executive Director on the execution of energy contracts greater than five (5) years in length (from contract execution date). Long-term power (greater than five years) purchase agreements (“PPAs”) are periodically necessary to fulfill regulatory requirements (e.g., Renewables Portfolio Standard), and for portfolio optimization.
4.5 Segregation of Duties
Pioneer shall maintain a segregation of duties, also referred to as "separation of function", to the extent practicable to help manage and control the risks outlined in this Policy. Individuals responsible for legally binding the CCA to a transaction will not perform confirmation, clearing or settlement functions. Pioneer staff roles and responsibilities are divided into front-middle-back-office activities, as described below. In executing these functions, Pioneer may rely on third-party to assist in performing various functions to preserve the intent of the separation of functions.
4.5.1 Front Office
The Front Office is the responsibility of the Chief Operating Officer.
The Front Office has overall responsibility for:
a) Managing all commodity transactions;
b) Analysis of fundamentals affecting Pioneer’s net position; and c) Transacting within the limits of this Policy, and associated policies, to balance loads and resources, and maximize the value of Pioneer’s assets through the exercise of approved optimization strategies.
Other duties associated with these responsibilities include:
392143.1 17
a) Develop and analyze hedging products and procurement strategies and bring recommendations to the ROC, utilizing the net forward power positions prepared by Middle Office
b) Prepare each month a monthly operating plan for the prompt months that gives direction to the day-ahead and real-time trading and scheduling staff regarding the bidding and scheduling of Pioneer's resource portfolio in the California Independent System Operator (“CAISO”) market c) Develop, price, and negotiate purchase and/or sale transactions for energy Resource Adequacy, renewable, green-house gas free energy d) Keep accurate records of all transactions
4.5.2 Middle Office
The Middle Office is the responsibility of the Director of Finance and Administration.
The Middle Office provides independent market and credit risk oversight.
The Middle Office has primary responsibility for trading controls, including forward trading. Primary responsibilities include:
a) Calculating and maintaining the short-term load forecasts and disseminating to Front and Back Office
b) Estimating and publishing forward monthly power price curves for a minimum of the balance of the current year through the next calendar year c) Ensuring that Pioneer adheres to all risk policies and procedures in letter and intent.
d) Calculating and maintaining the net forward power positions of Pioneer. e) Assisting Back Office in calculating Counterparty Credit Exposure.
4.5.3 Back Office
The Back Office is the responsibility of the Director of Finance and Administration.
The Back Office provides support with a wide range of administrative activities necessary to execute and settle transactions and to support the risk control efforts (e.g., transaction entry and/or checking, data collection, billing, etc.) consistent with this Policy.
The Back Office has primary responsibility for ensuring agreement with counterparties regarding the terms of all trades, including forward trading. Primary responsibilities include:
a) Handling confirmation of all transactions (physical and financial) and reconciling differences with the trading counterparties b) Reviewing transaction confirmations for adherence to approved limits c) Calculating a monthly Counterparty Credit Exposure report d) Ensuring all trades have been entered into the appropriate system of record 392143.1 18
e) Carrying out month-end checkout of all physical and financial transactions each month
f) Implementing and enforcing credit policies and limits 392143.1 19
Section 5: DELEGATION OF AUTHORITY
With the approval of the Policy, the Pioneer Board is explicitly delegating approval of transactions to the Executive Director, in consultation with the EPRC, as outlined in the following table:
Authority Contract or PPA
Term Limit
Executive Director after
recommendation from the Energy
Procurement Review Committee
Over 60 months
Executive Director Up to 60 months
Additionally, to adapt to changing market conditions and to facilitate the daily operations of Pioneer, the Board is delegating authority to the Executive Director to execute administrative amendments to duly approved transactions where such amendment does not exceed the Executive Director’s delegated authority as set forth above (for clarity, amendments exceeding Term limits shall require consultation with the EPRC) and further reduces Pioneer’s risk in furtherance of this Policy. Such administrative amendments must be reported at the next available ROC meeting.
All procurement executed under the delegation above must align with the Pioneer’s underlying risk exposure (locational, volume and temporal) that is being hedged consistent with the approved Procurement Strategy.
The point of delivery for all products must be at a location on the CAISO transmission grid.
5.1 Hedging Tolerances
The Front Office is responsible for managing portfolio risks within the limits of this Policy. To reduce market price risk and increase retail rate certainty Front Office will execute transactions based on the following hedge targets.
5.1.1 Energy Procurement Tolerances
Period Minimum
Coverage*
Fiscal Year % of Forecasted Load
Year 1 (Current Year) 90%
Year 2 70%
Year 3 50%
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Year 4 30%
Year 5 10%
*Prior to start of Current Year
5.1.2 Renewable Portfolio Standard
With respect to purchases to meet the Renewable Portfolio Standard (RPS), Pioneer must comply with regulatory requirements and is guided by the Board for purchases above those requirements. Pioneer purchases should be staggered to accommodate regulatory uncertainty and changes in load and supply price risks, as well as diversified with respect to technologies.
5.1.3 Resource Adequacy
Pioneer must comply with the regulatory requirements for procurement of capacity products for Resource Adequacy ("RA"). Pioneer must comply for local resource adequacy for one to three years by October 31st of each year. Additionally, Pioneer must demonstrate, on a month-ahead basis, full compliance with its monthly RA obligations. Pioneer endeavors to purchase RA products over time to meet its obligations and to diversify its purchases between suppliers and market conditions.
5.2 Monitoring, Reporting and Instances of Exceeding Risk Limits The Middle Office is responsible for monitoring, and reporting compliance with, all limits within this Policy. If a limit or control is violated, the Middle Office will send notification to the Executive Director, Chief Operating Officer, and the ROC. The ROC will discuss the cause and potential remediation of the exceedance to determine next steps for curing the exceedance.
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Section 6: CREDIT POLICY
All Counterparties shall be evaluated for creditworthiness by the Middle Office prior to execution of any transaction and no less than annually thereafter. Additionally, Counterparties shall be reviewed if a change has occurred, or perceived to have occurred, in market conditions or in a company’s management or financial condition. This evaluation, including any recommended increase or decrease to a credit limit, shall be documented, and inclusive of all information supporting such evaluation in a credit file for the counterparty. A credit limit for a Counterparty will not be recommended or approved without first confirming the Counterparty’s senior unsecured or corporate credit rating from one of the nationally recognized rating agencies and/or performing a credit review or analysis of the Counterparty’s or guarantor’s financial statements. The credit analysis shall include, at a minimum, current audited financial statements or other supplementary data that indicates financial strength commensurate with an investment grade rating. Trade and banking references, and any other pertinent information, may also be used in the review process.
Once a counterparty is determined to be creditworthy, a credit limit will be proposed. Although a counterparty may qualify for a certain maximum credit limit, anticipated transaction volumes and other business factors may prompt Pioneer to select a lower limit that is considered more appropriate.
Counterparties that do not qualify for an unsecured Credit Limit must post an acceptable form of credit support or Prepayment prior to the execution of any transaction, unless otherwise approved by the Executive Director. A Counterparty may choose to provide a guarantee from a third party, provided the third party satisfies the criteria for a Credit Limit as outlined herein.
6.1 Counterparty Credit Risk
Pioneer evaluates and monitors the financial strength of service and energy providers consistent with Pioneer’s Credit Guidelines.
6.2 Counterparty Concentration
In addition to maintaining credit exposure limits, Pioneer staff shall strive to diversify transactions among counterparties. Pioneer staff shall document the business reasons (e.g., differences in offer price, lack of qualified suppliers, etc.) for awarding additional contracts to counterparties with high concentrations of Credit Exposure.
392143.1 22
6.3 Credit Review Exceptions
Counterparties not subject to the above credit review criteria include those associated with day-ahead and current day purchases or market index-based contracts where risks associated with market movements are minimal.
6.4 Credit Exposure and Monitoring
The Back Office will monitor the current credit exposure for each Counterparty with whom Pioneer transacts and include such information in the quarterly Risk Management Report. This report will be made available, reviewed, and communicated to the ROC pursuant to the reporting requirements outlined in Section 7.
392143.1 23
Section 7: POSITION TRACKING AND MANAGEMENT REPORTING
Minimum reporting requirements are shown below. The reports outlined below will be made available to ROC members:
• Quarterly Financial Model Forecast
Latest projected financial performance, marked to current market prices, and shown relative to financial goals.
• Quarterly Net Position Report
Prepare a forward net position report, not less frequently than quarterly, and report the results to the ROC.
• Quarterly Report to the Board
Update on activities and projected financial performance to be presented least quarterly at Pioneer Board meetings.
• Quarterly Counterparty Credit Exposure
Updates on the notional and mark-to-market exposure to each Pioneer counterparty individually by deal and in aggregate by counterparty.
Counterparty credit exposure reporting includes contingent collateral posting risks arising from changes in market prices and other factors. • Counterparty Credit Exposure
This report will show credit exposures for transactions executed by Pioneer. • Risk Analysis
This will include a stress test of financial forecast relative to financial goals. 392143.1 24
Section 8: POLICY REVISION PROCESS
Pioneer’s Energy Risk Management Policy will evolve over time as market and business factors change. At least on an annual basis, the ROC will review this Policy and associated procedures to determine if they should be amended, supplemented, or updated to account for changing business and/or regulatory requirements. If an amendment is warranted, the Policy amendment will be submitted to the Pioneer Board for approval.
8.1 Acknowledgement of Policy
Any Pioneer employee participating in any activity or transaction within the scope of this Policy shall sign on an annual basis or upon any revision, a statement approved by the ROC that such employee:
• Has read Pioneer’s Energy Risk Management Policy
• Understands the terms and agreements of said Policy
• Will comply with said Policy
• Understands that any violation of said Policy shall be subject to employee discipline up to and including termination of employment.
8.2 Policy Interpretations
Questions about the interpretation of any matters of this Policy should be referred to the Executive Director. All legal matters stemming from this Policy will be referred to General Counsel.
392143.1 25
Appendix A: AUTHORIZED TRANSACTION TYPES, REGIONS, AND
MARKETS
All transaction types listed below must be executed within the limits set forth in this Policy or Credit Risk Guidelines.
Over the Counter Products
• CAISO Market Products
o Day-ahead and Real-time Energy
o Congestion Revenue Rights
o Convergence bids
o Inter Scheduling Coordinator Transactions
o Tagging into and out of CAISO
• Physical Power Products
o Power
o Physical Resource Adequacy Capacity
• Physical Transmission Products
o Physical WECC transmission
• Physical Environmental Products
o Renewable Energy Credits
o Specified Source Power
o Carbon Allowances and Obligations
392143.1 26
Appendix B: NEW TRANSACTION APPROVAL FORM
New or Non-Standard Transaction
Approval Form
Prepared By:
Date:
New or Non-Standard Transaction Name:
Business Rationale and Risk Assessment:
• Product description – including the purpose, function, expected impact on net revenues (i.e. increase, manage volatility, control variances, etc.) and/or benefit to Pioneer
• Identification of the in-house or external expertise that will be relied upon to manage and support the new or non-standard transaction
• Assessment of the transaction’s risks, including any material legal, tax or regulatory issues
• How the exposures to the risks above will be managed by the limit structure • Proposed valuation methodology (including pricing model, where appropriate) • Proposed reporting requirements, including any changes to existing procedures and system requirements necessary to support the new product
• Proposed accounting methodology
• Proposed Middle Office workflows/methodology, including systems • Brief description of the responsibilities of various departments within Pioneer who will have any manner of contact with the new or non-standard transaction Reviewed by:
Chief Operating Officer Date
General Counsel Date
Executive Director Date
392143.1 27
Appendix C: DEFINITIONS
Back Office: That part of a trading organization which manages transaction accounting, confirmations, management reporting, contract administration and working capital management.
Bilateral Transaction: Any physical or financial transaction between two counterparties, neither of whom is an Exchange or market entity such as CAISO.
Cash Flow at Risk: A measure of the potential shortfall in cash flow from a specified level during a specified period of time at a specified confidence level.
CAISO: California Independent System Operator. CAISO operates a California bulk power transmission grid, administers the State’s wholesale electricity markets, and provides reliability planning and generation dispatch.
CCA: Community Choice Aggregator. CCAs allow local government agencies such as cities and/or counties to purchase and/or develop generation supplies on behalf of their residents, businesses, and municipal accounts.
CFTC: Commodity Futures Trading Commission. The CFTC is a U.S. federal agency that is responsible for regulating commodity futures and swap markets. It goals include the promotion of competitive and efficient futures markets and the protection of investors against manipulation, abusive trade practices and fraud.
Clearing: Clearing is the process of reconciling purchases and sales of a commodity, as well as the direct transfer of funds from one financial institution to another. The process validates the availability of funds, records the transfer, and in the case of financial securities, ensures the delivery to the buyer.
Commodity: A basic good used in commerce that is interchangeable with other commodities of the same type. Commodities are most often used as inputs in the production of other goods or services. The quality of a given commodity may differ slightly, but it is essentially uniform across producers. When they are traded on an exchange, commodities must also meet specified minimum standards, also known as a basis grade.
Confirmation Letter: A letter agreement between two counterparties that details the specific commercial terms (e.g., price, quantity and point of delivery) of a transaction.
Congestion Revenue Right: A point-to-point financial instrument in the Day-Ahead 392143.1 28
Energy Market that entitles the holder to receive compensation for or requires the holder to pay certain congestion related transmission charges that arise when the transmission system is congested.
Counterparty Credit Risk: The risk of financial loss resulting from a counterparty to a transaction failing to fulfill its obligations.
Counterparty Credit Exposure: This measures the known exposures and is represented by the sum of both (a)Realized exposure and (b) Forward exposure, as those terms are defined below:
Realized exposure: payable or receivable amount owed between counterparties, is a measurement of cash flow for billed and unbilled transactions.
Forward exposure: measure of current unrealized exposure and includes the measure of a counterparty’s incentive to fulfill contractual obligations. Forward exposure measures the risk associated with having a payment default or the need to replace a transaction in the event of delivery default.
Day-ahead Market: The short-term forward market for efficiently allocating transmission capacity and facilitating purchases and sales of energy and scheduled bilateral transactions; conducted by CAISO prior to the operating day.
Delivery point: the point at which a commodity will be delivered and received.
FERC: Federal Energy Regulatory Commission. FERC is a federal agency that regulates the interstate transmission of electricity, natural gas, and oil. FERC also reviews proposals to build liquefied natural gas terminals, interstate natural gas pipelines, as well as licenses hydroelectric generation projects.
Front Office: That part of a trading organization which solicits customer business, services existing customers, executes trades and ensures the physical delivery of commodities.
Hedging products: Hedging products means capacity, energy, renewable energy credits or other products related to a specific transaction.
Hedging Transaction: A transaction designed to reduce the financial exposure of a specific outstanding position or portfolio; “fully hedged” equates to complete elimination of the targeted risk and “partially hedged” implies a risk reduction of less than 100%.
IOU: An Investor-Owned Utility (IOU) is a business organization providing electrical and/or natural gas services to both retail and wholesale consumers and is managed as a private enterprise.
392143.1 29
Middle Office: That part of a trading organization that measures and reports on market risks, develops risk management policies, and monitors compliance with those policies, manages credit, and keeps management and the Board informed on risk management issues.
Speculation: Speculation is the act of trading an asset with the expectation of realizing financial gain resulting from a change in price in the asset being transacted. 392143.2
ENERGY RISK
MANAGEMENT
POLICY
Revised: October 19, 2023
Plf)NEER
COMMUNITY ENERGY
392143.2 2
Table of Contents
Contents
Table of Contents .............................................................................................................................. 2 Section 1: POLICY OVERVIEW .................................................................................................................. 4
1.1 Background and Purpose .................................................................................................................................. 4
1.2 Scope ................................................................................................................................................................. 4
1.3 Energy Risk Management Objective ................................................................................................................. 5
1.4 Policy Administration ........................................................................................................................................ 5 Section 2: STRATEGY/GOALS AND RISK EXPOSURES ................................................................ 6
2.1 Strategy/Policy Goals ........................................................................................................................................ 6 a) Current Board-approved Procurement Strategy .............................................................................................. 6 b) Long-term Business Viability Goals .................................................................................................................. 6
2.2 Risk Exposures ................................................................................................................................................... 7
2.2.1 Customer Opt-Out Risk .................................................................................................................................. 7
2.2.2 Market Risk .................................................................................................................................................... 7
2.2.3 Regulatory Risk ............................................................................................................................................... 8
2.2.4 Volumetric Risk .............................................................................................................................................. 8
2.2.5 Model Risk ...................................................................................................................................................... 9
2.2.6 Operational Risk ............................................................................................................................................. 9
2.2.7 Counterparty Credit Risk ................................................................................................................................ 9
2.2.8 Liquidity Risk .............................................................................................................................................. 109
2.3 Risk Measurement Methodology .................................................................................................................... 10 Section 3: BUSINESS PRACTICES ......................................................................................................... 11
3.1 General Conduct ............................................................................................................................................ 11
3.2 Trading for Personal Accounts ........................................................................................................................ 11
3.3 Adherence to Statutory Requirements ........................................................................................................... 11
3.4 Transaction Type, Regions and Markets ......................................................................................................... 12
3.5 Counterparty Suitability .................................................................................................................................. 13
3.6 System of Record ............................................................................................................................................ 13
3.7 Transaction Valuation ..................................................................................................................................... 13
3.8 Stress Testing .................................................................................................................................................. 13 -
392143.2 3
3.9 Trading Practices ............................................................................................................................................. 13
3.10 Policy Compliance ......................................................................................................................................... 14 Section 4: ORG. STRUCTURE AND RESPONSIBILITIES ........................................................... 15
4.1 Risk Management Organizational Structure ................................................................................................... 15
4.2 Governing Board ............................................................................................................................................. 15
4.3 Risk Oversight Committee (“ROC”) ................................................................................................................. 15
4.4 Energy Procurement Review Committee (“EPRC”) ......................................................................................... 16
4.5 Segregation of Duties ...................................................................................................................................... 16
4.5.1 Front Office .................................................................................................................................................. 16
4.5.2 Middle Office ................................................................................................................................................ 17
4.5.3 Back Office ................................................................................................................................................... 17 Section 5: DELEGATION OF AUTHORITY .......................................................................................... 19
5.1 Hedging Tolerances ......................................................................................................................................... 19
5.1.1 Energy Procurement Tolerances .................................................................................................................. 19
5.1.2 Renewable Portfolio Standard ..................................................................................................................... 20
5.1.3 Resource Adequacy ...................................................................................................................................... 20
5.2 Monitoring, Reporting and Instances of Exceeding Risk Limits ...................................................................... 20 Section 6: CREDIT POLICY ........................................................................................................................ 21
6.1 Counterparty Credit Risk ................................................................................................................................. 21
6.2 Counterparty Concentration ....................................................................................................................... 2221
6.3 Credit Review Exceptions ................................................................................................................................ 22
6.4 Credit Exposure and Monitoring ..................................................................................................................... 22 Section 7: POSITION TRACKING AND MANAGEMENT REPORTING .................................. 23 Section 8: POLICY REVISION PROCESS ............................................................................................ 24
8.1 Acknowledgement of Policy ............................................................................................................................ 24
8.2 Policy Interpretations ...................................................................................................................................... 24 Appendix A: AUTHORIZED TRANSACTION TYPES, REGIONS AND MARKETS ............. 25 Appendix B: NEW TRANSACTION APPROVAL FORM .................................................................. 26 Appendix C: DEFINITIONS........................................................................................................................ 27 -
392143.2 4
Section 1: POLICY OVERVIEW
1.1 Background and Purpose
Pioneer Community Energy (“Pioneer”) is a public joint powers agency located within the geographic boundaries of El Dorado, Nevada, and Placer Counties.
Member agencies of Pioneer include the Unincorporated Counties of Placer and El Dorado, as well as the Cities of Auburn, Colfax, Grass Valley, Lincoln, Nevada City, Placerville, and Rocklin and the Town of Loomis.
Mission Statement: Pioneer is a locally owned provider of electricity – powering the communities we serve with competitive rates, reliable service, and a choice in energy options.
Pioneer will give its members an opportunity to procure electricity supplies and implement local programs that meet the goals of the local communities. Electricity procured to serve customers will continue to be delivered through Pacific Gas & Electrics’ (“PG&E”) transmission and distribution system.
Providing retail electric generation service to customers enrolled in the CCA program exposes Pioneer to risks such as customer opt-out risk, market risk, regulatory risk, volumetric risk, model risk, operational risk, counterparty credit risk and reputation risk.
This Energy Risk Management Policy (“Policy”) establishes Pioneer’s Energy Risk Management Program (“Program”) including risk management functions and procedures to manage the risks associated with power procurement activities.
The ultimate purpose of this Policy is to help Pioneer manage its risks by specifying management responsibilities, organizational structures, risk management standards, and operating controls and limits necessary to properly identify and manage Pioneer’s exposure to risk.
1.2 Scope
Unless otherwise explicitly stated in this Policy, or other policies approved by the Board, this Policy applies to all power procurement and related business activities that may impact the risk profile of Pioneer. This Policy documents the framework by which management and staff will:
• Identify and quantify risk
• Develop and execute procurement strategies
• Create a framework of controls and oversight
392143.2 5
• Monitor, measure, and report on the effectiveness of the Program
1.3 Energy Risk Management Objective
The objective of the Energy Risk Management Policy is to provide a framework for conducting procurement activities that will manage risks to support Pioneer meeting the goals listed in Section 2.1.
Pursuant to this Policy, Pioneer will identify and measure the magnitude of the risks to which it is exposed and contribute to the potential for not meeting identified goals.
1.4 Policy Administration
This Policy document shall be reviewed and approved by Pioneer’s Governing Board (“Board”) biennially.
392143.2 6
Section 2: STRATEGY/GOALS AND RISK EXPOSURES
2.1 Strategy/Policy Goals
a) Current Board-approved Procurement Strategy
The current Board approved Energy Procurement Strategy is to meet the State’s minimum renewable energy targets while procuring the remaining energy needs with less expensive power whether system power or other power sources to maintain competitive rates.
b) Long-term Business Viability Goals
To help ensure Pioneer’s long-term viability, this Program outlines the following business goals. Pioneer will establish metrics for modeling and measuring risk exposures for tracking performance relative to these goals. • Pioneer will target to maintain competitive retail rates compared to PG&E after adjusting for the Power Charge Indifference Adjustment (PCIA) and Franchise Fee.
• Pioneer will fund financial reserves with the following objectives:
o Establish long-term business sustainability
o Build collateral for power procurement activities
o Establish an investment grade credit rating
o Develop a source of funds for investment in generation and other local programs
o Stabilize rates and dampen year-to-year variability in procurement costs 120%
100%
80%
60%
40%
20%
0%
CA Renewable Portfolio Standards
Portfolio Composition Requirements
I I I I I I I I
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
CARPS Min% Non-Specified Power%
392143.2 7
The goals outlined above are incorporated into the financial models that are used in modeling and measuring risk exposures. It is important to note that the goals listed above are not intended to be a comprehensive list of goals for Pioneer.
2.2 Risk Exposures
The Program faces a range of risks during ongoing operations:
a) Customer Opt-Out risk
b) Market risk
c) Regulatory risk
d) Volumetric risk
e) Model risk
f) Operational risk
g) Counterparty credit risk
h) Liquidity risk
2.2.1 Customer Opt-Out Risk
Customer opt-out risk is the primary risk the CCA faces. Customer opt-out risk includes any condition or event that creates the potential for significant reductions in the CCA’s customer base, thereby increasing the potential for the CCA to not meet its Policy goals. A CCA faces other risks, but the ultimate concern is often how these other risks will affect customer opt-outs. This Policy addresses this paramount risk and secondary risk types listed below. These risks are not all inclusive but are identified as the risk factors driving the success of the CCA.
The most relevant measures of the success of this Policy include:
• Retail rate competitiveness with PG&E
• Financial reserve level
2.2.2 Market Risk
For this Policy, risk exposure is assessed on all the transactions (energy, environmental attributes, capacity, etc.) executed by Pioneer, as well as the risk exposure of open positions and the impacts of these uncertainties on the CCA’s load obligations. The following are components of Pioneer’s energy risk that will be monitored, assessed, and managed.
Market risk is the uncertainty of Pioneer’s financial performance due to variable commodity market prices (market price risk) and uncertain price relationships (basis risk). Variability in market prices creates uncertainty in Pioneer’s 392143.2 8
procurement costs and can materially impact Pioneer’s financial position. Market risk is managed by:
Regular measurement
An active hedging program
Execution of approved procurement and Congestion Revenue Right strategies The limit structure set forth in this Policy
2.2.3 Regulatory Risk
CCAs remain a comparatively new legal entity in the state of California and are subject to an evolving legal and regulatory landscape. Additionally, Pioneer is in direct competition with PG&E, which face the risk of stranded investments in generating assets and power purchase agreements procured in the past to serve now departing CCA loads. That stranded investment risk is passed on to Pioneer’s customers through the PCIA which impacts Pioneer’s competitiveness. The competitive and regulatory landscape results in retail rate competitiveness risks that are unique to CCAs. Regulatory risk is managed by:
• Monitoring and analyzing legislative and regulatory proceedings impacting CCAs • Monitoring and reporting of actual and projected financial results including stressed financial results assuming a range of market and retail rate scenarios (both Pioneer and PG&E)
• Structuring procurement strategies with the objective function of maintaining a favorable retail rate savings relative to PG&E
• Actively participating in and representing CCA customer interests during regulatory and legislative proceedings
2.2.4 Volumetric Risk
Volumetric risk is the uncertainty of Pioneer’s financial performance due to variability in the quantity of retail load served by Pioneer. Load variability can be the result of customer opt-outs, temperature deviation from normal, unforeseen adoption of behind the meter generation by Pioneer customers, as well as local, state, and national economic conditions. Volumetric risk is managed by:
• Quantifying the variability of PG&E generation and PCIA rates • Quantifying variability in procurement costs
• Monitoring and adjusting for non-regulatory factors driving volumetric uncertainty (e.g. weather)
• Implement robust short- and long-term load and generation supply forecast methodologies, including regular monitoring of forecast accuracy through time and refining such forecasts, including by incorporating Pioneer’s actual load data into forecasts as such data becomes available
• Adopting a formal procurement strategy
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• Implement a key accounts program and maintain strong relationships with local communities
• Monitoring trends in customer onsite generation, economic shifts, electric vehicle adoption, and other factors that affect electric consumption
2.2.5 Model Risk
Model risk is the uncertainty of Pioneer’s financial performance due to potentially inaccurate or incomplete characterization of a transaction or power supply portfolio elements due to fundamental deficiencies in models and/or information systems.
Model risk is managed by:
• Developing industry standard financial risk assessment models • Reviewing model outputs as part of risk control framework • Conducting ongoing Pioneer staff education and participation in CCA industry forums
• Updating and improving models as additional information and expertise are acquired
2.2.6 Operational Risk
Operational risk is the uncertainty of Pioneer’s financial performance due to weaknesses in the quality, scope, content, or execution of human resources, technical resources, and/or operating procedures within Pioneer. Operational risk can also be exacerbated by fraudulent actions by employees or third parties or inadequate or ineffective controls. Operational risk is managed by:
• Ensuring adequate controls set forth in this Policy
• Conducting routine oversight of procurement activity
• Perform timely and effective reporting by management
• Training staff to reinforcing a culture of compliance to ERM policies • Conducting Ongoing and timely internal and external audits • Separate internal operations between Front, Middle and Back Office responsibilities as set forth herein
• Provide training to Board members to enhance oversight
2.2.7 Counterparty Credit Risk
Counterparty credit risk is the potential that a Counterparty will fail to perform or meet its obligations in accordance with terms agreed under contract. Pioneer’s exposure to counterparty credit risk is controlled by the limit controls set forth in the Credit Policy described in Section 6.
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2.2.8 Liquidity Risk
Pioneer manages liquidity risk through adherence to its loan and power purchase agreement credit covenants, limiting commitments to provide cash security consistent with its Credit Guidelines, ensuring it has adequate loan facilities, prudent cash and investment management, and adherence to its Reserve Policy.
Pioneer monitors its liquidity (defined as unrestricted cash, investments, and unused bank lines of credit) no less than weekly. Pioneer utilizes scenario and sensitivity analyses while preparing budget, rate, and pro forma analyses to identify potential financial outcomes and ensure sufficient liquidity under adverse conditions.
2.3 Risk Measurement Methodology
A vital element in Pioneer’s Energy Risk Management Policy is the regular identification, measurement, and communication of risk. Pioneer will routinely evaluate industry accepted benchmarks of quantified risk measurements to determine the applicability of such benchmark to Pioneer operations and performance. To effectively communicate risk, all risk management activities must be monitored frequently using risk measurement methodologies that quantify the risks associated with Pioneer’s energy procurement and performance relative to goals.
Risk measurement is the comparison of Pioneer’s projected retail rates to those of PG&E under expected and stressed scenarios. The rate comparison will be adjusted for actual and projected PCIA and Franchise Fee charges. Risk measurement methodologies shall be re-evaluated on a periodic basis to ensure Pioneer adjusts its methods to reflect the evolving regulatory and competitive landscape. The implementation of these methods shall be overseen and ratified by the Risk Oversight Committee (“ROC”).
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Section 3: BUSINESS PRACTICES
3.1 General Conduct
It is the policy of Pioneer that all personnel, including the Board, management, and agents, adhere to standards of integrity, ethics, conflicts of interest, compliance with statutory law and regulations and other applicable Pioneer standards of personal conduct while employed by or affiliated with Pioneer.
3.2 Trading for Personal Accounts
All Pioneer Directors, management, employees and agents participating in any transaction or activity within the coverage of this Policy are obligated to give notice in writing to Pioneer of any interest such person has in any counterparty that seeks to do business with Pioneer, and to identify any real or potential conflict of interest such person has or may have regarding any contract or transaction with Pioneer.
Conflicts of Interest shall be identified and defined as set forth in the Pioneer Conflict of Interest Code, as amended from time to time by the Board, which incorporates the Political Reform Act requirements for all employees advising Pioneer.
If there is any doubt as to whether a prohibited condition exists, then it is the employee’s responsibility to discuss the possible prohibited condition with her/his manager or supervisor.
3.3 Adherence to Statutory Requirements
Compliance is required with rules promulgated by the state of California, California Public Utilities Commission, California Energy Commission, Federal Energy Regulatory Commission (FERC), Commodity Futures Trading Commission (CFTC), and other regulatory agencies.
In addition to statutory requirements, the goals of the Energy Risk Policy are to comply with Governing Board's approved policies and objectives including the Strategic Plan, the Integrated Resource Plan ("IRP"), the Procurement Plan and Cash Reserve Policy including retail rate stability and competitiveness and the accumulation of financial reserves.
Congress, FERC, and CFTC have enacted laws, regulations and rules that prohibit, among other things, any action or course of conduct that actually or potentially operates as a fraud or deceit upon any person in connection with the purchase or sale of electric energy or transmission services. These laws also prohibit any person or entity from making any untrue statement of fact or omitting to state a material fact where the omission would make a statement misleading. Violation of these laws can lead to both civil and criminal actions against the individual involved, as well as 392143.2 12
Pioneer. This Policy is intended to comply with these laws, regulations, and rules and to avoid improper conduct on the part of anyone employed by Pioneer. These procedures may be modified from time to time by legal requirements, auditor recommendations, ROC requests and other considerations.
In the event of an investigation or inquiry by a regulatory agency, Pioneer may provide legal counsel to employees. However, Pioneer, with the consent of the Board, will not appoint legal counsel to an employee if Pioneer determines that the employee was not acting in good faith within the scope of employment.
3.4 Transaction Type, Regions, and Markets
Authorized transaction types, regions and markets are listed in Appendix A to this Policy. These transaction types, regions and markets are and shall continue to be focused on supporting Pioneer’s financial policies, including approved procurement strategies. New or non-standard transaction types may provide Pioneer with additional flexibility and opportunity but may also introduce new risks. Therefore, transaction types, regions and markets not included in Appendix A, or transactions within already approved transaction types that are substantially different from any prior transaction executed by Pioneer, must be approved by the ROC prior to execution using the process defined below.
When seeking approval for a new or non-standard transaction type, region, and/or market, a New Transaction Approval Form, as shown in Appendix B, should be drafted describing all significant elements of the proposed transaction. The proposal write-up should, at a minimum, include:
• A description of the benefit to Pioneer, including the purpose, function and expected cost impact (i.e., decrease costs, manage volatility, control variances, etc.);
• Identification of the in-house or external expertise that will manage and support the new or non- standard transaction type;
• Assessment of the transaction’s risks, including any material legal, tax or regulatory issues;
• How the exposures to the risks above will be managed; • Proposed valuation methodology (including pricing model, where appropriate); • Proposed reporting requirements, including any changes to existing procedures and system requirements necessary to support the new transaction type; • Proposed accounting methodology.
It is the responsibility of Pioneer’s Executive Director to ensure that relevant departments have reviewed the proposed transaction and that material issues are resolved prior to submittal to the ROC for approval. If approved, Appendix A to the Policy will be updated to reflect the new transaction type. 392143.2 13
3.5 Counterparty Suitability
Pioneer’s counterparty credit limits and approval processes will govern counterparty suitability for all transactions executed by Pioneer, consistent with the credit policies described in Section 6. Credit limits should be approved prior to execution of contracts.
3.6 System of Record
Pioneer will maintain a set of records for all transactions executed in association with Pioneer procurement activities. The records will be maintained in US dollars and transactions will be separately recorded and categorized by type of transaction.
This system of record shall be auditable.
3.7 Transaction Valuation
Transaction valuation and reporting of positions shall be based on objective, market-observed prices. Open positions should be valued (mark-to-market), based on consistent valuation methods and data sources. Whenever possible, mark-to-market valuations should be based on independent, publicly available market information and data sources.
3.8 Stress Testing
Stress testing shall also be used to examine the performance of the Pioneer portfolio under adverse conditions. Stress testing is used to understand the potential variability in Pioneer’s projected procurement costs, and resulting retail rate impacts and competitive positioning, associated with low probability events.
3.9 Trading Practices
It is the expressed intent of this Policy to prohibit the acquisition of risk beyond that encountered in the efficient optimization of Pioneer’s generation portfolio and execution of procurement strategies. As such, speculative transactions are prohibited. During developing operating plans and conducting procurement activities, Pioneer recognizes that expertise must be employed by staff, and it is not the intent of this Policy to restrain the legitimate application of analysis and market expertise in executing procurement strategies intended to minimize costs and risks within the constraints of this Policy. If any questions arise as to whether a transaction constitutes speculation, the ROC shall review the transaction(s) to determine whether the transaction would constitute speculation and document its findings.
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3.10 Policy Compliance
Pioneer’s Director of Finance and Administration will provide a quarterly report monitoring compliance with the limits established by this Policy. 392143.2 15
Section 4: ORG. STRUCTURE AND RESPONSIBILITIES
4.1 Risk Management Organizational Structure
Pioneer’s Energy Risk Management Policy ensures proper segregation of responsibility for policy approval, valuation and reporting, and trading.
4.2 Governing Board
Pioneer’s Board has the responsibility to review and approve this Policy. With approval, the Board assumes responsibility for understanding the risks Pioneer is exposed to due to CCA Program activity and how the policies outlined in this document help Pioneer manage the associated risks. The Board is also responsible to:
• Determine Pioneer’s strategic direction
• Understand the procurement strategy employed
• Approve risk exposures beyond the Executive Director’s authority
4.3 Risk Oversight Committee (“ROC”)
The ROC shall include the following voting members: Executive Director, Director of Finance and Administration, and General Counsel or their designees in case of their absence. The Technical Procurement Advisor (which may be an outside consultant or as otherwise selected by the Executive Director) shall be a non-voting member of the ROC. The Executive Director shall act as the chair of the ROC.
The ROC shall meet quarterly or as otherwise called to order by the Executive Director. The Executive Director shall make reports and seek approval for any substantive changes to this Policy from the Board.
The ROC shall from time to time adopt and bring current risk management guidelines defining in detail the internal controls, strategies, and processes for managing market risks incurred through or attendant upon wholesale trading, retail marketing, long-term contracting, CRR trading and load and generation scheduling.
The ROC shall specify the categories of transactions permitted and set risk limits for wholesale trading. The ROC shall receive and review information and reports regarding risk management, wholesale trading transactions, and the administration of supply contracts.
The ROC maintains the authority and responsibility to:
• Approve and ensure that all procurement strategies are consistent with this Policy;
• Determine if changes in procurement strategies are warranted; 392143.2 16
• Approve new transaction types, regions, markets and delivery points; • Understand financial and risk models;
• Understand counterparty credit review models and methods for setting and monitoring credit limits;
• Receive and review reports as described in this Policy; • Meet to review actual and projected financial results and potential risks; • Escalate to the Board with any risks beyond the Executive Director’s authority; • Review summaries of limit violations;
• Review the effectiveness of Pioneer's energy risk measurement methods; • Maintain this Policy; and
• Monitor regulatory and legislative activities.
4.4 Energy Procurement Review Committee (“EPRC”)
The EPRC is authorized to review and advise the Executive Director on the execution of energy contracts greater than five (5) years in length (from contract execution date). Long-term power (greater than five years) purchase agreements (“PPAs”) are periodically necessary to fulfill regulatory requirements (e.g., Renewables Portfolio Standard), and for portfolio optimization.
4.5 Segregation of Duties
Pioneer shall maintain a segregation of duties, also referred to as "separation of function", to the extent practicable to help manage and control the risks outlined in this Policy. Individuals responsible for legally binding the CCA to a transaction will not perform confirmation, clearing or settlement functions. Pioneer staff roles and responsibilities are divided into front-middle-back-office activities, as described below. In executing these functions, Pioneer may rely on third-party to assist in performing various functions to preserve the intent of the separation of functions.
4.5.1 Front Office
The Front Office is the responsibility of the Chief Operating Officer.
The Front Office has overall responsibility for:
a) Managing all commodity transactions;
b) Analysis of fundamentals affecting Pioneer’s net position; and c) Transacting within the limits of this Policy, and associated policies, to balance loads and resources, and maximize the value of Pioneer’s assets through the exercise of approved optimization strategies.
Other duties associated with these responsibilities include:
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a) Develop and analyze hedging products and procurement strategies and bring recommendations to the ROC, utilizing the net forward power positions prepared by Middle Office
b) Prepare each month a monthly operating plan for the prompt months that gives direction to the day-ahead and real-time trading and scheduling staff regarding the bidding and scheduling of Pioneer's resource portfolio in the California Independent System Operator (“CAISO”) market c) Develop, price, and negotiate purchase and/or sale transactions for energy Resource Adequacy, renewable, green-house gas free energy d) Keep accurate records of all transactions
4.5.2 Middle Office
The Middle Office is the responsibility of the Director of Finance and Administration.
The Middle Office provides independent market and credit risk oversight.
The Middle Office has primary responsibility for trading controls, including forward trading. Primary responsibilities include:
a) Calculating and maintaining the short-term load forecasts and disseminating to Front and Back Office
b) Estimating and publishing forward monthly power price curves for a minimum of the balance of the current year through the next calendar year c) Ensuring that Pioneer adheres to all risk policies and procedures in letter and intent.
d) Calculating and maintaining the net forward power positions of Pioneer. e) Assisting Back Office in calculating Counterparty Credit Exposure.
4.5.3 Back Office
The Back Office is the responsibility of the Director of Finance and Administration.
The Back Office provides support with a wide range of administrative activities necessary to execute and settle transactions and to support the risk control efforts (e.g., transaction entry and/or checking, data collection, billing, etc.) consistent with this Policy.
The Back Office has primary responsibility for ensuring agreement with counterparties regarding the terms of all trades, including forward trading. Primary responsibilities include:
a) Handling confirmation of all transactions (physical and financial) and reconciling differences with the trading counterparties b) Reviewing transaction confirmations for adherence to approved limits c) Calculating a monthly Counterparty Credit Exposure report d) Ensuring all trades have been entered into the appropriate system of record 392143.2 18
e) Carrying out month-end checkout of all physical and financial transactions each month
f) Implementing and enforcing credit policies and limits 392143.2 19
Section 5: DELEGATION OF AUTHORITY
With the approval of the Policy, the Pioneer Board is explicitly delegating approval of transactions to the Executive Director, in consultation with the EPRC, as outlined in the following table:
Authority Contract or PPA
Term Limit
Executive Director after
recommendation from the Energy
Procurement Review Committee
Over 60 months1
Executive Director Up to 60 months
Additionally, to adapt to changing market conditions and to facilitate the daily operations of Pioneer, the Board is delegating authority to the Executive Director to execute administrative amendments to duly approved transactions where such amendment does not exceed the Executive Director’s delegated authority as set forth above (for clarity, amendments exceeding Term limits shall require consultation with the EPRC) and further reduces Pioneer’s risk in furtherance of this Policy. Such administrative amendments must be reported at the next available ROC meeting.
All procurement executed under the delegation above must align with the Pioneer’s underlying risk exposure (locational, volume and temporal) that is being hedged consistent with the approved Procurement Strategy.
The point of delivery for all products must be at a location on the CAISO transmission grid.
5.1 Hedging Tolerances
The Front Office is responsible for managing portfolio risks within the limits of this Policy. To reduce market price risk and increase retail rate certainty Front Office will execute transactions based on the following hedge targets.
5.1.1 Energy Procurement Tolerances
Period Minimum
Coverage*
Fiscal Year % of Forecasted Load
1 Pursuant to Resolution 2025-__, the Executive Director/CEO or designee may execute individual Power Purchase Agreements, contracts, or confirmations not exceeding 1.5% of Pioneer’s annual procurement budget as a maximum annual notional amount, together with a maximum 20-year term, without the EPRC’s consideration. 392143.2 20
Year 1 (Current Year) 90%
Year 2 70%
Year 3 50%
Year 4 30%
Year 5 10%
*Prior to start of Current Year
5.1.2 Renewable Portfolio Standard
With respect to purchases to meet the Renewable Portfolio Standard (RPS), Pioneer must comply with regulatory requirements and is guided by the Board for purchases above those requirements. Pioneer purchases should be staggered to accommodate regulatory uncertainty and changes in load and supply price risks, as well as diversified with respect to technologies.
5.1.3 Resource Adequacy
Pioneer must comply with the regulatory requirements for procurement of capacity products for Resource Adequacy ("RA"). Pioneer must comply for local resource adequacy for one to three years by October 31st of each year. Additionally, Pioneer must demonstrate, on a month-ahead basis, full compliance with its monthly RA obligations. Pioneer endeavors to purchase RA products over time to meet its obligations and to diversify its purchases between suppliers and market conditions.
5.2 Monitoring, Reporting and Instances of Exceeding Risk Limits The Middle Office is responsible for monitoring, and reporting compliance with, all limits within this Policy. If a limit or control is violated, the Middle Office will send notification to the Executive Director, Chief Operating Officer, and the ROC. The ROC will discuss the cause and potential remediation of the exceedance to determine next steps for curing the exceedance.
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Section 6: CREDIT POLICY
All Counterparties shall be evaluated for creditworthiness by the Middle Office prior to execution of any transaction and no less than annually thereafter. Additionally, Counterparties shall be reviewed if a change has occurred, or perceived to have occurred, in market conditions or in a company’s management or financial condition. This evaluation, including any recommended increase or decrease to a credit limit, shall be documented, and inclusive of all information supporting such evaluation in a credit file for the counterparty. A credit limit for a Counterparty will not be recommended or approved without first confirming the Counterparty’s senior unsecured or corporate credit rating from one of the nationally recognized rating agencies and/or performing a credit review or analysis of the Counterparty’s or guarantor’s financial statements. The credit analysis shall include, at a minimum, current audited financial statements or other supplementary data that indicates financial strength commensurate with an investment grade rating. Trade and banking references, and any other pertinent information, may also be used in the review process.
Once a counterparty is determined to be creditworthy, a credit limit will be proposed. Although a counterparty may qualify for a certain maximum credit limit, anticipated transaction volumes and other business factors may prompt Pioneer to select a lower limit that is considered more appropriate.
Counterparties that do not qualify for an unsecured Credit Limit must post an acceptable form of credit support or Prepayment prior to the execution of any transaction, unless otherwise approved by the Executive Director. A Counterparty may choose to provide a guarantee from a third party, provided the third party satisfies the criteria for a Credit Limit as outlined herein.
6.1 Counterparty Credit Risk
Pioneer evaluates and monitors the financial strength of service and energy providers consistent with Pioneer’s Credit Guidelines.
392143.2 22
6.2 Counterparty Concentration
In addition to maintaining credit exposure limits, Pioneer staff shall strive to diversify transactions among counterparties. Pioneer staff shall document the business reasons (e.g., differences in offer price, lack of qualified suppliers, etc.) for awarding additional contracts to counterparties with high concentrations of Credit Exposure.
6.3 Credit Review Exceptions
Counterparties not subject to the above credit review criteria include those associated with day-ahead and current day purchases or market index-based contracts where risks associated with market movements are minimal.
6.4 Credit Exposure and Monitoring
The Back Office will monitor the current credit exposure for each Counterparty with whom Pioneer transacts and include such information in the quarterly Risk Management Report. This report will be made available, reviewed, and communicated to the ROC pursuant to the reporting requirements outlined in Section 7.
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Section 7: POSITION TRACKING AND MANAGEMENT REPORTING
Minimum reporting requirements are shown below. The reports outlined below will be made available to ROC members:
• Quarterly Financial Model Forecast
Latest projected financial performance, marked to current market prices, and shown relative to financial goals.
• Quarterly Net Position Report
Prepare a forward net position report, not less frequently than quarterly, and report the results to the ROC.
• Quarterly Report to the Board
Update on activities and projected financial performance to be presented least quarterly at Pioneer Board meetings.
Quarterly Counterparty Credit Exposure
Updates on the notional and mark-to-market exposure to each Pioneer counterparty individually by deal and in aggregate by counterparty.
Counterparty credit exposure reporting includes contingent collateral posting risks arising from changes in market prices and other factors. • Counterparty Credit Exposure
This report will show credit exposures for transactions executed by Pioneer. • Risk Analysis
This will include a stress test of financial forecast relative to financial goals. 392143.2 24
Section 8: POLICY REVISION PROCESS
Pioneer’s Energy Risk Management Policy will evolve over time as market and business factors change. At least on an annual basis, the ROC will review this Policy and associated procedures to determine if they should be amended, supplemented, or updated to account for changing business and/or regulatory requirements. If an amendment is warranted, the Policy amendment will be submitted to the Pioneer Board for approval.
8.1 Acknowledgement of Policy
Any Pioneer employee participating in any activity or transaction within the scope of this Policy shall sign on an annual basis or upon any revision, a statement approved by the ROC that such employee:
• Has read Pioneer’s Energy Risk Management Policy
• Understands the terms and agreements of said Policy
• Will comply with said Policy
• Understands that any violation of said Policy shall be subject to employee discipline up to and including termination of employment.
8.2 Policy Interpretations
Questions about the interpretation of any matters of this Policy should be referred to the Executive Director. All legal matters stemming from this Policy will be referred to General Counsel.
392143.2 25
Appendix A: AUTHORIZED TRANSACTION TYPES, REGIONS, AND
MARKETS
All transaction types listed below must be executed within the limits set forth in this Policy or Credit Risk Guidelines.
Over the Counter Products
CAISO Market Products
o Day-ahead and Real-time Energy
o Congestion Revenue Rights
o Convergence bids
o Inter Scheduling Coordinator Transactions
o Tagging into and out of CAISO
Physical Power Products
o Power
o Physical Resource Adequacy Capacity
Physical Transmission Products
o Physical WECC transmission
Physical Environmental Products
o Renewable Energy Credits
o Specified Source Power
o Carbon Allowances and Obligations
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Appendix B: NEW TRANSACTION APPROVAL FORM
New or Non-Standard Transaction
Approval Form
Prepared By:
Date:
New or Non-Standard Transaction Name:
Business Rationale and Risk Assessment:
Product description – including the purpose, function, expected impact on net revenues (i.e. increase, manage volatility, control variances, etc.) and/or benefit to Pioneer
Identification of the in-house or external expertise that will be relied upon to manage and support the new or non-standard transaction
Assessment of the transaction’s risks, including any material legal, tax or regulatory issues
How the exposures to the risks above will be managed by the limit structure Proposed valuation methodology (including pricing model, where appropriate) Proposed reporting requirements, including any changes to existing procedures and system requirements necessary to support the new product
Proposed accounting methodology
Proposed Middle Office workflows/methodology, including systems Brief description of the responsibilities of various departments within Pioneer who will have any manner of contact with the new or non-standard transaction Reviewed by:
Chief Operating Officer Date
392143.2 27
General Counsel Date
Executive Director Date
Appendix C: DEFINITIONS
Back Office: That part of a trading organization which manages transaction accounting, confirmations, management reporting, contract administration and working capital management.
Bilateral Transaction: Any physical or financial transaction between two counterparties, neither of whom is an Exchange or market entity such as CAISO.
Cash Flow at Risk: A measure of the potential shortfall in cash flow from a specified level during a specified period of time at a specified confidence level.
CAISO: California Independent System Operator. CAISO operates a California bulk power transmission grid, administers the State’s wholesale electricity markets, and provides reliability planning and generation dispatch.
CCA: Community Choice Aggregator. CCAs allow local government agencies such as cities and/or counties to purchase and/or develop generation supplies on behalf of their residents, businesses, and municipal accounts.
CFTC: Commodity Futures Trading Commission. The CFTC is a U.S. federal agency that is responsible for regulating commodity futures and swap markets. It goals include the promotion of competitive and efficient futures markets and the protection of investors against manipulation, abusive trade practices and fraud.
Clearing: Clearing is the process of reconciling purchases and sales of a commodity, as well as the direct transfer of funds from one financial institution to another. The process validates the availability of funds, records the transfer, and in the case of financial securities, ensures the delivery to the buyer.
Commodity: A basic good used in commerce that is interchangeable with other commodities of the same type. Commodities are most often used as inputs in the production of other goods or services. The quality of a given commodity may differ slightly, but it is essentially uniform across producers. When they are traded on an exchange, commodities must also meet specified minimum standards, also known as 392143.2 28
a basis grade.
Confirmation Letter: A letter agreement between two counterparties that details the specific commercial terms (e.g., price, quantity and point of delivery) of a transaction.
Congestion Revenue Right: A point-to-point financial instrument in the Day-Ahead Energy Market that entitles the holder to receive compensation for or requires the holder to pay certain congestion related transmission charges that arise when the transmission system is congested.
Counterparty Credit Risk: The risk of financial loss resulting from a counterparty to a transaction failing to fulfill its obligations.
Counterparty Credit Exposure: This measures the known exposures and is represented by the sum of both (a)Realized exposure and (b) Forward exposure, as those terms are defined below:
Realized exposure: payable or receivable amount owed between counterparties, is a measurement of cash flow for billed and unbilled transactions.
Forward exposure: measure of current unrealized exposure and includes the measure of a counterparty’s incentive to fulfill contractual obligations. Forward exposure measures the risk associated with having a payment default or the need to replace a transaction in the event of delivery default.
Day-ahead Market: The short-term forward market for efficiently allocating transmission capacity and facilitating purchases and sales of energy and scheduled bilateral transactions; conducted by CAISO prior to the operating day.
Delivery point: the point at which a commodity will be delivered and received.
FERC: Federal Energy Regulatory Commission. FERC is a federal agency that regulates the interstate transmission of electricity, natural gas, and oil. FERC also reviews proposals to build liquefied natural gas terminals, interstate natural gas pipelines, as well as licenses hydroelectric generation projects.
Front Office: That part of a trading organization which solicits customer business, services existing customers, executes trades and ensures the physical delivery of commodities.
Hedging products: Hedging products means capacity, energy, renewable energy credits or other products related to a specific transaction.
Hedging Transaction: A transaction designed to reduce the financial exposure of a 392143.2 29
specific outstanding position or portfolio; “fully hedged” equates to complete elimination of the targeted risk and “partially hedged” implies a risk reduction of less than 100%.
IOU: An Investor-Owned Utility (IOU) is a business organization providing electrical and/or natural gas services to both retail and wholesale consumers and is managed as a private enterprise.
Middle Office: That part of a trading organization that measures and reports on market risks, develops risk management policies, and monitors compliance with those policies, manages credit, and keeps management and the Board informed on risk management issues.
Speculation: Speculation is the act of trading an asset with the expectation of realizing financial gain resulting from a change in price in the asset being transacted.
Staff Report – Item 2
To: The Governing Board
From: Donald Eckert Jr., Chief Executive Officer
Item 2: Presentation by Dr. Faruqui on Energy Issues Impacting California Date: 7/10/2025
RECOMMENDATION
Receive a presentation from our guest speaker, Dr. Ahmad Faruqui, on a variety of topics impacting California’s electricity markets.
BACKGROUND
Pioneer staff were introduced to Dr. Faruqui at a municipal rates symposium hosted by Sacramento Municipal Utility District in May 2024. Subsequently, Dr. Faruqui was invited to speak at the June 2024 Board meeting on the state of the California energy market with an emphasis on the Income Graduated Fixed Charge.
Staff are pleased to bring back Dr. Faruqui in 2025 with updates on issues impacting electricity affordability.
ANALYSIS & DISCUSSION
Ahmad has 45 years of consulting, teaching and research experience in rate design, load flexibility, energy efficiency, demand response, distributed energy resources, demand forecasting, decarbonization, and electrification. He has worked for over 150 clients on five continents and testified or appeared one hundred times before regulatory bodies, governments, and legislative councils on six continents.
He has authored or coauthored more than one hundred papers in peer-reviewed and trade journals and co-edited books on industrial structural change, customer choice, and electricity pricing. His work has been cited in Bloomberg, Business Week, The Economist, and Forbes, and in Los Angeles Times, Mercury News, San Francisco Chronicle, New York Times, San Diego Union-Tribune, Sacramento Bee, and the Washington Post. He has appeared on NPR and Fox Business News.
Dr. Faruqui has taught economics at San Jose State, UC Davis and the University of Karachi and delivered guest lectures at Carnegie Mellon, Harvard, Idaho, MIT, New York, Northwestern, Rutgers, San Francisco, Stanford, and UC Berkeley. He holds an MA in Agriculture Economics and a PhD in Economics from UC Davis, and a BA and an MA in Economics from the University of Karachi, Pakistan.
STRATEGIC PLAN
The recommendation supports the Be a Community Partner goal.
FISCAL IMPACT
There is no fiscal impact with the recommendation.
ATTACHMENTS
There are no attachments to the recommendation.
Plf)NEER
COMMUNITY ENERGY
Staff Report – Item 3
To: The Governing Board
From: Sam Kang, Chief Operating Officer
Gina Stassi-Vanacore, Director of Communications
Item 3: Update on Expansion Efforts and Planning for October 2027 Service Launch Date: 7/10/2025
RECOMMENDATION
Receive an update on expansion efforts and an overview of planning for an October 2027 service launch.
BACKGROUND
At the February 27, 2025, Pioneer Community Energy (“Pioneer”) Board of Directors (“Board”) meeting, The Board adopted a Resolution Approving Amendment No. 7 to the Amended and Restated Joint Exercise of Powers Agreement (“JPA”) Expanding Pioneer’s Joint Powers Authority Membership.
On March 11, in compliance with Public Utilities Code (“PUC”) section 366(c)(3), Pioneer filed Addendum No. 3 to the Community Choice Implementation Plan and Statement of Intent (“Implementation Plan”) with the California Public Utilities Commission (“CPUC”) addressing Pioneer’s expansion into the cities of Chico, Live Oak, Orland, Oroville, Sonora, Willows, and Yuba City, the Town of Paradise, and Unincorporated Counties of Butte, Glenn, Nevada, Sutter, and Tuolumne with a service launch in October 2027.
On June 9, 2025, the CPUC certified the Implementation Plan. Staff immediately began the administrative processes needed to file required documents with the California Secretary of State ad State Controller’s Office, which include securing a signed intent to join Pioneer from each new member. As of the date of this report, all potential new members will have provided the required documents.
This expansion will more than double our electrical load to serve and number of customer accounts and make Pioneer geographically the largest Community Choice Aggregator (CCA) in California.
ANALYSIS & DISCUSSION
Among the primary considerations for the Board related to expansion is ensuring there are 1) sufficient power resources to serve the expansion and 2) adequate staffing and planning for a successful launch that leads to a strong participation rate.
Procurement: As a community choice aggregator and load-serving entity, Pioneer procures power on behalf its customers that accounts for over 90% of Pioneer’s operating costs. In order to meet the renewable energy (RECs) and resource adequacy (RA) compliance requirements for its future customers from the expansion, Pioneer has been actively negotiating power purchase agreements (PPAs) totaling over 1,500,000 MWhs of energy/RECs and 500 MWs of RA with 7 unique counterparties. Some PPAs have been executed, and all should be completed by the end of July.
Communications and Outreach: While local leaders in each of the territories are aware of Pioneer and its benefits to customers, staff believe the general public has limited or no familiarity with Pioneer. As such, staff already are doing research into stakeholders, influencers, and the most effective communications mediums in each of the new territories to ensure a strong, accurate, and consistent flow of information during the next 27 months.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: 3 Agenda Date: 7/10/2025
The table below shows representative planning for the October 2027 service launch, with early research taking place to understand the nuances, sensitivities, and unique needs of each territory. Communications activity ramps up over time, culminating multi-dimensional communications and community outreach efforts throughout 2027 with more frequent and comprehensive information leading up to the launch. The general approach will be similar to what took place leading up to the January 2024 service launch in Grass Valley and Nevada City, which resulted in a 97.2 percent participation rate.
Specific details are to be determined once additional information is received and as the service launch draws closer.
2025:
Research and Planning
2026:
Conditioning the Environment
& Plan Development
2027:
Implementation &
Real-Time Response
Learning the landscape and
prioritizing outreach efforts
Focus on education and
awareness
Execute communications and
ground campaigns
Research
ID stakeholders, influencers,
and community organizations
for engagement
Initial planning for 2026
Develop comms campaign (Q2)
Marketing
Earned media
Outreach priorities
Sponsorship
Social media groups and
regional influencers
Direct mail campaign begins
“We are coming!” (Q1)
“How Pioneer Works” (Q2)
“Q&A/what bill will look like”
(Q3)
“We are here/programs focus”
(Q4)
Meet with leadership of all 13
expansion jurisdictions to reaffirm
joining Pioneer
Presentations at public meetings;
respond to questions
Secure speaking opportunities
Town Hall meetings (February
– March)
Civic/Fraternal group
meetings (April – October)
Business and civic groups
- Fraternal orgs (veterans)
- HOAs
- Senior groups
Develop comprehensive media
and newsletter lists
Initial outreach to local media:
press releases; offer background
briefings
Earned media outreach
Develop comprehensive media
Background briefings for all
local media outlets
Targeted social media
campaign
Public affairs programming
opportunities
Earned media push
Develop and pitch story angles
o Announce new Board
members
o Service is coming
Proactive media outreach and
story placement
Media response and
commentary
Join local Chambers
Chico
Oroville
Paradise Ridge
Orland
Willows
Yuba Sutter
Live Oak
South Nevada County
Tuolumne County
Sonora
Cultivate speaking opportunities
with key community organizations
and chambers
Renew sponsorships
Paid media
(Theme: Coming in October 2027)
Paid media campaign: brand
awareness (April – October)
Radio
Outdoor
Local print
Digital
Agenda Item: 3 Agenda Date: 7/10/2025
Social
Social media monitoring Social media monitoring and
management
Social media monitoring,
management, and engagement
STRATEGIC PLAN
The report supports the Fiscally Strong & Resilient goal.
FISCAL IMPACT
Pioneer conducted an Impact Assessment Study to determine the financial feasibility of expansion. The study considered projected costs compared to current rates to ensure existing ratepayers are not subsidizing future ratepayers. The study was the first step in the expansion process and concluded to avoid existing ratepayer subsidization, the launch occurs in October 2027. The expansion has a net positive impact on Pioneer’s balance sheet.
ATTACHMENTS
There are no attachments to the report.
Staff Report – Item 4
To: The Governing Board
From: Devin Reaves, Power Resources Manager
Item 4: Update on Power Markets and Energy Procurement
Date: 7/10/2025
RECOMMENDATION
Receive an update on power markets and energy procurement.
BACKGROUND
Energy Procurement accounts for over 90% of Pioneer Community Energy’s (Pioneer) operating costs and has been extremely volatile in the past couple of years. Staff have assembled this report in order to provide an update on the state of the power markets, to explain the reasons for the increased market volatility, and to provide updates on energy procurement including power purchase agreements (PPAs) for the expansion, biomass projects, and asset optimization results.
In the 2021-2024 time period, increased demand for renewable energy credits (RECs) and resource adequacy (RA) in an already scarce California market due to legislative and regulatory requirements were primarily driven by California Senate Bills (SB) 350 and 100 (requiring minimum renewable energy purchases), and California Public Utilities Commission decisions on resource adequacy. SB 350 increased California's renewable electricity procurement goal from 33% by 2020 to 50% by 2030 with incremental increases on an annual basis and required that 65% of a load-serving entities’ (LSE) entire portfolio come from renewable resources on a compliance period basis.
• SB 350 formally defines three new Compliance Periods:
• Compliance Period 4: 2021-2024, four years
• Compliance Period 5: 2025-2027, three years
• Compliance Period 6: 2028-2030, three years
• SB 100 established a policy increasing renewable electricity procurement goal to 60% by 2030 and requiring renewable energy and zero-carbon resources supply 100 percent of electric retail sales to end-use customers by 2045.
• The California Public Utilities Commission (CPUC) requires all LSEs to procure their load share amount of resource adequacy on an annual basis.
• CPUC Decision 10-11-016 (Nov-2019) assigned an incremental 3,300 MW shared by all LSEs (18.5 MW for Pioneer)
• CPUC D.21-06-035 Mid-Term Reliability (MTR) (June 2021) assigned an incremental 11,500 MW (70 MW for Pioneer)
• Decision D.23-02-040 (February 2023) Updating and Adding to D.21-06-035 MTR Procurement Requirements assigned an incremental 4,000 MW (38 MW for Pioneer) • The CPUC has most recently developed reforms to its processes, including a “slice-of-day” resource adequacy program designed to ensure that load-serving entities procure sufficient resources to meet peak demand and charge system batteries after solar energy declines at the end of the day. Specifically, the CPUC’s 24-hour slice-of-day framework requires each load-serving entity to demonstrate enough capacity to satisfy its specific gross load profile — including a planning reserve margin — in all 24 hours on the ISO’s “worst day” of each month.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: 4 Agenda Date: 7/10/2025
“Worst day” is defined as the day of the month that contains the hour with the highest peak load forecast. The SOD compliance requirement begins in 2025.
Since then, there has been a massive shift in pricing from 2024 and 2025 in the REC and RA markets. In 2024 Pioneer experienced all-time highs in both markets, with pricing at $90/MWh for a portfolio content category 1 (PCC1) bucket REC and calendar year 2024 (CAL 24) RA strip going for $30/kW-mo. A year later, today we are seeing 2022-23 level pricing with PCC1s at mid to low $20/MWh and CAL 26 RA strip at $10-$11/kW-mo.
Being compliant with legislative and regulatory requirements is very important to Pioneer, as it saves us tens of millions of dollars in avoided cost penalties. Even in these volatile market prices and scarce resource environment, Pioneer has managed to remain compliant in all categories. Pioneer has also made great progress on meeting its D.21-06-035 and D.23-02-040 requirements as will be further discussed below.
ANALYSIS & DISCUSSION
Pioneer procures three types of energy products, namely California Independent System Operator (CAISO) Energy (Energy), RECs and RA. The following are updates on the respective markets.
Energy Markets
After another mild summer in 2024, forward Energy Prices have been on a decline. The reasons for the decline of CAISO Energy includes:
• Mild Weather Continuing
• Above average hydro production
• Battery penetration onto grid
• Cheap Natural Gas and Gas Storage surplus
The table below shows the year over year change of the forward curve for the time frame of June 2025 - May 2026, from snapshots taken between June 2024 – June 2025. The forward curve shows a decline in prices since the summer of 2024. The mild weather and strong supply stack, stated above, are the main drivers behind the decline in prices.
$-
$20.00
$40.00
$60.00
$80.00
$100.00
$120.00 $/MWh
CAISO Energy Prices (NP 15)
Jun-24 Sep-24 Dec-24 Mar-25 Jun-25
-
Agenda Item: 4 Agenda Date: 7/10/2025
Renewables Portfolio Standard (RPS) Market
The RPS market has fallen dramatically from the all-time highs Pioneer experienced last year. The current price quote for a PCC1 bucket REC is in the mid-low $20/MWh, whereas this time last year pricing was seen around $90/MWh. In the table below, pricing has come down to levels that were seen almost 3 years ago.
In last year’s report, Pioneer discussed that pricing could start seeing relief once project delays begin to resolve.
That is what is happening now. With the continued buildout of California’s renewable energy stack no longer running into delays, the market has been flooded with RECs. This led to the large drop in pricing that is being seen now. The supply is outpacing the demand and unless there are changes legislatively/regulatory than the pricing will remain.
RA Market
The RA market has also experienced a large drop in pricing from last year. Like RECs, project delays beginning to resolve are bringing more RA into the market. Another big reason is there is more clarity on the Slice-of-Day (SOD) RA framework since it has been implemented. Pioneer suspects that any LSEs that may have had excess RA last year, held onto their length because there were still many unknows with SOD. Now that SOD has been around for a year LSEs feel more comfortable selling off any RA length, bringing more RA into the market. $-
$10
$20
$30
$40
$50
$60
$70
$80
$90
$100
Jan 2023 May 2023 Sep 2024 June 2025
PCC1 Renewable Energy Prices ($/MWh)
$-
$20.00
$40.00
$60.00
$80.00
$100.00
$120.00
$140.00
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Resource Adequacy Prices ($/kW-mo)
Jan 2023 Oct 2023 June 2024
- June 2025
Agenda Item: 4 Agenda Date: 7/10/2025
Forward pricing shows a slight upward trend in pricing. Where calendar year 2026 (CAL 26) is pricing $11/kW-mo and CAL 27 is at $17/kW-mo. This is mostly driven by the Year Ahead compliance deadline and is not reflective of how much RA is in the market.
Regulatory Compliance
Pioneer works hard to be compliant with all the Legislative and Regulatory requirements from agencies such as the CPUC and California Energy Commission. Pioneer has continued to stay in full compliance to save tens of millions of dollars in avoided cost penalties. Below is a list of the important compliance filings that Pioneer must complete:
Resource Adequacy
Year Ahead Load Forecast
Monthly Load Forecast Update
Year Ahead Compliance Demonstration, System RA
Year Ahead Compliance Demonstration, Flexible RA
Historical load data, annual
Monthly Compliance Demonstration, System and Flexible RA. Year Ahead RA Plan
Monthly RA Plan
Annual Flexible Capacity Needs Assessment
MIC Expansion Request
New Use Import Commitment
Local RA participation in Central Procurement Entity (CPE) showings/auctions CAISO Maximum Import Capability Allocation Process
Renewables Portfolio Standards
Annual RPS Compliance Report
WREGIS REC Retirement Report
Periodic Certificate Retirement (ongoing; not specific to a compliance program) Compliance Report Verification
RPS Procurement Plan data templates and select portions of narrative WREGIS account management, certificate transfer review and retirement.
Power Source Disclosure Program
Annual Report: Power Source Disclosure Program
Annual Power Source Disclosure Report and Power Content Label Attestation Annual Power Content Label
Quarterly Fuels and Energy Reports (QFER)
CEC-1306B - Load Serving Entity (LSE) Quarterly Report US Energy Information Agency
EIA 861M
o EIA 861
Integrated Energy Policy Report (IEPR)
IEPR Demand Forecast (Biennial)
IEPR Resource Plans (Biennial)
Integrated Resource Plan
Load forecast comments and adjustments
IRP data templates and select portions of plan narrative D.19-11-016 and D.21-06-035 Mid-Term Reliability Procurement data template updates Joint Rate Comparison
Joint Rate Comparison
Joint Rate Comparison and Joint Rate Mailer
Agenda Item: 4 Agenda Date: 7/10/2025
PCIA Price Reporting
PCIA Resource Adequacy Price Data Request
PCIA RPS Price Data Request
Annual Emission Performance Standard Compliance Filing
Contracts and compliance category for all contracts with terms of five years or longer Pioneer has recently submitted its IRP update for the Mid Term Reliability Decisions (D.21-06-035/D.23-02- 040) and is making great progress to meeting all of its requirements.
The table above shows Pioneer’s obligations for D.21-06-035 and D.23-02-040. The green cells show Pioneer has met their requirements and the yellow cells are open positions but are close to being filled. The requirement is that for each year Pioneer must procure the corresponding amount of MWs under a new build long-term power purchase agreement (PPA). Other than 2023, the online date or commercial operation date (COD) for the new build PPAs must be June 1st of each corresponding year (Example: Pioneer procured 19MWs in 2026 that had an online date of 6/1/2026 or before). Pioneer is in a great position to fulfill the rest of its requirements and is confident that it will continue to stay compliant.
Procurement for Expansion Communities
In order to meet the REC and RA compliance requirements as well as securing energy for its future customers, Pioneer has been actively negotiating PPAs totaling over 1,500,000 MWhs and 500 MWs of RA with 7 unique counterparties. Some PPAs have been executed, and all should be completed by the end of July. Approximately $2.5 billion in notional value will be considered for a prepay transaction that could save tens of millions of dollars annually for Pioneer customers.
Biomass Projects
Pioneer continues to work on developing biomass projects. Two projects that are under active development include one in Grass Valley with West Biofuels, and one at the Western Placer County Waste Management Authority with Wisewood Energy. Other projects that are in discussions or in the pipeline include projects in Anderson, Oroville, Mt. Lassen, and Georgetown (via Microgrid Incentive Program).
If all goes well, Pioneer expects the Grass Valley project to come online in 2026, helping to reduce fire-hazardous woody biomass from Grass Valley and the surrounding areas, providing much needed baseload renewable energy to the grid, and creating local jobs. The other projects are in varying stages of development.
Feed In Tariff
In November 2023, Pioneer’s Board approved a feed-in-tariff (FIT) specifically tailored towards local procurement of biomass and small hydroelectricity in its service territory. A few biomass projects have shown promise, but issues including sizing and pricing remain a constraint based on the current FIT parameters for projects to move forward.
To foster more engagement with the program an amendment was made to allow for RA-only contracts with standalone battery storage (BESS) contracts. Pioneer may need to add a full toll (energy and RA) contract price for BESS to allow more pricing options to developers.
CPUC DECISION 2023 2024 2025 2026 2027 2028
D.21-06-035 MTR Requirement in NQC MWs 12 37 9 6 6
Diablo Canyon Replacement *included in the 37MW 15 8-Hour Battery Biomass D.23-02-040 Requirement in NQC MWs 19 19
Agenda Item: 4 Agenda Date: 7/10/2025
Asset Optimization
In September 2023 the Pioneer Board approved the use of NextEra Analytics portfolio optimization software to maximize the day-ahead, real-time, and ancillary services of the Yellow Pine PPA consisting of solar plus battery storage. Measured on an annual basis beginning in May 2024, as of the end of May 2025, the software enabled Pioneer to realize approximately $2.9 million in incremental value.
Pioneer is utilizing cQuant software for PPA valuations and slice of day reporting purposes, among other things, and continues to seek out software to help manage and optimize its portfolio.
FISCAL IMPACT
None.
Staff Report – Item 5
To: The Governing Board
From: Donald Eckert Jr., Chief Executive Officer
Item 5: Adopt Resolution Honoring the Memory of Dan Karleskint Date: 7/10/2025
RECOMMENDATION
Adopt Resolution honoring the memory of former Director Dan Karleskint for his contributions to the success of Pioneer Community Energy (“Pioneer”) and his outstanding service to the community.
BACKGROUND
The City of Lincoln City Council appointed Mr. Karleskint as Director to Pioneer’s Governing Board in December 2017. During his tenure on the Board, Mr. Karleskint also served on the Audit & Finance Committee and Expansion Committee.
ANALYSIS & DISCUSSION
Mr. Karleskint passed away on June 22, 2025. Mr. Karleskint was one of Pioneer’s original Board Directors and guided Pioneer through its challenging early years and continued to serve until his retirement in November 2024.
Mr. Karleskint’s business acumen, creative thinking and leadership directly impacted Pioneer and contributed to Pioneer’s success. Mr. Karleskint always made decisions in the best interest of the ratepayers while strengthening Pioneer’s financial resiliency.
STRATEGIC PLAN
The report supports the Be a Community Partner goal.
FISCAL IMPACT
There is no fiscal impact from the recommendation.
ATTACHMENTS
1. Resolution Honoring the Memory of Former Board Director Dan Karleskint.
Plf)NEER
COMMUNITY ENERGY
Before the Governing Board of
Pioneer Community Energy
Resolution No.: ____________
The following Resolution was duly passed by the Governing Board of Pioneer Community Energy at a regular meeting held July 10, 2025, by the following vote on roll call:
Ayes:
Noes:
Absent:
Signed and approved by me after its passage.
______________________________
Chair of the Governing Board
Attest:
_______________________
Secretary
WHEREAS, Dan Karleskint passed away on June 22, 2025; and WHEREAS, the City of Lincoln City Council appointed Mr. Karleskint as Director to Pioneer Community Energy’s Governing Board beginning December 2017 and was active on the Pioneer Community Board from its initial launch until his retirement from public service in November 2024; and
WHEREAS, Mr. Karleskint also served on the Audit & Finance Committee, and the Expansion Committee of Pioneer Community Energy during his tenure; and WHEREAS, throughout his tenure on this Board, Mr. Karleskint brought his astute business judgement, his humor, the benefit of his experience, and his ability as a leader to set ambitious goals to inspire staff to follow and contributed to Pioneer Community Energy’s success; and WHEREAS, the Pioneer Community Energy Governing Board honors the memory of Mr. Dan Karleskint, recalling fondly of his life of purpose and commitment and his many valuable contributions to his community.
In the matter of: RESOLUTION HONORING
THE MEMBORY OF FORMER BOARD
DIRECTOR DAN KARLESKINT
2 BE IT RESOLVED, the Governing Board of Pioneer Community Energy, State of California, hereby finds, declares, and resolves as follows:
1. The above recitals are true and correct.
2. The Governing Board hereby celebrates the life and accomplishments of Mr. Dan Karleskint and expresses its admiration for a life well lived.
3. The Governing Board also extends our sympathy and condolences to Mr.
Karleskint’s family and many friends.
3. This Resolution shall take effect immediately upon its adoption.
Resolution 2025-__
July 10, 2025
Staff Report – Item IV-B
To: The Governing Board
From: Donald Eckert Jr., Chief Executive Officer
Item IV-B: CEO Report
Date: 7/10/2025
PERSONNEL
Pioneer ended Fiscal Year 2024-25 with all authorized positions filled.
With the approval of the Fiscal Year 2025-26 budget, there are four (4) additional positions. The recruitment process has begun for the Power Resources Manager and Legislative and Regulatory Analyst positions.
CHIEF EXECUTIVE OFFICER AGREEMENTS EXECUTED (NON-POWER SUPPLY) The following agreements have been carried out by the Chief Executive Officer, consistent with the authority delegated by the Board:
Consultant Services Agreement with Capital Network Solutions for managed IT services in an amount not to exceed $75,000.
AUGUST IS “DARK”
A reminder to the Board that August is dark and no Board or Committee meetings are scheduled. If an urgent matter arises, we can convene a special meeting. Enjoy your summer vacation!
EXPANSION UPDATE
On June 9th, Pioneer received certification from the California Public Utilities Commission of the submittal of Addendum No. 3 to the Implementation Plan and Statement of Intent allowing Pioneer to move forward with the expansion into thirteen (13) communities with service launch in October 2027.
Subsequently, staff worked with the new communities to receive signatures to our Joint Exercise of Powers Agreement (“JPA”) as final confirmation of their intent to move forward. We are pleased to report that all communities have signed the JPA and preparations for the launch have begun.
AB 706, THE FOREST AND WILDFIRE PREVENTION FUND ACT, AUTHORED BY AGUIAR-CURRY AND
SPONSORED BY PIONEER
The effort has been put on pause. Ideally, the author would like to align the timing of the bill with the Greenhouse Gas Prevention Fund (GGRF) re-authorization negotiations. However, since those negotiations have been delayed until further into the year, or next year, considering we are in Year 1 of a two-year legislative session, the author decided it was best to put the bill on pause until there is a better opportunity to secure funding. In the meantime, the author has assured us that she is still committed to the efforts outlined in AB 706 and will continue to advocate for funding to be allocated towards a biomass procurement fund in the ongoing GGRF and wider budget negotiations she is a part of.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: IV-B Agenda Date: 7/10/2025
PIONEER’S INAUGURAL CONTRACTOR EVENT
To encourage HVAC and solar contractors to participate in Pioneer programs, we are hosting an event specifically for contractors on Wednesday, July 16, from 10:00 – 2:00 at the Pioneer office. Contractors are invited to stop by for a quick bite to eat, get a better understanding of the benefits these programs offer customers, and learn more about how our programs can help support their businesses. A similar event will be held in El Dorado County (location TBD) in August.
MICROGRID INCENTIVE PROGRAM
Staff reported on this effort at the June Board meeting. There are four (4) sites identified with two (2) located in Grass Valley, along with Georgetown and Forest Hill. As of the date of this report, we are pleased to report that all four sites are still under consideration. The next step is to complete the online Consultation Form due July 15th. We will continue to inform the Board of developments in this very important initiative.
JOINT RATE MAILER (“JRM”)
The JRM is a mailer document that provides a comparison of the cost of electricity between a local CCA and the respective IOU, which for Pioneer, is PG&E. The JRM is a regulatory requirement by the California Public Utilities Commission (CPUC) and is intended to provide a side-by-side comparison of rates and other related information to help customers make an informed choice about their electricity provider. In the past years, we have sent one JRM, using the Placer County vintage year as our baseline Pioneer rate for the purposes of rate comparison.
However, this year, the difference in PCIA vintages between Placer County and El Dorado County/ Grass Valley/ Nevada City caused a significant discrepancy in the rate savings, approximately 20%. Therefore, we will be changing our JRM production process this year to accommodate two separate JRMs for the two PCIA vintages, one for Placer County and one for El Dorado County/ Grass Valley/ Nevada City, to ensure all customers receive the most accurate rate savings information. We worked with PG&E and the CPUC to request an extension on the normal JRM deadline of July 1st and we were granted an additional 60 days to accommodate the JRM process changes and increased complexity. We are currently in close cooperation with PG&E to produce the updated JRMs and anticipate distributing them before our September 1st deadline without issue.
STRATEGIC PLAN
This quarter’s progress report on the strategic plan includes the completion of year one of the three-year plan.
See Attachment 5.
PIONEER COMMUNITY ENERGY
Attention HVAC and solar contractors:
FOR OUR FIRST EVER
CONTRACTORS'EVENT
Learn How P1 onoor Supports Contractors
AC Tune-Up Rebate Program:
Pioneer customers receive up
to $75 bock for AC tune- up
service from April I-October 1.
WHEN:
WEDNESDAY
JULY 16, 2025
10 AM - 2 PM
GridGen Program: Pioneer
customers con install solar
and battery storage with no
upfront costs or credit checl<.
WHERE:
2510 WARREN DR,
SUITE 8
ROCKLIN, CA 95677
RSVP to Steve Lund (916) 758 - 8945
[email protected]
Agenda Item: IV-B Agenda Date: 7/10/2025
GOOGLE REVIEWS
Four years ago, Pioneer averaged less than one-star on its customer reviews on google. This past month, we have achieved a 3.4 average review from google. The rating is second highest amongst CCAs and speaks volumes to the emphasis staff places on providing exceptional customer service with timely and accurate information.
COUNTY FAIRS
Pioneer was present at the El Dorado County Fair this year that included a booth. We also were present at the Place County Fair that included sponsorship of the Rib Cook-Off. Pioneer’s Kris Antigua was a judge at the event.
CHIEF EXECUTIVE OFFICER POWER SUPPLY CONTRACTS EXECUTIED The following agreements have been carried out by the Chief Executive Officer, consistent with the authority delegated by the Board:
Presentations and Relevant Meetings attended by the Chief Executive Officer
1. Participated in CalCCA Weekly/Monthly Board meetings.
2. Presented to the Auburn Meddlers
Counterparty Name Execution
Date Type Product Start Date End Date Notional Value
Southern California Edison Company 6/4/2025 Sell Resource Adequacy - System 9/1/2025 9/30/2025 $324,000 City of Lancaster 6/10/2025 Buy Resource Adequacy - System 8/1/2025 8/31/2025 $5,000 Enterprise Solar Storage V, LLC 6/3/2025 Buy Renewable Energy - PCC1 6/1/2027 5/31/2042 $453,909,098 Enterprise Solar Storage V, LLC 6/3/2025 Buy Resource Adequacy - System 6/1/2027 5/31/2042 $614,250,000 Agenda Item: IV-B Agenda Date: 7/10/2025
QUARTERLY SPONSOSHIP ACTIVITY REPORT
This quarter’s report includes activity for Fiscal Year 2024-25 based on unaudited financials.
ATTACHMENTS
1. Agenda Planning Document
2. Legislative and Regulatory Report
3. Communications Report
4. Programs Report
5. Quarterly Strategic Plan Progress Report
Event Date Member
Community Vendor Special Event Amount
CY 2024 Lincoln Lincoln Potters Baseball Club, Inc. 2024 Season Partnership $2,000 CY 2024 Rocklin Rocklin Area Chamber of Commerce
2024 Government Relations Committee
Meeting Sponsor $750
CY 2024 Statewide League of California Cities 2024 Cal Cities Partner $ 5,000 8/8/2024 Statewide
Mountain Counties Water Resources
Association MCWRA/EID Regional Leaders Reception $250
9/18 - 9/20,
2024 Statewide
Rural County Representatives of
California 2024 RCRC Annual Meeting $7,500
10/4/2024 Loomis Loomis Basin Chamber of Commerce 2024 Fruit Shed Festival $1,500 11/21/2024 Auburn Auburn Chamber of Commerce Auburn State of the City Dinner $1,500 12/7/2024 Lincoln Lincoln Area Chamber of Commerce Lincoln Hometown Christmas Parade $500 12/15/2024 Nevada City Nevada City Chamber of Commerce Victorian Christmas $500 12/7/2024 Rocklin Rocklin Area Chamber of Commerce Rocklin Tree Lighting $300 CY 2025 Rocklin Rocklin Area Chamber of Commerce
2025 Government Relations Committee
Meeting Sponsor $750
2/11/2025 Statewide
Calforests - California Forestry
Association
2025 Forestry Strategies and Innovations
(FSI) Conference $2,000
4/13/2025 Nevada City Nevada City Chamber of Commerce 4th Annual Earth Fest Celebration $1,000 CY 2025 Lincoln Lincoln Potters Baseball Club, Inc. 2025 Season Partnership $3,500 5/16/2025 Lincoln
Lighthouse Counseling & Family
Resource Center 2025 Celebrity Waiter Luncheon $1,500
5/21/2025 Statewide
Mountain Counties Water Resources
Association 2025 Legislative Reception $1,500
6/3/2025 Rocklin Sierra College Foundation 2025 Sierra Workforce Summit $2,500 6/12-6/15,
2025
El Dorado County/
Placerville El Dorado County Fair Association 2025 El Dorado County Fair $4,500 6/26, & 7/10,
2025 Grass Valley Grass Valley Downtown Association
2025 Thursday Night Market Summer
Series $1,000
6/27/2025 Rocklin Rocklin Area Chamber of Commerce 2025 State of the City $1,000 6/29/2025 Placer County At the Grounds 2025 Placer County Fair Rib Cook-off $5,000 TOTAL $39,050
Fiscal Year 2024-25
Agenda Planning Document – Pioneer Community Energy ATTACHMENT 1 07-07-25
BOARD OF
DIRECTORS
JULY 10, 2025
SPECIAL MEETING
2:45 PM
(Post Agenda: July 8)
SEPTEMBER 18, 2025
REGULAR MEETING
3:00 PM
(Post Agenda: September 12)
OCTOBER 16, 2025
REGULAR MEETING
3:00 PM
(Post Agenda: October 10)
IN THE FUTURE
Special Meeting
Closed Session
2:45 PM
Closed Session
Real Property Negotiators
(re: lease & improvements)
NO MEETING IN AUGUST
Regular Meeting
3:00 PM
Special Meeting
Consent 1a Minutes for Approval-JUN 19, 2025 Minutes for Approval-JULY 17, 2025 Minutes for Approval-SEPT 18, 2025 RES Yes Energy (Kang) 1b Receive Draft Financials: MAY 2025
(Koehn)
Receive Draft Financials: JULY 2025
(Koehn)
Receive Draft Financials: AUG 2025
(Koehn)
RES IT Policies – part 2 (Koehn)
1c RES amending Resolution 2021-11 re:
Long-term PPAs (Kang/GC)
RES Power Content Label
(Stassi-Vanacore)
1d RES Compensation Adjustments &
Employee Welfare & Benefits (Koehn)
RES IT Policies (Koehn)
Presentation 2 presentation - Dr. Ahmad Faruqui
(discussion-Eckert)
guest presenter-in person
Power Charge Indifference Adjustment
(discussion-Eckert)
guest presenter
RES Revised NEM Policy (action-Koehn)
Regular 3 Expansion Planning
(discussion- Stassi-Vanacore & Kang)
Update on advertising campaign
(discussion- Stassi-Vanacore)
Expansion update (discussion-Eckert)
4 Power Supply Market Update
(discussion-Kang)
Fiscal Year 2024-25 in Review
(discussion-Koehn)
End of Legislative Session Update
(discussion-Kang)
5 RES honoring Dan Karleskint (action-Eckert)
SEPT LMS Compliance Plan (action-Kang)
JAN Annual Appointment of EPRC
Members (2026)
General Function II Chief Executive Officer’s Report
REG Reports:
Leg/Reg; Communications; Programs;
New EE introduction;
QTRLY Updates requested by the Board
Strategic Plan Objectives
Sponsorship Activity
Chief Executive Officer’s Report
REG Reports:
Leg/Reg; Communications; Programs;
Chief Executive Officer’s Report
REG Reports:
Leg/Reg; Communications; Programs;
QTRLY Updates requested by the Board
Strategic Plan Objectives
Sponsorship Activity
Chief Executive Officer’s Report
QTRLY Updates requested by the Board
JAN – APR – JULY – OCT
Strategic Plan Objectives
Sponsorship Activity
Informational Items
Glossary of Terms
Informational Items
Glossary of Terms
Informational Items
Glossary of Terms
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Agenda Planning Document – Pioneer Community Energy ATTACHMENT 1 07-07-25
AUDIT/FINANCE COMMITTEE TO BE SCHEDULED - SEPTEMBER
in-person & remote locations IN THE FUTURE
David Ring, Chair
Richard Pearl, Vice Chair
Greg Janda
Gary Petersen
ENERGY PROCUREMENT REVIEW
AD HOC COMMITTEE
TO BE SCHEDULED – PRIOR TO JULY 24
zoom only IN THE FUTURE
Gary Petersen, Chair
Alice Dowdin Calvillo, Vice Chair
Ryan Carter
Greg Janda
Sean Lomen
(JAN-BOARD) Annual Appointment of EPRC Members (2026)
EXPANSION
AD HOC COMMITTEE
WEDNESDAY, JULY 9, 2025 – 2:00 PM
zoom only IN THE FUTURE
Alice Dowdin Calvillo, Chair
Tom Ivy, Vice Chair
Suzanne Jones
Lori Parlin
o Power Procurement/Communications Plan for Thirteen
New Members
o Potential Expansion Opportunities
GOVERNANCE COMMITTEE TO BE SCHEDULED – AUGUST/SEPTEMBER in-person & remote locations IN THE FUTURE
Board - Chair
Board - Vice Chair
Committee Chairs
Board Chair, Ex Officio (prior year)
o Closed Session (Compensation Study; Welfare & Benefits)
COMMUNITY ADVISORY COMMITTEE
TO THE CHIEF EXECUTIVE OFFICER AUGUST 27, 2025 IN THE FUTURE Meets on the 4th Wednesday
(even-numbered months)
Attachment 2: Legislative and Regulatory Update
Date: 7/10/2025
Legislative Affairs
On April 17, 2025, Pioneer Staff presented the 2025 Legislative Policy and Platform to the Board of Directors. Pioneer staff recommended and submitted letters of support for the following bills based on the Board’s approval:
o AB 706 (Aguiar-Curry): This is a Pioneer sponsored bill that would establish the FOREST and Wildfire Prevention Fund, to promote biomass utilization that contributes to California’s wildfire fuel reduction targets while providing clean firm energy to improve grid resiliency. o AB 66 (Tangipa): This bill would provide a temporary CEQA exemption, until January 1, 2032, for projects that create or improve emergency egress routes in residential areas and communities that currently lack a secondary route.
o SB 88 (Caballero): This bill would require the California Air Resources Board, CalFire and the California Energy Commission to take specific steps to track, locate, and quantify the emissions from the burning of forest and agricultural waste. This bill intends to monetize the value of avoided emissions during biomass waste utilization processes and encourage the beneficial use of biomass residues to prevent wildfires and avoid managed open pile burning. o SB 540 (Becker): This bill would provide the California Independent System Operation (CAISO) with authority to implement the “Pathways Initiative”, which would allow CAISO to tap into a wider market of electricity sources throughout the broader Western region. Many studies have shown establishing a regional energy market stands to provide Californians with significant cost savings, enhanced grid reliability, and reduced air pollution. As of May 23, 2025, the deadline for fiscal committees to meet, below are the results for Pioneer’s high priority bills from their respective houses’ appropriations committees:
o AB 706 (Aguiar-Curry): Passed Assembly floor vote with minor amendments o AB 66 (Tangipa): Passed Assembly floor vote with no amendments o SB 88 (Caballero): Passed Senate floor vote with substantive amendments o SB 540 (Becker): Passed Senate floor vote with substantive amendments Pioneer submitted a letter of support for AB 1227 (Essayli), which was elevated to a high priority bill due to its recent amendments focused on accelerating wildfire fuel reduction projects. AB 1227 would affirm the Governor’s State of Emergency Proclamation, issued on March 1, 2025, ordering state agencies to fast-track critical wildfire prevention projects, by requiring the California Environmental Protection Agency and the Natural Resources Agency to report on the implementation of the Governor’s directives. The bill would also create a temporary CEQA exemption, until January 1, 2028, for critical fuels reduction projects conducted in communities located in high fire hazard severity zones. Since many of the communities that Pioneer serves are classified as high fire risk zones, Pioneer is supporting AB 1227 to accelerate fuel reduction and wildfire prevention projects that would promote community safety and provide biomass supply for bioenergy plants, boosting local economic development.
Pioneer-sponsored bill, AB 706 (Aguiar-Curry) has been put on pause by the author’s office, due to the delay of budget negotiations. The author’s office is still committed to advocating for funding allocation for a biomass development program, as outlined in AB 706, through the ongoing budget negotiations. CalCCA’s Legislative Committee and Executive Board voted to take positions on the following bills:
o “Oppose unless amended” position on AB 825 (Petrie-Norris): This bill would implement several affordability measures including creating a Public Transmission Financing Fund, increasing oversight of the IOUs’ wildfire prevention planning and spending, creating a Plf)NEER
COMMUNITY ENERGY
[Publish Date] Agenda Date: 7/10/2025
Permitting Local Assistance for Clean Energy Program, coordinating centralized planning for undergrounding projects, and establishing a Statewide Demand Side Management Program Review Task Force which would give the California Energy Commission and the California Public Utilities Commission the authority to evaluate the efficacy of all energy efficiency (EE) and demand response (DR) programs, and order the consolidation or closure of programs deemed not efficient. Although Pioneer supports many of the affordability measures in this bill, the provision proposing to establish a task force to review and order the closure of EE and DR programs presents a significant jurisdictional creep issue for CCAs. CalCCA is working with the author’s office to remove or amend this provision, to explicitly carve out CCA-funded programs from this requirement, maintaining CCA autonomy to administer programs.
Regulatory Proceedings
Below is a summary table of the key terms and issues, followed by further details on activities since our last Board Meeting on a few ongoing priority Pioneer regulatory proceedings and matters. More updates will follow at future Board meetings as regulatory proceedings and matters evolve.
Key Terms
CPUC- California Public Utilities Commission CAISO- California Independent System Operator CEC- California Energy Commission OIR- Order Instituting Rulemaking/ “Proceeding” LSE- Load Serving Entity AL- Advice Letter
IOU- Investor-Owned Utility PD- Proposed Decision
ALJ- Administrative Law Judge
Proceeding Issue Pioneer Position
R.22-10-010 OIR to Implement AB 843 (2022) –
The Bioenergy Adjusting Tariff
Program (BioMAT)
Expeditiously implement AB 843 to
allow CCA access to the BioMAT
program for future subsidies for
biomass procurement
R.20-05-003 OIR to Continue Electric Integrated
Resource Planning (IRP) and
Related Procurement Processes
Advocate for procurement planning
policies that prioritize affordable
baseload resources such as biomass
energy
R.24-01-017; CEC OIR 21-RPS-02
OIR to Continue Implementation
and Administration, and Consider
Further Development, of California
Renewables Portfolio Standard
Program (RPS)
Ensure Pioneer maintains
compliance with RPS mandates and
advocate for fair inclusion of
biomass in RPS guidelines
R.23-10-011 OIR to Oversee the Resource
Adequacy (RA) Program, Consider
Program Reforms and Refinements,
and Establish Forward Resource
Adequacy Procurement Obligations
Refine the current RA Program
construct; reduce volatility of RA
prices; increase RA procurement
availability and grid reliability
R.22-07-005 OIR to Advance Demand Flexibility
Through Electric Rates
Limit negative impacts of the
Income Based Graduated Fixed
Charge and educate Pioneer Board
and customers prior to the rollout.
A.20-02-009; A.21-03-008;
A.21-06-001; A.22-05-029;
A.24-05-009; A.25-05-011
PG&E 2019 Energy Resource
Recovery Account (ERRA)
Compliance Application; PG&E 2020
Reduce the ERRA impact on the
PCIA; increase data transparency
from the IOUs
[Publish Date] Agenda Date: 7/10/2025
ERRA Compliance Application; 2021
ERRA Compliance Application; 2022
ERRA Compliance Application; 2023
ERRA Compliance Application; 2023
ERRA Forecast Application; 2024
ERRA Forecast Application; 2024
ERRA Compliance Application; 2025
ERRA Forecast Application; 2026
ERRA Forecast Application
R.21-03-011 OIR to Implement Provider of Last
Resort (POLR)
Limit the impacts of changes to the
Financial Security Requirement
(FSR)
R.18-12-005 Utility De-energization, Public
Safety Power Shutoffs (PSPS), and
Enhanced Powerline Safety Settings
(EPSS)
Reduce impacts of PSPS and EPSS
events; increase coordination and
communications with IOUs to
ensure public safety during de-energization; limit PSPS and EPSS impacts on CCA load scheduling
CEC 21-OIR-03; 23-LMS-01 Load Management Standards (LMS) Ensure Pioneer maintains compliance with CEC mandates and
requirements
R.25-02-005 OIR to Update and Reform Energy
Resource Recovery Account (ERRA)
and Power Charge Indifference
Adjustment (PCIA) Policies and
Processes
Advocate for ERRA and PCIA
reforms that will not result in unfair
cost shifts between bundled and
unbundled customers
AB 843 BioMAT Implementation:
• October 20, 2022- The OIR was opened to examine the implementation of AB 843. November 30, 2023- The CPUC voted to approve the revised PD which clarified many of the issues raised in the comments of the PD, while retaining the favorable outcome for CCAs. January 2, 2024- The IOUs submitted their Tier 2 ALs modifying the BioMAT Tariff to incorporate CCAs. January 29, 2024- 60 days from the Decision- CCAs finalized two provisions with Accion for website work and third-party administrator. In addition, CCAs submitted a revised tariff, a program participation request, power purchase agreement, rate schedule, and balancing statement as part of a Tier II AL to the CPUC. February 1, 2024- Tier III ALs were submitted by 4 CCAs indicating interest in participating in the BioMAT program (3CE, Pioneer, RCEA, and OCPA).
February 23, 2024- CalCCA submitted a 15-day extension until March 14 to meet the requirement for the central BioMAT Accion webpage and standard framework for individual CCA webpages within 90 days of the decision due to an issue raised by Accion in the third-party administrator Statement of Work that the CCAs, IOUs, and Accion are attempting to resolve.
February 25, 2024- RCRC submitted reply comments in support of the Joint CCAs proposal to consider extending the BioMAT program sunset date.
March 1, 2024- A group of CCAs (Pioneer, RCEA, 3CE, OCPA, MCE, and VCE) submitted comments in the RPS proceeding asking the CPUC to consider expediting consideration of an extension to the BioMAT program beyond 2025.
March 5, 2024- There is an agreement with Accion as the Third-Party Administrator. The agreement has been reviewed and signed by Pioneer as well as the other 3 CCAs. March 21, 2024- There was a meeting with CPUC staff on implementation of AB 843. Brad Hill will be moving over to the Natural Resources Agency.
March 28, 2024- Assembly Member Aguiar-Curry submitted a letter of support to the CPUC for the extension [Publish Date] Agenda Date: 7/10/2025
of the BioMAT program. This letter included the support of other legislators: Senator Alvarado-Gil, Senator Dahle, Senator Talamantes Eggman, and Assembly Member Dahle. March 28, 2024- CalCCA submitted a third request for extension of time for an additional 31-day extension of time (until April 29) for the central BioMAT Accion webpage and standard framework for individual CCA webpages to be completed within 90 days of the effective date of the decision. Work has been delayed pending final agreement from all parties to revisions to the third-party administrator Statement of Work. April 4, 2024- There was a prehearing conference to address the preliminary scope of issues in the OIR for IRP where the Joint CCAs are asking for an extension of the BioMAT program. During this conference, Scott Blaising represented the Joint CCAs and asked for 1) the CPUC to expedite the extension of the BioMAT program and 2) broadly review the program.
May 1, 2024- CPUC approved the joint CCAs Tier 2 Advice Letter which approved the BioMAT standard program documentation which included the tariff, the pro-forma power purchase agreement, program participation request forms, BioMAT program website and portal development contracts, independent third-party contracts, initial balancing account statements, and non-bypassable charge rate scheduled. Pioneer has completed the implementation of the BioMAT program. The website and all necessary documents for BioMAT are live.
June 20, 2024- CPUC issued a Draft Resolution to approve participating CCAs’ forecast revenue requirements, which is $0 for 2024-2025 for all participating CCAs, since no BioMAT projects are forecasted to COD before then.
September 1, 2024- CPUC granted the joint CCAs’ extension request for the BioMAT application for prudent contract management, since there are no BioMAT contracts to report on. The new deadline will be 6 months after the first BioMAT contract is executed or September 1, 2025, whichever date comes first. January 31, 2025- Pioneer submitted a Tier 3 AL to seek cost recovery for forecasted revenue requirements for 2026, which are $0.
March 6, 2025- The CPUC issued a notice to Pioneer, informing us that our Tier 3 AL seeking cost recovery for BioMAT forecasted revenue requirements for 2026 is suspended for review for up to 120 days beginning March 3, 2025.
April 7, 2025- Pioneer filed supportive reply comments to the Bioenergy Association of California (BAC)’s Petition to Modify (PFM) CPUC Decision 20-08-043 in the 2018 RPS proceeding, regarding changes to the BioMAT program. In its PFM, BAC urged the CPUC to extend or remove the sunset date on the BioMAT program, along with other program revisions, to ensure the program can meet its statutory requirement of enabling the procurement of 250 MW of distributed generation bioenergy. Pioneer, in partnership with the Redwood Coast Energy Authority (RCEA), filed comments, detailing our BioMAT project development efforts and urging the CPUC to consider expedited action on the extension of the BioMAT program, considering it is scheduled to sunset at the end of 2025. Pioneer’s comments also echoed BAC’s other requested changes to the BioMAT program to enable more subscription, including improving interconnection issues and removing cost caps for Category 3 projects using forest biomass waste.
Integrated Resource Planning:
October 7, 2015- The California Legislature adopted SB 350, the Clean Energy and Pollution Reduction Act of 2015, which increased the state’s greenhouse gas reduction target, requiring 50% renewable electricity procurement by 2030, and mandating a doubling of energy efficiency. To meet these goals, SB 350 ordered large utilities to develop and submit integrated resource plans (IRPs), which will be reviewed by the CPUC.
The IRP proceeding serves as the vehicle for the CPUC to evaluate utilities’ progress towards meeting the SB 350 goals, as well as the general planning proceeding to consider California’s long-term energy needs and electric procurement policies.
June 24, 2021- In Decision 21-06-035, the CPUC ordered the collective procurement of 11,500 MW of new net qualify capacity (NQC) to come online in 2023-2026. 2,000 MW NQC must come from long lead-time resources providing clean firm power or long duration energy storage. March 13, 2023- In Decision 23-02-040, the CPUC ordered the collective procurement of an additional new [Publish Date] Agenda Date: 7/10/2025
4,000 MW NQC in 2026-2027. The decision also extends the deadline for procurement of new long lead-time resources to 2028.
October 7, 2024- Pioneer filed reply comments in response to the ALJ’s ruling seeking comments on the proposed resource portfolios for the 2025-2026 Transmission Planning Process (TPP). Pioneer urged the Commission to recognize the value of biomass as a clean firm resource needed to meet reliability and renewable energy goals. Our comments ultimately recommended an increase of 0.1 GW growth of biomass in the proposed portfolio. January 10, 2025- The CPUC issued the PD transmitting electricity resource portfolios to the CAISO for the 2025-2026 TPP. The PD failed to adopt many of the requests made by party comments, including Pioneer’s recommendation to increase the growth of biomass. January 10, 2025- The Long Duration Energy Storage (LDES) Council filed a petition for modification (PFM), urging the CPUC to clarify that derated short-duration battery energy storage cannot be used to meet the mid-term reliability procurement obligation for long-duration storage, as ordered in Decision 21-06-035.
Pioneer does not have any derated short-duration battery energy storage resources in our portfolio that would be negatively impacted if the PFM were to go into effect. February 10, 2025- CalCCA responded to the LDES Council’s PFM, recommending the CPUC to deny the petition due to the clear nature of the language already present in the original decision, as well as to avoid the precedent of retroactive policymaking which would disadvantage LSEs who already made procurement decisions based on the given language.
February 20, 2025- The CPUC issued the final decision (D. 25-02-026) transmitting electricity resource portfolios to the CAISO for the 2025-2026 TPP, which adopted the originally proposed base case and sensitivity portfolios.
April 29, 2025: The CPUC issued a Staff Proposal on Reliable and Clean Power Procurement Program (RCPPP), with an ALJ ruling seeking comments. RCPPP is a new proposal for a long-term procurement planning framework, intended to forecast procurement needs for reliability and GHG reduction goals 10 years forward. Staff will review and work with CalCCA to provide comments. May 15, 2025- CalCCA requested a deadline extension on comments to the RCPPP Staff Proposal and was granted an extension from the original deadline of June 5 to July 15. In the meantime, CPUC Staff will host two workshops to facilitate stakeholder discussion on the RCPPP proposals, which include two options for a reliability procurement framework and one option for a new GHG reduction procurement framework called the “Clean Energy Standard (CES)”. In these discussions, Pioneer will continue to advocate for programmatic changes and policies that allow us to meet state-mandated reliable clean energy goals, while limiting unnecessarily complex and costly compliance measures.
Renewables Portfolio Standards:
September 12, 2002- The Renewables Portfolio Standards (RPS) program was established in 2002, by Senate Bill (SB) 1078 with the initial requirement that 20% of electricity retail sales must be served by renewable resources by 2017. The program was accelerated in 2015 with SB 350 which mandated a 50% RPS target by 2030. In 2018, SB 100 was signed into law, which again increased the RPS target to 60% by 2030 and requires all the state’s electricity to come from carbon-free resources by 2045. The RPS proceeding at the CPUC serves as the vehicle for the CPUC to implement and administer RPS compliance rules for LSEs including Pioneer. Concurrently, the CEC is responsible for the certification of electrical generation facilities as eligible renewable energy resources and adopting regulations for the enforcement of RPS procurement requirements.
July 22, 2024- Pioneer filed our Draft 2024 RPS Procurement Plan to the CPUC. August 1, 2024- Pioneer submitted our 2023 RPS Compliance Reporting materials to the CPUC. November 1, 2024- Pioneer filed comments on the CEC RPS docket, regarding the Draft 10th Edition of the RPS Eligibility Guidebook. Our comments urge the CEC to consider changes to the Guidebook that would reduce barriers to the certification of biomass facilities and burdens associated with reporting and verification. Furthermore, Pioneer recommended that the Guidebook should provide guidance to potential developers on eligible biomass conversion technologies and ensure accurate accounting of the generation from these sources.
[Publish Date] Agenda Date: 7/10/2025
June 30, 2025- Pioneer filed our 2025 RPS Procurement Plan to the CPUC, providing an overview of our procurement progress and plans to meet current and future load needs for our service territories, in accordance with the RPS mandates.
Resource Adequacy:
• May 25, 2023- The CPUC issued a PD barring non-compliant LSEs from expansion for two calendar years following a system RA deficiency.
June 14, 2023- CalCCA filed comments recommending the CPUC fully reject the PD’s restrictions on LSE expansion due to RA deficiencies and modify the RA deficiency penalty.
June 29, 2023- The CPUC issued a decision adopting a one percent minimum threshold for RA deficiencies that would limit CCA expansions; clarifying that if an LSE “cures” its year-ahead RA deficiency in the month-ahead timeframe, the year-ahead deficiency will not be applied to the expansion requirement. • July 26, 2023- CalCCA and CCCE filed two Applications for Rehearing (AfR) of the decision to limit CCA expansion for two years due to uncured RA deficiencies. CalCCA’s PfR cited a lack of CPUC statutory authority to limit CCA expansion, and that it gives itself new unauthorized powers to needlessly discriminate against CCAs to prevent their growth; it also asserted, that without credible evidence, the CPUC determined that addition of new CCA load would be detrimental to grid reliability, and that the decision violates the CPUC’s legal requirement to apply RA enforcement measures in a nondiscriminatory manner, not just to CCAs.
• On September 19, 2023, PG&E and SCE submitted their annual central procurement entity (CPE) reports.
PG&E is short RA for all months - up to 4,400 MW.
• October 12, 2023- The Commission opened the new RA proceeding through OIR R.23-10-011, which proposes the scope, schedule, and administration of this next RA proceeding. November 9, 2023- CalCCA submitted comments recommending additional scoping items for the RA proceeding, including additional refinements to the RA program for the local RA CPE, compliance and penalty structure, slice-of-day (SOD) transactability, and RA import rules. December 14, 2023- CPUC denied CalCCA’s request for a rehearing of the decision on RA procurement obligations and the prohibition against CCA expansion for failure to comply. January 17, 2024- Petition for Writ of Review prohibition of CCA expansion filed. Shell also filed a petition for somewhat different reasons. CPUC is seeking to consolidate since there are two filings. CalCCA did not oppose the motion.
January 19, 2024- Proposals due in the RA proceeding for Track 1, addressing time-sensitive issues that must be resolved for the 2025 RA compliance year. CalCCA has identified 3 major problems that the RA proposals should address: RA market scarcity, the potential exercise of market power, and removing the economic incentives not to comply. CalCCA is seeking to remove the prohibition from CCA expansion in the event of noncompliance and add the ability for the CPUC to waive penalties if CCAs can show reasonable efforts to comply were unsuccessful. The RA proposal approved by CalCCA’s Board included a temporary waiver proposal for system and flexible RA from 2025 to 2027. Partial waivers would waive the penalty points and non-fiscal consequences, and a full waiver would also be available that would waive financial penalties as well under certain circumstances. A slice of day waiver would also be available. February 23, 2024- There was a SOD proposal workshop. CalCCA is asking for a delay in SOD implementation from 2025 until 2026 because the showing and compliance tools are not working properly. March 22, 2024- CalCCA submitted comments on the RA Program with regards to considering RA reforms and refinements and establishing forward RA procurement obligations. CalCCA believes the focus should be to adopt proposals that protect customers against excessive RA costs and increase RA capacity availability. June 6, 2024- CalCCA filed comments on the CPUC’s RA Track 1 PD, regarding key issues with SOD implementation. CalCCA emphasized how customer affordability will be put at risk due to the hourly transactability issue, and the CPUC’s refusal to delay SOD implementation or offer system RA waivers. The comments also included a host of other issues including the CPUC’s insistence on using a higher than necessary planning reserve margin (PRM), exclusion of existing resources in cure period extensions, restrictions on the amount of RA imports allowed, and concerns about the resource counting methodology. [Publish Date] Agenda Date: 7/10/2025
June 14, 2024- CalCCA filed comments on the Assigned Commissioner’s Scoping Memo and Ruling on Track 2, proposing an adjustment of the CPE timeline. Currently, the Commission authorizes the CPE to procure local RA until 2 months before LSEs must submit their year-ahead RA showings. This leaves LSEs with limited time to fill their shortages in response to CPE allocation. CalCCA’s proposal urges the Commission to require the CPE to provide their LSEs with their local RA allocations at least 1 year prior to their year-ahead RA filings.
June 20, 2024- The CPUC issued a decision to adopt local capacity requirements for 2025-2027, flexible capacity requirements for 2025, and refinements to the RA program as scoped in Track 1. The Commission maintains that the 2025 RA compliance year will be the first year for the new SOD framework, but remains open to considering hourly transactability after implementation, should any issues arise. August 23, 2024- CalCCA filed reply comments on the ALJ ruling modifying the Track 2 schedule, expressing concerns about the upcoming loss of load expectation (LOLE) study and how it will be used to set the PRM for SOD implementation, and the proposed changes to the CPE framework and timeline. August 30, 2024- Energy Division (ED) published the revised version of their RA LOLE study, which the CPUC will use to calibrate the PRM for the 2026 SOD implementation. Based on the LOLE study, ED staff recommended the CPUC adopt a 26.5% PRM during the months of January to May and a 23.5% PRM during the months of June through December, to maintain the target reliability level of 1 day in 10 years (0.1 LOLE). This recommended PRM is much higher than the originally set 17% PRM in the 2025 SOD implementation framework.
September 9, 2024- CalCCA filed comments on the published RA LOLE study, urging the Commission to conduct further analysis before adopting the recommended PRM of 26.5% PRM during the months of January to May and a 23.5% PRM during the months of June through December. CalCCA cited concerns with potential study methodology flaws and significant impacts to ratepayer affordability associated with the recommended PRM.
September 19, 2024- PG&E released their 2024 CPE Annual Compliance report. The report shows they are short in their centralized procurement of RA for 3 years forward. October 29, 2024- The CPUC issued a PD for RA Track 2, which deals with the PRM and CPE framework.
Regarding the proposed PRM, the Commission agreed additional vetting and further analysis is needed, authorizing ED to undertake a further revision of the 2026 PRM analysis which will be considered in Track 3 of the proceeding. As for the CPE framework, the Commission successfully adopted CalCCA’s proposal to lock in CPE allocations one year earlier, giving LSEs more time to self-procure, along with various other revisions.
November 18, 2024- CalCCA filed comments on the RA Track 2 PD, recommending that the CPUC recognize the significant impact that changes to the PRM can have on reliability and affordability, and allow for earlier adoption of the 2026 PRM if thorough analysis is completed by all relevant stakeholders in advance of the Track 3 timeline. CalCCA also urged the CPUC to adopt revisions to the CPE framework as outlined in the PD, with an opportunity to review their effectiveness at the end of 2027. December 20, 2024- ED published another revised version of their RA LOLE study, recommending an updated 2026 PRM of 21% for the months of October to May and 22.5% for the months of June to September. Due to affordability concerns, ED also included two proposals to mitigate the adverse effects of the high PRMs. The first proposal entails adopting a 17% PRM as an RA requirement, paired with an effective PRM of 22.5% which only IOUs are required to comply with; this proposal would extend the current 2025 status quo. The second proposal entails adopting a 22.5% PRM, but with an option for LSEs to apply for temporary System Waivers in peak months (June to September) for requirements above a 17% PRM based on a cost threshold.
January 17, 2025- CalCCA filed their RA Track 3 proposals, recommending the CPUC to allow LSEs to transact load obligations on an hourly basis, address co-located generation and RA needs, and incorporate the local RA CPE data request process into the existing RA filing rather than the IRP data collection process. February 25, 2025- ED issued a correction to their LOLE study, updating their recommended 2026 PRM to 20% for the months of November to May (off-peak) and 21% for the months of June through October (peak). Under this new PRM, the two price mitigation proposals change accordingly. Proposal A entails [Publish Date] Agenda Date: 7/10/2025
adopting a 17% PRM as an RA requirement, paired with an effective PRM of 21% in the peak months of June through October, which only IOUs are required to comply with; this proposal would extend the current 2025 status quo. Proposal B entails adopting a 20% PRM for off-peak months and 21% PRM for peak months, paired with an option for LSEs to apply for temporary System Waivers in peak months for requirements above a 17% PRM based on a cost threshold.
February 28, 2025- The CalCCA Board voted to support Proposal B, which would require LSEs to adopt an increased PRM of 20% in the off-peak months and a 21% PRM in the peak months, with the option of applying for a System Waiver in the peak months for obligations above a 17% PRM. March 3, 2025- Opening comments were filed on the RA Track 3 Proposals. Most parties, except the IOUs, supported CalCCA’s proposals to adopt hourly load transactability and allow co-located energy only resources to count as RA under SOD. Furthermore, most parties opposed the price mitigation Proposal B which would allow for System RA waivers, and instead recommended the adoption of a PRM that will allow the grid to consistently meet the pre-determined target of 0.1 LOLE. March 17, 2025- Reply comments were filed on the RA Track 3 Proposals. CalCCA urged the CPUC to reject arguments made by PG&E, SDG&E, and Middle River Power regarding the hourly transactability proposal. As for the proposed PRM and price mitigation proposals, CalCCA reasserted that the CPUC should adopt a 21% PRM in peak months, 20% PRM in off peak months, along with a system RA waiver option in peak months for obligations above a 15.5% PRM, as indicated by SCE’s independent PRM study. However, due to the ongoing disputes over a correct PRM to meet the 0.1 LOLE target, CalCCA urges the CPUC to continue refining their LOLE modeling for the upcoming 2027 PRM. April 16, 2025 - CalCCA held ex-partes with CPUC Commissioners to continue advocating for adoption of the hourly load obligation trading proposal, setting the PRM at 21% in peak months and 20% in off-peak months with an option for system RA waiver for requirements above 15.5% consistent with Southern California Edison’s modeling results, and enabling increased co-located resource RA participation under the RA slice-of-day framework.
May 22, 2025- The CPUC issued a PD adopting local capacity obligations for 2026-2028, flexible capacity obligations for 2026, and program refinements as proposed in Track 3 of the RA proceeding. Regarding the PRM proposals, the PD adopts an 18% binding PRM with extension of the effective PRM target of 3-5.5% for June to October, for the 2026 RA year. The effective PRM procurement target will be divided between the three IOUs based on the approximate CAISO load share. As for CalCCA’s proposals, the PD does not adopt hourly load obligation trading. Instead, the PD directs ED to conduct an evaluation after a full year of SOD implementation to assess the need, benefits, and feasibility of an hourly load obligation trading mechanism, by Q2 2026.
June 11, 2025- Pioneer collaborated with Central Coast Community Energy (3CE) to file opening comments on the RA Track 3 PD, urging the Commission to reduce the effective PRM target from 3-5.5% to 3%, which when paired with the binding 18% PRM, is more in line with ED’s recommended total PRM of 21%. The comments also urge the Commission to reconsider adopting CalCCA’s hourly load transactability proposal, due to the abundance of supporting evidence on the record of its potential widespread affordability benefits.
In reply comments filed on June 16, 2025, multiple parties echoed Pioneer and 3CE’s argument for reducing the effective PRM target, to not exceed ED’s recommended PRM, based on intensive modeling/ study results.
Demand Flexibility:
• June 30, 2022- AB 205 passed giving the CPUC the authority to approve a pricing structure that incorporates an Income Based Graduated Fixed Electricity Charge (IGFC). • July 14, 2022- The Commission issued an OIR to begin this proceeding to establish demand flexibility policies and modify electric rates to advance the following objectives: 1) enhance the reliability of California’s electric system; 2) make electric bills more affordable and equitable; 3) reduce the curtailment of renewable energy and greenhouse gas emissions associated with meeting the state’s future system load; 4) enable widespread electrification of buildings and transportation to meet the state’s climate goals; 5) reduce long-term system costs through more efficient pricing of electricity; and 6) to enable participation in demand flexibility by both bundled and unbundled customers. [Publish Date] Agenda Date: 7/10/2025
July 31, 2023- Parties submitted Comments on the IGFC Implementation Pathways considering the ALJ Ruling’s questions.
August 21, 2023- CalCCA submitted Reply Comments to refute parties’ arguments regarding including the PCIA or Competitive Transition Charge (CTC) as fixed costs eligible for inclusion in the IGFC. October 27, 2023- 22 Democratic lawmakers sent a letter to the CPUC asking for an extension of the timeline for the proceeding and require public participation hearings before implementing an IGFC. • November 3, 2023- Track A (IGFC)- CalCCA filed a reply brief continuing to refute party proposals that the PCIA be included in the IGFC and noting that the parties advocating for inclusion of the PCIA have not addressed the arguments put forth by CalCCA.
• December 15, 2023- Track B (demand flexibility)- The CPUC issued a PD which directs PG&E to expand the Valley Clean Energy Ag-Fit pilot program. CCAs that participate in the expanded pilot may receive $20/kW for each year of customer enrollment in the PGE Ag-Fit pilot as an incentive. The incentive is capped at $1.8 million for PG&E’s territory. The budgets are for all the CCAs wanting to participate to share. PG&E will be administering the pilot so there will be no administrative costs, but several of the CCAs want to have a say in how the pilot is administered and the education and outreach of the pilot. December 18, 2023- Track A (IGFC)- CPUC issued a ruling requesting implementation information from the IOUs on the IGFC. The ruling directs the IOUs to file additional information about the proposed budgets for implementing the first income-graduated fixed charges by January 24, 2024. January 23, 2024- (Track B) There was a revised PD on the expanded pilots. Pioneer is considering offering the expanded Ag-Fit program to its customers. The pilot will be administered by PG&E so it will involve minimal work on behalf of Pioneer staff, but it will also bolster our Load Management Standards program and keep us competitive with PG&E.
January 26, 2024- The CPUC approved the expanded pilots revised decision. In D.24-01-032 to Advance Demand Flexibility Through Electric Rates, the CPUC directed PG&E to expand the Valley Clean Energy Ag Real Time Pricing Pilot (VCE AgFIT Pilot). The decision orders PG&E to extend the duration and expand participation of the VCE AgFIT Pilot to agricultural customers throughout PG&E’s service territory. January 30, 2024- (Track A)- There was a press conference held by a group of 20 Democratic Legislators calling for the repeal of income-graduated fixed charge. AB 1999 would repeal the income-graduated fixed charge approved under AB 205 (2022) and replace it with a $5 fixed charge for CARE customers and a $10 fixed charge for all other residential customers.
February 13, 2024- Pioneer staff sent PG&E an email indicating interest in possibly participating in the expanded pilot expansion program, particularly the Ag Pilot. February 13, 2024- at the Senate Utilities, Energy and Communications hearing the IGFC was brought up by CPUC president, Alice Reynolds, who indicated the CPUC was working on an IGFC decision possibly by the end of Q1.
March 1, 2024- There is an expanded pilot workshop to address dual participation, since some demand flexibility programs prohibit dual enrollment. Dual Participation is allowed for- Critical Peak Pricing: (Peak Day Pricing and SmartRate), Electrification Rates: (E-ELEC), TOU Rates (E-TOU, E-TOU-D), Simple NEM and NBT, and ELRP Subgroup A: (A1-A6). Dual Participation is Prohibited- Supply-Side DR Programs (BIP, CBP, ART, DRAM, non-DRAM DR RA Contracts, DSGS Option 2), Flex Market Pilot, DAHRTP, ELRP Subgroup B:
B1-B2, and Other Event-Based Load-Modifying Programs (OBMC, SLRP). March 25, 2024- PG&E submitted their Tier 2 AL for implementation plans for PG&E’s Expanded Ag Pilot. 5 CCAs have expressed an interest in participating in PG&E’s Ag Pilot in 2024 (Ava, SVCE, VCE, 3CE, and Pioneer). PG&E will launch the pilot in June of 2024. Participants will continue to pay their current bill and will receive the shadow bill, which they will not pay. The shadow bill will illustrate a customer’s potential savings under the dynamic pilot rate. There is also a $20 per unbundled kW per year incentive, subject to a $1.8 million cap for all CCA incentives.
March 27, 2024- The CPUC issued a PD addressing AB 205 (Income Graduated Fixed Charge) requirements for electric utilities. The earliest this PD could be adopted is May 9, 2024. This decision authorizes all IOUs to shift the recovery of a portion of fixed costs from volumetric rates to a separate, fixed amount on bills without changing the total costs that utilities may recover from customers. As a result, this decision reduces the volumetric price of electricity (in cents per kilowatt hour) for all residential customers of IOUs. The CPUC [Publish Date] Agenda Date: 7/10/2025
did not adopt the IOUs’ proposal and instead the proposal would have Tier 1 (customers enrolled in CARE) pay $5 a month, Tier 2 (customers enrolled in FERA or who live in affordable housing restricted to residents with incomes at or below 80% of Area Median Income) pay $12 a month, and Tier 3 (all other customers) pay $24.15 per month. This new billing structure would apply to all residential rates of the IOUs, except for master-meter rates that are not sub-metered.
May 9, 2024- CPUC approved implementation of the Income Graduated Fixed Charge without any changes to the structure described in the previous bullet.
June 12, 2024- CalCCA filed reply comments on the Track B Proposal, urging the CPUC to reconsider the process for updating marginal cost values and to clarify a cost recovery structure that ensures CCA customers do not get double-charged for being unbundled.
PG&E ERRA Compliance and ERRA Forecast:
• The ERRA proceedings act as a review of an IOU’s prior year portfolio management and accounting and seeks to identify errors and discrepancies between PG&E’s revenue requirements vis-à-vis collected revenues through the IOUs’ General Rate Case (GRC) which ultimately affects CCA rates through the Power Charge Indifference Adjustment (PCIA).
• May 14, 2023- PG&E’s 2023 – 2024 ERRA Forecast and Testimony was released. June 1, 2023- NewGen sent over the new rate forecast spreadsheet. The forecast looks good with the PCIA remaining negative over many vintages, but this will change before the October Update. June 16, 2023- Keyes and Fox filed a Protest to PG&E's Forecast Application. • August 10, 2023- CalCCA filed a Protest to PG&E’s ERRA Trigger Application proposing a rate increase in November to correct and account for under-collections.
• September 6, 2023- CalCCA provided Testimony on the 2024 PG&E ERRA Forecast case and touched upon the fixed generation cost issue.
October 16, 2023- PG&E’s October Update to its 2024 ERRA Forecast came out. Energy prices have softened relative to PG&E’s original forecast (which would, all else equal, cause PCIA rates to increase), but RA and RPS benchmarks have increased significantly since PG&E's filing (dampening the impact of energy prices).
All told, forecast rates increased relative to the original forecast across the board, but forecast rates remain negative for vintages 2021 and later.
November 1, 2023- Keyes and Fox submitted comments on PG&E’s ERRA Trigger proposal and comments on PG&E’s October update.
November 16, 2023- The CPUC unanimously approved the Alternate PD and indicated that “the decision balances a myriad of competing interests- affordability, feasibility, safety, and reliability.” PG&E requested $15.4 billion for 2023, and the decision reduced that amount by $1.8 billion to $13.5 billion. This is an 11% increase from the authorized 2022 revenue requirement. For the typical residential customer, their combined monthly electric and natural gas bill will increase by $32.62 or 12.8%, compared to PG&E’s request of $38.73 or 17.9% increase.
November 30, 2023- The PD for the PG&E 2024 ERRA Forecast came out. There were a couple of disputed issues including whether to amortize the 2023 trigger balance over 6 months or 12. CalCCA was asking for 12 and PG&E was asking for 6 months. The CPUC adopted PG&E’s recommendation. The second issue was whether PG&E should apply a first-in-first-out methodology to the use of excess prior year RECs or a last-in-first-out methodology. The CPUC ruled with PG&E on a last-in-first-out methodology. December 12, 2023- A revision to the PD came out and CalCCA won its argument on first-in-first-out, meaning the CPUC is requiring PG&E to use a first-in-first-out methodology for RECs banked in or after 2019.
December 29, 2023- PG&E submitted their Annual True-Up to change PG&E’s electric rates on January 1, 2024.
March 21, 2024- There was a Preliminary Issue Review with Keyes and Fox. The 2021 ERRA proceeding is still open but coming to an end, 2022 is still busy, and 2023 is just starting up. Some of the big issues to watch include PG&E’s RA Sales and Accounting; DWR reimbursement to PG&E; and Retained, Sold and Unsold RPS.
June 12, 2024- The Assigned Commissioner issued the Scope Ruling in PG&E’s 2023 ERRA Compliance [Publish Date] Agenda Date: 7/10/2025
proceeding. The ruling does not adopt CalCCA’s recommendation to expressly clarify that the reasonableness of PG&E’s record year RA activities and sales is within the scope of this proceeding. It excludes the RA scoping issue out of this proceeding altogether, possibly in hopes the issue will be settled in PG&E’s 2022 ERRA Compliance proceeding. The Scope Ruling also lays out the procedural schedule. NewGen and Keyes & Fox will continue to work on discovery and reconvene with CalCCA before Intervenor testimony is due in September.
June 17, 2024- CalCCA filed a protest to PG&E’s 2025 ERRA Forecast application. In this proceeding, the 2025 levels for the PCIA will be established. Due to forecasted low brown energy prices and high RA prices, the PCIA is expected to decrease, which will result in increased generation rates for PG&E’s bundled customers. PG&E’s 2025 ERRA Forecast application proposes a new ratemaking method to ensure reasonable rates for bundled ratepayers, by freezing the RA market price benchmark (MPB) at its 2024 forecast level, rather than using the 2025 forecast or the 2024 actual RA MPBs. CalCCA responded, urging the Commission against considering these broad policy questions, which fall outside the scope of the ERRA Forecast proceeding. CalCCA also argues that implementing an RA value cap would inappropriately inflate PCIA rates, shifting costs to unbundled customers, in violation of the PCIA ratemaking framework that has been established.
July 25, 2024- The CPUC issued an ALJ ruling in PG&E’s 2022 ERRA Compliance proceeding, re-opening discovery to examine potential RA withholding actions taken by PG&E. August 1, 2024- Assigned Commissioner issued a Scoping Memo and Ruling in PG&E’s 2025 ERRA Forecast application, supporting CalCCA’s protest that this proceeding is not the correct venue to address the RA MPB issue.
September 3, 2024- CalCCA filed a direct testimony, prepared by Brian Dickman, in PG&E’s 2025 ERRA Forecast proceeding on behalf of CCAs. The testimony urges the CPUC to reject PG&E’s proposed change to its common cost allocation method and its proposal to create a new category of RPS-eligible resources outside of the previously recognized context of the PCIA calculation. The testimony also calls upon PG&E to make corrections to their calculation of “negative retained system RA” and “amount included as the amortization of the gain on the sale of its San Francisco General Office headquarters”. October 4, 2024- CalCCA filed an opening brief, prepared by Keyes and Fox, in PG&E’s 2022 ERRA Compliance proceeding regarding the issue of PG&E withholding excess RA. CalCCA urged the Commission to revisit PG&E’s Bundled Procurement Plan in the IRP proceeding to ensure PG&E is making its excess RA available to the market in a timely and comprehensive manner, which is critical due to current RA market shortages. The brief incorporated the new discovery responses received from PG&E, once the ALJ re-opened the discovery window for CalCCA in July 2024.
October 4, 2024- Energy Division released the 2024 Final MPBs and 2025 Forecast MPBs that are used to calculate the PCIA in PG&E’s 2025 ERRA Forecast proceeding. They have since issued corrections to the MPBs several times.
October 8, 2024- In the PG&E 2025 ERRA Forecast proceeding, the ALJ issued an email ruling asking for comments regarding the impact of the recently released MPBs. The questions posed ask parties whether they expect the released MPBs to have a significant impact on the issues within the scope of the proceeding, and to offer any procedural options to address these impacts. October 14, 2024- PG&E and CalCCA replied to the ALJ ruling asking for party comments relating to the impact of the released MPBs. PG&E stated the released RA MPBs will result in a $500 million increase to the bundled customer generate revenue requirement, while departed load customers would see a net reduction of $500 million through their PCIA. Furthermore, the released RPS MPB would increase the bundled service customer generation revenue requirement by an additional $250 million, with a corresponding reduction to departed load customers. For these reasons, PG&E asks the Commission to delay the procedural timeline and consider various mitigation methods such as producing additional rate-setting scenarios and establishing a tracking account to remediate any potential cost shifts while further investigating this issue.
CalCCA stated in their replies that the RA MPB is operating as the Commission intended, therefore, no modifications to the ratemaking process in this proceeding are warranted. CalCCA reiterated that proposals to modify the PCIA revenue requirement calculation methodology are outside the scope of this proceeding [Publish Date] Agenda Date: 7/10/2025
and should not be considered in response to the ALJ ruling. October 23, 2024- PG&E filed their Fall Update, in which they argue the recently released MPBs were wrongly calculated and inflated. Considering how the high price of the RA MPB does not appropriately incentivize procurement compliance, PG&E urges the Commission to consider mitigation measures. They present various mitigation proposals which involve freezing the RA and/ or RPS MPBs to 2024 forecast levels and tracking the differences in a balancing account.
October 31, 2024- CalCCA filed a motion to strike PG&E’s MPB discussion and mitigation proposals from the record, as they were already deemed out of scope for this proceeding in a previous ALJ ruling. CalCCA also filed a reply brief which reiterates that the Commission should not consider MPB mitigation measures in this proceeding and argues that the “gross revenue requirement” methodology equitably allocates common costs to customers.
November 15, 2024- CalCCA held an ex parte and met with Maria Sotero from Commissioner Reynold’s office to discuss the MPB issues and better understand what strategies the CPUC wants to pursue in this case. The CPUC expressed understanding of CalCCA’s recommendation to maintain consistent usage of the MPB methodology in PG&E’s 2025 ERRA Forecast proceeding but did indicate a desire to open a new rulemaking to consider changes to the MPB methodology.
November 15, 2024- PG&E submitted their Annual Electric True-Up to change PG&E’s electric rates on January 1, 2025.
November 25, 2024- The CPUC issued a PD for the PG&E 2025 ERRA Forecast proceeding which maintained that PG&E’s RA mitigation proposal is out of scope, securing CalCCA’s win in preventing $1B in costs to the PCIA. PG&E was ordered to use the 2024 MPBs that ED released. However, the PD states that the CPUC may open a new rulemaking to consider modifications to MPB methodology, with possible retroactive rate collections in PG&E’s 2025 Annual Electric True-Up. Furthermore, the PD adopts PG&E’s common cost allocation proposal, but sides with CalCCA that the change should be applied prospectively in 2025 and forward, not to 2024 costs.
December 2, 2024- CalCCA filed opening comments to the PD in PG&E’s 2025 ERRA Forecast proceeding, emphasizing the importance of providing adequate timelines and discovery rights for non-IOU parties in any future proceeding that will deal with modifications to the RA MPB methodology. Considering recent changes in the RA market including System RA scarcity and sharp price increases in short-term RA, CalCCA does not oppose revisiting the RA MPB methodology, but urges the Commission to consider a more comprehensive evaluation of the methodology. CalCCA’s comments also push back on the CPUC’s adoption of PG&E’s common cost allocation methodology and urges the CPUC to instead adopt CalCCA’s proposal based on gross revenue requirements.
December 19, 2024- The CPUC issued a final decision in PG&E’s 2025 ERRA Forecast proceeding, bringing it to a close. The decision adopts PG&E’s revised proposal of common costs allocation beginning with January 1, 2025 rates. PG&E’s estimated 12-month net revenue requirement for 2025 is $2.25 billion, resulting in an expected decrease of bundled residential customers’ rates by 2% and a decrease of unbundled residential customers’ rates of 4.4%.
December 30, 2024- PG&E filed their final Annual Electric True-Up, reflecting the CPUC’s final decision, to update their electric rates effective January 1, 2025.
February 3, 2025- CalCCA filed an opening brief in the PG&E 2024 ERRA Forecast proceeding recommending that the CPUC should not modify the definition of fixed generation costs, which most other parties were in consensus with. CalCCA also encouraged the CPUC to address any changes in the common cost allocation methodology in a separate, non-expedited rulemaking with all three IOUs as parties, in order to ensure consistency in their practices.
February 28, 2025- PG&E filed its 2024 ERRA Compliance Application. ERRA Compliance proceedings review PG&E’s activities in the prior year related to its ERRA and PCIA to ensure that those activities were reasonable and comply with Commission decisions and that associated accounts are accurate. April 4, 2025 – CalCCA filed a Protest of PG&E’s 2024 ERRA Compliance Application, arguing that the Commission should set the matter for hearing to provide CalCCA an opportunity to analyze the application, including preliminary issues it identified concerning PG&E’s RA sales activities, PG&E contract amendments, [Publish Date] Agenda Date: 7/10/2025
changes to PG&E’s Retained RA Tracker, and PG&E’s treatment of “banked” renewable energy credits to meet its Renewable Portfolio Standard (RPS) requirement. CalCCA also argues that the Commission should explicitly include PG&E’s attempts to sell excess RA consistent with its Bundled Procurement Plan in 2024 within the scope of the proceeding.
April 23, 2025 – The ALJ issued a PD in PG&E’s 2022 ERRA Compliance proceeding that found that issues concerning PG&E's sales or attempts to sell excess RA during the summer of 2022 are not relevant to issues in the proceeding. CalCCA will file comments on the PD pushing back on this finding given that the ERRA Compliance proceedings are the only venue we have to examine PG&E’s excess RA transactions. May 2, 2025 – The ALJ in PG&E’s 2024 ERRA Compliance proceeding issued a scoping ruling that included CalCCA's request to include as an issue whether PG&E made reasonable attempts to sell excess RA consistent with its Bundled Procurement Plan. This Scoping Ruling conflicts with the 2022 ERRA Compliance PD, providing support for CalCCA’s arguments in comments on that PD. May 15, 2025 – PG&E filed its 2026 ERRA Forecast application, which will, in part, establish the PCIA rate for 2026.
June 11, 2025 – Keyes & Fox and NewGen convened a preliminary issue review regarding the PG&E 2026 ERRA Forecast application. From NewGen’s preliminary analysis, it is apparent that there will be a significant under-collection for Portfolio Allocation Balancing Account, which will have to be recovered through the 2026 PCIA, putting upward pressure on that rate. There are other issues that Keyes & Fox will litigate to potentially help ease the PCIA rate increase in 2026 (e.g., battery RA valuation, use of banked RECs, PG&E’s GHG free sales, etc.), but even if successful, that increase is expected to be significant. June 18, 2025 – CalCCA filed a protest of PG&E’s 2026 ERRA forecast. The protest highlighted the issues discussed in the June 11, 2025 preliminary issues review regarding PG&E valuation of both pre-2019 banked RECs and the RA attributable to batteries in its PCIA portfolio. PG&E effectively values both at zero, which has the effect of increasing the PCIA.
Provider of Last Resort (POLR):
• October 2, 2019- SB 520 passed requiring the establishment of a POLR. As part of the proceeding to implement SB 520, the CPUC is seeking to establish new policies to plan for and prevent catastrophic failures in the event of an unplanned return en masse of CCA customers to IOU service. Additionally, the CPUC will review and update existing procedures and policies for Financial Security Requirements (FSR), re-entry fees, and LSE de-registration process and compliance requirements. • July 31, 2023- CalCCA's Reply Briefs were submitted and address PG&E’s proposal to modify the FSR to reflect two months of forecast energy costs, other parties’ recommendations on elements of the existing FSR calculation, mandatory contract assignments, financial monitoring, and the duration of POLR service. • March 14, 2024- The CPUC issued a PD, with a mix of favorable and unfavorable decisions. For example, it rejected PG&E’s proposal to require FSR postings to reflect 2 months of POLR service, it maintains the ability to use service bonds, and it keeps confidential the information about LSEs that trigger financial monitoring.
However, the PD also approved using PG&E’s Administrative Fee ($4.24) without sufficient evidence of the costs, the CPUC should clarify that November 2024 FSR Calculation would be the earliest possible calculation under the new rules, and the CPUC should clarify the timing of the second tier of reporting requirements so CCAs know when to evaluate their metrics. The biggest issue the PD addressed was updating the FSR requirements. The minimum FSR remains $147,000, but now CCAs must use the IOU’s Administrative Fee multiplied by the number of accounts the CCA has, and post whichever amount is higher. For CCAs in PG&E’s territory the administrative fee is $4.24 per customer, while the other IOUs’ administrative fees are significantly less (around $.50 per customer). If the final decision requires CCAs within PG&E’s service territory to use PG&E’s administrative fee, all CCAs within PG&E’s service territory will likely be paying an FSR well over the $147,000 minimum.
April 23, 2024- CPUC adopted a revised POLR Decision inclusive of several of CalCCA’s requests.
Specifically:
o Reducing RA costs in the FSR by accounting for returning CPE RA allocations, in addition to the CAM and DR RA allocations.
o Nets PCIA in the FSR whether the PCIA is positive or negative. [Publish Date] Agenda Date: 7/10/2025
o Affirms current timing for calculating FSRs.
o Provides CCAs with an additional 60 days to file first FSR following IOU tariffs implementing this decision.
o Requires CCAs to file the Tier 1 audited financial report to Energy Division once a year, in January or July, whichever comes earlier relative to the availability of the audited financial statement.
o Allows 90 days for CCAs to submit joint advice letter on new CCA registration process July 12, 2024- CalCCA, on behalf of Pioneer, filed a Tier 2 AL to formalize the Financial Monitoring and Reporting Guidance document. The CPUC requires financial reporting to be done on a 2-tier system. Tier 1 requires every CCA to submit an annual audited financial report. Tier 2 requires CCAs to submit additional financial reporting, if certain trigger events such as a change in credit rating occur. This document clarifies the process and procedures CCAs must follow to comply with Tier 2 financial reporting conditions. o July 22, 2024- The joint IOUs filed a protest to the joint CCAs’ AL on Financial Monitoring and Reporting Guidance, insisting CCAs’ use “lines of credit” instead of “letters of credit” as the primary financial instrument to demonstrate days of liquidity of hand (DLOH). The IOUs also insisted CCAs report financial triggers 10 days after they occur, instead of the proposed 60 days.
o September 6, 2024- CalCCA met with Energy Division to express that CCAs agree to comply with the joint IOUs’ request to use “lines of credit” to calculate DLOH. On the issue of minimum days required to report financial trigger events, CCAs insist on keeping 60 days, as this is the minimum amount of time required to prepare accurate financial statements due to complex billing and accounting systems.
July 17, 2024- CalCCA, on behalf of Pioneer, filed a Tier 2 AL to clarify requirements for the new CCA registration process and implementation plan. These requirements include (1) submission of a feasibility study and pro forma financial statement with the Implementation Plan, (2) establishment of annual assumptions to be included in the pro forma financial statement, (3) establishment of milestones for critical implementation action and review progress, and (4) submission of an updated proforma financial statement six months prior to launch. The AL served to provide additional examples for annual assumptions and critical milestones.
o August 6, 2024- PG&E filed a protest to the joint CCAs’ AL on additional implementation plan requirements, citing the proposal would limit the CPUC’s ability to assess whether enhancements to the implementation plan would result in cost shifts to bundled customers. o August 13, 2024- CalCCA filed a reply to PG&E’s protest on the additional implementation plan requirements, citing the additional requirements proposed are correctly slotted under the umbrella of CPUC authority to certify implementation plans and determine a cost-recovery mechanism for CCA customers that prevents cost shifts to bundled customers. August 6, 2024- An ALJ Ruling was issued to define the scoping issues in Phase 2 of the POLR proceeding, which will be primarily concerned with clarifying requirements for an application for a non-IOU LSE to become the POLR.
August 23, 2024- The prehearing conference for Phase 2 was held, in which CalCCA filed a statement agreeing with the current set of questions proposed in the Phase 2 scope. In its statement, CalCCA also urged the CPUC to reject PG&E’s request to scope in issues regarding the liquidity needs of the POLR and analysis of seasonal RA pricing.
October 24, 2024- The CPUC issued a scoping ruling for Phase 2 of the POLR proceeding which sets two primary topic areas. The first is establishing the regulatory framework for non-IOU POLRs and the second is the development of the joint application for a non-IOU LSE to serve as POLR. November 12, 2024- The IOUs filed their ALs for the bi-annual FSR updates. CalCCA compiled the IOU ALs and confirmed they all made their FSR calculations consistent with the current authorization. Given that the IOU ALs implementing Phase 1 are still pending resolution, the FSR updates use the methodology in place without the Phase 1 Decision modifications. Due to the hold on the ALs, all CCAs will be obliged to post the minimum FSR of $147,000 come January 1, 2025.
November 26, 2024- The CalCCA Regulatory Committee voted in favor of CalCCA engaging in Phase 2 of the POLR proceeding on behalf of its members, to ensure CCAs have a voice in the discussion for how a non-IOU [Publish Date] Agenda Date: 7/10/2025
POLR will be established and regulated. CalCCA will present the results of the Regulatory Committee’s vote to the Executive Committee on December 3, 2024, and to the CalCCA Board on December 12, 2024. December 12, 2024- CalCCA’s Board of Directors voted to engage in Phase 2 of the POLR proceeding. January 10, 2025- Opening comments were filed on the CPUC’s Phase 2 threshold questions. No IOUs expressed interest in transferring their POLR responsibilities. However, all three IOUs argued that any non-IOU LSE that serves as POLR should be subject to full CPUC jurisdictional authority. Furthermore, no non-IOU LSEs expressed interest in becoming the POLR, except for Shell Energy who only wants to serve commercial and industrial customers.
January 24, 2025- CalCCA filed reply comments on the CPUC’s Phase 2 threshold questions, recommending the CPUC to establish a core framework for non-IOU LSE requirements and joint application process, but stopping short of building out the entirety of the framework due to the current lack of interest by parties in the designated POLR role. CalCCA also rejected arguments regarding the need for broad jurisdictional CPUC authority of a designated POLR.
April 28, 2025- The CPUC approved PG&E’s AL 7326-E and 7326-E-A, allowing PG&E to update the FSR methodology. The decision implemented by this AL also now requires CCAs to post the greatest value out of the minimum requirement of $147,000, the per-customer administrative fee (# accounts * $4.24 for PG&E), or the FSR calculation. CCAs will have 60 days after the IOU POLR informs us of our new FSR calculation to complete our first FSR posting. After that, it will return to the normal deadlines of January 1 and July 1.
Changes to the FSR methodology include:
o Use the CPUC’s RA MPB to value RA, instead of the current RA Report by ED o Use the IOU POLR’s system average residential and nonresidential customer generation rates, instead of the system average rates
o Account for CCA customers’ allocation of RA from the IOU POLR’s cost allocation mechanism (CAM), central procurement entity (CPE) allocations, and demand response (DR) resources o Remove revenues from PCIA rates of CCA customers from the IOU POLR’s generation revenues
o Incorporate seasonal generation rates
o Remove the netting of negative procurement costs against the incremental administrative costs
May 12, 2025- PG&E sent Pioneer our FSR calculation worksheet and advice letter. The materials indicate Pioneer must post the new FSR minimum of the per-customer admin fee. Pioneer has posted our balance to reflect our new FSR minimum.
May 28, 2025- An ALJ issued a ruling proposing a procedural pathway for Phase 2. Due to lack of interest from non-IOU entities in assuming the POLR role, as indicated in the Phase 2 opening comments, the ALJ ruling proposes for the CPUC to issue a decision providing a framework for its regulatory authority over a non-IOU POLR and the services it provides. That decision would then close the current proceeding, and direct any non-IOU entity seeking POLR status to file a Petition for Rulemaking at least 12 months before filing an application to assume POLR responsibilities. The Commission would then resume consideration of threshold questions and topic areas set forth in the Scoping Memo. The ALJ ruling also seeks comments on proposed definitions regarding “POLR services”, to inform the framework around CPUC regulatory authority over a non-IOU POLR entity.
June 13, 2025- CalCCA filed opening comments on the ALJ ruling, supporting the proposed procedural pathway for Phase 2. As for the proposed definitions regarding “POLR services”, CalCCA clarifies that the Commission need only to adopt a definition for “POLR-specific services”, because defining “Full-severable services” or “Non-severable services” is unnecessary as they are not within the Commission’s jurisdiction according to existing regulation and statute. CalCCA emphasizes that any POLR framework must preserve the protected autonomy of non-IOU LSEs by limiting the CPUC’s jurisdiction to POLR-specific services. June 20, 2025- CalCCA filed reply comments on the ALJ ruling, responding to opening comments from parties including Cal Advocates, PG&E, SDG&E, and SCE, which try to unreasonably assert broader CPUC jurisdiction over non-IOU LSE POLRs.
[Publish Date] Agenda Date: 7/10/2025
Utility De-energization, PSPS, and EPSS:
• July 12, 2022-Pioneer, along with Joint CCAs, Joint Local Governments, and Rural County Representatives of California (RCRC), filed a motion with the CPUC on July 12, 2022, to consider EPSS issues in the De-energization or its own Proceeding. The arguments in the motion seek to treat EPSS events with the same regulations and oversight as Public Safety Power Shutoff (PSPS) events. • September 21, 2023- The CPUC approved a PSPS citation program for violations of the established PSPS guidelines.
• August 30-31, 2023- PG&E provided a post PSPS report. A total of 3,928 customers were deenergized. • October 10, 2023- The Joint CCAs, RCRC, and Joint Local Governments had a meeting with the Public Advocates Office to see if there is agreement on the need to further do more with regards to Fast Trips. The Public Advocates Office indicated that the CPUC and Office of Energy Infrastructure Safety are not inclined to act to regulate Fast Trips and that more data is needed. The Public Advocates Office is looking to submit a report in the beginning of 2024.
January 16, 2024- The data for December’s Fast Trips and YTD data came out. These are the following circuits in Pioneer’s territory with 8 or more outages in 2023:
o Placerville 2106 (EDC)- 19
o Apple Hill 2102 (EDC)- 18
o Shingle Springs 2109 (EDC)- 11
o Mountain Quarries 2101 (EDC)- 11
o El Dorado PH 2101 (EDC)- 11
o Clarksville 2104 (EDC)- 9
o Apple Hill 2104 (EDC)- 9
o Lincoln 1101 (Placer)- 8
o Penryn 1103 (Placer)- 8
o Penryn 1107 (Placer)- 8
o Brunswick 1105 (Nevada)- 17
o Brunswick 1106 (Nevada)- 15
January 29, 2024- A data request was made by joint CCAs (including Pioneer) using the circuits listed above to PG&E requesting the number of customers served by each circuit, the number of life support customers, the number of medical baseline customers, and the number of critical facilities served by each circuit. March 8, 2024- Part of the information we were seeking regarding the data request came back. Pioneer staff will be reviewing this information.
August 23, 2024- PG&E completed our data request made in January, except for information regarding hardening projects on the circuit including their pole numbers, project location and timeline, and type of hardening work to be completed, on the grounds these questions are out of scope and are unduly burdensome. Pioneer staff will be reviewing the rest of the data request provided. May 8, 2025 – The CPUC will host a workshop regarding outage data collection, specifically focusing on data definitions and reporting.
CEC Load Management Standards (LMS):
• October 12, 2022- The CEC adopted the Load Management Standards regulation which requires the development of a statewide standard tool for authorized rate data access by third parties that is compatible with each IOU, large POUs, and large CCAs with the idea that electricity customers or their authorized third-party agents can look at rates that the customer is eligible to switch and allow the customer to change the customer’s current rate to rates they are eligible for. • June 8, 2023- CEC staff provided a schedule of the key LMS adoption and compliance dates. • August 1, 2023- Pioneer, through Calpine, uploaded its rates and will continue to work with Calpine on uploading all time dependent rates to meet deadlines.
• January 17, 2024- Workshop on implementation of LMS. Comments on the workshop are due on January
31. • March 21, 2024- Pioneer’s LMS plan presented to the Pioneer’s Board for approval. • March 26, 2024- Pioneer submitted the Board-approved LMS plan. [Publish Date] Agenda Date: 7/10/2025
• April 1, 2024- All large CCAs are required to file their plan for compliance with LMS regulations. • April 16, 2024- CEC held a scoping meeting to discuss development of the statewide rate access tool.
Discussions on how the tool will be funded are ongoing. • May 31, 2024- CPUC granted PG&E’s request to delay commencement of enrollment in its dynamic rates pilots from June 1, 2024 to November 1, 2024.
• July 15, 2024- The CEC requires LSEs to jointly develop and submit a Single Statewide Tool (SST) for their review by October 1, 2024. The joint IOUs, led by SDG&E, released a 50-page draft of a proposed model for the SST, and will host weekly workshops to receive input from CCAs and POUs. • September 4, 2024- Pioneer met with CEC staff to receive feedback on our LMS Compliance Plan and discuss the development of our LMS programs.
• October 1, 2024- In compliance with LMS regulation requirements, Pioneer filed the Single Statewide Tool concept design, terms and conditions, and pleading document, jointly with the IOUs, Large CCAs, and POUs.
In addition, Pioneer submitted our individual LMS Load Flexibility Programs List to the CEC. • January 17, 2025- CalCCA filed comments on the LMS docket, urging the CEC to pause its LMS implementation and assess next steps in regard to the necessity for LMS requirements and funding for the SST development.
• February 21, 2025- A small group of CalCCA Directors met with CEC Commissioner McCallister to discuss issues with the current application of LMS regulations by CEC staff, including how inconsistent the regulations are being applied among different CCAs and the steering of certain outcomes versus a non-biased review process based on economic and technological feasibility. Commissioner McCallister stated his intentions to work with his LMS staff to expedite CCAs’ LMS Compliance plans for approvals through increased flexibility.
• March 5, 2025- Pioneer corresponded with CEC LMS staff regarding program development in our LMS Compliance Plan. We provided an update that our LMS programs are not currently set up to connect price signals to the CEC’s MIDAS system, which is currently not functioning well per an operations update from our vendor who handles MIDAS interactions, Calpine. Pioneer will continue to monitor the situation to see if it is technologically and financially feasible to add this component of MIDAS price signals to our LMS programs in the future, when the MIDAS system issues are resolved. • May 8, 2025- The CEC, in a business meeting, will vote to delay the SST submission until May 8, 2026. • June 19, 2025- The CEC issued a formal revision request letter to Pioneer regarding our LMS Compliance Plan, which we are directed to revise to, in part, commit to offer the hourly flexible rate pilot programs of PG&E. The CEC directs us to file our board-approved revised plans by September 17, 2025 or 1 week following board approval of the revised plan.
Power Charge Indifference Adjustment (PCIA):
• February 20, 2025- The CPUC issued a new rulemaking to update and reform ERRA and PCIA policies and processes. This rulemaking was created as an avenue to deal with the RA MPB issue in the previous PG&E ERRA 2025 Forecast, where PG&E argued a new RA MPB methodology is needed to bring down the price.
Track 1 of the proceeding will consider changes to the RA MPB calculation on an expedited basis, aiming to implement the updated methodology in the upcoming October release of the annual MPBs. Track 2 of the proceeding will consider broader issues including review of revisions to the MPBs, evaluating need for ERRA-specific implementation guidance for RA program changes including SOD, how to reduce rate volatility, additional guidance for vintaging resources, and evaluating need for changes to bundled procurement plan processes. All CCAs are named as individual respondents, but all CCAs will file our responses collectively under CalCCA.
• March 18, 2025- CalCCA filed opening comments on the PCIA OIR, arguing that the CPUC has an obligation to both bundled and unbundled customers to administer the PCIA framework fairly and accurately, to ensure indifference. CalCCA included arguments that caution the CPUC against making changes to the PCIA framework or MPB methodology that would only serve to benefit bundled customers in current market conditions, which is considered a cost-shifting, not affordability measure. CalCCA also commented on the five RA MPB revision proposals set forth by ED, advocating for the CPUC to (1) reject including historic RA [Publish Date] Agenda Date: 7/10/2025
transactions in the RA MPB, (2) utilize a single RA MPB incorporating system, flex, and local values, (3) exclude affiliate transactions from the RA MPB, (4) exclude swap and sleeve transactions from the RA MPB, and (5) utilize monthly values for the RA MPB, instead of the current annual one to more accurately reflect seasonality. Opening comments by the Joint IOUs argued to include revisions to the RPS MPB in Track 1, as well as requesting the CPUC to consider the issue of their portfolio management and negative PCIA rates. • April 2, 2025- CalCCA filed reply comments on the PCIA OIR, reasserting the CCAs’ positions on the RA MPB revision proposals, and arguing that the Joint IOUs’ proposals to incorporate RPS MPB revisions and portfolio management concerns are not within the scope of Track 1, and the issue of negative PCIA rates should not be re-opened altogether.
• April 8, 2025- The Scoping Ruling for Track 1 was issued, setting a narrow focus on revisions to the RA MPB methodology, including the consideration of incorporating historic RA transaction data, combining of system, local, and flex values, and eliminating transactions that are duplicative or not reflective of market-based transactions. The Joint IOUs’ proposal to consider revisions to the RPS MPB, portfolio management, and negative PCIA rates were not included in the Track 1 scope. The ruling directs all parties to address the issue of retroactive rate setting in their opening briefs, making an argument on whether it is appropriate to apply a revised RA MPB methodology to the 2025 ERRA true-up. The ruling aims to produce a Track 1 PD by May 2025 and final decision by June 2025.
• April 21, 2025 - Parties submitted opening briefs. The briefs were largely legal arguments, with CalCCA arguing that application of any changes to the RA MPB to true-up 2025 rates is not allowed under the prohibition against retroactive ratemaking and that any decision must be supported by substantial evidence and narrowly tailored to the supposed transaction volume problem. The IOUs also filed testimony with substantive arguments supporting their position that the CPUC should look at historic RA transactions when determining the RA MPB.
• April 23, 2025 - CalCCA filed an opposition to the IOUs' motion to admit testimony, arguing that such testimony is inconsistent with the procedures established by the Administrative Law Judge and prejudices other parties.
• April 30, 2025 - Parties filed reply briefs primarily focusing on the legal arguments and the issue of whether to include historic RA transactions in the calculation of the RA MPB. CalCCA also filed its own testimony in response to the IOUs'. This may create a procedural and due process problem for the CPUC that could possibly delay a decision.
• May 23, 2025 – The Administrative Law Judge issued a PD on Track One of the PCIA rulemaking. If adopted by the Commission, the PD would make a variety of changes to the RA MPB methodology intended to make the result of that calculation more representative of RA value. Many of the changes were generally agreed upon by parties, including eliminating non-market transactions and combining the three different RA products (local, flex, and system) into a single RA MPB calculation. The most controversial change regarded whether to include more historical transactions and, if so, from how far back. The PD would include transactions up to four years prior. The PD would also apply all these changes to true-up currently effective 2025 rates, which will create a significant under-recovery that will have to be collected in 2026 rates, increasing the PCIA. In comments on the PD, CalCCA will oppose both the four-year historic transaction period and the application of the revised RA MPB to 2025 rates. • June 27, 2025 – The CPUC issued a Final Decision adopting the PD on Track 1 of the PCIA rulemaking. As described above, the effect of the decision will decrease the value of the IOU’s generation resources in rates effective in 2025, which will increase the 2025 PCIA under-collection. That under-collection will need to be recovered in the 2026 PCIA rates, increasing that rate for Pioneer’s customers. 1 Attachment 3: Communications and Outreach Updates
Date: 7/10/2025
NOTABLE ACHIEVEMENTS – JUNE 2025
June was marked by a busy events schedule, with Pioneer having a strong and visible presence at the El Dorado and Placer County fairs, the El Dorado Hills Business Summit and follow-up meetings with expansion communities, to name a few.
Our Q2 newsletter effectively drove traffic to our website, with large spikes in visitor traffic in the days following its release. Programs are creating positive customer reviews, with an increase in 5-star reviews through Google and post-call surveys.
COMMUNITY OUTREACH
Extensive community outreach took place in June through events, speaking engagements, meeting participation, and sponsorships. El Dorado County Fair booth and sponsorship
Placer County Fair Rib Cook Off Sponsorship
El Dorado County Chamber Business Showcase
Sierra College Workforce Summit Sponsorship
Loomis Chamber Joint Economic Development &
Government Affairs Meeting
Loomis Chamber Government Relations Committee Meeting Shingle Springs Field Day
Lincoln Joint Chamber/GRC Meeting
PG&E Second Quarter North Valley/Sierra Regional Working Group
Placer County Regional Economic Development meeting
Rocklin State of the City Sponsorship
Expansion
Meetings took place to educate new leaders and staff, including with the Interim Yuba City Manager. Additionally, Pioneer monitored public meetings and was available to answer questions for the Oroville City Council, Glenn County Board of Supervisors meeting, and Sutter County Board of Supervisors meeting.
CUSTOMER CARE
Our customer care team saw a 14% increase in calls during June, many in response to outreach and mailers. A total of 125 surveys were completed with a 94.4% satisfaction rate. The total number of calls was 455, with 103 calls on Friday, June 30. The most frequent topics were Billing Inquiry (15.46%) and NEM (13.11%). It is worth noting that the categories of “PR Campaign,” “Rebates,” and “Tracked Topics” combined accounted for 16.8% of the calls. (A reminder that these are topics the CSRs may use to track calls emanating from our mailers and ads).
There were 6 re-enrollments in June.
Plf)NEER
COMMUNITY ENERGY
ing a
I
ngs
ed public
ity
Chatbot:
475 interactions
o 73 live conversations (down 12%)
o Average of three conversations a day
June 24th had the most live conversations (11). This is likely related to the program mailer. Rating of 4.6/5 in satisfaction surveys
SOCIAL MEDIA
Our social media presence continues to grow.
Placer County Fair made two joint Instagram posts with Pioneer for the Rib Cookoff, which created access to stakeholders and engagement from new networks.
Top performing posts for June 2025:
Facebook
HVAC Tech Appreciation Day
LinkedIn
Ice Energy repost
Instagram
Money Saving Programs Webinar
WEBSITE
Pioneer’s Q2 newsletter was distributed via email on June 5 to an estimated 120,000 recipients, generating a spike in website activity. From June 18-21, a paid search ad campaign was active and created increased traffic during that same timeframe. There is a direct correlation to direct mail efforts and website traffic, with the top five web pages visited in June being:
1. AC Tune-Up Rebate
2. Home page
3. Grid Gen
4. PowerShift Rewards
5. Residential Rates
PAID MEDIA
Our current ad campaign supporting programs is running with programmatic digital, social media, and some radio ads. Key highlights:
Nearly 1,100,000 impressions were delivered.
Radio ads ran on Nevada City Community radio (KVMR), The Breeze (KBEB), The River (KYRV), The Mix (KYMX), and New County 105 (KNCI).
Ads generated a total of 419 conversions.
PowerShift Rewards creative (ad design) performed best with the most clicks and highest click-through-rates. f ~ ~~~lM!9Y .
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HVAC TECH
APPRECIATION DAY
Schedule your AC tune-up today, so you can get a $75 rebate from P1oneerl a:cl
We are proud to offer money-saving programs for our business and commercial customers!
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Placer and El Dorado Counties - the Ice Bear'"' program Is now available ... lci!Enll!rgy
Staff are paying close attention to performance analytics and plan to refine the ad campaign based on data. For example, we know that the best performing search keywords were:
o AC Tune Up: AC repair, AC rebate, AC tune up
o GridGen: solar rebate program, energy savings program, Tesla solar o PowerShift Rewards: residential energy incentive program, Pioneer electricity, and PG&E bill Ads appear below.
Pioneer also placed ads in the Comstock’s Magazine Placer County edition and other locally focused publications in our service area.
Get Paid to
Power Down.
Attachment 4: Program Updates
Date: 7/10/2025
AC Tune-Up (rebates for AC tune-up)
The tune-up program relaunched April 1, 2025
The current application count for the program season is 582 A program-specific postcard hit mailboxes the week of June 23rd 116 different contractors have participated in the program A contractor informational session is planned for mid-July in Placer County. This event is designed to cultivate an increased understanding of our programs and build partnerships with local contractors in our service area. An event in El Dorado County will be planned for August.
GridGen (solar + storage)
The expansion of the GridGen program to include battery retrofit, CARE/FERA offering, and commercial and industrial customers opened to customers the week of May 26th Pioneer has generated a total of 276 leads, though not all leads follow through on system installation o 57 customers in the active pipeline
o 11 have reached permission to operate
o 11 additional customers have signed contracts
Pioneer staff is reaching out to customers who do not complete the process to gain insights and information for improving participation
Pioneer is collecting customer testimonials to help promote the program A GridGen specific direct mail piece was mailed to customers the week of June 9th The quarterly newsletter was delivered June 5th and highlighted programs, including GridGen and the new program offerings
PowerShift Rewards (incentives for energy conservation) PowerShift Rewards relaunched on May 1, 2025
The program has over 1,100 customers enrolled
PowerShift Rewards has received CAISO certification as a Demand Response program The quarterly newsletter was delivered June 5th and highlighted programs, including PowerShift Rewards and the refer a friend offering
A PowerShift Rewards-specific postcard sent to all residential customers during the week of July 7th LED Discount (discounted LEDs at local hardware stores) The LED Discount program has expanded to include Dollar Tree stores, bringing the total number of participating stores to 26
This program remains popular and provides visibility through community partnerships o Retail partners are posting/distributing flyers about Pioneer’s other money-saving programs At the June 19, 2025, board meeting, the Board approved the extension of the Greenlite contract Ice Energy Storage (ice technology used for AC energy reduction) The Ice Energy team has started outreach to commercial customers:
o 196 site visits
o 35 site surveys completed
o 9 sites have agreements to participate, with an estimated 61 Ice Bears to be installed Initial outreach focuses on Ice Energy's existing network of customers, with Pioneer providing support as needed
This program has been promoted to all area Chambers of Commerce for visibility in the business community
Plf)NEER
COMMUNITY ENERGY
Agenda Item: x Agenda Date: 5/25/2023
Hourly Flex Pricing Pilot (credits for energy conservation for Ag customers) The first Pioneer Ag customer has applied for participation in the program and is expected to move forward in the program, which includes 9 meters
Due to concerns from CCAs, the Hourly Flex Pricing Pilot has re-opened for customer enrollments.
However, capacity on incentives may be reached soon and next steps are being discussed among PG&E and CCAs
Online Marketplace (solar and/or battery storage purchasing) Twenty-one (21) leads have been generated through the Electrum Marketplace Staff will continue to evaluate opportunities to improve uptake in the program Community Advisory Committee
The Community Advisory Committee meeting was held on June 25, 2025 FY 2025-2027 Strategic Plan
Quarterly Progress Report
CEO Report
July 10, 2025
FY 2025-2027 Strategic Plan
• The plan was adopted in September 2024
• Five (5) Strategic Goals to support the
Mission and Vision
1. Be a Community Partner
2. Be Fiscally Strong & Resilient
3. Provide Exceptional Customer Service
4. Achieve Operational Optimization
5. Be a Great Place to Work
• Quarterly report will provide progress
towards each goal and highlights for next
quarter
Year One
• This progress report represents the
completion of year one of the three-year plan
• Pleased to report significant progress was
achieved in the first year of the plan
impacting all five strategic goals
Progress Report
Be a Community Partner
Objective: Community Engagement
• Progress: (1) Amended rates twice in FY 2024-25 and
both rate changes were decreases; (2) Rates set in
January 2025 in effect all calendar year; (3) Average
discount in the territory of 10% compared to PG&E’s
generation rate.
Objective: Community Advisory Committee
Representation
• Progress: (1) Membership represents <75% of
Members but will be active in recruitment the 2nd half
of 2025; (2) On course to have at least five meetings in 2025.
Be a Community Partner (cont.)
Objective: Legislative & Regulatory
Representation
• Progress: (1) Supported AB706 that would have funded
biomass projects through Greenhouse Gas Reduction
funds, but bill is parked until 2026; (2) Listening to our elected officials, Pioneer is active in the MicroGrid
Incentive Program with four sites in our territory that could alleviate power shut-offs; (3) Working with
CalCCA on issues such as the PCIA to protect our
ratepayers.
Objective: Build Local & Regional Partnerships
• Progress: (1) Represented in all our members
Chambers of Commerce; (2) Sponsorship with RCRC
and hosting League of Cities lunch later in 2025; (3)
Green100 expanding to State Agencies and Possible
other Members
Be a Community Partner (cont.)
Objective: Launch & Monitor Energy Efficiency
Programs
• Progress: (1) Expanded scope of the GridGen program,
introduced the Power Shift Rewards program in
summer 2024, launched LCFS program in spring 2025,
relaunched the HVAC Rebate program; launched the
ICE Energy Program for Commercial customers, and
the Hourly Flex Pricing Program for Agricultural
customers; (2) Continued marketing of the programs to
achieve a strong participation rate; (3) Launch 1-2
Programs 2nd half of 2025.
Provide Exceptional Customer
Service
Objective: Stable & Competitive Rates
• Progress: (1) Pioneer currently offers an average 10% discount across the territory compared to PG&E’s
generation rate; (2) Only change rates twice between
July 2024 through end of 2025 and both changes were
decreases in Pioneer’s generation rate.
Objective: Increase Customer Understanding
• Progress: (1) Conducted webinars on most common
questions from customers; (2) Walk customers through
the complicated PG&E bills; (3) Improved coordination
with Calpine’s call center so customer gets the answer
they need on the first try.
Provide Exceptional Customer
Service (cont.)
Objective: Responsiveness to Customers Needs
• Progress: (1) Provide excellent customer service with timely and accurate information; (2) Result has been
an improvement in Google reviews from less than one
star to nearly 4 stars.
Objective: Utilize Technology to Improve the
Customer Experience
• Progress: (1) Continue to improve the ChatBot which
has been provided thousands of positive interactions;
(2) Streamlined the HVAC Program to allow for online
transactions.
Achieve Operational
Optimization
Objective: Compliance
• Progress: (1) Pioneer received no fines or penalties
from the CPUC, CEC, CAISO, or any other state agency
in FY 2024-25; (2) Pioneer takes its responsibility of
being a good GRID citizen with upmost importance.
Objective: Opportunities
• Progress: (1) Generated $2.7 million of revenues from optimization of the battery at Yellow Pine project; (2) Invested in software that improves our valuation of
PPAs such as cQuant and Amperon which can improve
our load forecasting that saves in power supply cost.
Achieve Operational
Optimization (cont.)
Objective: Protection of Customer Data
• Progress: (1) Received a strong audit report from our Triennial AMI as required by the CPUC showing we have
proper controls in place to protect our customer data;
(2) Continued phishing training throughout the year for employees to stay diligent; (3) Introducing IT policies in the 2nd half of 2025 to keep us cyber safe.
Objective: Risk Management Best Practices
• Progress: (1) Conduct quarterly ROC meetings to
review our positions and energy portfolio; (2) reviewed our employee handbook in Spring 2025; (3) Amended
Energy Risk Management Policy in Summer 2025; (4)
Conduct weekly all-employee meetings.
Be a Great Place to Work
Objective: Employer of Choice
• Progress: (1) Conducting triennial compensation study to be presented to the Governance Committee in
September 2025; (2) Overhauled benefits in 2024 that
significantly improved our competitiveness.
Objective: Align the Culture with the Employees
• Progress: Completed annual employee survey resulting
in no responses below neutral. Ended the fiscal year
with all authorized positions filled.
Be a Great Place to Work (cont.)
Objective: Employee Engagement
• Progress: (1) Achieved >100 volunteer hours for Fiscal Year 2024-25; (2) Host appreciation events throughout
the year to celebrate victories as well as occasions such as the holidays or end of fiscal year.
Objective: High Performing Workforce
• Progress: (1) Tuition Reimbursement Program helped
an employee earn his Bachelors and another earn his
Masters; (2) Training on excel and other job specific
tools available; (3) CalCCA training for all employees
occurs quarterly.
Be Fiscally Strong & Resilient
Objective: Maintain Investment Grade Credit
Rating
• Progress: (1) Adopted FY 2025-26 budget that is
balanced; (2) Adopted policy to set cash reserves
target to 270 expense coverage days that will move the
needle towards an “A” rating
Objective: Financial Integrity and Transparency
• Progress: (1) Competed financial audit by independent auditory with a good report that included no material
weaknesses or significant deficiencies; (2) Pioneer has the proper internal controls in place to protect our
ratepayers funds.
Be Fiscally Strong & Resilient
(cont.)
Objective: Expansion of Pioneer’s Service
Territory
• Progress: (1) Conducted Impact Assessment Study on
thirteen communities; (2) Received certification from
the CPUC on addition of new members with service
launch of October 2027.
Objective: Balanced Approach to Rate-Setting
• Progress: (1) Lowered Pioneer Generation rate by 3%
in 2024 and 1% in 2025; (2) Continue to adopt
budgets that contribute to reserves
Be Fiscally Strong & Resilient
(cont.)
Objective: Community Reinvestment
• Progress: (1) BioMAT potential projects in Grass Valley and Lincoln; (2) Awarded $500,000 printing and
mailing contract to a shop located in Auburn; (3)
Amended the Feed-In Tariff to expand scope of
qualified technologies; (4) Continue power
procurement with local agencies such as El Dorado
Irrigation District and meeting with Placer County
Water Agency in summer 2025 to explore
opportunities; Awarded nearly $40,000 in sponsorships
in FY 2024-25; (5) Later in 2025 will be to award a
grant shared with Calpine to eligible 501c(3) agencies
located in our territory.
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Pioneer Community Energy
Glossary of Terms
CAISO - California Independent System Operator - a non-profit independent system operator that oversees the operation of the California bulk electric power system, transmission lines and electricity market generated and transmitted by its members (~80% of California's electric flow). Its stated mission is to "operate the grid reliably and efficiently, provide fair and open transmission access, promote environmental stewardship and facilitate
effective markets and promote infrastructure development. CAISO is regulated by FERC and governed by a five-member governing board appointed by the governor.
CALCCA - California Community Choice Association -Association made up of Community Choice Aggregation {CCA) groups which represents the interests of California's community choice electricity providers.
CARB - California Air Resources Board - The CARB is charged with protecting the public from the harmful effects of air pollution and developing programs and actions to fight climate change in California.
CEC- California Energy Commission
CPUC - California Public Utility Commission
C&I - Commercial and Industrial - Business customers
CP - Compliance Period -Time period to become RPS compliant, set by the CPUC {California Public Utilities Commission)
DA- Direct Access - An option that allows eligible customers to purchase their electricity directly from third party providers known as Electric Service Providers (ESP).
DA Cap- the maximum amount of electric usage that may be allocated to Direct Access customers in California, or more specifically, within an Investor-Owned Utility service territory.
DA Lottery - a random drawing by which DA waitlist customers become eligible to enroll in DA service under the currently-applicable Direct Access Cap.
DA Waitlist - customers that have officially registered their interest in becoming a DA customer but are not yet able to enroll in service because of DA cap limitations.
DAC - Disadvantaged Community
DASR - Direct Access Service Request - Request submitted by C&I to become direct access eligible.
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Demand - The rate at which electric energy is delivered to or by a system or part of a system, generally expressed in kilowatts {kW), megawatts {MW), or gigawatts {GW), at a given instant or averaged over any designated interval of time. Demand should not be confused with Load or Energy.
DER - Distributed Energy Resource -A small-scale physical or virtual asset {e.g., EV charger, smart thermostat, behind-the-meter solar/storage, energy efficiency) that operates locally and is connected to a larger power grid at the distribution level.
Distribution - The delivery of electricity to the retail customer's home or business through low voltage distribution lines.
DLAP- Default Load Aggregation Point- In the CAISO's electricity optimization model, DLAP is the node at which all bids for demand should be submitted and settled. Pioneer settles its CAISO load at the PG&E DLAP as Pioneer is in the PG&E transmission access charge area.
DR - Demand Response - An opportunity for consumers to play a significant role in the operation of the electric grid by reducing or shifting their electricity usage during peak periods in response to time-based rates or other forms of financial incentives.
DWR - Department of Water Resources - DWR manages California's water resources, systems, and infrastructure in a responsible, sustainable way.
ELCC- Effective Load Carrying Capacity -The additional load met by an incremental generator while maintaining the same level of system reliability. For solar and wind resources the ELCC is the amount of capacity which can be counted for Resource Adequacy purposes.
EPIC - Electric Program Investment Charge -The EPIC program was created by the CPUC to support investments in clean energy technologies that provide benefits to the electricity ratepayers of PG&E, San Diego Gas & Electric Company {SDG&E), and Southern California Edison Company {SCE) ERRA - Energy Resource Recovery Account - ERRA proceedings are used to determine fuel and purchased power costs which can be recovered in rates. The utilities do not earn a rate of return on these costs, and only recover actual costs. The costs are forecast for the year ahead. If the actual costs are lower than forecast, then the utility gives money back, and vice versa.
ESP- Energy Service Provider - An energy entity that provides service to a retail or end-use customer.
EV - Electric Vehicle
GHG - Greenhouse gas - water vapor, carbon dioxide, tropospheric ozone, nitrous oxide, methane, and chlorofluorocarbons (CFCs). A gas that causes the atmosphere to trap heat radiating from the earth. The most common GHG is Carbon Dioxide, though Methane and others have this effect as well.
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GRC- General Rate Case - Proceedings used to address the costs of operating and maintaining the utility system and the allocation of those costs among customer classes. For California's three large IOUs, the GRCs are parsed into two phases. Phase I of a GRC determines the total amount the utility is authorized to collect, while Phase II determines the share of the cost each customer class is responsible and the rate schedules for each class. Each large electric utility files a GRC application every three years for review by the Public Advocates Office and interested parties and approval by the CPUC.
GWh - Gigawatt-hour - The unit of energy equal to that expended in one hour at a rate of one billion watts. One GWh equals 1,000 megawatt-hours.
IEP - Independent Energy Producers - California's oldest and leading nonprofit trade association, representing the interest of developers and operators of independent energy facilities and independent power marketers.
IOU - Investor Owned Utility- A private electricity and natural gas provider.
IRP- Integrated Resource Plan -A plan which outlines an electric utility's resource needs in order to meet expected electricity demand long-term.
kW - Kilowatt - Measure of power where power (watts)= voltage (volts) x amperage (amps) and 1 kW= 1000 watts
kWh - Kilowatt-hour - This is a measure of consumption. It is the amount of electricity that is used over some period of time, typically a one-month period for billing purposes. Customers are charged a rate per kWh of electricity used.
LCFS- Low Carbon Fuel Standard -A CARB program designed to encourage the use of cleaner low-carbon fuels in California, encourage the production of those fuels, and therefore, reduce greenhouse gas emissions.
LCR - Local (RA) Capacity Requirements -The amount of Resource Adequacy capacity required to be demonstrated in a specific location or zone.
LMP - Locational Marginal Price - Each generator unit and load pocket is assigned a node in the CAISO optimization model. The model will assign a LMP to the node in both the day- ahead and real time market as it balances the system using the least cost. The LMP is comprised of three components: the marginal cost of energy, congestion, and losses. The LMP is used to financially settle transactions in the CAISO.
Load - An end use device or customer that receives power from an energy delivery system. Load should not be confused with Demand, which is the measure of power that a load receives or requires.
See Demand.
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SE - Load-serving Entity- Entities that have been granted authority by state, local law, or regulation to serve their own load directly through wholesale energy purchases and have chosen to exercise that authority.
NEM - Net Energy Metering -A program in which solar customers receive credit for excess electricity generated by solar panels.
NRDC- Natural Resources Defense Council
OIR - Order Instituting Rulemaking - A procedural document that is issued by the CPUC to start a formal proceeding. A draft OIR is issued for comment by interested parties and made final by vote of the five Commissioners of the CPUC.
MW - Megawatt - measure of power. A megawatt equals 1,000 kilowatts or 1 million watts.
MWH - Megawatt-hour- measure of energy
NP-15 - North Path 15 - NP-15 is a CAISO pricing zone usually used to approximate wholesale electricity prices in northern California in PG&E's service territory.
PCCl - RPS Portfolio Content Category 1- Bundled renewables where the energy and REC are dynamically scheduled into a California Balancing Authority (CBA) such as the CAISO. Also known as "in-state" renewables.
PCC2 - RPS Portfolio Content Category 2 - Bundled renewables where the energy and REC are from out-of-state and not dynamically scheduled to a CBA.
PCC3 - RPS Portfolio Content Category 3 - Unbundled REC PCIA or "exit fee" - Power Charge Indifference Adjustment (PCIA) is an "exit fee" based on stranded costs of utility generation set by the California Public Utilities Commission. It is calculated annually and assessed to customers of CCAs and paid to the IOU that lost those customers as a result of the formation of a CCA.
PCL - Power Content Label - A user-friendly way of displaying information to California consumers about the energy resources used to generate the electricity they sell, as required by AB 162 (Statue of 2009) and Senate Bill 1305 (Statutes of 1997).
PD- Proposed Decision -A procedural document in a CPUC Rulemaking process that is formally commented on by Parties to the proceeding. A PD is a precursor to a final Decision voted on by the five Commissioners of the CPUC.
Pnode - Pricing Node - In the CAISO optimization model, it is a point where a physical injection or withdrawal of energy is modeled and for which a LMP is calculated.
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PPA- Power Purchase Agreement -A contract used to purchase the energy, capacity, and attributes from a renewable resource project.
RA - Resource Adequacy - Under its Resource Adequacy (RA) program, the California Public Utilities Commission (CPUC) requires load-serving entities-both independently owned utilities and electric service providers-to demonstrate in both monthly and annual filings that they have purchased capacity commitments of no less than 115% of their peak loads.
RE - Renewable Energy - Energy from a source that is not depleted when used, such as wind or solar power.
REC - Renewable Energy Certificate - A REC is the property right to the environmental benefits associated with generating renewable electricity. For instance, homeowners who generate solar electricity are credited with 1 solar REC for every MWh of electricity they produce. Utilities obligated to fulfill an RPS requirement can purchase these RECs on the open market.
RPS - Renewable Portfolio Standard - Law that requires CA utilities and other load serving entities (including CCAs) to provide an escalating percentage of CA qualified renewable power (culminating at 33% by 2020) in their annual energy portfolio.
SCE - Southern California Edison
SDG&E - San Diego Gas & Electric
SGIP - Self-Generation Incentive Program - A program which provides incentives to support existing, new, and emerging distributed energy resources (storage, wind turbines, waste heat to power technologies, etc.)
TCR EPS Protocol - The Climate Registry Electric Power Sector Protocol - Online tools and resources provided by The Climate Registry to assist organizations to measure, report, and reduce carbon emissions.
Time-of-Use (TOU) Rates - The pricing of delivered electricity based on the estimated cost of electricity during a particular time-block. Time-of-use rates are usually divided into three or four time-blocks per 24-hour period (on-peak, mid-peak, off-peak and sometimes super off peak) and by seasons of the year (summer and winter). Real time pricing differs from TOU rates in that it is based on actual (as opposed to forecasted) prices that may fluctuate many times a day and are weather sensitive, rather than varying with a fixed schedule.
TURN - The Utility Reform Network - A ratepayer advocacy group charged with ensuring that California IOUs implement just and reasonable rates.
Unbundled RECs - Renewable energy certificates that verify a purchase of a MWH unit of renewable power where the actual power and the certificate are "unbundled" and sold to different buyers.
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VPP - Virtual Power Plant - A cloud-based network that leverages an aggregation of distributed energy resources (DERs) to shift energy demand or provide services to the grid. For example, thousands of EV chargers could charge at a slower speed and hundreds of home batteries could discharge to the grid during a demand peak to significantly reduce the procurement of traditional supply resources.