Agenda, regular meeting — Pioneer Community Energy Board of Directors, September 18, 2025 (part 1 of 2)

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
September 18, 2025

REGULAR MEETING
3:00 PM
Pioneer Community Energy Board Room
2510 Warren Drive, Suite B, Rocklin, CA 95677
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. RECONVENE OPEN SESSION

1. Roll Call
B. PUBLIC REPORT OF CLOSED SESSION
C. 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 July 10, 2025 special meeting. (ECKERT) b) LEGISLATIVE & REGULATORY
Adopt a resolution approving an attestation regarding the veracity of information reflected in Pioneer Community Energy’s 2024 Power Source Disclosure Report for Pioneer Standard (“Base Service”) and for Pioneer Green 100. (KANG) c) PROGRAMS
Adopt resolution authorizing the Chief Executive Officer to extend access to Cost-Neutral Programs to new Member Agencies prior to October 2027 Service Expansion. (STASSI-VANACORE)
d) LEGISLATIVE & REGULATORY
Adopt a resolution approving and authorizing the Pioneer Community Energy Revised Load Management Standards Compliance Plan and Submission to the California Energy Commission.(KANG)
e) FINANCE & ADMINISTRATION
Adopt Resolution to authorize the Chief Executive Officer to execute an amendment to the agreement with Braun Blaising & Wynne, P.C. to amend hourly rates. (KOEHN 2) PRESENTATION
Review of the Power Charge Indifference Adjustment (DISCUSSION-ECKERT) Recommendation: Receive an overview of the current state of the PCIA, or Power Charge Indifference Adjustment, including an overview of its purpose and calculation, anticipated changes to PCIA rates in 2026, and Pioneer advocacy efforts.

III. REGULAR AGENDA
3) MARKETING & COMMUNICATIONS
Adopt Resolution to Allow for the Chief Executive Officer to Initiate the Expansion Process to Allow for the Addition of Unincorporated Madera County and the Cities of Colusa, Madera, and Chowchilla (ACTION-STASSI-VANACORE)
Recommendation: Adopt Resolution to allow for the Chief Executive Officer to initiate the expansion process to allow for the addition of Unincorporated Madera County and the Cities of Colusa, Madera, and Chowchilla.
4) FINANCE & ADMINISTRATION
Adopt Resolution Approving an Update to the Net Energy Metering (NEM) Service Policy (ACTION-KOEHN )
Recommendation: Adopt Resolution approving an update to the Net Energy Metering (NEM) Service Policy.
5) MARKETING & COMMUNICATIONS
Adopt Resolution Authorizing the Chief Executive Officer to Execute an Agreement with PaulosAnalysis to Provide an Online Incentive Finder Tool for Customers, for an Amount Not to Exceed $75,000 for a One-Year Term with the Option of Two One-Year Extensions (ACTION- STASSI-VANACORE)
Recommendation: Adopt Resolution authorizing the Chief Executive Officer to execute an Agreement with PaulosAnalysis to provide an online Incentive Finder Tool for customers, for an amount not to exceed $75,000 for a one-year term with the option of two one-year extensions. 6) FINANCE & ADMINISTRATION
Adopt Resolution Approving the Artificial Intelligence Acceptable Use Policy (ACTION-KOEHN) Recommendation: Adopt Resolution approving the Artificial Intelligence Acceptable Use Policy.

IV. GENERAL ADMINISTRATIVE FUNCTION – PART 2
A. BOARD MEMBER COMMUNICATIONS

1. Audit & Finance Committee, Committee Chair Ring

2. Governance Committee, Committee Chair Dowdin
Calvillo
B. CHIEF EXECUTIVE OFFICER COMMUNICATIONS
C. ITEMS FOR INFORMATION

1. Glossary of Terms
D. ADJOURNMENT
Upcoming Meeting of the Board:

October 16, 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 September 18, 2025 regular meeting of the Pioneer Community Energy Governing Board was posted and available for public review on September 12, 2025 at the offices of Pioneer Community Energy, 2510 Warren Drive, Suite B, Rocklin, CA 95677; 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
July 10, 2025

SPECIAL MEETING
Entry No. 1
Heard General Administrative Functions – Part I
Call to Order
Pioneer Community Energy Governing Board met in open session at 2:46 PM on July 10, 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; at remote location Nevada City - City Hall, Wetherall Conference Room, 317 Broad Street, Nevada City, CA 95959; 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/.

A. Roll Call

Present: City of Auburn (Dowdin Calvillo), County of El Dorado (Parlin), City of Colfax (Lomen), City of Grass Valley (Ivy), City of Lincoln (Pearl), Town of Loomis (Ring), County of Placer (DeMattei), City of Placerville (Carter).

Absent: Nevada City (Petersen), County of Placer (Jones), City of Rocklin (Janda).

Chair Dowdin Calvillo presided over the meeting.

B. Public Comment
There were no comments from members of the public on items not listed on this agenda.

C. Closed Session
Adjourned to Closed Session at 2:47 PM.

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
Reconvened Open Session at 3:09 PM.

1. Roll Call
Director Petersen joined the meeting prior to reconvening open session.

Present: City of Auburn (Dowdin Calvillo), County of El Dorado (Parlin), City of Colfax (Lomen), City of Grass Valley (Ivy), City of Lincoln (Pearl), Town of Loomis (Ring), Nevada City (Petersen), County of Placer (DeMattei), City of Placerville (Carter).

Absent: County of Placer (Jones), City of Rocklin (Janda).

DRAFT Minutes
July 10, 2025 – page 2
E. PUBLIC REPORT OF CLOSED SESSION
In the matter of
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.

There was no reportable action taken during the Closed Session.

F. AGENDA REVIEW
Reviewed and agreed by consensus to revise the meeting agenda for July 10, 2025 as follows:

1. Adjourn today’s meeting in honor of former Board Director, Dan Karleskint.

2. Pulled Item 2, Presentation from guest speaker, Dr. Ahmad Faruqui, to be rescheduled for a future meeting.

3. Added presentation to Chief Executive Officer Eckert in recognition of serving Pioneer Community Energy for five years.

Entry No. 2
Acted on the Consent Agenda as follows:

Received Fiscal Year 2024-25 Draft Monthly Financial Reports through May 2025.

Adopted Resolution 2025-29 approving an 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.

Approved the Consent Agenda less Item 1a, Minutes of the June 19, 2025 regular meeting, which was pulled for separate consideration.

MOTION: Parlin/Pearl. Vote: 9:0:2.

Ayes: Carter, Dowdin Calvillo, DeMattei, Ivy, Lomen, Parlin, Pearl, Petersen, Ring.

Absent: Janda, Jones.

Entry No. 3
Approved Consent Agenda Item 1a, Minutes of the June 19, 2025 regular meeting, as amended with a clarification to the motion made in adopting the Cash Reserves Policy (Entry No. 5) was applied as “Adopt Resolution 2025-27 increasing the cash liquidity target to 270 days, and, if Pioneer exceeds 270 days, for the matter to be scheduled for future discussion by the Board concerning the use of the excess liquidity beyond the target.”
MOTION: Dowdin Calvillo/Parlin. Vote: 9:0:2.

Ayes: Carter, Dowdin Calvillo, DeMattei, Ivy, Lomen, Parlin, Pearl, Petersen, Ring.

Absent: Janda, Jones.

Entry No. 4
Item 2, presentation from guest speaker, Dr. Ahmad Faruqui, on a variety of topics impacting California’s electricity markets, will be rescheduled to a future meeting.

DRAFT Minutes
July 10, 2025 – page 3
Entry No. 5
Update on Expansion Efforts and Planning for October 2027 Service Launch Received an update on expansion efforts and an overview of planning for an October 2027 service launch.

Entry No. 6
Update on Power Markets and Energy Procurement
Received an update on power markets and energy procurement.

Entry No. 7
Adopt Resolution Honoring the Memory of Dan Karleskint
Adopted Resolution 2025-30 honoring the memory of former Board Director Dan Karleskint for his contributions to the success of Pioneer Community Energy and his outstanding service to the community.

Board Chair Dowdin Calvillo read aloud the Resolution for the record; and many added their comments and expressed appreciation for Director Karleskint.

RESOLUTION HONORING THE MEMORY OF FORMER BOARD DIRECTOR

DAN KARLESKINT

FOR HIS CONTRIBUTIONS TO THE SUCCESS OF PIONEER COMMUNITY ENERGY AND HIS

OUTSTANDING SERVICE TO THE COMMUNITY
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.

NOW, THEREFORE, BE IT RESOLVED that the Pioneer Community Energy Board does hereby celebrates the life and accomplishments of Mr. Dan Karleskint and expresses its admiration for a life well lived; and extends its sympathy and condolences to Mr. Karleskint’s family and many friends.

MOTION: Pearl/Lomen. Vote: 9:0:2.

Ayes: Carter, Dowdin Calvillo, DeMattei, Ivy, Lomen, Parlin, Pearl, Petersen, Ring.

Absent: Janda, Jones.

Entry No. 8
Heard General Administrative Function – Part II
DRAFT Minutes
July 10, 2025 – page 4
Board Member Communications
Committee Chair Dowdin Calvillo reported that the Expansion ad hoc Committee met on July 9, 2025.

The Committee received, discussed, and provided direction to staff regarding: (1) the Communication Plan and Power Procurement for Pioneer’s thirteen new Members; and, (2) potential new members interested in joining Pioneer Community Energy.

Board Chair Dowdin Calvillo announced that the Google ratings for Pioneer Community Energy have greatly improved and are now the second highest rating for all CCAs; and, expressed appreciation for the Customer Care Team and staff for outreach and positive community involvement; and, others also expressed their appreciation of staff.

Chief Executive Officer Communications
Chief Executive Officer Eckert announced that August is “dark” and no Board or Committee meetings are scheduled. If an urgent matter arises, we will convene a special meeting.

Chief Executive Officer Eckert informed the Board that AB 706, The Forest and Wildfire Prevention Fund Act (biomass project funding), has bipartisan support and has moved through the House and the Senate, but State funds are not available so AB 706 is on hold for next year’s session. A full recap on Legislative items, will be presented by staff at a future meeting of the Board.

Chief Executive Officer Eckert announced that the MicroGrid incentive program has four open projects and noted that Pioneer is the only CCA participating in this program; and, announced that Pioneer will be launching our first Contractors’ Breakfast Event next week to encourage all HVAC and solar contractors to participate in Pioneer programs.

Items for Information
Received the Glossary of Terms.

Adjournment
The meeting was adjourned at 3:59 PM in honor of former Board Director, Dan Karleskint.

Page 1 of 2 ends

Staff Report – Item 1b
To: The Governing Board
From: Chau Pham, Legislative and Regulatory Policy Analyst Item 1b: Power Source Disclosure Attestation
Date: 9/18/2025

RECOMMENDATION
Adopt a resolution approving an attestation regarding the veracity of information reflected in Pioneer’s 2024 Power Source Disclosure Report for Pioneer Standard (Base Service) and Pioneer Green100.

BACKGROUND
California’s Power Source Disclosure Program (PSD), as administered by the California Energy Commission (CEC), requires that retail energy sellers like Pioneer Community Energy distribute a Power Content Label (PCL) to customers each year – the PCL serves as a “nutritional label” for each retail energy seller’s supply portfolio, providing information regarding the composition of such supply and the various generating technologies contributing to the reported resource mix. This process typically occurs during the late Summer/early Fall, following submittal of an annual PSD report to the CEC, which details specified-source energy purchases completed during the prior calendar year (the reporting year, which, in this case, is 2024). Pioneer timely submitted its PSD report addressing 2024 power purchases, along with a signed attestation from our Chief Executive Officer to the CEC prior to the June 1, 2025 reporting deadline.

The CEC has modified the process of generating and submitting the PCL from prior years to implement recent legislative changes (SB 1158 (2022) and AB 242 (2021)). In previous years, retail suppliers were directed to use the PCL template provided by the CEC on its website to generate their own PCL. However, beginning in 2025 and each year thereafter, the PCL will be produced by CEC PSD staff and given to retail suppliers to share with their customers. Accordingly, the PCL will no longer require a separate attestation from the governing boards of public agencies, which will only need to attest to the veracity of their submitted annual PSD report.

Pioneer is required to submit the requested board attestation of the annual PSD report to the CEC by October 1, 2025.

The CEC has announced it will distribute the PCL to retail suppliers by mid-September. Upon receipt, Pioneer will display the PCL on its website by October 1, 2025 and provide the PCL to our customers by December 31, 2025, in compliance with the CEC PSD regulations.

ANALYSIS & DISCUSSION
Among other details, the annual PSD report includes information specifying the proportionate share of total energy supply attributable to various generating technologies, including both renewable and conventional fuel sources. In the event a retail seller meets a certain percentage of its energy requirements from unspecified resources, the report must identify such purchases as “unspecified sources of power.” A number of Pioneer’s power supply contracts do not identify specific generating sources, which is a common contracting convention for certain types of energy transactions. These purchases, as well as electric energy provided by the California Independent System Operator for purposes of grid balancing, have been appropriately identified as “unspecified sources of power” in the PSD report.

Plf)NEER

COMMUNITY ENERGY
Agenda Item: 1b Agenda Date: 9/18/2025

Page 2 of 2 ends

The CEC requires that the Pioneer Board provide an attestation regarding the accuracy of information included in the 2024 PSD report, which addresses power portfolio details related to the Pioneer Standard and Pioneer Green100 retail service options. Due to recent changes in the CEC’s administration of the PSD program, a Pioneer Board attestation related to the PCL is no longer required, as the PCL will be generated by CEC PSD Staff on behalf of retail suppliers. Pioneer’s consultant, Pacific Energy Advisors, Inc., completed a detailed review of Pioneer’s 2024 energy purchases, and prepared and submitted the aforementioned 2024 PSD report on behalf of Pioneer, which is included as an attachment to this staff report.

The PSD shows that Pioneer’s Base Service plan contains 42% bundled renewable energy, along with 3% unbundled renewable energy credits (RECs), totaling 45% renewable energy content for this service option.

The 3% of retail sales covered by retired unbundled RECs relate to renewable energy production from California-sited biomass resources and Alberta-sited wind resources. In addition, the PSD shows that Pioneer’s Green100 plan offers a premium product that consists of 100% bundled renewable energy with zero portfolio emissions.

After the Board provides the required attestation for Pioneer’s 2024 PSD report, Pioneer’s consultant, Pacific Energy Advisors Inc., will submit the following items to the CEC: 1) this staff report and the attached resolution; and 2) meeting minutes for today’s Board meeting (when approved). Submittal of these materials is expected to fulfill Pioneer’s obligations under the PSD Program for the 2024 calendar year.

STRATEGIC PLAN
The recommendation supports the “Achieve Operational Optimization” goal.

FISCAL IMPACT
Staff estimates the printing and distribution of Pioneer’s 2024 PCL, per CEC requirement, will cost less than $20,000, which is included in Pioneer’s operating budget and consistent with last year. Delivery of the PCL will take place via email to customers who have consented to receiving electronic communications. All others will be mailed.

ATTACHMENTS
A. Resolution of the Pioneer Community Energy Board approving the attestation of veracity for the 2024 Power Source Disclosure Report for Pioneer’s Base Service and Pioneer Green100 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 September 18, 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, Public Utility Code 398.4 and 398.5 establish a Power Source Disclosure (“PSD”) program that requires retail sellers of electricity to annually submit a power source disclosure report to the California Energy Commission (“CEC”); and WHEREAS, Pioneer has the authority to aggregate electric load to purchase and supply electricity for customers within its jurisdiction; and
WHEREAS, Pioneer is a retail seller of electricity as defined by the PSD Program and is therefore required to submit a PSD report; and
WHEREAS, Pioneer timely submitted the 2024 Annual Power Source Disclosure Report for Pioneer Base Service and Pioneer Green 100 to the CEC in accordance with the PSD regulation; and
WHEREAS, Pioneer, as a retail supplier that is a public agency providing electric services, is required to submit to the CEC an attestation from the Board of Directors of the veracity of the 2024 Annual Power Source Disclosure Report for Pioneer Base Service and Pioneer Green 100.

In the matter of: APPROVING AN

ATTESTATION REGARDING THE VERACITY

OF INFORMATION REFLECTED IN PIONEER
COMMUNITY ENERGY’S (PIONEER) 2024

POWER SOURCE DISCLOSURE REPORT FOR
PIONEER STANDARD (“BASE SERVICE”) AND
PIONEER GREEN 100
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. Approve an attestation regarding the veracity of information reflected in Pioneer’s 2024 Power Source Disclosure Report for Pioneer Base Service and Pioneer Green100, and submission of the report to the CEC.

3. This Resolution shall take effect immediately upon its adoption.

Exhibits:

A: Pioneer’s 2024 Power Source Disclosure Report – Base Service and Green100 Resolution 2025- ___
September 18, 2025
Version: April 2025
Submit the Annual Report and signed Attestation in PDF format with the Excel version of the Annual Report to [email protected]. Remember to complete the Retail Supplier Name and contact information above.

NOTE: Information submitted in this report is not automatically held confidential. If your company wishes the information submitted to be considered confidential an authorized representative must submit an application for confidential designation California Energy Commission's website.

If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 639-0573.

TITLE Consultant
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2024
Retail suppliers are required to use the posted template and are not allowed to make edits to this format. Please complete all requested information.

GENERAL INSTRUCTIONS

RETAIL SUPPLIER NAME
Pioneer Community Energy

CONTACT INFORMATION
NAME Kirby Dusel
EMAIL [email protected]

WEBSITE URL

FOR PCL

POSTING
https://pioneercommunityenergy.org/
MAILING 1839 Iron Point Road, Suite 120
CITY, STATE, ZIP Folsom, CA 95630
PHONE 916-936-3300
Annual Data
Instructions:

1. Enter the electricity portfolio name in cell O25 and additional electricity portfolio names as needed in cells P25-V25.2. Enter information about all power procurements and retail sales. Insert additional rows as needed. All fields in white should be filled out. Fields in grey auto-populate as needed and should not be filled out.3. For all specified purchases, enter the facility name, fuel type, state or province, WREGIS ID of REC source, RPS ID of REC source, EIA ID of delivered energy, gross MWhs procured, and specified resales MWhs.4. For firmed-&-shaped procurements specifically, enter all fields from step 3. Additionally, enter the EIA ID of the substitute power in the "EIA ID of delivered energy" field and select "Yes" in the "Firmed-&-Shaped Resource?" field. If the associated GHG emissions are eligible for firmed-&-shaped grandfathering, select "Yes" in the relevant field.5. Proxy EIA IDs for unspecified power and specified system mixes from asset-controlling suppliers have been provided. Enter "Unspecified Power", "BPA", or "Tacoma Power" as applicable. 6. Proxy EIA IDs for aggregated reporting of WAPA CVP or PCIA resoures; Enter "CVP", "PCIA Solar", "PCIA Wind", "PCIA Eligible Hydro", or "PCIA Large Hydro" as applicable.7. Procurements of unspecified power must not be entered as line items below; unspecified power will be calculated automatically in the individual electricity portfolio tables to the right after all specified resources have been allocated.

8. Allocate net MWhs procured to each electricity portfolio until the loads are balanced across each portfolio. If the total Net MWhs Procured exceeds the total retail sales of all portfolios, allocate only enough MWh to meet the retail sales of each portfolio.

Over allocation check ✓
Under allocation
check ✓
Coal check ✓
Negative oversupply
check ✓
Retail Sales 5455.023 1736606.028
Unmet Load 0 934545
Facility Name Fuel Type State or Province WREGIS ID of REC source RPS ID of REC source EIA ID of delivered energy Gross MWhs Procured Specified Resales MWhs Net MWhs Procured Firmed & Shaped Resource? Eligible for Firmed & Shaped Grandfathering? Total EF (MT CO2e/MWh) Total GHGs PCL EF (MT CO2e/MWh) Green100 Base Plan A. G. Wishon Powerhouse - A. G. Wishon Power Eligible Hydroelectric CA W344 60032A 293 97 97 0.0000 0.0000 97 Agua Caliente Solar - Block 1 Solar AZ W2427 60894A 57373 316 316 0.0000 0.0000 316Agua Caliente Solar - Block 10 Solar AZ W3621 60894A 57373 264 264 0.0000 0.0000 264Agua Caliente Solar - Block 11 Solar AZ W3829 60894A 57373 264 264 0.0000 0.0000 264Agua Caliente Solar - Block 12 Solar AZ W3953 60894A 57373 120 120 0.0000 0.0000 120Agua Caliente Solar - Block 2 Solar AZ W2576 60894A 57373 316 316 0.0000 0.0000 316Agua Caliente Solar - Block 3 Solar AZ W2668 60894A 57373 316 316 0.0000 0.0000 316Agua Caliente Solar - Block 4 Solar AZ W2782 60894A 57373 225 225 0.0000 0.0000 225Agua Caliente Solar - Block 5 Solar AZ W2838 60894A 57373 318 318 0.0000 0.0000 318Agua Caliente Solar - Block 6 Solar AZ W2844 60894A 57373 318 318 0.0000 0.0000 318Agua Caliente Solar - Block 7 Solar AZ W2925 60894A 57373 318 318 0.0000 0.0000 318Agua Caliente Solar - Block 8 Solar AZ W3240 60894A 57373 264 264 0.0000 0.0000 264Agua Caliente Solar - Block 9 Solar AZ W2812 60894A 57373 264 264 0.0000 0.0000 264Alamo Solar - Alamo Solar Solar CA W4546 61453A 59469 255 255 0.0000 0.0000 255Alta Powerhouse - Alta Powerhouse Eligible Hydroelectric CA W335 60033A 214 7 7 0.0000 0.0000 7Antelope West Solar - Antelope West Solar Solar CA W4322 61850A 59443 279 279 0.0000 0.0000 279Atwell Island - Atwell Island PV Solar Generating Solar CA W3159 60947A 58366 170 170 0.0000 0.0000 170AV Solar Ranch 1, LLC - Antelope Solar Ranch - Solar CA W3474 60790A 57378 371 371 0.0000 0.0000 371AV Solar Ranch 1, LLC - AVSR1 - Antelope Sola Solar CA W4141 60790A 57378 598 598 0.0000 0.0000 598AV Solar Ranch 1, LLC - AVSR1 - Antelope Sola Solar CA W2803 60790A 57378 357 357 0.0000 0.0000 357AV Solar Ranch 1, LLC - AVSR1 - Antelope Sola Solar CA W3274 60790A 57378 282 282 0.0000 0.0000 282AV Solar Ranch 1, LLC - AVSR1 - Antelope Sola Solar CA W3275 60790A 57378 252 252 0.0000 0.0000 252AV Solar Ranch 1, LLC - AVSR1 - Antelope Sola Solar CA W3280 60790A 57378 207 207 0.0000 0.0000 207AV Solar Ranch 1, LLC - AVSR1 - Antelope Sola Solar CA W3849 60790A 57378 668 668 0.0000 0.0000 668Bakersfield Solar - SKIC 20 Solar CA W4550 61558A 59412 220 220 0.0000 0.0000 220Bayshore Solar A - Big Sky Solar 6 Solar CA W5731 63133A 60481 260 260 0.0000 0.0000 260 Bayshore Solar B - Big Sky Solar 7 Solar CA W5737 63134A 60474 254 254 0.0000 0.0000 254 Bayshore Solar C - Big Sky Solar 8 Solar CA W5738 63135A 60475 232 232 0.0000 0.0000 232Blackwell Solar - Blackwell Solar, LLC Solar CA W4587 61892A 59524 154 154 0.0000 0.0000 154CA Flats 150 - CA Flats 150 Solar CA W7112 62552A 60034 1751 1751 0.0000 0.0000 1751California Valley Solar Ranch - Block1 Solar CA W2847 60603A 57439 272 272 0.0000 0.0000 272California Valley Solar Ranch - Block2 Solar CA W3106 60603A 57439 807 807 0.0000 0.0000 807California Valley Solar Ranch - Block3 Solar CA W3111 60603A 57439 1539 1539 0.0000 0.0000 1539California Valley Solar Ranch - Block4 Solar CA W3187 60603A 57439 417 417 0.0000 0.0000 417Cantua Solar Station - Cantua Solar Station Solar CA W2580 61823A 57522 165 165 0.0000 0.0000 165CED Corcoran - CED Corcoran Solar CA W3408 60948A 58374 176 176 0.0000 0.0000 176CED White River Solar - CED White River Solar Solar CA W3406 60949A 58373 226 226 0.0000 0.0000 226CID Solar - Corcoran Irrigation District - CID SolaSolar CA W4227 62285A 59183 241 241 0.0000 0.0000 241 Coleman Powerhouse - Coleman Powerhouse Eligible Hydroelectric CA W347 60037A 227 120 120 0.0000 0.0000 120Copper Mountain Solar 2 - CMS 2 (1) Solar NV W2818 60990A 58017 413 413 0.0000 0.0000 413Copper Mountain Solar 2 - CMS 2 (2) Solar NV W2943 60990A 58017 367 367 0.0000 0.0000 367Copper Mountain Solar 2 - CMS 2 (3) Solar NV W3201 60990A 58017 367 367 0.0000 0.0000 367Copper Mountain Solar 2 - CMS 2 (4) Solar NV W4555 60990A 58017 368 368 0.0000 0.0000 368Copper Mountain Solar 2 - CMS 2 (5) Solar NV W4589 60990A 58017 305 305 0.0000 0.0000 305Crane Valley Powerhouse - Crane Valley PowerhEligible Hydroelectric CA W349 60039A 230 5 5 0.0000 0.0000 5Cuyama Solar - Cuyama Solar Solar CA W5611 61891A 60043 358 358 0.0000 0.0000 358De Sabla Powerhouse - De Sabla Powerhouse Eligible Hydroelectric CA W351 60041A 232 115 115 0.0000 0.0000 115DESERT SUNLIGHT 300, LLC - DSL-BLK01 - 04Solar CA W3793 61068A 57993 1648 1648 0.0000 0.0000 1648DESERT SUNLIGHT 300, LLC - DSL-BLK05 & 0Solar CA W3798 61068A 57993 539 539 0.0000 0.0000 539DESERT SUNLIGHT 300, LLC - DSL-BLK07 & 0Solar CA W3800 61068A 57993 260 260 0.0000 0.0000 260DESERT SUNLIGHT 300, LLC - DSL-BLK09 Solar CA W3801 61068A 57993 215 215 0.0000 0.0000 215DESERT SUNLIGHT 300, LLC - DSL-BLK10 & 1Solar CA W3783 61068A 57993 539 539 0.0000 0.0000 539Dutch Flat #2 Powerhouse - Dutch Flat #2 PowerEligible Hydroelectric CA W488 60264A 413 77 77 0.0000 0.0000 77Dutch Flat No. 1 Powerhouse - Dutch Flat No. 1 PEligible Hydroelectric CA W352 60042A 237 174 174 0.0000 0.0000 174El Dorado Powerhouse - ElDorado_7_unit1 Eligible Hydroelectric CA W905 60601A 238 37873 37873 0.0000 0.0000 2000 35873El Dorado Powerhouse - ElDorado_7_unit2 Eligible Hydroelectric CA W906 60601A 238 43222 43222 0.0000 0.0000 43222Five Points Solar Station - Five Points Solar StatiSolar CA W2201 61432A 57498 78 78 0.0000 0.0000 78FPL Energy Montezuma Wind - FPL Energy MonWind CA W1745 60543A 57201 435 435 0.0000 0.0000 435Gaskell West 3 Solar CA W15529 63619A P216 322 322 0.0000 0.0000 322Gaskell West 4 Solar CA W15585 63617A P215 326 326 0.0000 0.0000 326Gaskell West 5 Solar CA W15586 63618A P214 323 323 0.0000 0.0000 323Gates Solar Station - Gates Solar Station Solar CA W3477 62353A 57892 169 169 0.0000 0.0000 169GENESIS SOLAR, LLC - SGN-1 Solar CA W3790 60605A 57394 1492 1492 0.0000 0.0000 1492GENESIS SOLAR, LLC - SGN2 Solar CA W3791 60605A 57394 1540 1540 0.0000 0.0000 1540Geysers Power Plant - Sonoma/Calpine Geyser Geothermal CA W127 60010A 510 70272 70272 0.0432 3036 0.0000 1455.023 68816.977Giffen Solar Station - Giffen Solar Station Solar CA W2581 61822A 57521 71 71 0.0000 0.0000 71Guernsey Solar Station - Guernsey Solar Station Solar CA W3476 62354A 57891 122 122 0.0000 0.0000 122Halsey Powerhouse - Halsey Powerhouse Eligible Hydroelectric CA W353 60043A P221 43 43 0.0000 0.0000 43Hat Creek No. 1 Powerhouse - Hat Creek No. 1 PEligible Hydroelectric CA W355 60045A 243 122 122 0.0000 0.0000 122Hat Creek No. 2 Powerhouse - Hat Creek No. 2 PEligible Hydroelectric CA W356 60046A 244 124 124 0.0000 0.0000 124Henrietta Solar Plant - Parrey, LLC Solar CA W5056 61841A 58975 1168 1168 0.0000 0.0000 1168Huron Solar Station - Huron Solar Station Solar CA W2579 61821A 57523 152 152 0.0000 0.0000 152Ivanpah - Unit 1 Solar CA W3189 62273A 57074 956 956 0.0894 85 0.0894 956Ivanpah - Unit 3 Solar CA W3190 62275A 57075 1360 1360 0.0894 122 0.0894 1360Java Solar - Java Solar Solar CA W13698 63137A 65965 157 157 0.0000 0.0000 157Kansas - Kansas Solar CA W4192 61263A 58985 191 191 0.0000 0.0000 191Kent South - Kent South Solar CA W4193 61262A 58991 237 237 0.0000 0.0000 237Lost Hills - Lost Hills Solar, LLC Solar CA W4586 61893A 58711 273 273 0.0000 0.0000 273Mammoth Pacific L. P. (MP1) - Mammoth Pacific Geothermal CA W417 60306A 10480 319 319 0.0757 24 0.0000 319Mammoth Pacific L. P. I (PLES) - Mammoth Paci Geothermal CA W416 60315A 10479 553 553 0.0757 42 0.0000 553Mesquite Solar 1 (10) - Mesquite Solar 1 (10) Solar AZ W3205 60875A 57707 117 117 0.0000 0.0000 117Mesquite Solar 1 (11) - Mesquite Solar 1 (11) Solar AZ W3130 60875A 57707 193 193 0.0000 0.0000 193Mesquite Solar 1 (12) - Mesquite Solar 1 (12) - MSolar AZ W3183 60875A 57707 192 192 0.0000 0.0000 192Mesquite Solar 1 (1-3) - Mesquite Solar 1 (1-3) Solar AZ W2399 60875A 57707 503 503 0.0000 0.0000 503Mesquite Solar 1 (4) - Mesquite Solar 1 (4) Solar AZ W2755 60875A 57707 193 193 0.0000 0.0000 193Mesquite Solar 1 (5) - Mesquite Solar 1 (5) Solar AZ W2784 60875A 57707 193 193 0.0000 0.0000 193Mesquite Solar 1 (6) - Mesquite Solar 1 (6) Solar AZ W2807 60875A 57707 96 96 0.0000 0.0000 96Mesquite Solar 1 (7) - Mesquite Solar 1 (7) Solar AZ W2841 60875A 57707 193 193 0.0000 0.0000 193Mesquite Solar 1 (8) - Mesquite Solar 1 (8) Solar AZ W2871 60875A 57707 144 144 0.0000 0.0000 144Mesquite Solar 1 (9) - Mesquite Solar 1 (9) Solar AZ W3095 60875A 57707 193 193 0.0000 0.0000 193Mesquite Solar 3, LLC - Mesquite Solar 3 (1) Solar AZ W4959 62897A P217 197463 197463 0.0000 0.0000 197463Michael E. Bowler Memorial Solar Farm - Westla Solar CA W3963 61755A 58616 180 180 0.0000 0.0000 180Midway Solar Farm I - Midway Solar Farm I Solar CA W5367 61295A 60336 671 671 0.0000 0.0000 671Mojave Solar Project - Mojave Solar Project - AlpSolar CA W4255 60848A 57331 1582 1582 0.0000 0.0000 1582Mojave Solar Project - Mojave Solar Project - BetSolar CA W4450 60848A 57331 1582 1582 0.0000 0.0000 1582Montezuma Wind II - Nextera Energy MontezumaWind CA W2400 61345A 57701 997 997 0.0000 0.0000 997Nevada Irrigation District - Bowman Hydro ProjecEligible Hydroelectric CA W635 60171A 50546 54 54 0.0000 0.0000 54Newcastle Powerhouse - Newcastle PowerhouseEligible Hydroelectric CA W364 60053A 632 27 27 0.0000 0.0000 27North Sky River - North Sky River - Phase I Wind CA W3206 61385A 58154 2299 2299 0.0000 0.0000 2000 299North Star Solar - North Star Solar, LLC Solar CA W4629 61198A 58713 674 674 0.0000 0.0000 674 Old River One - Old River One Solar CA W4194 60853A 58986 192 192 0.0000 0.0000 192 Orion Solar I - Orion Solar I, LLC Solar CA W3981 61570A 58718 150 150 0.0000 0.0000 150Phoenix Powerhouse - Phoenix Powerhouse Eligible Hydroelectric CA W366 60054A 264 39 39 0.0000 0.0000 39Portal Ridge Solar C - Portal Ridge Solar C Solar CA W5211 61684A 60311 138 138 0.0000 0.0000 138Potrero Hills Energy Producers - Potrero Hills En Biomass & Biogas CA W4867 63116A 59952 300 300 0.5638 169 0.0029 300RE Astoria 1 - RE Astoria 1 Solar CA W4930 62284A 59976 1015 1015 0.0000 0.0000 1015RE Kansas South - RE Kansas South Solar CA W3109 61264A 58148 260 260 0.0000 0.0000 260Rising Tree Wind Farm II LLC - Rising Tree WindWind CA W4445 62426A 59235 318 318 0.0000 0.0000 318 Rock Creek - Rock Creek Unit 1 Eligible Hydroelectric CA W2643 62269A 275 123 123 0.0000 0.0000 123Rock Creek - Rock Creek Unit 2 Eligible Hydroelectric CA W2644 62269A 10809 139 139 0.0000 0.0000 139Rollins Powerhouse - Rollins Powerhouse Eligible Hydroelectric CA W699 60265A 34 200 200 0.0000 0.0000 200San Joaquin No. 1-A Powerhouse - San Joaquin Eligible Hydroelectric CA W345 60056A 278 1 1 0.0000 0.0000 1Sanborn Solar 1A - Sub Project S3 - Edwards SaSolar CA W12675 64740A 64877 83578 83578 0.0000 0.0000 83578Shafter Solar, LLC - Shafter Solar, LLC Solar CA W4680 62325A 59408 83 83 0.0000 0.0000 83Shiloh IV Wind Project, LLC - Shiloh IV Wind ProWind CA W2780 61617A 57725 1471 1471 0.0000 0.0000 1471Sierra Pacific Burney Facility - Sierra Pacific InduBiomass & Biogas CA W667 60087A 50110 371 371 0.4729 175 0.0092 371Sierra Pacific Ind. (Lincoln) - Sierra Pacific IndustBiomass & Biogas CA W668 60088A 10144 278 278 0.4928 137 0.0113 278Sierra Pacific Ind. (Quincy) - Sierra Pacific IndustBiomass & Biogas CA W669 60089A 50112 801 801 2.3575 1888 0.0499 801Sierra Pacific Sonora - Sierra Pacific Sonora Biomass & Biogas CA W852 60576A 54517 98 98 3.6356 356 0.0784 98Solar Alpine LLC - Solar Alpine LLC Solar CA W2872 60755A 57295 605 605 0.0000 0.0000 605South Powerhouse - South Powerhouse Eligible Hydroelectric CA W370 60059A 280 60 60 0.0000 0.0000 60Spaulding No. 1 Powerhouse - Spaulding No. 1 PEligible Hydroelectric CA W371 60060A 281 57 57 0.0000 0.0000 57Spaulding No. 2 Powerhouse - Spaulding No. 2 PEligible Hydroelectric CA W372 60061A 282 25 25 0.0000 0.0000 25Spaulding No. 3 Powerhouse - Spaulding No. 3 PEligible Hydroelectric CA W373 60062A 283 74 74 0.0000 0.0000 74SPI Anderson 2 - SPI Anderson 2 Biomass & Biogas CA W4674 61146A 59658 504 504 0.3893 196 0.0105 504Spring Gap Powerhouse - Spring Gap Powerhou Eligible Hydroelectric CA W374 60063A 284 131 131 0.0000 0.0000 131SPS Alpaugh 50 - SPS Alpaugh 50 Solar CA W2826 60945A 58003 432 432 0.0000 0.0000 432SPS Alpaugh North - SPS Alpaugh North Solar CA W2825 60946A 58002 160 160 0.0000 0.0000 160Stockton Biomass - Stockton Biomass Biomass & Biogas CA W3540 60964A 54238 1724 1724 1.4585 2514 0.0288 1724Stroud Solar Station - Stroud Solar Station Solar CA W2203 61434A 57497 108 108 0.0000 0.0000 108Sunray 2- SEGS II - Sunray 2- SEGS II Solar CA W466 62694A 10437 302 302 0.0000 0.0000 302Sunshine Gas Producers - Sunshine Gas ProducBiomass & Biogas CA W4144 60815A 58429 611 611 0.7045 430 0.0036 611Toadtown Powerhouse - Toadtown Powerhouse Eligible Hydroelectric CA W375 60064A 714 12 12 0.0000 0.0000 12Topaz Solar Farms LLC - Topaz 10-16 Solar CA W3226 61698A 57695 1708 1708 0.0000 0.0000 1708Topaz Solar Farms LLC - Topaz 17 - 20 Solar CA W3227 61698A 57695 930 930 0.0000 0.0000 930Topaz Solar Farms LLC - Topaz 1-9 Solar CA W3193 61698A 57695 2355 2355 0.0000 0.0000 2355Topaz Solar Farms LLC - Topaz 21 - 22 Solar CA W3229 61698A 57695 328 328 0.0000 0.0000 328Vaca Dixon Solar Station - Vaca Dixon Solar StatSolar CA W1455 60966A 57041 16 16 0.0000 0.0000 16Vasco Winds - Vasco Winds Wind CA W2401 61344A 57700 1136 1136 0.0000 0.0000 1136Volta No. 2 Powerhouse - Volta No. 2 PowerhousEligible Hydroelectric CA W378 60067A 180 14 14 0.0000 0.0000 14West Gates Solar Station - West Gates Solar StaSolar CA W3478 62352A 58206 103 103 0.0000 0.0000 103West Point Powerhouse - West Point PowerhousEligible Hydroelectric CA W379 60068A 291 212 212 0.0000 0.0000 212Western Antelope Blue Sky Ranch A - WABSRA Solar CA W4264 61517A 58626 240 240 0.0000 0.0000 240Westside Solar Station - Westside Solar Station Solar CA W2202 61433A 57499 70 70 0.0000 0.0000 70Wise No. 1 Powerhouse - Wise No. 1 PowerhousEligible Hydroelectric CA W380 60069A 292 144 144 0.0000 0.0000 144YP 2A PV Solar NV W17619 65331A 66357 124375 124375 0.0000 0.0000 124375Clearwater Paper Corporation - #3 turbine generaBiomass & Biogas ID W128 60533A Unspecified Powe 14000 14000 Yes 0.4280 5992 0.4280 14000Clearwater Paper Corporation - #4 turbine generaBiomass & Biogas ID W129 60533A Unspecified Powe 32276 32276 Yes 0.4280 13814 0.4280 32276Glacier Wind 1 - Glacier Wind 1 Wind MT W818 60708A Unspecified Powe 40011 40011 Yes 0.4280 17125 0.4280 40011Glacier Wind 2 - Glacier Wind 2 Wind MT W1318 60709A Unspecified Powe 36 36 Yes 0.4280 15 0.4280 36Kittitas Valley Wind Farm - Sagebrush Power ParWind WA W1876 60939A Unspecified Powe 32677 32677 Yes 0.4280 13986 0.4280 32677Balch PH #1 Large Hydroelectric CA 217 3546 3400 146 0.0000 0.0000 146.372Balch PH #2 Large Hydroelectric CA 218 11401 10000 1401 0.0000 0.0000 1400.651Belden Large Hydroelectric CA 219 9362 9362 0 0.0000 0.0000 0.047Bucks Creek Large Hydroelectric CA 220 2421 2200 221 0.0000 0.0000 221.262Butt Valley Large Hydroelectric CA 221 3767 3400 367 0.0000 0.0000 367.236Caribou 1 Large Hydroelectric CA 222 6264 5900 364 0.0000 0.0000 363.957Caribou 2 Large Hydroelectric CA 223 8634 7600 1034 0.0000 0.0000 1033.837Cresta Large Hydroelectric CA 231 8395 7500 895 0.0000 0.0000 895.121Drum #1 Large Hydroelectric CA 235 796 500 296 0.0000 0.0000 296.409Drum #2 Large Hydroelectric CA 236 3800 3200 600 0.0000 0.0000 600.007Electra Large Hydroelectric CA 239 7219 6000 1219 0.0000 0.0000 1219.477Haas Large Hydroelectric CA 240 11909 10000 1909 0.0000 0.0000 1909.46James B Black Large Hydroelectric CA 249 11414 10000 1414 0.0000 0.0000 1414.199Kerckhoff #2 PH Large Hydroelectric CA 682 10815 10000 815 0.0000 0.0000 814.948Kings River Large Hydroelectric CA 254 2856 2400 456 0.0000 0.0000 455.883Pit 1 Large Hydroelectric CA 265 5219 4700 519 0.0000 0.0000 518.877Pit 3 Large Hydroelectric CA 266 8219 7500 719 0.0000 0.0000 718.507Pit 4 Large Hydroelectric CA 267 8389 8200 189 0.0000 0.0000 189.253Pit 5 Large Hydroelectric CA 268 11588 10000 1588 0.0000 0.0000 1588.266Pit 6 Large Hydroelectric CA 269 6263 4500 1763 0.0000 0.0000 1763.471Pit 7 Large Hydroelectric CA 270 8265 8265 0.0000 0.0000 8264.991Poe Large Hydroelectric CA 272 13741 13741 0.0000 0.0000 13741.16Rock Creek Large Hydroelectric CA 275 13901 3638 10263 0.0000 0.0000 10262.726 Salt Springs Large Hydroelectric CA 279 2695 2695 0.0000 0.0000 2694.883 Stanislaus Large Hydroelectric CA 285 6828 6828 0.0000 0.0000 6828.431Tiger Creek Large Hydroelectric CA 287 5678 5678 0.0000 0.0000 5678.394NID-Chicago Park Large Hydroelectric CA 412 1533 1533 0.0000 0.0000 1532.512GCPD - Priest Rapids & Wanapum Large Hydroelectric WA I I 3887 8729I I I 8729 0.0000 0.0000 8729 Green100 Portfolio Totals PCL Data Base Plan Portfolio Totals PCL Data Retail Sales 5455 Retail Sales 1736606
Total Specified 5455 Total Specified 802061
Biomass & Biogas 0 0% Biomass & Biogas 50963 3%
Geothermal 1455 27% Geothermal 69689 4%
Eligible Hydroelectric 2000 37% Eligible Hydroelectric 81291 5% Solar 0 0% Solar 449089 26%
Wind 2000 37% Wind 77380 4%
Large Hydroelectric 0 0% Large Hydroelectric 73649 4%
Nuclear 0 0% Nuclear 0 0%
Emerging Technologies 0 0% Emerging Technologies 0 0%
Other 0 0% Other 0 0%
Natural Gas 0 0% Natural Gas 0 0%
Coal & Petroleum 0 0% Coal & Petroleum 0 0%
Unspecified Power - ACS 0 Unspecified Power - ACS 0
Unspecified Power - Spot Market 0 Unspecified Power - Spot Market 934545 Unspecified Power - Total 0 0% Unspecified Power - Total 934545 54% Total PCL GHGs (MT CO2e) 0.0 Total PCL GHGs (MT CO2e) 451236.4 Emissions intensity (MT CO2e/MWh) 0.000 Emissions intensity (MT CO2e/MWh) 0.260 PCL GHG Intensity (lbs CO2e/MWh) 0 PCL GHG Intensity (lbs CO2e/MWh) 573 Unbundled REC %
0%
Unbundled REC %
3%
Green100 Base Plan
Facility Name Fuel Type Net Procurement
Annual
PCL
GHGs
(MT CO2e)
Facility Name Fuel Type Net Procurement
Annual
PCL
GHGs
(MT CO2e)
- - - 0 A. G. Wishon Powerhouse - A. G. WishoEligible Hydroelectric 97 0 - - - 0 Agua Caliente Solar - Block 1 Solar 316 0- - - 0 Agua Caliente Solar - Block 10 Solar 264 0- - - 0 Agua Caliente Solar - Block 11 Solar 264 0- - - 0 Agua Caliente Solar - Block 12 Solar 120 0- - - 0 Agua Caliente Solar - Block 2 Solar 316 0- - - 0 Agua Caliente Solar - Block 3 Solar 316 0- - - 0 Agua Caliente Solar - Block 4 Solar 225 0- - - 0 Agua Caliente Solar - Block 5 Solar 318 0- - - 0 Agua Caliente Solar - Block 6 Solar 318 0 - - - 0 Agua Caliente Solar - Block 7 Solar 318 0
- - - 0 Agua Caliente Solar - Block 8 Solar 264 0- - - 0 Agua Caliente Solar - Block 9 Solar 264 0- - - 0 Alamo Solar - Alamo Solar Solar 255 0- - - 0 Alta Powerhouse - Alta Powerhouse Eligible Hydroelectric 7 0- - - 0 Antelope West Solar - Antelope West SoSolar 279 0 - - - 0 Atwell Island - Atwell Island PV Solar GeSolar 170 0- - - 0 AV Solar Ranch 1, LLC - Antelope Solar Solar 371 0 - - - 0 AV Solar Ranch 1, LLC - AVSR1 - AnteloSolar 598 0 - - - 0 AV Solar Ranch 1, LLC - AVSR1 - AnteloSolar 357 0- - - 0 AV Solar Ranch 1, LLC - AVSR1 - AnteloSolar 282 0- - - 0 AV Solar Ranch 1, LLC - AVSR1 - AnteloSolar 252 0- - - 0 AV Solar Ranch 1, LLC - AVSR1 - AnteloSolar 207 0- - - 0 AV Solar Ranch 1, LLC - AVSR1 - AnteloSolar 668 0- - - 0 Bakersfield Solar - SKIC 20 Solar 220 0- - - 0 Bayshore Solar A - Big Sky Solar 6 Solar 260 0- - - 0 Bayshore Solar B - Big Sky Solar 7 Solar 254 0- - - 0 Bayshore Solar C - Big Sky Solar 8 Solar 232 0- - - 0 Blackwell Solar - Blackwell Solar, LLC Solar 154 0- - - 0 CA Flats 150 - CA Flats 150 Solar 1751 0- - - 0 California Valley Solar Ranch - Block1 Solar 272 0- - - 0 California Valley Solar Ranch - Block2 Solar 807 0- - - 0 California Valley Solar Ranch - Block3 Solar 1539 0- - - 0 California Valley Solar Ranch - Block4 Solar 417 0- - - 0 Cantua Solar Station - Cantua Solar StatSolar 165 0- - - 0 CED Corcoran - CED Corcoran Solar 176 0- - - 0 CED White River Solar - CED White RiveSolar 226 0- - - 0 CID Solar - Corcoran Irrigation District - CSolar 241 0
- - - 0 Coleman Powerhouse - Coleman Power Eligible Hydroelectric 120 0- - - 0 Copper Mountain Solar 2 - CMS 2 (1) Solar 413 0- - - 0 Copper Mountain Solar 2 - CMS 2 (2) Solar 367 0- - - 0 Copper Mountain Solar 2 - CMS 2 (3) Solar 367 0- - - 0 Copper Mountain Solar 2 - CMS 2 (4) Solar 368 0- - - 0 Copper Mountain Solar 2 - CMS 2 (5) Solar 305 0- - - 0 Crane Valley Powerhouse - Crane ValleyEligible Hydroelectric 5 0- - - 0 Cuyama Solar - Cuyama Solar Solar 358 0- - - 0 De Sabla Powerhouse - De Sabla PowerEligible Hydroelectric 115 0- - - 0 DESERT SUNLIGHT 300, LLC - DSL-BLSolar 1648 0- - - 0 DESERT SUNLIGHT 300, LLC - DSL-BLSolar 539 0- - - 0 DESERT SUNLIGHT 300, LLC - DSL-BLSolar 260 0- - - 0 DESERT SUNLIGHT 300, LLC - DSL-BLSolar 215 0- - - 0 DESERT SUNLIGHT 300, LLC - DSL-BLSolar 539 0- - - 0 Dutch Flat #2 Powerhouse - Dutch Flat #Eligible Hydroelectric 77 0- - - 0 Dutch Flat No. 1 Powerhouse - Dutch FlaEligible Hydroelectric 174 0El Dorado Powerhouse - ElDorado _7_unEligible Hydroelectric 2000 0 El Dorado Powerhouse - ElDorado _7_unEligible Hydroelectric 35873 0
- - - 0 El Dorado Powerhouse - ElDorado
_7_unEligible Hydroelectric 43222 0
- - - 0 Five Points Solar Station - Five Points SoSolar 78 0- - - 0 FPL Energy Montezuma Wind - FPL EneWind 435 0- - - 0 Gaskell West 3 Solar 322 0- - - 0 Gaskell West 4 Solar 326 0- - - 0 Gaskell West 5 Solar 323 0 - - - 0 Gates Solar Station - Gates Solar StationSolar 169 0 - - - 0 GENESIS SOLAR, LLC - SGN-1 Solar 1492 0- - - 0 GENESIS SOLAR, LLC - SGN2 Solar 1540 0Geysers Power Plant - Sonoma/Calpine Geothermal 1455.023 0 Geysers Power Plant - Sonoma/Calpine Geothermal 68816.977 0 - - - 0 Giffen Solar Station - Giffen Solar StationSolar 71 0 - - - 0 Guernsey Solar Station - Guernsey Sola Solar 122 0 - - - 0 Halsey Powerhouse - Halsey PowerhousEligible Hydroelectric 43 0 - - - 0 Hat Creek No. 1 Powerhouse - Hat CreeEligible Hydroelectric 122 0- - - 0 Hat Creek No. 2 Powerhouse - Hat CreeEligible Hydroelectric 124 0- - - 0 Henrietta Solar Plant - Parrey, LLC Solar 1168 0- - - 0 Huron Solar Station - Huron Solar Statio Solar 152 0- - - 0 Ivanpah - Unit 1 Solar 956 85.4664- - - 0 Ivanpah - Unit 3 Solar 1360 121.584- - - 0 Java Solar - Java Solar Solar 157 0- - - 0 Kansas - Kansas Solar 191 0- - - 0 Kent South - Kent South Solar 237 0- - - 0 Lost Hills - Lost Hills Solar, LLC Solar 273 0- - - 0 Mammoth Pacific L. P. (MP1) - Mammot Geothermal 319 0 - - - 0 Mammoth Pacific L. P. I (PLES) - Mam
mGeothermal 553 0
- - - 0 Mesquite Solar 1 (10) - Mesquite Solar 1Solar 117 0 - - - 0 Mesquite Solar 1 (11) - Mesquite Solar 1Solar 193 0- - - 0 Mesquite Solar 1 (12) - Mesquite Solar 1Solar 192 0- - - 0 Mesquite Solar 1 (1-3) - Mesquite Solar Solar 503 0 - - - 0 Mesquite Solar 1 (4) - Mesquite Solar 1 (Solar 193 0 - - - 0 Mesquite Solar 1 (5) - Mesquite Solar 1 (Solar 193 0- - - 0 Mesquite Solar 1 (6) - Mesquite Solar 1 (Solar 96 0- - - 0 Mesquite Solar 1 (7) - Mesquite Solar 1 (Solar 193 0- - - 0 Mesquite Solar 1 (8) - Mesquite Solar 1 (Solar 144 0- - - 0 Mesquite Solar 1 (9) - Mesquite Solar 1 (Solar 193 0- - - 0 Mesquite Solar 3, LLC - Mesquite Solar 3Solar 197463 0- - - 0 Michael E. Bowler Memorial Solar Farm Solar 180 0- - - 0 Midway Solar Farm I - Midway Solar Far Solar 671 0- - - 0 Mojave Solar Project - Mojave Solar ProjSolar 1582 0- - - 0 Mojave Solar Project - Mojave Solar ProjSolar 1582 0- - - 0 Montezuma Wind II - Nextera Energy MoWind 997 0- - - 0 Nevada Irrigation District - Bowman Hyd Eligible Hydroelectric 54 0 - - - 0 Newcastle Powerhouse - Newcastle Po
wEligible Hydroelectric 27 0
North Sky River - North Sky River - PhasWind 2000 0 North Sky River - North Sky River - PhasWind 299 0- - - 0 North Star Solar - North Star Solar, LLC Solar 674 0- - - 0 Old River One - Old River One Solar 192 0- - - 0 Orion Solar I - Orion Solar I, LLC Solar 150 0- - - 0 Phoenix Powerhouse - Phoenix PowerhoEligible Hydroelectric 39 0- - - 0 Portal Ridge Solar C - Portal Ridge Sola Solar 138 0 - - - 0 Potrero Hills Energy Producers - PotreroBiomass & Biogas 300 0.87 - - - 0 RE Astoria 1 - RE Astoria 1 Solar 1015 0- - - 0 RE Kansas South - RE Kansas South Solar 260 0- - - 0 Rising Tree Wind Farm II LLC - Rising T Wind 318 0 - - - 0 Rock Creek - Rock Creek Unit 1 Eligible Hydroelectric 123 0- - - 0 Rock Creek - Rock Creek Unit 2 Eligible Hydroelectric 139 0- - - 0 Rollins Powerhouse - Rollins PowerhousEligible Hydroelectric 200 0 - - - 0 San Joaquin No. 1-A Powerhouse - San Eligible Hydroelectric 1 0 - - - 0 Sanborn Solar 1A - Sub Project S3 - Ed
wSolar 83578 0
- - - 0 Shafter Solar, LLC - Shafter Solar, LLC Solar 83 0- - - 0 Shiloh IV Wind Project, LLC - Shiloh IV WWind 1471 0
- - - 0 Sierra Pacific Burney Facility - Sierra PacBiomass & Biogas 371 3.4132- - - 0 Sierra Pacific Ind. (Lincoln) - Sierra PacifBiomass & Biogas 278 3.1414- - - 0 Sierra Pacific Ind. (Quincy) - Sierra PacifBiomass & Biogas 801 39.9699- - - 0 Sierra Pacific Sonora - Sierra Pacific SonBiomass & Biogas 98 7.6832- - - 0 Solar Alpine LLC - Solar Alpine LLC Solar 605 0- - - 0 South Powerhouse - South Powerhouse Eligible Hydroelectric 60 0- - -0Spaulding No. 1 Powerhouse - SpauldingEligible Hydroelectric 57 0- - -0Spaulding No. 2 Powerhouse - SpauldingEligible Hydroelectric 25 0- - -0Spaulding No. 3 Powerhouse - SpauldingEligible Hydroelectric 74 0- - - 0 SPI Anderson 2 - SPI Anderson 2 Biomass & Biogas 504 5.292- - -0Spring Gap Powerhouse - Spring Gap PoEligible Hydroelectric 131 0- - - 0 SPS Alpaugh 50 - SPS Alpaugh 50 Solar 432 0- - - 0 SPS Alpaugh North - SPS Alpaugh NorthSolar 160 0- - - 0 Stockton Biomass - Stockton Biomass Biomass & Biogas 1724 49.6512- - - 0 Stroud Solar Station - Stroud Solar StatioSolar 108 0- - - 0 Sunray 2- SEGS II - Sunray 2- SEGS II Solar 302 0- - - 0 Sunshine Gas Producers - Sunshine GasBiomass & Biogas 611 2.1996- - - 0 Toadtown Powerhouse - Toadtown PoweEligible Hydroelectric 12 0- - - 0 Topaz Solar Farms LLC - Topaz 10-16 Solar 1708 0- - - 0 Topaz Solar Farms LLC - Topaz 17 - 20 Solar 930 0- - - 0 Topaz Solar Farms LLC - Topaz 1-9 Solar 2355 0- - - 0 Topaz Solar Farms LLC - Topaz 21 - 22 Solar 328 0- - - 0 Vaca Dixon Solar Station - Vaca Dixon SSolar 16 0
- - - 0 Vasco Winds - Vasco Winds Wind 1136 0- - - 0 Volta No. 2 Powerhouse - Volta No. 2 PoEligible Hydroelectric 14 0- - - 0 West Gates Solar Station - West Gates SSolar 103 0
- - - 0 West Point Powerhouse - West Point PoEligible Hydroelectric 212 0- - - 0 Western Antelope Blue Sky Ranch A - WSolar 240 0
- - - 0 Westside Solar Station - Westside Solar Solar 70 0- - - 0 Wise No. 1 Powerhouse - Wise No. 1 PoEligible Hydroelectric 144 0- - - 0 YP 2A PV Solar 124375 0- - - 0 Clearwater Paper Corporation - #3 turbinBiomass & Biogas 14000 5992- - - 0 Clearwater Paper Corporation - #4 turbinBiomass & Biogas 32276 13814.13- - - 0 Glacier Wind 1 - Glacier Wind 1 Wind 40011 17124.71- - - 0 Glacier Wind 2 - Glacier Wind 2 Wind 36 15.408- - - 0 Kittitas Valley Wind Farm - Sagebrush P Wind 32677 13985.76 - - - 0 Balch PH #1 Large Hydroelectric 146.372 0- - - 0 Balch PH #2 Large Hydroelectric 1400.651 0- - - 0 Belden Large Hydroelectric 0.047 0- - - 0 Bucks Creek Large Hydroelectric 221.262 0- - - 0 Butt Valley Large Hydroelectric 367.236 0- - - 0 Caribou 1 Large Hydroelectric 363.957 0- - - 0 Caribou 2 Large Hydroelectric 1033.837 0- - - 0 Cresta Large Hydroelectric 895.121 0- - - 0 Drum #1 Large Hydroelectric 296.409 0- - - 0 Drum #2 Large Hydroelectric 600.007 0- - - 0 Electra Large Hydroelectric 1219.477 0- - - 0 Haas Large Hydroelectric 1909.46 0 - - - 0 James B Black Large Hydroelectric 1414.199 0
- - - 0 Kerckhoff #2 PH Large Hydroelectric 814.948 0- - - 0 Kings River Large Hydroelectric 455.883 0- - - 0 Pit 1 Large Hydroelectric 518.877 0- - - 0 Pit 3 Large Hydroelectric 718.507 0- - - 0 Pit 4 Large Hydroelectric 189.253 0- - - 0 Pit 5 Large Hydroelectric 1588.266 0- - - 0 Pit 6 Large Hydroelectric 1763.471 0- - - 0 Pit 7 Large Hydroelectric 8264.991 0- - - 0 Poe Large Hydroelectric 13741.16 0- - - 0 Rock Creek Large Hydroelectric 10262.726 0- - - 0 Salt Springs Large Hydroelectric 2694.883 0- - - 0 Stanislaus Large Hydroelectric 6828.431 0- - - 0 Tiger Creek Large Hydroelectric 5678.394 0- - - 0 NID-Chicago Park Large Hydroelectric 1532.512 0- - - 0 GCPD - Priest Rapids & Wanapum Large Hydroelectric 8729 0 - 59,334

RETIRED UNBUNDLED RECS RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh) Facility Name Fuel Type State or
Province RPS ID Total Retired (in MWh)
Sierra Pacific Burney Facility - SPI Burney OnBiomass & Bioga CA 60087A 9052 Sierra Pacific Ind. (Lincoln) - SPI Lincoln OnsiBiomass & Bioga CA 60088A 15900 Sierra Pacific Ind. (Quincy) - SPI Quincy Onsi Biomass & Bioga CA 60089A 13164 Blackspring Ridge 1A - Blackspring Ridge 1A Wind AB 60987A 2239 Blackspring Ridge 1B - Blackspring Ridge 1B Wind AB 60988A 2435 Sierra Pacific Sonora - SPI Sonora Onsite LoaBiomass & Bioga CA 60576A 6865 SPI Anderson 2 Onsite Load - SPI Anderson 2Biomass & Bioga CA 61146A 9679 Base Plan
Total Retired Unbundled RECs Total Retired Unbundled RECs Green100
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2024
Pioneer Community Energy
I, Don Eckert, Executive Director, declare under penalty of perjury, that the information provided in this report is true and correct and that I, as an authorized agent of Pioneer Community Energy, have authority to submit this report on the retail supplier's behalf. I further declare that all of the electricity claimed as specified purchases as shown in this report was sold once and only once to retail customers.

Name: Don Eckert
Representing (Retail Supplier): Pioneer Community Energy Signature:

Dated: 6/6/2025
Executed at: Rocklin, CA

Page 1 of 2 ends

Staff Report – Item 1c
To: The Governing Board
From: Gina Stassi-Vanacore, Director of Communications
Item 1c: Adopt Resolution Authorizing the Chief Executive Officer to Extend Access to Cost-Neutral Programs to New Member Agencies Prior to the October 2027 Service Expansion
Date: 9/18/2025

RECOMMENDATION
Adopt resolution authorizing the Chief Executive Officer to extend access to cost-neutral programs to new member agencies prior to the October 2027 service expansion.

BACKGROUND
On April 17, 2025, The Pioneer Community Energy (“Pioneer”) Governing Board approved a resolution authorizing the Chief Executive Officer to execute an agreement with Energy Mission Control dba FuSE Carbon Technologies (“FuSE) for Low Carbon Fuels Standard (“LCFS”) program services.

This program was created to support member agencies with their clean transportation efforts by monetizing LCFS credits. Through this program, FuSE can sell member credits on behalf of member agencies to entities that create emissions. Members, as the selling parties, realize the monetary value associated with the credits.

When credits are sold, 90 percent of the profits are returned to the member agency, and profits earned from selling LCFS credits could then be used to further clean transportation efforts. Pioneer and FuSE also receive a portion of the profits from the remaining profits. Participation in the program is completely voluntary, and all that is required for a member agency to join is a Memorandum of Understanding between the member agency and Pioneer. The program is cost-neutral to ratepayers.

ANALYSIS & DISCUSSION
There is currently an opportunity to extend Pioneer’s LCFS program – now called the Clean Fleet Revenue Program – to expansion agencies, which will allow for early opportunities to partner with expansion members, provide added value, and create goodwill.

During expansion efforts, staff found that many of our new members actively look for opportunities to generate additional revenue and expressed a strong interest in Pioneer programs and the added value they provide.

Pioneer’s expansion members could benefit from the Clean Fleet Revenue program by monetizing credits from their clean fuel transportation efforts.

If approved, Pioneer staff will proactively reach out to new member agency staff to introduce them to the Clean Fleet Revenue program and offer an opportunity to participate. Should new members choose to participate, Pioneer staff will support them in working with FuSE to collect all necessary fleet and charging infrastructure data.

The Recommendation allows staff to introduce yet to be developed cost-neutral programs to the expansion communities before the October 2027 launch.

STRATEGIC PLAN
The recommendation supports Pioneer’s strategic priority to “Be a Community Partner.” Plf)NEER

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Agenda Item: 1c Agenda Date: 9/18/2025

Page 2 of 2 ends

FISCAL IMPACT
There is no fiscal impact with this recommendation, and no budgetary adjustment is required.

Extending access to the Clean Fleet Revenue Program to expansion communities would have a net positive impact due to the profit-sharing associated with the monetization of LCFS credits.

ATTACHMENTS

1. Resolution Authorizing the Chief Executive Officer to Extend Access of Cost-Neutral Programs to New Member Agencies Prior to the October 2027 Service Expansion 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 September 18, 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, Pioneer Community Energy (“Pioneer”) is a locally owned not-for-profit electricity provider that prioritizes steady and competitive rates, a choice in energy options, and strong community partnership; and
WHEREAS, the Pioneer Governing Board has approved and authorized program offerings for customers that align with our mission and strategic priorities; and WHEREAS, programs have been favorably received by customers and existing members; and WHEREAS, Pioneer’s new member agencies have expressed interest in and appreciation for the added-value programs Pioneer provides; and
WHEREAS, it is proposed that cost-neutral programs be extended to new members in advance of the October 2027 planned service launch; and
WHEREAS, the extension of programs is limited to programs that are cost-neutral to current ratepayers; and
WHEREAS, extending cost-neutral programs does not have any impact on the current Fiscal Year 2025-26 budget and no budgetary adjustment is required; and In the matter of: ADOPT RESOLUTION

AUTHORIZING THE CHIEF EXECUTIVE

OFFICER TO EXTEND ACCESS TO COST-NEUTRAL PROGRAMS TO NEW MEMBER

AGENCIES PRIOR TO THE OCTOBER
2027 SERVICE EXPANSION
Resolution 2025-__
September 18, 2025
2 WHEREAS, participating in Pioneer programs is voluntary for customers, existing members, and expansion members.

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 authorizes the Chief Executive Officer to extend access of cost-neutral programs to new member agencies prior to the October 2027 service expansion.

3. This Resolution shall take effect immediately upon its adoption.

Page 1 of 3 ends

Staff Report – Item 1d
To: The Governing Board
From: Lee Ewing, Legislative and Regulatory Manager
Item 1d: Adopt a Resolution Approving Pioneer Community Energy’s Revised Load Management Standards Compliance Plan and Submission to the California Energy Commission
Date: 9/18/2025

RECOMMENDATION
Adopt a resolution approving Pioneer Community Energy’s Revised Load Management Standards Compliance Plan and authorizing the Plan to be delivered to the California Energy Commission (CEC).

BACKGROUND
To better align electricity consumption with generation times, in January of 2023 the CEC adopted new Load Management Standards (LMS). These standards have the stated goals of encouraging the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. These standards make several requests of Pioneer Community Energy (Pioneer).

Among them is the request that Pioneer assess whether the implementation of a marginal cost-based rate will achieve the goals of the regulations and if found not likely to achieve these goals, to provide a list of load shifting programs that will achieve the stated goals.

Section 1623.1 of LMS requires all large Community Choice Aggregators, including Pioneer, to submit a board-approved LMS compliance plan to the CEC no later than May 1, 2024. On March 26, 2024, Pioneer Community Energy (Pioneer) submitted its Load Management Standards Compliance Plan (Plan) to the CEC in accordance with section 1623.1(a)(3)(A) of LMS. This Plan was approved and authorized for submission by Pioneer’s Board of Directors (Board) in a duly noticed public meeting held on March 21, 2024.

In the Plan, Pioneer expressed its commitment to the goals articulated in §1623.1(a)(1) of the Load Management Standards.1 Consistent with CCR § 1623.1(a)(1), Pioneer detailed how it intended to meet the goals of encouraging the use of electrical energy at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. The Plan also evaluated marginal cost-based rates for each customer class in terms of cost effectiveness, equity, technological feasibility, benefits to the grid, and benefits to customers.

However, after thoroughly analyzing marginal cost-based rates, the Plan found it could not cost effectively implement such rates to meet the goals of § 1623.1(a)(1). As an alternative, the Plan provided a list of load flexibility programs that Pioneer was implementing or making available to its customers, including the Flexible Irrigation Pilot Program for Agriculture (AgFIT) administered by Pacific Gas & Electric (PG&E), now commonly referred to as the hourly flexible pricing pilot (HFP Pilot). The Plan explained how these load flexibility programs were designed to meet the LMS goals.
1 Pioneer also disputed the CEC’s jurisdiction over Community Choice Aggregators and made clear that its participation in the Load Management Standards is voluntary.

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Agenda Item: 1d Agenda Date: 9/18/2025

Page 2 of 3 ends

On May 16, 2024, Pioneer submitted an advice letter to the California Public Utilities Commission (CPUC) noting its intent to participate in PG&E’s HFP Pilot. On November 21, 2024, Pioneer Staff updated its Board on its participation in the PG&E HFP Pilot, stating that the pilot “is available to qualifying agricultural customers and runs from an estimated launch in December 2024, through December 31, 2027.” Pioneer currently makes this program available to its customers.2
On June 19, 2025, the Executive Director of the CEC issued a letter on the Plan’s compliance with 20 CCR §§ 1623.1(a)(1) and 1623.1(a)(2) (Compliance Letter). The Compliance Letter found that the Plan was compliant with those regulations, “with the exception that it does not provide for marginal, cost-based rates to customers, such as a commitment to participate in dynamic rate pilot programs that [Pioneer] is considering joining or other pathways to compliance.” The Compliance Letter suggests that Pioneer “modify its plan to commit to implementing the expanded marginal cost-based IOU CalFUSE pilots authorized in CPUC Decision (D.) 24-01- 032 and making them available to its ratepayers or commit to following an alternate pathway to achieving compliance, and resubmitting a Board approved revised plan to the CEC for approval.”3 The Compliance Letter also directs Pioneer to add the below language regarding the Statewide RIN Tool to the Plan, acknowledging a “development issue” related to this tool. [Pioneer] has been working with the other regulated load serving entities (LSEs) on creating the statewide RIN tool pursuant to 20 CCR Section 1623(c). A proposed plan for the tool was submitted to the CEC for review on October 1, 2024. We will continue to work with the other LSEs and the CEC to implement and maintain the statewide RIN tool in a timely manner subject to the tool’s approval by the CEC.

Virtually identical letters were also issued on the compliance plans of Central Coast Community Energy, CleanPowerSF, Silicon Valley Clean Energy, and Marin Clean Energy. Each CCA, including Pioneer, must resubmit its plan with the Compliance Letters recommended revisions by September 17, 2025. Recognizing that the next available opportunity for the Pioneer Board to approve a revision to the Compliance Plan would not occur until the Board meeting on September 18, 2025, Pioneer requested that the CEC permit an extension to its deadline to submit revisions. The CEC agreed to an extension and directed Pioneer to submit the revised Plan “to the docket as soon as possible, within one week of its approval.”

ANALYSIS & DISCUSSION
The revisions to the Pioneer LMS Compliance Plan requested by the CEC Compliance Letter are minor and only contemplate documenting actions that Pioneer has already undertaken, consistent with prior Board approvals. Specifically, these actions are offering the PG&E HFP Pilot to Pioneer’s customers and continuing to work with the other LSEs and the CEC to implement and maintain the statewide RIN tool. Staff therefore revised the Pioneer LMS Compliance Plan consistent with the CEC’s direction and, subject to Board approval of the revised Plan, will submit it to the CEC as soon as possible following such approval.

STRATEGIC PLAN
The recommendation supports the “Operational Optimization” goal.

FISCAL IMPACT
There is no fiscal impact with the recommendation.
2 https://pioneercommunityenergy.org/hourly-flex-pricing-pilot/ 3 In D. 24-01-032, the CPUC authorized two expanded pilots in AgFIT (or Hourly Flex Pricing Expanded Pilot #1) and Hourly Flex Pricing Expanded Pilot #2, a dynamic rate pilot available to a broader swath of customer tariffs, including residential and non-residential customers. At this time, Pioneer does not offer Hourly Flex Pricing Expanded Pilot #2.

Agenda Item: 1d Agenda Date: 9/18/2025

Page 3 of 3 ends

ATTACHMENTS

1. Resolution Approving and Authorizing the Pioneer Revised Load Management Standards Compliance Plan and Submission to the California Energy Commission

2. Revised LMS Compliance Plan (redline)
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 September 18, 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 and authorizing the Pioneer Community Energy (Pioneer) Revised Load Management Standard (LMS) Compliance Plan has been brought before the Governing Board; and
WHEREAS, the Governing Board of Pioneer approved and authorized the LMS Compliance Plan in a duly noticed public meeting held on March 21, 2024; and WHEREAS, on March 26, 2024, Pioneer submitted its LMS Compliance Plan to the California Energy Commission (CEC); and
WHEREAS, on June 19, 2025, the Executive Director of the CEC issued a letter on Pioneer’s LMS Compliance Plan’s compliance with the CEC Load Management Standards; and WHEREAS, in its letter, the Executive Director of the CEC recommended that Pioneer revise and resubmit its LMS Plan; and
WHEREAS, the revisions recommended by the Executive Director of the CEC are consistent with actions already authorized by the Governing Board of Pioneer.

In the matter of: A RESOLUTION APPROVING

AND AUTHORIZING THE PIONEER COMMUNITY

ENERGY REVISED LOAD MANAGEMENT

STANDARDS COMPLIANCE PLAN AND

SUBMISSION TO THE CALIFORNIA ENERGY

COMMISSION
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 approves and authorizes the Pioneer Revised LMS Compliance Plan (Exhibit A).

3. The Governing Board hereby approves and authorizes the submission of the Pioneer Revised LMS Compliance Plan to the CEC.

4. This Resolution shall take effect immediately upon its adoption.

Exhibit A: Pioneer’s Revised LMS Compliance Plan
Resolution 2025-___
September 18, 2025
1 Load Management
Standards
Compliance Plan
(Revised)
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COMMUNITY ENERGY
2 Contents

1. Introduction ............................................................................................................................ 4 I. About CEC & LMS................................................................................................................ 4 II. About Pioneer..................................................................................................................... 6 III. Format of Analysis .............................................................................................................. 7

2. Rates........................................................................................................................................ 7 I. Marginal Cost-Based Rates................................................................................................. 8 A. Cost Effectiveness........................................................................................................... 8 B. Technological Feasibility ................................................................................................... 11 i. Discussion - Residential................................................................................................. 12 ii. Discussion – Commercial/Industrial ............................................................................. 12 C. Benefits to the Grid........................................................................................................... 12 i. Discussion - Residential................................................................................................. 13 ii. Discussion – Commercial/Industrial ............................................................................. 13 D. Benefits to Customers....................................................................................................... 13 i. Discussion – Residential & Commercial/Industrial....................................................... 13 E. Equity ................................................................................................................................ 13 i. Discussion – Residential & Commercial/Industrial....................................................... 14 F. Conclusion - Rates............................................................................................................. 14

3. Load Flexibility Programs...................................................................................................... 15 I. Hardware Programs.......................................................................................................... 15 A. Cost Effectiveness......................................................................................................... 16 B. Technological Feasibility ............................................................................................... 16 C. Benefits to the Grid....................................................................................................... 16 D. Benefits to Customers................................................................................................... 17 E. Equity ............................................................................................................................ 17 F. Conclusion – Hardware Programs ................................................................................ 17 II. Incentive Based Program Paired with Software............................................................... 18 A. Cost Effectiveness......................................................................................................... 19 B. Technological Feasibility ............................................................................................... 19 C. Benefits to the Grid....................................................................................................... 19 Plf)NEER

COMMUNITY ENERGY
3 D. Benefits to Customers................................................................................................... 20 E. Equity ............................................................................................................................ 20 F. Conclusion - Incentive Based Program Paired with Software ...................................... 20 III. Existing Government Programs........................................................................................ 20 A. Cost Effectiveness......................................................................................................... 21 B. Technological Feasibility ............................................................................................... 22 C. Benefits to the Grid....................................................................................................... 22 D. Benefits to Customers................................................................................................... 22 E. Equity ............................................................................................................................ 22 F. Conclusion – Existing Government Programs............................................................... 23

4. Summary ............................................................................................................................... 23 Plf)NEER

COMMUNITY ENERGY
4 1.Introduction
Pursuant to California Energy Commission’s (CEC) amended Load Management Standards (LMS), this document (Plan) demonstrates how Pioneer Community Energy (Pioneer) intends to meet the articulated goals of the regulation. Pioneer does not accept CEC’s belief that they hold jurisdiction over Community Choice Aggregators (CCAs), and it is participating in this decision voluntarily.

I. About CEC & LMS
The CEC was established and granted specific load planning and management powers by the Warren-Alquist Act of 1974 (known as Load Management Standards). In 2022, LMS was amended, and new regulations were implemented with the broader goals of encouraging the use of electrical energy at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions1 .

The following is Pioneer’s roadmap for compliance in the form of a table listing the new requirements, their deadlines, and their respective statuses:

Relevant Section Requirement Deadline Status
§1623.1(c) Upload time-dependent
rates in the Market
Informed Demand
Automation Server
(MIDAS)
July 1, 2023 Complete
§1623.1(a)(1) Evaluate and
implement a marginal
cost-based rate or, in
the alternative, a plan
of programs designed
to achieve the same
goals
April 1, 2024 Addressed with this
plan
§1623.1(a)(3)(A) Submit the plan to CEC
within 30 days of
Board adoption.

Respond to any
requests for additional
information or requests
for plan revisions
within 90 days.
30 days after Pioneer
Board approval
Complete
§1623(c)(4) Within 1 year of the
LMS effective date,
April 1, 2024 Complete
1 §1623.1(a)(1).

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5 provide customers
access to their Rate
Identification Numbers
(RIN) on billing
statements and in
online accounts using
both and QR code.
§1623(c)(2)(A) Develop and submit to
the CEC, in
conjunction with the
other obligated utilities,
a single statewide
standard tool for
authorized rate data
access by third parties
along with the terms
and conditions for use
of the tool. Upon CEC
approval, the tool will
be live and obligated
LSEs must maintain
and improve the tool.

October 1, 2024 In Progress
§1623.1(b)(3) Submit to CEC a list of
load flexibility
programs deemed cost-effective with at least
one option for
automating response to
MIDAS signals for
each customer class.

October 1, 2024 Complete
§1623.1(a)(3)(C) Submit annual reports
to CEC demonstrating
implementation of the
Plan, as approved by
the Board.

One year after
compliance plan
adoption and annual
thereafter
In Progress
§1623.1(b)(2) Submit at least one
marginal cost-based
rate or program to the
Pioneer Board for
approval for any
customer class where
such a rate will
materially reduce peak
load.

July 1, 2025 In Progress
§1623.1(b)(5) Conduct a public
information campaign
to inform and educate
customers on why
marginal cost-based
rates or load flexibility
No deadline provided In Progress
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COMMUNITY ENERGY
6 programs are needed,
how they are used, and
how these rates and
programs can save
customers money.
§1623.1(a)(1)(C) Review the Plan at least
once every 3 years after
the Plan is adopted by
the Pioneer board.

Submit any updates of
the Plan to the Board if
there is a material
change.

Triennially Ongoing
(Updated September 2025)
II. About Pioneer
Pioneer is a CCA that serves unincorporated Placer and El Dorado County along with the Town of Loomis and the cities of Auburn, Colfax, Grass Valley, Lincoln, Nevada City, Placerville, and Rocklin2. Pioneer is governed by a Board of Directors made up of elected officials from its member agencies3
. It currently serves approximately 166,000 accounts consuming approximately 2,000 gigawatt hours annually. Pioneer has a relatively small staff compared to other CCAs4. Currently, the staff is made up of fourteen individuals. Many necessary business functions are handled by outside contractors.

As mentioned previously, per the amended LMS regulations Pioneer must provide a plan that describes how Pioneer will meet the goals of encouraging the use of electrical energy at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions5
. Specifically, the plan must evaluate
marginal cost-based rates for each customer class in terms of cost effectiveness, equity, technological feasibility, benefits to the grid, and benefits to customers6. After weighing these factors, Pioneer may decide that marginal cost-based rates are not necessary and may instead propose programs that enable automated response to marginal cost signal(s) for each customer class and evaluate them based on the previously mentioned factors7 .
2 Amendment No. 5 to the Amended and Restated Joint Exercise of Powers Agreement for Pioneer Community Energy, Res. No. 2022-26 (2022). 3 Id. 4 https://pioneercommunityenergy.org/, (last visited March 7, 2024). 5 §1623.1(a)(1). 6 §1623.1(a)(1)(A). 7 §1623.1(a)(1)(B).

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7 III. Format of Analysis
The LMS Regulation requires an analysis of marginal time-based rates and any subsequent programs for each customer class8. In consideration of CEC guidance, Pioneer has divided Customer Class into two distinct classes – residential and industrial/commercial.

Pursuant to the LMS regulations, marginal time-based rates and the subsequent programs will be analyzed under the following factors:
• Cost Effectiveness,
• Technological Feasibility,
• Benefits to the Grid,
• Benefits to Customers, and
• Equity.

Cost Effectiveness will be broken down individually into Cost and Effectiveness. Where analysis and discussion for each customer class is substantially the same, the sections will be combined.

2. Rates
CCA governing boards have jurisdiction over rate setting for their customers9. This provides CCAs with flexibility in how they want to procure energy and correspondingly set rates for the communities that they serve. With that concept in mind, Pioneer has a strong emphasis on keeping ratepayers’ costs low.

Implementing new rates involve considerable costs to Pioneer. The Pioneer Board of Directors (Pioneer Board) is required to review rates annually10. However, staff can bring suggested rate changes first to the Finance Committee and then to the Board of Directors. In assessing rates, Pioneer has many considerations. These include traditional business costs such as operating expenses, paying for power supply and regulatory products, and maintaining creditworthiness.

However, unlike traditional utilities, CCAs must also consider the ability of a ratepayer to opt out of service. Because of this, Pioneer (like many other CCAs) relies on a strategy of mirroring Large Investor-Owned Utility (IOU) rates with a targeted discount.

The LMS regulations requires the Pioneer Board to assess for approval at least one marginal cost-based rate by June 30, 202711. Pioneer may apply for approval of a marginal cost-based rate 8 §1623.1(a)(1)(A). 9 Public Utilities Code Section 366.2(c)(3). 10 Financial Policies, (Oct. 21, 2021), https://pioneercommunityenergy.org/wp-content/uploads/2022/04/2021-10- 21-Financial-Policies.pdf. 11 §1623.1(b)(2).

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8 offered by PG&E12. PG&E stated their intent to provide one marginal cost-based rate by January 2027 which Pioneer can mirror upon its implementation13. In the meantime, Pioneer commits to making a marginal cost-based rate available to its agricultural customers in the form of PG&E's Hourly Flex Pricing Pilot (HFP Pilot), formerly referred to as the Flexible Irrigation Pilot Program for Agriculture (AgFIT). The HFP Pilot is an expanded marginal cost-based PG&E CalFUSE pilot authorized in CPUC Decision D. 24-01-032. By offering the HFP Program, Pioneer is providing one marginal cost-based rate for its agricultural customers. With that in mind, per the requirements of the regulations, Pioneer must assess developing a marginal cost-based rate outside of mirroring one developed by PG&E. Pioneer will consider offering further marginal cost-based rates as appropriate and consistent with its authority over its own rates, subject to the limitations identified below.

I. Marginal Cost-Based Rates
Marginal cost is calculated as “the sum of the marginal energy cost, the marginal capacity cost (generation, transmission, and distribution), and any other appropriate time- and location-dependent marginal costs, including the locational marginal cost of associated greenhouse gas emissions, on a time interval of no more than one hour14. Energy cost computations shall reflect locational marginal cost pricing as determined by the associated balancing authority, such as the California Independent System Operator, the Balancing Authority of Northern California, or other balancing authority15. Marginal capacity cost computations shall reflect the variations in the probability and value of system reliability of each component (generation, transmission, and distribution).16” There is an immediate issue with the provided definition of marginal cost-based rates – Pioneer does not control the transmission and distribution in its service territory so it cannot accurately compute a marginal cost-based rate. Additionally, it is hard to quantify greenhouse gas emission costs. It appears that the regulations intend for these rates to be dynamic, responding to demand on the grid. For ease of reference, this Plan will refer to marginal cost-based rates as Dynamic Pricing.

A. Cost Effectiveness
As mentioned previously, Pioneer relies heavily on outside contractors. Any implementation of dynamic pricing would require amending contracts with multiple contractors. This means that overall cost will be unquantifiable, as the contract amendments will need to be negotiated. To weigh cost against effectiveness, Pioneer believes it is best to assess the effectiveness of Dynamic Pricing first in order to ascertain any unforeseen costs. 12 Id. 13 2023 COMPLIANCE PLAN for the LOAD MANAGEMENTS STANDARDS, D 23-LMS-01. 14 §1623.1(b)(1). 15 Id. 16 Id.

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9 i. Effectiveness
Pioneer will analyze “Effectiveness” on whether the implemented rate will consistently lead to the desired load shifting outcome.

In November of 2023, Lawrence Berkeley Lab released a report titled "The use of price-based demand response as a resource in electricity system planning.17” This paper analyzed twelve utilities use of time-based rates. They included Time of Use Pricing, Real Time Pricing, Variable Peak Pricing, Critical Peak Pricing, and Critical Peak Rebate in their analysis of price-based demand response.

Approximately one-third of the utilities studied did not include price-based demand response in the Integrated Resource Plan (IRP) as they found that there was not sufficient participation to deem it significant in impacting demand18. Furthermore, of the customers that did participate, their response to price signals was often erratic and hard to predict19.

In studying participation rate, one utility studied showed a five-fold increase in customer participation from an opt-out model compared to an opt-in model20. This shows that these pricing schemes are generally unpopular for ratepayers. Consumer advocates have raised serious concerns about opt-out pricing as they can be especially burdensome for low-income ratepayers (See Equity). For CCAs, an opt-out approach presents serious business risks as the ratepayer may choose to opt out of the CCA completely if they are upset with the dynamic rate. A large amount of unexpected opt-outs of CCA service have credit implications which in turn leads to higher procurement costs. This in turn leads to higher rates in order to maintain the financial stability of the CCA.

For the opt-in model, participation ranged from three percent to thirty percent21. Similarly, a 2016 Department of Energy sponsored study of several utilities found a fifteen percent opt-in rate for dynamic pricing rates22. This is consistent with several other studies mentioned in the Lawrence Berkeley Lab report, with no dynamic pricing rate exceeding thirty percent enrollment for opt-in participation23.

In the Lawrence Berkeley Lab study, only one utility reported load reduction for opt-in participation24. Residential ratepayers of that utility showed load reduction levels eighty to ninety percent lower than other residential customers25. However, for commercial and industrial 17 Juan Pablo Carvallo and Lisa Schwartz, The use of price-based demand response as a resource in electricity system planning, Energy Markets & Policy, Nov. 2023. 18 Id at Pg. 5 19 Id. 20 Id at Pg.7. 21 Id. 22 Dept. of Energy, Customer Acceptance, Retention, and Response to Time-Based Rates from the Consumer Behavior Studies, Electricity Delivery & Energy Reliability, Nov. 2016. 23 Carvallo, supra note 17. 24 Id. 25 Id.

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10 ratepayers, the utility found only a ten percent higher load reduction compared to other commercial and industrial ratepayers26.

As mentioned previously, studies show inconsistent results in using dynamic pricing to achieve consistent demand response. One study showed that automated demand response programs are overridden on average 14% of the time27. This study also found that the longer a demand response event lasts, the more likely automation will be overridden with events lasting from the two to four-hour range being overridden up to 30% of the time28. a. Discussion - Residential
To offset any risk to Pioneer’s business model, any dynamic pricing rate would need to be opt-in.

As mentioned above, an opt-out model could lead to a large number of unexpected opt-outs of CCA service. This would have credit implications which in turn would increase procurement costs for the CCA. These costs would then be passed on to the remaining ratepayers in future rate changes, which is a fundamentally inequitable result.

As the studies show, an opt-in model would lead to at best thirty percent participation. However, for this percentage to strongly show load reduction based on price signals, the participating ratepayers would need smart thermostats29. For ratepayers that do not have this technology, a method of providing notice (such as automated texts) would need to be developed.

In sum, current evidence does not show that Dynamic Pricing results in consistently shifting energy usage. Furthermore, it shows that that Dynamic Pricing is not popular with ratepayers, which means its aggregate effects may not be substantial. These conclusions mean that Cost should be comparably light for Pioneer to find the exercise a worthwhile endeavor. b. Discussion – Commercial/Industrial
Much of the same logic for residential holds true that any Dynamic Pricing that any program would need to be opt-in rather than opt-out. Depending on the size of the customer, serious automation investments would need to be made. Furthermore, the only datapoint available to determine if there would be actual load reductions and shifts to off-peak hours demonstrates only a ten percent reduction compared to opted out customers. This may be because many commercial/industrial accounts cannot, for business reasons, shift their energy consumption (e.g.

Target could not shut off its HVAC from 4 p.m. to 9 p.m. without discouraging shoppers from 26 Id. 27 Pamela Jordan Wildstein, Quantifying the Impact of Override Behavior on the Performance of a Summer Direct Load Control Program, Uni. Of Michigan, April 2022.
28 Id. 29 Carvallo, supra note 17, at Pg. 9
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11 spending time in their store). In sum, there is not enough evidence to show that Dynamic Pricing for commercial/industrial customers would be effective in shifting energy consumption to off-peak hours. ii. Costs
Pioneer will assess “Costs” based on the actual financial cost to Pioneer.

In creating a new rate class, per regulatory requirements, Pioneer would need to develop the class from the ground up rather than mirroring PG&E classes. This would require first a rate study to determine the amount of ratepayers likely to enroll in the class and the cost the rate needs to be to recoup all expenses related to the rate. The latter factor becomes considerably harder to determine when the rate is dynamic rather than fixed which in turn makes the study more complicated and more expensive. This study would also have to assess the impact the new dynamic rate would have on enrollment in existing classes.

Pioneer is contracted with Calpine to handle billing matters. To institute a new rate class, Pioneer would then need to amend that contract. Outside of the negotiation period, Calpine estimates that instating a dynamic pricing rate would take approximately six months or more. Concurrent with this implementation would be a marketing and outreach campaign to educate ratepayers on the rate and their ability to opt-in to the rate. This would require amending Pioneer’s contract with JSR Strategies, Pioneer’s marketing consulting vendor.

A. Discussion – Residential & Commercial/Industrial
As mentioned above, process costs for this initiative are unquantifiable as it would require amending several contracts with outside contractors. However, in assessing staff time to renegotiate the contracts and to participate in the initiative itself, the cost would be especially burdensome. Time taken to initiate the dynamic pricing rate and related customer education campaign takes from other pressing matters that Pioneer’s staff must handle. As mentioned above, Pioneer has a lean staff model, so staff generally have limited bandwidth outside of their normal job duties. Taking significant time away from core job functions could have unintended cascading effects which could impact Pioneer’s business model. In sum, the process costs are especially high for Pioneer to implement a Dynamic Pricing rate at this time. Pioneer will monitor and consider offering, as part of the triennial plan review, new IOU dynamic rates or our own rates and programs, as more data from the PG&E HFP Pilot is gathered and the rates are reviewed for cost effectiveness.

B.Technological Feasibility
Pioneer will assess “Technological Feasibility” based on whether the requisite technology is commercial and not experimental.

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12 Pioneer is contracted with Calpine to handle billing matters. As a CCA, Pioneer does not have real time access to customer meters. Instead, meter data is handled by PG&E which is then transmitted to Calpine to generate customer invoices. In order to determine if it is technically feasible to implement hourly and sub-hourly rates, Pioneer would need to know if customer meters are capable of handling hourly and sub-hourly intervals in their service area (Advanced Metering Infrastructure). This information is not readily available and requires instituting a query through Calpine which Pioneer would have to pay for.

The ability to react to price signals depends entirely on notice. It is fundamentally unfair to expect a ratepayer to react to price signals if they are unaware of them. That is why there must be sufficient technology to 1) provide notice to customers and 2) enable automation devises to react to said price signals.
i. Discussion - Residential
Pioneer would not be able to accurately determine total technological feasibility without incurring additional cost. Furthermore, to ensure that the initiative is a success, Pioneer would need to contract with a third party for the ability to text opt-in customers when they need to shift their load and would need to help ratepayers obtain a smart thermostat. Pioneer would also need to work with PG&E, and Calpine to create a way to access meter data in real time. In sum, Dynamic Pricing may be technologically feasible for residential customers, but Pioneer cannot make an accurate determination without incurring additional costs. ii. Discussion – Commercial/Industrial
Similarly, Pioneer cannot determine whether all Commercial/Industrial meters are capable of reading hourly and sub-hourly without incurring additional cost. Furthermore, Pioneer is not in a position to speculate on what technology upgrades for a Commercial/Industrial customer to be able to react and shift their energy consumption based on price signals. Also, as stated above, Pioneer would need to work with PG&E and Calpine to develop a way to access meter data in real time. In sum, Dynamic Pricing may be technically feasible for Commercial/Industrial customers, but Pioneer cannot make an accurate determination without incurring additional costs.

C. Benefits to the Grid
Pioneer will assess “Benefits to the Grid” on whether the proposed rate will reduce periods of high demand which constrain the grid.

An opt-in dynamic pricing rate may provide many benefits to the grid. CAISO energy prices are subject to supply and demand economic principles. Periods of high pricing are due to substantially greater demand than supply. A dynamic pricing rate would incentivize ratepayers to reduce their demand and there are supply constraints. Similarly, transmission costs are subject to supply and demand economic principles. To reduce demand for energy generation would also reduce demand Plf)NEER

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13 for energy transmission. Finally, a dynamic pricing rate could reduce greenhouse gas emissions as times of high demand are when fossil fuels are generally used the most. i. Discussion - Residential
There are many theoretical benefits to the grid. If these benefits are realized, it would be in line with Pioneer’s commitment to keep costs low for their ratepayers. However, these benefits are purely speculative as there is no reliable data showing Dynamic Pricing has resulted in consistent reductions in peak demand.
ii. Discussion – Commercial/Industrial
The same logic also applies to Commercial/Industrial customers. The only reliable data point we have demonstrated a ten percent reduction during peak times. This is not enough data to draw a determination that Dynamic Pricing will provide consistent benefits to the grid.

D.Benefits to Customers
Pioneer will assess “Benefits to Customers” on whether the proposed rate will result in lower costs to Pioneer customers.

Dynamic Pricing provides an incentive for customers to shift their energy consumption to times when it cheaper. As mentioned above, this similarly impacts transmission prices. However, there are currently no available studies showing consistent energy savings when customers are on a Dynamic Pricing rate. Of the studies Pioneer reviewed, all were designed to show potential savings – not demonstrate actual savings.
i. Discussion – Residential & Commercial/Industrial
Any benefits to customers of either class are purely speculative. Pioneer has been unable to find any studies that show consistent energy consumption shifting due to Dynamic Pricing.

Furthermore, Pioneer has not found any studies demonstrating consistent savings to a ratepayer by utilizing a Dynamic Pricing rate.

E.Equity
Pioneer will assess “Equity” on whether the proposed rate will disproportionately burden certain populations.

Customers may see benefits on their bills. The ability to shift energy consumption to periods of lower costs would mean lower bills. However, as mentioned above, for the program to truly be successful it would require the ability of the ratepayer to receive notice and for them to have access to smart thermostat technology which can react to price signals.

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14 i. Discussion – Residential & Commercial/Industrial
The equitable benefits of a dynamic price rate are contingent on many factors. The evidence that these factors aligning will result in the desired behavior is so far not substantive.

As noted above, utility consumer advocates have noted that Dynamic Pricing is disproportionally burdensome on the poor. The poor are more likely to have less efficient appliances and would have to pay for text messages sent to them to receive notice of the price fluctuations. During heat wave events when air conditioning must be used for health reasons, the poor would be forced to choose between high rates or their own health. If a low-income customer mistakenly leaves an appliance on, the resulting bill could be catastrophic, having direct impacts on their budgetary considerations for food, health, and shelter30. In sum, the equitable benefits are hypothetical while the burden on the poor is concrete.

F.Conclusion - Rates
The LMS goals, articulate in §1623.1(a)(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening, or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), implementing a marginal cost-based rate would not be cost effective at achieving these goals. Studies show that at most thirty percent of residential ratepayers would utilize the program with the actual outcome in reducing demand being highly contingent on access to certain technologies. This outcome is also based solely on the reporting of one IOU. Furthermore, Pioneer has not seen any studies showing that Dynamic Pricing works in consistently shifting consumption. In contrast, Pioneer would need to invest significant money and staff time to ensure that the program is a success. Furthermore, Pioneer cannot ascertain the technological feasibility of instituting the rate without incurring additional cost. As noted above, a key issue with technological feasibility is that Pioneer does not have real time access to the meters in its service area. There may be benefits to the grid, but studies show that these benefits are not consistent. For customers, Dynamic Pricing could be beneficial, but it could equally be punitive and lead to inequitable results for lower income customers. For these reasons, Pioneer will not institute a marginal cost-based rate at this time. In the alternative, Pioneer will proceed with instituting the following load flexibility programs and offering PG&E's HFP Pilot, the expanded marginal cost-based CalFUSE pilot authorized in CPUC Decision D. 24-01-032.. 30 Stephanie Kelly, Peter Szekely, Jennifer Hiller, Texas freeze raises concerns about ‘ridiculous’ variable rate bills, Reuters, Fe. 22, 2021
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15 3.Load Flexibility Programs
As mentioned previously, Pioneer has a lean staff model. The Pioneer Programs Manager position was not filled until July 2023. Pioneer staff have developed the following roadmap for program implementation of programs the enable automated response to marginal cost signals.

These programs are analyzed under the same framework as Dynamic Pricing (Cost Effectiveness, Cost, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity). Effectiveness and Cost will be truncated. They will be broken down into the following categories and analyzed together:
• Programs that help customers obtain hardware that helps shift energy usage. • Programs that incentivize energy usage behaviors.
• Existing government programs not administered by Pioneer staff.

I. Hardware Programs
The following are programs that help customers obtain hardware that help customers shift their energy usage. The table has the name of the program, a brief description of the program, Pioneer staff’s progress on the program, and the expected date of implementation:

Program Provider Program Description Progress Date of Implementation Participate Energy Pioner customers
contract with
Participate Energy for
leased home solar and
storage products. These
customers are
aggregated into a
virtual power plant. It
shifts energy usage by
charging the battery
when times are
cheapest (compared to
self-generation) and
then uses power from
the battery at high-cost
hours.

Pioneer Board
approved program
Second Quarter of 2024
Thule Energy Storage Pioneer customers
install Thule’s
proprietary technology
in line with the air
conditioning system at
low upfront cost to the
customer. This
Under Development Second Quarter of 2025
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16 technology freezes
water into ice during
periods of low demand
and then thaws the ice
as part of the air
conditioning system
during periods of high
demand.

A. Cost Effectiveness
Pioneer will assess “Effectiveness” whether the program will consistently lead to the desired load shifting outcome. “Cost” will also be assessed based on the actual cost to Pioneer.

These are all programs that have demonstrated effectiveness in consistently shifting energy habits without incurring significant costs from Pioneer. Participate Energy’s program to help customers install a battery on their home allows for customers to pull from their own reserve of power during high-cost times. Similarly, Thule Energy Storage would use periods of cheap grid energy to freeze ice, which in turn is used in conjunction with air conditioning to lessen the amount of energy needed by the air conditioning unit during periods of high energy cost. Pioneer believes that while none of these programs is a silver bullet in consistently reducing demand, when aggregated together they can provide consistent demand reduction. Furthermore, since these programs are done in partnership with a third party, Pioneer would not need to invest significant time and resources to get the programs running.

B. Technological Feasibility
Pioneer will assess “Technological Feasibility” based on whether the requisite technology is commercial and not experimental.

All listed programs in the section rely on proven technology. Participate Energy is partnered with Tesla to use Tesla’s battery and photovoltaic technology. Thule Energy Storage’s technology have logged more than 60 million operating hours at over 300 locations since 200531. Thule Energy Storage has previously partnered with Southern California Edison for a successfully implemented load shifting program relying on their technology.

C.Benefits to the Grid
31 https://www.thuleenergystorage.com/projects/, last visited March 7, 2024.

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17 Pioneer will assess “Benefits to the Grid” on whether the proposed rate will reduce periods of high demand which constrain the grid.

The programs mentioned have a proven track record of providing benefits to the grid. Residential solar and storage helps reduce demand from the grid during high demand hours and residents can draw from their battery instead of the grid32. Similarly, the Thule Ice Energy shifts energy use for air conditioning to low demand hours.

D.Benefits to Customers
Pioneer will assess “Benefits to Customers” on whether the proposed programs will result in lower costs to Pioneer customers.

These programs were specifically sought out due to their ability to help Pioneer customers. This program allows Pioneer customers to have solar and storage systems that normally would not be able to. As mentioned above, Participate Energy handles all maintenance and upkeep of the system and covers upfront installation costs. Thule Energy Storage would also be administered at low upfront cost to the customer.

E. Equity
Pioneer will assess “Equity” on whether the proposed program will disproportionately burden certain populations.

These programs are also structured to reduce upfront costs for customers which means that lower income individuals can take advantage of the program. This creates an equal opportunity for all populations to participate and realize the benefits of these load shifting programs.

F. Conclusion – Hardware Programs
The LMS goals, articulate in §1623.1(a)(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), these programs will achieve the aims of the LMS regulations in a consistently effective manner without leading to inequitable results. They are cost effective as they rely on proven technologies and do not require substantial staff time to implement.

Similarly, they are technologically feasible as the technologies are commercially available and not experimental. Studies show they provide proven benefits to the grid. Customers are able to benefit as these programs are designed to be provided to customers with little or no upfront cost. 32 Hou Sheng Zhou, A case study on the behavior of residential battery energy storage systems during network demand peaks, Renewable Energy, Dec. 2021.

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18 Finally, for the same rationale, these programs are equitable as lower income ratepayers can access the programs at little or no upfront cost.

II. Incentive Based Program Paired with Software
Pioneer believes that an incentive-based program would be more successful in consistently shifting energy usage than a punitive based one. With this in mind, Pioneer staff has been meeting with Sonoma Clean Power staff to implement a program similar to their GridSavvy program. This program offers customers that reduce their load during peak hours compensation that can be redeemed or donated to a participating nonprofit organization. An alert is sent to participating customers in advance of an anticipated peak load period. The compensation is based on kWh reduced during the event and there is no penalty if the customer decides to continue their usage as usual. This program is expected to launch by the second quarter of 2025.

In conjunction with this program, Pioneer is exploring leveraging software to automate smart appliances. As mentioned above, studies show that technology is required to consistently shift load for demand response. The software would also be combined with an EV charging optimization program.

The table has the name of the program, a brief description of the program, Pioneer staff’s progress on the program, and the expected date of implementation:

Program Provider Program Description Progress Date of Implementation Pioneer would need to
issue an RFO for a
provider.

Incentivization based
program which pays
Pioneer customers who
shift their energy usage
during peak demand
times.

Under Development Second Quarter of 2025
Virtual Peaker Operates a Distributed
Energy Resource
Management System
(DERMS) platform.

This platform connects
with customers smart
devices to help shift
energy habits to low-cost hours.

Under Development Second Quarter of 2026
Pioneer would need to
issue an RFO for a
provider.

EV Charging
Optimization.

Under Development Fourth Quarter of 2024
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19 A. Cost Effectiveness
Pioneer will assess “Effectiveness” whether the program will consistently lead to the desired load shifting outcome. “Cost” will also be assessed based on the actual cost to Pioneer.

Studies show that incentive-based approaches effectively reduce peak load during heatwave events without harm to vulnerable groups33. Notably, in a study of incentive-based demand response in China, researchers found that the repeated and frequent implementation of the program did not result in an attenuation of the effect34. This demonstrates that incentive-based demand response can lead to consistent results in shifting energy usage.

In order to gauge the complete financial cost and solicit competitive proposals, Pioneer would need to issue a Request for Offers. This process aims to assess the feasibility and pricing structures associated with implementing an incentive-based program to shift energy usage. At this current junction, in preliminary conversations with other CCAs with similar programs, costs are not presumed to be substantial.

B. Technological Feasibility
Pioneer will assess “Technological Feasibility” based on whether the requisite technology is commercial and not experimental or theoretical.

These programs have been shown to be technologically feasible in other CCA service areas35.

These appliances and software have been on the market now for many years. If the program intends to make the periods of load shifting more granular (i.e sub-hourly) Pioneer would need to determine how many meters in our service area are AMI.

C.Benefits to the Grid
Pioneer will assess “Benefits to the Grid” on whether the proposed programs will reduce periods of high demand which constrain the grid.

These programs will help shift load during peak load hours which in turn reduces strain on the grid. As seen in the previously mentioned study, incentive-based programs result in consistent load reduction36. These load reductions, especially in periods of high demand, mean less price volatility and lowers the change of a brown out.
33 Wang, Lu, Want, Qiu, Zhang, Li, Li, and Zhao, Incentive based emergency demand response effectively reduces peak load during heatwave without harm to vulnerable groups, Nature Communications, Oct. 2023 34 Id. 35 https://sonomacleanpower.org/programs/gridsavvyrewards, last viewed March 7, 2024. 36 Wang, supra at note 34.

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20 D.Benefits to Customers
Pioneer will assess “Benefits to Customers” on whether the proposed programs will result in lower costs to Pioneer customers.

This program will provide customers with the ability to either earn money from their shift in energy consumption or donate to a participating nonprofit. Rather than being punitive, these programs reward behavior with money that can go back into their account. Though this rebate program, Pioneer customers will realize lower costs.

E. Equity
Pioneer will assess “Equity” on whether the proposed program will disproportionately burden certain populations.

As mentioned above, studies show that these types of programs are more equitable than punitive based programs37. Rather than risk losing money, they can instead earn money by changing their habits. A customer will not have to worry about a large bill due to factors outside their control (say a medically necessary reason to keep an air conditioner running). Because of this model, no population can be disproportionately burdened with the costs of shifting energy usage.

F. Conclusion - Incentive Based Program Paired with Software The LMS goals, articulate in §1623.1(a)(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), these programs will achieve the aims of the LMS regulations in a consistently effective manner without leading to inequitable results. They are cost effective as studies show incentive based cost shifting programs lead to consistent load shifting. The programs rely on commercially available technology which means they are technologically feasible. Studies show that these types of programs lead to consistent load shifting behavior which provides benefits to the grid. The programs are beneficial to customers as they are rewarded, rather than penalized for shifting their behavior. Finally, for the same reason, these programs are equitable as low-income individuals are able to avoid the risk of a catastrophic electricity bill.

III. Existing Government Programs
The table has the name of the government program, a brief description of the program, Pioneer staff’s progress on the program, and the expected date of implementation:
37 Id.

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21 Program Name Program Description Progress Date of Implementation AgFIT The Flexible Irrigation
Pilot Program for
Agriculture (AgFIT)
was successfully
piloted by Valley Clean
Energy. The D.24-01-
032 ruling expanded
the program to all
agricultural customers
and allows all CCAs in
PG&E service territory
to participate until its
conclusion on
December 31, 2027.

This program would be
administered by PG&E
and would use
automation technology
and/or a notice to shift
agriculture pumping
times.

Pioneer must submit an
Advice Letter stating
their intent to
participate by March
2025
The Second Quarter of
2025
ELRP A program
administered by the
IOUs which pays
customers who
voluntarily reduce
electricity demand
during a grid
emergency. The
program also pays
customers who produce
energy during a grid
emergency under
certain conditions.

Currently ongoing Set to expire December
31, 2025
A. Cost Effectiveness
Pioneer will assess “Effectiveness” whether these programs consistently lead to the desired load shifting outcome. “Cost” will also be assessed based on the actual cost to Pioneer.

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22 These programs have been proven to be effective at shifting energy consumption to off-peak hours for irrigation. It is due to their effectiveness that CPUC expanded these programs38. Since these programs are administered by the IOUs, they would be administered at no cost to Pioneer.

B. Technological Feasibility
Pioneer will assess “Technological Feasibility” based on whether the requisite technology is commercial and not experimental or theoretical.

Since these are programs that have already been piloted or are currently running, they have proven technological feasibility. Any requisite technology is commercially available.

C.Benefits to the Grid
Pioneer will assess “Benefits to the Grid” on whether the proposed programs will reduce periods of high demand which constrain the grid.

The AgFIT program shifts load to times of low demand which reduces strain on the grid. The ELRP is a more traditional demand response program but is incentive based rather than punitive.

Both are designed to reduce demand from the grid which helps stabilize prices and reduce the risk of brown out.

D.Benefits to Customers
Pioneer will assess “Benefits to Customers” on whether the proposed programs will result in lower costs to Pioneer customers.

Both of these programs provide benefits to customers as they reduce demand during peak periods. Reductions like help stabilize costs which in turn helps keep Pioneer rates low.

Furthermore, Pioneer customers that are part of the ELRP program are compensated for the reductions in energy usage, which in turn means they realize lower energy costs.

E. Equity
Pioneer will assess “Equity” on whether the proposed program will disproportionately burden certain populations.

Both of these programs are opt-in incentive based rather than punitive, fostering a more balance and fair outcome. This approach not only encourages compliance but also promotes a positive and cooperative relationship between customers and the LSE, leading to outcomes seen as fairer and more equitable. As mentioned previously, incentive-based programs lead to more equitable outcomes39.
38 Staff Proposal on Existing Dynamic Rate Pilot Expansion, R.22-07-005, Aug. 15, 2023. 39 Wang, supra at note 34.

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23 F. Conclusion – Existing Government Programs
The LMS goals, articulate in §1623.1(a)(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), these programs will achieve the aims of the LMS regulations in a consistently effective manner without leading to inequitable results. These programs are cost effective as the CPUC has found them to be effective at consistently shifting load. They are also not administered by Pioneer, so cost is negligible. As they are existing programs, they are shown to be technologically feasible. The programs provide proven benefits to the grid by shifting load times away from peak periods. Since these are incentive based, they provide benefits to customers as they see a gain from shifting behavior rather than a penalty. Finally, for a similar rationale, they are incentive based so the programs do not lead to inequitable outcomes.

4. Summary
The amended LMS regulations require Pioneer to assess implementing a marginal cost-based rate, and if that implementation would result in the goals of the regulation. These goals are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening, or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions.

In assessing the if the implementation will achieve these goals, Pioneer must weigh cost effectiveness, technological feasibility, benefits to the grid, benefits to customers, and equity. If, after weighing these factors, Pioneer chooses not to implement a marginal cost-based rate, Pioneer must instead provide load shifting programs designed to achieve the previously state goals.

Pioneer assessed the implementation of a marginal cost-based rate and found that the rate scheme is not cost effective in achieving the stated goals of the regulation. There is not substantive enough evidence that a marginal cost-based rate would lead to consistent energy shifting behavior for the large cost that would be incurred by Pioneer. Currently, Pioneer does not have access to real time meter data which is required for the implementation of a rate like this.

Accessing that data would require significant costs and staff time for Pioneer. The rate also may be punitive and lead to inequitable outcomes for lower income customers. With that in mind, Pioneer has developed the following list of programs which will achieve the goals of the regulation:

Program Provider Program Description Progress Date of
Implementation
Participate Energy Pioneer customers
contract with Participate
Energy for leased home
solar and storage products
Pioneer (GridGen)
launched in 2024.

Fourth Quarter of 2024
Expanded in
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24 with no upfront costs and
no credit check.

Customers are aggregated
into a virtual power plant
that shifts energy usage by
charging the battery when
rates are lower (compared
to self-generation) and
then uses power from the
battery at higher-cost
hours.

The program was
expanded to offer
battery-only retrofits
and access for

CARE/FERA
customers.

To date:
• 6 completed installs
• 11 customers
achieved permission
to operate (PTO)
• 87 customers in the
active pipeline
Third Quarter of 2025
Demand Response Incentivize-based program
that pays customers who
shift their energy usage
during times of peak
demand/grid strain.

Program (PowerShift
Rewards) launched fall
2024 and runs May
through October.

Customers receive an
incentive for enrolling
in the program and
additional incentives
for reducing energy
consumption during
times of peak demand
or when the grid is
strained.

To date, more than
1,400 customers are
enrolled, resulting in a

1.4 MWh energy
reduction.

Third Quarter of 2024
PG&E The Hourly Flex Pricing
Pilot Program, formerly
known as AgFIT, was
successfully
piloted by Valley Clean
Energy. The D.24-
01-032 ruling expanded
the program to all
agricultural customers and
allows all CCAs in PG&E
service territory to
participate until its
conclusion on
December 31, 2027. This
program uses
Program launched in
late 2024, but the
application period
closed abruptly in
spring.

Applications period
was reopened in spring
due to CCA concerns.

However, incentive
funding is limited and
likely will reach
capacity soon.

Pioneer currently has
two customers with a
Fourth Quarter of 2024
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25 automation technology
and/or a notice to
shift agriculture pumping
times.
combined 19 meters
enrolled in the
program.

Ice Energy Storage Pioneer customers install
Ice Energy’s technology to
the air conditioning unit at
low upfront costs. The
technology freezes water
into ice during periods of
low energy demand, then
uses the ice during periods
of high demand to reduce
energy use by taking
pressure off the condenser,
thereby using less energy.

Program launched in
spring
• 22 Participation
Agreements under
review
o Roughly 130 units
would be installed
• 35 site surveys
Second Quarter of
2025
Pioneer would issue
an RFO for a provider
or partner with an
existing project
EV Charging
Optimization/Accessibility
Under development Third Quarter of 2026
(Updated September 2025)
Finally, Pioneer has been working with the other load serving entities (LSEs) on creating the statewide RIN tool pursuant to 20 CCR Section 1623(c). A proposed plan for the tool was submitted to the CEC for review on October 1, 2024. Pioneer will continue to work with the other LSEs and the CEC to implement and maintain the statewide RIN tool in a timely manner subject to the tool’s approval by the CEC.

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Load Management
Standards
Compliance Plan
(Revised)
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Contents

1. Introduction ................................................................................................................. ........... 4 I. About CEC & LMS ................................................................................................................ 4 II. About Pioneer ..................................................................................................................... 6 Ill. Format of Analysis .............................................................................................................. 7

2. Rates ...................................... .......................................................................... ............. .......... 7 I. Marginal Cost-Based Rates .................................................. ..... .......................................... 8 A. Cost Effectiveness ........................................................................................................... 8 B. Technological Feasibility ................................................................................................... 11 i. Discussion - Residential ............................... ................................................................. 12 ii. Discussion - Commercial/Industrial ........................ .. ...... ........................ ..................... 12 C. Benefits to the Grid ........................................................................................................... 12 i. Discussion - Residential ..................................................................................... ........... 13 ii. Discussion - Commercial/Industrial ..................... ................................... ............... ...... 13 D. Benefits to Customers ................................. ..................................................................... 13 i. Discussion - Residential & Commercial/Industrial ....................................................... 13 E. Equity ......... .. .. .............................. ........... .................................................................. ........ 13 i. Discussion - Residential & Commercial/Industrial ..................................... .................. 14 F. Conclusion - Rates .. ........................................................................................................... 14

11. Incentive Based Program Paired with Software ............................................................... 18 A. Cost Effectiveness ...................................................... ................................................... 19 B. Technological Feasibility ............................................................................................... 19 C. Benefits to the Grid ........................................................... ............................................ 19 2 Plf)NEEA

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D. Benefits to Customers .................................................................................................. 20 E. Equity ............................................................................................................................ 20 F. Conclusion - Incentive Based Program Paired with Software ...................................... 20 111. Existing Government Programs ........................................................................................ 20 A. Cost Effectiveness ......................................................................................................... 21 B. Technological Feasibility ............................................................................................... 22 C. Benefits to the Grid ....................................................................................................... 22 D. Benefits to Customers .................................................................................................. 22 E. Equity ................................................................................... ........ ....... .......................... 22 F. Conclusion - Existing Government Programs ............................................................... 23

4. Summary ............................................................................................................................... 23 3 Plf)NEER

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1. Introduction
Pursuant to California Energy Commission's (CEC) amended Load Management Standards (LMS), this document (Plan) demonstrates how Pioneer Community Energy (Pioneer) intends to meet the articulated goals of the regulation. Pioneer does not accept CEC's belief that they hold jurisdiction over Community Choice Aggregators (CCAs), and it is participating in this decision voluntarily.

The following is Pioneer's roadmap for compliance in the form of a table listing the new requirements, their deadlines, and their respective statuses:

Relevant Section Requirement Deadline Status
§ 1623.l(c) Upload time-dependent July 1, 2023 Complete rates in the Market
Informed Demand
Automation Server
(MIDAS)
§ 1623. l (a)(l) Evaluate and April 1, 2024 Addressed with this implement a marginal plan
cost-based rate or, in
the alternative, a plan
of programs designed
to achieve the same
goals
§ 1623.1 (a)(3)(A) Submit the plan to CEC 30 days after Pioneer In ProgressComplete within 30 days of Board approval
Board adoption.

Respond to any
requests for additional
information or requests
for plan revisions
within 90 days.
§1623(c)(4) Within 1 year of the April 1, 2024 In ProgressComplete LMS effective date,
1 §1623. l(a)(l).
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provide customers
access to their Rate
Identification Numbers
(RIN) on billing
statements and in
online accounts using
both and QR code.
§ 1623( c )(2)(A) Develop and submit to October 1, 2024 In Progress the CEC, in
conjunction with the
other obligated utilities,
a single statewide
standard tool for
authorized rate data
access by third parties
along with the terms
and conditions for use
of the tool. Upon CEC
approval, the tool will
be live and obligated
LSEs must maintain
and improve the tool.
§1623.l(b)(3) Submit to CEC a list of October I, 2024 In ProgressComplete load flexibil ity
programs deemed cost-effective with at least
one option for
automating response to
MIDAS signals for
each customer class.
§ 1623. l(a)(3)(C) Submit annual reports April I, ~Q~§ , ane In Progress to CEC demonstrating anm1ally thereafterOne
implementation of the year after compliance
Plan, as approved by plan adoption and
the Board. annual thereafter
§ 1623 .1 (b)(2) Submit at least one July I, 2025 In Progress marginal cost-based
rate or program to the
Pioneer Board for
approval for any
customer class where
such a rate will
material ly reduce peak
load.
§1623.l(b)(S) Conduct a public No deadline provided 1 n Progress information campaign
to inform and educate
customers on why
marginal cost-based
rates or load flexibility
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programs are needed,
how they are used, and
how these rates and
programs can save
customers money.
§ I 623 .1 (a)(l )(C) Review the Plan at least Triennially Ongoing once every 3 years after
the Plan is adopted by
the Pioneer board.

Submit any updates of
the Plan to the Board if
there is a material
change.
(Updated September 2025)
II. About Pioneer
Pioneer is a CCA that serves unincorporated Placer and El Dorado County along with the Town of Loomis and the cities of Auburn, Colfax, Grass Valley, Lincoln, Nevada City, Placerville, and Rocklin2. Pioneer is governed by a Board of Directors made up of elected officials from its member agencies3. It currently serves approximately 166,000 accounts consuming approximately 2,000 gigawatt hours annually. Pioneer has a relatively small staff compared to other CCAs4 .

Currently, the staff is made up of fourteen individuals. Many necessary business functions are handled by outside contractors.

As mentioned previously, per the amended LMS regulations Pioneer must provide a plan that describes how Pioneer will meet the goals of encouraging the use of electrical energy at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions5. Specifically, the plan must evaluate marginal cost-based rates for each customer class in terms of cost effectiveness, equity, technological feasibility, benefits to the grid, and benefits to customers6. After weighing these factors, Pioneer may decide that marginal cost-based rates are not necessary and may instead propose programs that enable automated response to marginal cost signal(s) for each customer class and evaluate them based on the previously mentioned factors 7. 2 Amendment No. 5 to the Amended and Restated Joint Exercise of Powers Agreement for Pioneer Community Energy, Res. No. 2022-26 (2022).
3 Id.
4 https:/lpioneercommunityenergy.orgl, (last visited March 7, 2024). 5 § 1623.1 (a)(l ).
6 §1623 . l(a)(l)(A).
7 §1623.l(a)(l)(B).
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III. Format of Analysis
The LMS Regulation requires an analysis of marginal time-based rates and any subsequent programs for each customer class8. In consideration of CEC guidance, Pioneer has divided Customer Class into two distinct classes - residential and industrial/commercial.

Cost Effectiveness will be broken down individually into Cost and Effectiveness. Where analysis and discussion for each customer class is substantially the same, the sections will be combined.

Implementing new rates involve considerable costs to Pioneer. The Pioneer Board of Directors (Pioneer Board) is required to review rates annually 1°. However, staff can bring suggested rate changes first to the Finance Committee and then to the Board of Directors. In assessing rates, Pioneer has many considerations. These include traditional business costs such as operating expenses, paying for power supply and regulatory products, and maintaining creditworthiness.

However, unlike traditional utilities, CCAs must also consider the ability of a ratepayer to opt out of service. Because of this, Pioneer (like many other CC As) relies on a strategy of mirroring Large Investor-Owned Utility (IOU) rates with a targeted discount.

The LMS regulations requires the Pioneer Board to assess for approval at least one marginal cost-based rate by June 30, 202i 1. Pioneer may apply for approval of a marginal cost-based rate 8 § 1623 .1 (a)( I )(A).
9 Public Utilities Code Section 366.2(c)(3).
1° Financial Policies, (Oct. 21, 2021 ), https://pioneercommunityenergy.org/wp-content/uploads/2022/04/2021-10- 21-Financial-Policies.pdf.
11 § 1623 .1 (b)(2).
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offered by PG&E 12. PG&E stated their intent to provide one marginal cost-based rate by January 2027 which Pioneer can mirror upon its implementation 13 . In the meantime, Pioneer commits to making a marginal cost-based rate available to its agricultural customers in the form of PG&E's Hourly Flex Pricing Pilot (HFP Pilot), formerly referred to as the Flexible Irrigation Pilot Program for Agriculture (AgFIT). The HFP Pilot is an expanded marginal cost-based PG&E CalFUSE pilot authorized in CPUC Decision D. 24-01 -032. By offering the HFP Program, Pioneer is providing one marginal cost-based rate for its agricultural customers. With that in mind, per the requirements of the regulations, Pioneer must assess developing a marginal cost-based rate outside of mirroring one developed by PG&E. Pioneer will consider offering further marginal cost-based rates as appropriate and consistent with its authority over its own rates, subject to the limitations identified below.

I. Marginal Cost-Based Rates
Marginal cost is calculated as "the sum of the marginal energy cost, the marginal capacity cost (generation, transmission, and distribution), and any other appropriate time- and location-dependent marginal costs, including the locational marginal cost of associated greenhouse gas emissions, on a time interval of no more than one hour 14. Energy cost computations shall reflect locational marginal cost pricing as determined by the associated balancing authority, such as the California Independent System Operator, the Balancing Authority of Northern California, or other balancing authority 15. Marginal capacity cost computations shall reflect the variations in the probability and value of system reliability of each component (generation, transmission, and distribution). 16" There is an immediate issue with the provided definition of marginal cost-based rates - Pioneer does not control the transmission and distribution in its service territory so it cannot accurately compute a marginal cost-based rate. Additionally, it is hard to quantify greenhouse gas emission costs. It appears that the regulations intend for these rates to be dynamic, responding to demand on the grid. For ease of reference, this Plan will refer to marginal cost-based rates as Dynamic Pricing.

A. Cost Effectiveness
As mentioned previously, Pioneer relies heavily on outside contractors. Any implementation of dynamic pricing would require amending contracts with multiple contractors. This means that overall cost will be unquantifiable, as the contract amendments will need to be negotiated. To weigh cost against effectiveness, Pioneer believes it is best to assess the effectiveness of Dynamic Pricing first in order to ascertain any unforeseen costs. 12 Id.
13 2023 COMPLIANCE PLAN for the LOAD MANAGEMENTS STANDARDS, D 23-LMS-01. 14 §1623.l(b)(l).
1s Id.
16 Id.
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1. Effectiveness
Pioneer will analyze "Effectiveness" on whether the implemented rate will consistently lead to the desired load shifting outcome.

In November of 2023, Lawrence Berkeley Lab released a report titled "The use of price-based demand response as a resource in electricity system planning. 17" This paper analyzed twelve utilities use of time-based rates. They included Time of Use Pricing, Real Time Pricing, Variable Peak Pricing, Critical Peak Pricing, and Critical Peak Rebate in their analysis of price-based demand response.

Approximately one-third of the utilities studied did not include price-based demand response in the Integrated Resource Plan (IRP) as they found that there was not sufficient participation to deem it significant in impacting demand 18. Furthermore, of the customers that did participate, their response to price signals was often erratic and hard to predict 19 .

For the opt-in model, participation ranged from three percent to thirty percent21 . Similarly, a 2016 Department of Energy sponsored study of several utilities found a fifteen percent opt-in rate for dynamic pricing rates22 . This is consistent with several other studies mentioned in the Lawrence Berkeley Lab report, with no dynamic pricing rate exceeding thirty percent enrollment for opt-in participation23 .

In the Lawrence Berkeley Lab study, only one utility reported load reduction for opt-in participation24 . Residential ratepayers of that utility showed load reduction levels eighty to ninety percent lower than other residential customers25 . However, for commercial and industrial 17 Juan Pablo Carvallo and Lisa Schwartz, The use of price-based demand response as a resource in electricity system planning, Energy Markets & Policy, Nov. 2023.
18 Id at Pg. 5
19 Id.
20 Id at Pg.7.
21 Id.
22 Dept. of Energy, Customer Acceptance, Retention, and Response to Time-Based Rates from the Consumer Behavior Studies, Electricity Delivery & Energy Reliability, Nov. 2016. 23 Carvallo, supra note 17.
24 Id.
2s Id.
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ratepayers, the utility found only a ten percent higher load reduction compared to other commercial and industrial ratepayers26 .

As mentioned previously, studies show inconsistent results in using dynamic pricing to achieve consistent demand response. One study showed that automated demand response programs are overridden on average 14% of the time27. This study also found that the longer a demand response event lasts, the more likely automation will be overridden with events lasting from the two to four-hour range being overridden up to 30% of the time28 . a. Discussion - Residential
To offset any risk to Pioneer's business model, any dynamic pricing rate would need to be opt-in.

As the studies show, an opt-in model would lead to at best thirty percent participation. However, for this percentage to strongly show load reduction based on price signals, the participating ratepayers would need smart thermostats29 . For ratepayers that do not have this technology, a method of providing notice (such as automated texts) would need to be developed.

In sum, current evidence does not show that Dynamic Pricing results in consistently shifting energy usage. Furthermore, it shows that that Dynamic Pricing is not popular with ratepayers, which means its aggregate effects may not be substantial. These conclusions mean that Cost should be comparably light for Pioneer to find the exercise a worthwhile endeavor. b. Discussion - Commercial/Industrial
Much of the same logic for residential holds true that any Dynamic Pricing that any program would need to be opt-in rather than opt-out. Depending on the size of the customer, serious automation investments would need to be made. Furthermore, the only datapoint available to determine ifthere would be actual load reductions and shifts to off-peak hours demonstrates only a ten percent reduction compared to opted out customers. This may be because many commercial/industrial accounts cannot, for business reasons, shift their energy consumption ( e.g.

Target could not shut off its HV AC from 4 p.m. to 9 p.m. without discouraging shoppers from 26 Id.
27 Pamela Jordan Wildstein, Quantifying the Impact of Override Behavior on the Performance of a Summer Direct load Control Program, Uni. Of Michigan, April 2022.
2s Id.
29 Carvallo, supra note 17, at Pg. 9
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spending time in their store). In sum, there is not enough evidence to show that Dynamic Pricing for commercial/industrial customers would be effective in shifting energy consumption to off-peak hours.

11. Costs
Pioneer will assess "Costs" based on the actual financial cost to Pioneer.

In creating a new rate class, per regulatory requirements, Pioneer would need to develop the class from the ground up rather than mirroring PG&E classes. This would require first a rate study to determine the amount of ratepayers likely to enroll in the class and the cost the rate needs to be to recoup all expenses related to the rate. The latter factor becomes considerably harder to determine when the rate is dynamic rather than fixed which in turn makes the study more complicat~d and more expensive. This study would also have to assess the impact the new dynamic rate would have on enrollment in existing classes.

Pioneer is contracted with Calpine to handle billing matters. To institute a new rate class, Pioneer would then need to amend that contract. Outside of the negotiation period, Calpine estimates that instating a dynamic pricing rate would take approximately six months or more. Concurrent with this implementation would be a marketing and outreach campaign to educate ratepayers on the rate and their ability to opt-in to the rate. This would require amending Pioneer's contract with JSR Strategies, Pioneer's marketing consulting vendor.

A. Discussion - Residential & Commercial/Industrial
As mentioned above, process costs for this initiative are unquantifiable as it would require amending several contracts with outside contractors. However, in assessing staff time to renegotiate the contracts and to participate in the initiative itself, the cost would be especially burdensome. Time taken to initiate the dynamic pricing rate and related customer education campaign takes from other pressing matters that Pioneer's staff must handle. As mentioned above, Pioneer has a lean staff model, so staff generally have limited bandwidth outside of their normal job duties. Taking significant time away from core job functions could have unintended cascading effects which could impact Pioneer's business model. In sum, the process costs are especially high for Pioneer to implement a Dynamic Pricing rate at this time. Pioneer will monitor and consider offering, as part of the triennial plan review, new IOU dynamic rates or our own rates and programs, as more data from the PG&E HFP Pilot is gathered and the rates are reviewed for cost effectiveness.

B. Technological Feasibility
Pioneer will assess "Technological Feasibility" based on whether the requisite technology is commercial and not experimental.
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Pioneer is contracted with Calpine to handle billing matters. As a CCA, Pioneer does not have real time access to customer meters. Instead, meter data is handled by PG&E which is then transmitted to Calpine to generate customer invoices. In order to determine if it is technically feasible to implement hourly and sub-hourly rates, Pioneer would need to know if customer meters are capable of handling hourly and sub-hourly intervals in their service area (Advanced Metering Infrastructure). This information is not readily available and requires instituting a query through Calpine which Pioneer would have to pay for.

The ability to react to price signals depends entirely on notice. It is fundamentally unfair to expect a ratepayer to react to price signals if they are unaware of them. That is why there must be sufficient technology to 1) provide notice to customers and 2) enable automation devises to react to said price signals.
i. Discussion - Residential
Pioneer would not be able to accurately determine total technological feasibility without incurring additional cost. Furthermore, to ensure that the initiative is a success, Pioneer would need to contract with a third party for the ability to text opt-in customers when they need to shift their load and would need to help ratepayers obtain a smart thermostat. Pioneer would also need to work with PG&E, and Calpine to create a way to access meter data in real time. In sum, Dynamic Pricing may be technologically feasible for residential customers, but Pioneer cannot make an accurate determination without incurring additional costs. n. Discussion - Commercial/Industrial
Similarly, Pioneer cannot determine whether all Commercial/Industrial meters are capable of reading hourly and sub-hourly without incurring additional cost. Furthermore, Pioneer is not in a position to speculate on what technology upgrades for a Commercial/Industrial customer to be able to react and shift their energy consumption based on price signals. Also, as stated above, Pioneer would need to work with PG&E and Calpine to develop a way to access meter data in real time. In sum, Dynamic Pricing may be technically feasible for Commercial/Industrial customers, but Pioneer cannot make an accurate determination without incurring additional costs.

C. Benefits to the Grid
Pioneer will assess "Benefits to the Grid" on whether the proposed rate will reduce periods of high demand which constrain the grid.

COMMUNITY ENERGY
for energy transmission. Finally, a dynamic pricing rate could reduce greenhouse gas emissions as times of high demand are when fossil fuels are generally used the most. i. Discussion - Residential
There are many theoretical benefits to the grid. If these benefits are realized, it would be in line with Pioneer's commitment to keep costs low for their ratepayers. However, these benefits are purely speculative as there is no reliable data showing Dynamic Pricing has resulted in consistent reductions in peak demand.
ii. Discussion - Commercial/Industrial
The same logic also applies to Commercial/Industrial customers. The only reliable data point we have demonstrated a ten percent reduction during peak times. This is not enough data to draw a determination that Dynamic Pricing will provide consistent benefits to the grid.

D.Benefits to Customers
Pioneer will assess "Benefits to Customers" on whether the proposed rate will result in lower costs to Pioneer customers.

Dynamic Pricing provides an incentive for customers to shift their energy consumption to times when it cheaper. As mentioned above, this similarly impacts transmission prices. However, there are currently no available studies showing consistent energy savings when customers are on a Dynamic Pricing rate. Of the studies Pioneer reviewed, all were designed to show potential savings - not demonstrate actual savings.
i. Discussion - Residential & Commercial/Industrial
Any benefits to customers of either class are purely speculative. Pioneer has been unable to find any studies that show consistent energy consumption shifting due to Dynamic Pricing.

Furthermore, Pioneer has not found any studies demonstrating consistent savings to a ratepayer by utilizing a Dynamic Pricing rate.

E.Equity
Pioneer will assess "Equity" on whether the proposed rate will disproportionately burden certain populations.

COMMUNITY ENERGY
i. Discussion - Residential & Commercial/Industrial
The equitable benefits of a dynamic price rate are contingent on many factors. The evidence that these factors aligning will result in the desired behavior is so far not substantive.

F. Conclusion - Rates
The LMS goals, articulate in § 1623 .1 ( a )(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening, or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), implementing a marginal cost-based rate would not be cost effective at achieving these goals. Studies show that at most thirty percent of residential ratepayers would utilize the program with the actual outcome in reducing demand being highly contingent on access to ce1tain technologies. This outcome is also based solely on the reporting of one IOU. Furthermore, Pioneer has not seen any studies showing that Dynamic Pricing works in consistently shifting consumption. In contrast, Pioneer would need to invest significant money and staff time to ensure that the program is a success. Furthermore, Pioneer cannot ascertain the technological feasibility of instituting the rate without incurring additional cost. As noted above, a key issue with technological feasibility is that Pioneer does not have real time access to the meters in its service area. There may be benefits to the grid, but studies show that these benefits are not consistent. For customers, Dynamic Pricing could be beneficial, but it could equally be punitive and lead to inequitable results for lower income customers. For these reasons, Pioneer will not institute a marginal cost-based rate at this time. In the alternative, Pioneer will proceed with instituting the following load flexibility programs and offering PG&E's HFP Pilot, the expanded marginal cost-based CalFUSE pilot authorized in CPUC Decision D. 24-01 - 032.Pioneer will proceed vlith instituting the following load fle>dbility programs. 30 Stephanie Kelly, Peter Szekely, Jennifer Hiller, Texas freeze raises concerns about 'ridiculous' variable rate bills, Reuter~ Fe. 22, 2021
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3. Load Flexibility Programs
As mentioned previously, Pioneer has a lean staff model. The Pioneer Programs Manager position was not filled until July 2023. Pioneer staff have developed the following roadmap for program implementation of programs the enable automated response to marginal cost signals.

I. Hardware Programs
The following are programs that help customers obtain hardware that help customers shift their energy usage. The table has the name of the program, a brief description of the program, Pioneer staffs progress on the program, and the expected date of implementation:

Program Provider Program Description Progress Date of Implementation Participate Energy Pioner customers Pioneer Board Second Quarter of 2024 contract with approved program
Participate Energy for
leased home solar and
storage products. These
customers are
aggregated into a
virtual power plant. It
shifts energy usage by
charging the battery
when times are
cheapest (compared to
self-generation) and
then uses power from
the battery at high-cost
hours.

Thule Energy Storage Pioneer customers Under Development Second Quarter of 2025 install Thule's
proprietary technology
in line with the air
conditioning system at
low upfront cost to the
customer. This
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technology freezes
water into ice during
periods of low demand
and then thaws the ice
as part of the air
conditioning system
during periods of high
demand.

A. Cost Effectiveness
Pioneer will assess "Effectiveness" whether the program will consistently lead to the desired load shifting outcome. "Cost" will also be assessed based on the actual cost to Pioneer.

These are all programs that have demonstrated effectiveness in consistently shifting energy habits without incurring significant costs from Pioneer. Participate Energy's program to help customers install a battery on their home allows for customers to pull from their own reserve of power during high-cost times. Similarly, Thule Energy Storage would use periods of cheap grid energy to freeze ice, which in turn is used in conjunction with air conditioning to lessen the amount of energy needed by the air conditioning unit during periods of high energy cost. Pioneer believes that while none of these programs is a silver bullet in consistently reducing demand, when aggregated together they can provide consistent demand reduction. Furthermore, since these programs are done in partnership with a third party, Pioneer would not need to invest significant time and resources to get the programs running.

B. Technological Feasibility
Pioneer will assess "Technological Feasibility" based on whether the requisite technology is commercial and not experimental.

All listed programs in the section rely on proven technology. Participate Energy is partnered with Tesla to use Tesla's battery and photovoltaic technology. Thule Energy Storage's technology have logged more than 60 million operating hours at over 300 locations since 200531 • Thule Energy Storage has previously partnered with Southern California Edison for a successfully implemented load shifting program relying on their technology.

C. Benefits to the Grid
31 https://www.thuleenergvstorage.com/projects/, last visited March 7, 2024. 16 Plf)NEER

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Pioneer will assess "Benefits to the Grid" on whether the proposed rate will reduce periods of high demand which constrain the grid.

The programs mentioned have a proven track record of providing benefits to the grid. Residential solar and storage helps reduce demand from the grid during high demand hours and residents can draw from their battery instead of the grid32 . Similarly, the Thule Ice Energy shifts energy use for air conditioning to low demand hours.

D. Benefits to Customers
Pioneer will assess "Benefits to Customers" on whether the proposed programs will result in lower costs to Pioneer customers.

E. Equity
Pioneer will assess "Equity" on whether the proposed program will disproportionately burden certain populations.

F. Conclusion - Hardware Programs
The LMS goals, articulate in § 1623 .1 (a)( 1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), these programs will achieve the aims of the LMS regulations in a consistently effective manner without leading to inequitable results. They are cost effective as they rely on proven technologies and do not require substantial staff time to implement.

COMMUNITY ENERGY
Finally, for the same rationale, these programs are equitable as lower income ratepayers can access the programs at little or no upfront cost.

The table has the name of the program, a brief description of the program, Pioneer staff's progress on the program, and the expected date of implementation:

Program Provider Program Description Progress Date of Implementation Pioneer would need to lncentivization based Under Development Second Quarter of 2025 issue an RFO for a program which pays
provider. Pioneer customers who
shift their energy usage
during peak demand
times.

Virtual Peaker Operates a Distributed Under Development Second Quarter of 2026 Energy Resource
Management System
(DERMS) platform.

This platform connects
with customers smart
devices to help shift
energy habits to low-cost hours.

Pioneer would need to EV Charging Under Development Fourth Quarter of 2024 issue an RFO for a Optimization.
provider.
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A. Cost Effectiveness
Pioneer will assess "Effectiveness" whether the program will consistently lead to the desired load shifting outcome. "Cost" will also be assessed based on the actual cost to Pioneer.

Studies show that incentive-based approaches effectively reduce peak load during heatwave events without harm to vulnerable groups33 . Notably, in a study of incentive-based demand response in China, researchers found that the repeated and frequent implementation of the program did not result in an attenuation of the effect34 . This demonstrates that incentive-based demand response can lead to consistent results in shifting energy usage.

B. Technological Feasibility
Pioneer will assess "Technological Feasibility" based on whether the requisite technology is commercial and not experimental or theoretical.

These programs have been shown to be technologically feasible in other CCA service areas35 .

C. Benefits to the Grid
Pioneer will assess "Benefits to the Grid" on whether the proposed programs will reduce periods of high demand which constrain the grid.

These programs will help shift load during peak load hours which in turn reduces strain on the grid. As seen in the previously mentioned study, incentive-based programs result in consistent load reduction 36. These load reductions, especially in periods of high demand, mean less price volatility and lowers the change of a brown out.
33 Wang, Lu, Want, Qiu, Zhang, Li, Li, and Zhao, Incentive based emergency demand response effectively reduces peak load during heatwave without harm to vulnerable groups, Nature Communications, Oct. 2023 34 fd.
35 https://sonomacleanpower.org/programs/gridsavvyrewards, last viewed March 7, 2024. 36 Wang, supra at note 34.
19 Plf)NEEA

COMMUNITY ENERGY
D. Benefits to Customers
Pioneer will assess "Benefits to Customers" on whether the proposed programs will result in lower costs to Pioneer customers.

E. Equity
Pioneer will assess "Equity" on whether the proposed program will disprop01iionately burden certain populations.

As mentioned above, studies show that these types of programs are more equitable than punitive based programs37 . Rather than risk losing money, they can instead earn money by changing their habits. A customer will not have to worry about a large bill due to factors outside their control (say a medically necessary reason to keep an air conditioner running). Because of this model, no population can be disproportionately burdened with the costs of shifting energy usage.

F. Conclusion - Incentive Based Program Paired with Software The LMS goals, articulate in § 1623 .1 ( a )(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), these programs will achieve the aims of the LMS regulations in a consistently effective manner without leading to inequitable results. They are cost effective as studies show incentive based cost shifting programs lead to consistent load shifting. The programs rely on commercially available technology which means they are technologically feasible. Studies show that these types of programs lead to consistent load shifting behavior which provides benefits to the grid. The programs are beneficial to customers as they are rewarded, rather than penalized for shifting their behavior. Finally, for the same reason, these programs are equitable as low-income individuals are able to avoid the risk of a catastrophic electricity bill.

III. Existing Government Programs
The table has the name of the government program, a brief description of the program, Pioneer staff's progress on the program, and the expected date of implementation:
37 Id.
20 Plf)NEEA

COMMUNITY ENERGY
Program Name Program Description Progress Date ofimplementation AgFIT The Flexible Irrigation Pioneer must submit an The Second Quarter of Pilot Program for Advice Letter stating 2025
Agriculture (AgFIT) their intent to
was successfully participate by March
piloted by Valley Clean 2025
Energy. The D.24-01-
032 ruling expanded
the program to all
agricultural customers
and allows all CCAs in
PG&E service territory
to participate until its
conclusion on
December 31 , 2027.

This program would be
administered by PG&E
and would use
automation technology
and/or a notice to shift
agriculture pumping
times.

ELRP A program Currently ongoing Set to expire December administered by the 31 , 2025
IOUs which pays
customers who
voluntarily reduce
electricity demand
during a grid
emergency. The
program also pays
customers who produce
energy during a grid
emergency under
certain conditions.

A. Cost Effectiveness
Pioneer will assess "Effectiveness" whether these programs consistently lead to the desired load shifting outcome. "Cost" will also be assessed based on the actual cost to Pioneer. 21 Plf)NEER

COMMUNITY ENERGY
These programs have been proven to be effective at shifting energy consumption to off-peak hours for irrigation. It is due to their effectiveness that CPUC expanded these programs38 . Since these programs are administered by the IOUs, they would be administered at no cost to Pioneer.

B. Technological Feasibility
Pioneer will assess "Technological Feasibility" based on whether the requisite technology is commercial and not experimental or theoretical.

Since these are programs that have already been piloted or are currently running, they have proven technological feasibility. Any requisite technology is commercially available.

C. Benefits to the Grid
Pioneer will assess "Benefits to the Grid" on whether the proposed programs will reduce periods of high demand which constrain the grid.

The AgFIT program shifts load to times of low demand which reduces strain on the grid. The ELRP is a more traditional demand response program but is incentive based rather than punitive.

Both are designed to reduce demand from the grid which helps stabilize prices and reduce the risk of brown out.

D. Benefits to Customers
Pioneer will assess "Benefits to Customers" on whether the proposed programs will result in lower costs to Pioneer customers.

Both of these programs provide benefits to customers as they reduce demand during peak periods. Reductions like help stabilize costs which in tum helps keep Pioneer rates low.

Furthermore, Pioneer customers that are part of the ELRP program are compensated for the reductions in energy usage, which in turn means they realize lower energy costs.

E. Equity
Pioneer will assess "Equity" on whether the proposed program will disproportionately burden certain populations.

Both of these programs are opt-in incentive based rather than punitive, fostering a more balance and fair outcome. This approach not only encourages compliance but also promotes a positive and cooperative relationship between customers and the LSE, leading to outcomes seen as fairer and more equitable. As mentioned previously, incentive-based programs lead to more equitable outcomes39 .
38 Staff Proposal on Existing Dynamic Rate Pilot Expansion, R.22-07-005, Aug. 15 , 2023 . 39 Wang, supra at note 34.
22 PIE~NEER

COMMUNITY ENERGY
F. Conclusion - Existing Government Programs
The LMS goals, articulate in § 1623 .1 ( a )(1) of the amended regulations, are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions. In weighing all the factors (Cost Effectiveness, Technological Feasibility, Benefits to the Grid, Benefits to Customers, and Equity), these programs will achieve the aims of the LMS regulations in a consistently effective manner without leading to inequitable results. These programs are cost effective as the CPUC has found them to be effective at consistently shifting load. They are also not administered by Pioneer, so cost is negligible. As they are existing programs, they are shown to be technologically feasible. The programs provide proven benefits to the grid by shifting load times away from peak periods. Since these are incentive based, they provide benefits to customers as they see a gain from shifting behavior rather than a penalty. Finally, for a similar rationale, they are incentive based so the programs do not lead to inequitable outcomes.

4.Summary
The amended LMS regulations require Pioneer to assess implementing a marginal cost-based rate, and if that implementation would result in the goals of the regulation. These goals are to encourage the use of electricity at off-peak hours, encouraging the control of daily and seasonal peak loads to improve electric system efficiency and reliability, lessening, or delaying the need for new electrical capacity, and reducing fossil fuel consumption and greenhouse gas emissions.

Program Provider Program DescriQtion Progress Date of
lmolementation
ParticiQate Energy Pioneer customers Pioneer (GridGen) Fourth Quarter of 2024 contract with ParticiQate launched in 2024.

Energy for leased home
solar and stora!!e oroducts Exoandedin
23 Plf)NEER

COMMUNITY ENERGY
with no UQfront costs and The Qrogram was Third Quarter of 2025 no credit check. ex12anded to offer
battery-only retrofits
Customers are aggregated and access for
into a virtual QOwer Qlant CARE/FERA
that shifts energy usage by customers.
charging the battery when
rates are lower (com12ared To date:
to self-generation} and • 6 com12leted installs
then uses QOWer from the • 11 customers
battery at higher-cost achieved 12ermission
hours. to OQerate (PTO}
• 87 customers in the
active oioeline
Demand Res12onse Incentivize-based Qrogram Program (PowerShift Third Quarter of 2024 that Qays customers who Rewards} launched fall
shift their energy usage 2024 and runs May
during times of 12eak through October.
demand/grid strain.

Customers receive an
incentive for enrolling
in the 12rogram and
additional incentives
for reducing energy
consum12tion during
times of 12eak demand
or when the grid is
strained.

To date, more than
1,400 customers are
enrolled, resulting in a

1.4 MWh energy
reduction.

PG&E The Hourly Flex Pricing Program launched in Fourth Quarter of 2024 Pilot Program, formerly late 2024, but the
known as AgFIT, was aQQlication 12eriod
successfully closed abruQtly in
Qiloted by Valley Clean W!.!1&.

Energy. The 0 .24-
0 I -03 2 ruling ex12anded AQQlications 12eriod
the Qrogram to all was reo12ened in SQring
agricultural customers and due to CCA concerns.
allows all CCAs in PG&E However, incentive
service territory to funding is limited and
12artici12ate until its likely will reach
conclusion on ca12aci!)' soon.

December 31, 2027. This
Qrogram uses Pioneer currently has
two customers with a
24 Plf)NEER

COMMUNITY ENERGY
automation technology combined 19 meters
and/or a notice to enrolled in the
shift agriculture 12um12ing Qrogram.
times.

Ice Energy Storage Pioneer customers install Program launched in Second Quarter of Ice Energy's technology to fil2!l!!£ 2025
the air conditioning unit at
low u12front costs. The • 22 Partici12ation
technology freezes water Agreements under
into ice during 12eriods of review
low energy demand, then o Roughly 130 units
uses the ice during 12eriods would be installed
of high demand to reduce • 35 site surveys
energy use by taking
12ressure off the condenser,
thereby using less energy_
Pioneer would issue EV Charging Under develo12ment Third Quarter of 2026 an RFO for a 12rovider OQtim ization/ Accessibil i!y
or 12artner with an
existing oroiect
(Updated September 2025)
n ··- n .. _ . ., n_ n. --· -- n __ -- n. -CT.--1 .• : -··· -~ .. -··· .... . --- - -· - PG&£ The HFP Pilot, Pioneer Board I<o1:1rth ~1:1arter o:f 2;()2 4 fermerly lrnown as a~~ro,,,ed ~rogram
Agl<I+, was
s1:1eeessfu I ly
~iloted ey Valle~' Glean
Energy. The 9.24
QI Qn rnling e*~anded
the ~rogram to all
agrie1:1lt1:1ral e1:1stomers
and allows all
GGAs in PG&B ser,,,iee
territOPi' to
~artiei~ate 1:1ntil its
eonel1:1sion on
9eeemeer ~I, 2Q2+.

This ~rogram wo1:1ld
ee administered ey
PG&B and wo1:1ld 1:1se
a1:1tomation teehnolog~'
and/or a Hotiee to
shift agrie1:1lt1:1re
-· -'.-- .. -~.

Partieipate Bnergy PioAer e1:1stomers Pioneer Board Seeond Q1:1arter o:f W2 4 eontraet with approved program
Partieipate Bnergy for
leased ho1:ne solar and
-- _, 'T't ·- -·- ,... ___ .., .... ---
25 Plf)NEEA

COMMUNITY ENEAGV
eHstomeFs aFe
aggFegated ittto a
,,,iFt1:1al poweF plattt. It
shifts eHeFg)' Hsage by
ehaFgittg the batte~'
whett times aFe
eheapest EeompaFeEI to
self getteratiott1 attEI
theR Hses poweF fFom
the battery at high eost
OOtlfS-;-
ThHle Ettergy Storage PiotteeF el:lstomeFs UttdeF Developmettt Seeottd QHaFteF of 2025 iHstall +hHle's
pF013rietary teehttolegy
iA liAe with the aiF
eeAElitioAiAg system at
Jew HpfFoHt eest to the
e1:1stomeF. +his
teehttelegy freezes
water iAte iee dHriAg
perieds ef 10'1,' demaAd
aAd theH thaws the iee
as 13art of the aiF
eottElitiottittg system
EIHring 13eriods of high
de1flaRd.

PiotteeF wo1:1ld Heed to IAeeAfrvizatioH based UttdeF Developmettt SeeoHd QHaFter of 2025 iss1:1e an RFO fur a pFOgra1fl whieh pays
pFOvider. PioAeer eHstomers who
shift tlleiF ettergy Hsage
EIHriRg peak demattd
times-:

ViFtl:lal Peaker Operates a DistFibHted UttEler Developmettt Seeettd QHaFter ef 2026 EneFg)' R:esol:lree
MaAagemeRt S)'Stem
(DeR:MS1 platfurlfl.
+llis platfurm eonneets
,,,i'ith el:lsto1flers s1f1aft
deviees to llelp shift
eAergy habits to low
eost hoHrs.

PiotteeF 'NOHld tteeEI to EV GhargiHg Under Development FoHFth QHaFter of 2024 issl:le aR R:FO fuF a Optim izatioR. ·,..1-- ..,.~ ~-- .

Finally, Pioneer has been working with the other load serving entities (LSEs) on creating the statewide RIN tool pursuant to 20 CCR Section 1623(c). A proposed plan for the tool was submitted to the CEC for review on October 1, 2024. Pioneer will continue to work with the other LSEs and the CEC to implement and maintain the statewide RIN tool in a timely manner subject to the tool's approval by the CEC.
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COMMUNITY ENERGY
27

Page 1 of 1 ends

Staff Report – Item 1e
To: The Governing Board
From: Brad Koehn, Director of Finance and Administration Item 1e: Adopt Resolution to Authorize the Chief Executive Officer to Execute an Amendment to the Agreement with Braun Blaising & Wynne, P.C. to Amend Hourly Rates Date: 9/18/2025

RECOMMENDATION
Adopt resolution to authorize the Chief Executive Officer to execute an amendment to the agreement with Braun Blaising & Wynne, P.C. to amend hourly rates.

BACKGROUND
On June 17, 2021, the Governing Board authorized the Chief Executive Officer to execute a third agreement with Braun Blaising & Wynne, P.C. (formerly Braun Blaising Smith & Wynne, P.C.) (“BB&W”) for legal regulatory support for Pioneer Community Energy (“Pioneer”), ensuring continuation of BB&W’s services to Pioneer since 2019.

BB&W monitors numerous California Public Utilities Commission (“CPUC”) proceedings for issues of interest to Pioneer including the Power Charge Indifference Adjustment, Public Safety Power Shut-offs, Microgrids, and Net Energy Metering/Solar Billing Plan. BB&W prepares comments and related filings on behalf of Pioneer in these proceedings and also helps prepare most of Pioneer’s more complex regulatory compliance filings, such as for Integrated Resource Planning and Renewables Portfolio Standards.

Pioneer’s costs are reduced where possible through joint filings with other community choice aggregators on the same proceedings.

ANALYSIS & DISCUSSION
Pioneer’s proposed amendment to the existing agreement with BB&W will allow BB&W to (1) update its hourly rates, and (2) undergo annual review of its hourly rates. These amendments will ensure that Pioneer continues to receive essential legal regulatory support from BB&W while not requiring any budgetary adjustment.

STRATEGIC PLAN
The recommendation supports the Strategic Goal to “Achieve Operational Optimization."

FISCAL IMPACT
The cost of the legal regulatory services provided by the firm will vary based on Pioneer’s needs but is expected to not exceed $140,000 for Fiscal Year 2025-26 and does not require any budgetary adjustment.

ATTACHMENTS

1. Resolution to Authorize the Chief Executive Officer to Execute an Amendment to the Agreement with Braun Blaising & Wynne, P.C. to Amend Hourly Rates

2. Original Agreement between Pioneer and Braun Blaising & Wynne, P.C.

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 September 18, 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, Braun Blaising & Wynne, P.C. (formerly Braun Blaising Smith & Wynne, P.C.) (“BB&W”) have been providing key legal regulatory support services to Pioneer Community Energy (“Pioneer”) since 2019 related to various California Public Utilities Commission (“CPUC”) proceedings and compliance filings; and
WHEREAS, Pioneer and BB&W entered into a Consultant Services Agreement for legal regulatory services on June 17, 2021 (“Original Agreement”), wherein BB&W agreed to provide legal counsel services to Pioneer, with compensation not-to-exceed $140,000 each fiscal year; and
WHEREAS, Pioneer and BB&W desire to amend the Original Agreement to allow for the amendment of hourly rates to ensure continuance of key legal regulatory services.

In the matter of: RESOLUTION TO AUTHORIZE

THE CHIEF EXECUTIVE OFFICER TO EXECUTE AN

AMENDMENT TO THE AGREEMENT WITH BRAUN
BLAISING & WYNNE, P.C. TO AMEND HOURLY
RATES
Resolution 2025-__
September 18, 2025
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 authorizes the Chief Executive Officer to execute the First Amendment to the Consultant Services Agreement with Braun Blaising & Wynne, P.C., as attached hereto as Exhibit “A”, and on behalf of Pioneer Community Energy, with any minor clerical or clarifying changes proposed by the Chief Executive Officer and General Counsel.

3. This resolution shall take effect immediately upon its adoption.

Exhibit A: First Amendment to Consultant Services Agreement with Braun Blaising & Wynne.

Administering Agency: Pioneer Community Energy
Contract Description: Regulatory and Legal Services

CONSULTANT SERVICES AGREEMENT
AMENDMENT NO. 1
THIS AGREEMENT, originally executed June 17, 2021, by and between the Pioneer Community Energy (“Pioneer”), and Braun Blaising & Wynne, P.C. (formerly Braun Blaising Smith & Wynne) (“Consultant”), is hereby amended with an effective date of September 1, 2025 as described below:
• Section 3 “Fees and Description of Services,” is amended as follows:
(a) Individual Client Services: For services provided under this Agreement directly to the Client, as requested and authorized by the Client, the Client shall pay the Firm in accordance with the following hourly rates for the following categories:

Shareholder: $525
Senior Attorney: $410
Senior Associate: $395
Junior Associate: $350
Law Clerk: $195
Administrative Support: $140
(d) Hourly Rates: All office, research, travel and meeting time shall be billed at the hourly rates set forth above; provided, however, travel time shall be billed at 50% of actual time.

The hourly rates for services provided under this Agreement are reviewed annually by the firm on or about June 1, are subject to adjustment no less than 30 days written notice.

Unless expressly amended in this Amendment, all provisions, conditions, covenants, and terms of the Consultant Services Agreement shall remain in full force and effect.

Executed as of the last date indicated below:

PIONEER COMMUNITY ENERGY
By:_____________________________ Date: ______________
Name: Donald Eckert
Title: Chief Executive Officer
By:_____________________________ Date: ______________
Name: David Ruderman
Title: General Counsel
BRAUN BLAISING & WYNNE, P.C.

By:_____________________________ Date: ______________
Name: Scott Blaising
Title: Principal/Shareholder
Third Legal Services Agreement
This Third Legal Services Agreement (Agreement) is entered into by and between Pioneer Community Energy, a California joint powers authority (Client), and Braun Blaising Smith Wynne, P.C., a California professional corporation (Firm). The Firm and the Client shall be collectively referred to herein as the Parties.

A. The Firm provides regulatory and legal services related to, among other things, rates, rules, policies and regulations affecting Community Choice Aggregation (CCA) programs.

B. The Parties entered into a legal services agreement, dated January 11, 2018, as amended on May 13, 2019 (First Agreement), by which the Firm began providing legal and regulatory services in support of the Client's CCA program, including the provision of certain joint services provided by the Firm to the Client and other CCA clients (CCA Group). The Parties entered into the Second Legal Services Agreement on August 20, 2019, as amended on April 9, 2020, which replaced the First Agreement.

C. The Parties are interested in entering into this Agreement to replace the Second Agreement and to set forth the terms and conditions, and budgetary limitations, associated with the Firm's continuing provision of legal and regulatory services. - Agreement -
The Parties agree as follows:

I. Term and Termination. This Agreement shall be effective as of June 17, 2021, and shall continue in effect until terminated, as described below. For the avoidance of doubt, it is the intention of the Parties that this Agreement shall succeed and replace services provided under the Second Agreement, such that there is no lapse in services provided by the Firm to the Client.

This Agreement shall authorize payment of any agreed-upon services performed since the expiration of the Second Agreement on April 9, 2021 and prior to the effective date of this Agreement. Either Party may terminate this Agreement by providing no less than 30 days written notice.

2. General Scope of Services. The Firm shall provide (a) regulatory and legal services, as directed and authorized by the Client, in support of the Client's CCA program, as described further in Section 3(a), (b) joint representation of Client and other participants in the CCA Group on matters before California regulatory agencies, as described further in Section 3(b), and (c) joint reporting services provided by the Firm to the Client and to the CCA Group, as described further in Section 3(c).

3. Fees and Description of Services.
(a) Individual Client Services: For services provided under this Agreement directly to the Client, as requested and authorized by the Client, the Client shall pay the Firm in accordance with the following hourly rates for the following categories:
1 Senior Shareholders:

Junior Shareholders:

Senior Associates:

Junior Associates:

Paralegal/ Law Clerk:

Administrative Assistant:
$420
$360
$310
$275
$165
$60
(b) Joint Representation: As authorized by the Client and other clients in the Firm's CCA Group, the Firm shall provide joint representation on various regulatory matters at the California Public Utilities Commission (CPUC). The Client's share of such joint services shall generally be its pro-rata share based on the number of participating CCA's, but in any event shall be described to and authorized by the Client in writing. Costs associated with joint representation shall generally be setup as a separate matter in the Firm's accounting system.

Further information regarding joint representation is described in Section 8. (c) Regulatory Reports and Summaries: The Firm provides a variety of regulatory reporting services. On a fixed-fee basis, the Firm shall continue to provide regulatory reports on the same basis as provided under the First Agreement and Second Agreement, namely (I) a bi-weekly, comprehensive regulatory report, (2) alternate week email regulatory bulletins, (3) agenda summaries of energy-related items on the CPUC's meeting agenda and (4) an email report on the outcome of energy-related items on the CPU C's meeting agenda. The current monthly fee for this service is $1,750 but may be adjusted upward or downward based on mutual written agreement of the Parties. In addition to these regulatory reports, the Firm also provides regulatory summaries of issues and activities of interest to the CCA Group. The cost of this service will be shared on a pro-rata basis among participating clients. At any time, upon written notice from the Client, the Client may suspend or modify the scope of either the regulatory reports or the regulatory summaries.
( d) Hourly Rates: All office, research, travel and meeting time shall be billed at the hourly rates set forth above; provided, however, travel time shall be billed at 50% of actual time.
(e) Not to Exceed Budget: The total amount of charges under this Agreement shall not exceed $140,000 on a fiscal year-basis (namely, from July through June), without the express written consent of the Client.
(f) Other Attorney(s): As needed and as authorized by the Client in writing, the Firm may contract with other attorney(s) to provide services under the guidance and direction of the Firm's assigned attorney (Scott Blaising). The Firm will provide advance notice to the Client of the hourly rates for attorneys with whom the Firm has contracted for services provided under this Agreement. The Client will be billed at the specified hourly rate for the contract attorney(s) regardless of the amount of charge to the Firm for services provided by the contract attorney(s).
(g) Other Providers: As needed and as authorized by the Client in writing, the Firm may contract with electric industry professionals (e.g., rate consultants, etc.) (Other 2 Provider(s)) in order to perform Client-directed tasks. In the event that such tasks are authorized and the Client wishes the Firm to pay Other Providers on the Client's behalf, the Client and the Firm will agree on a reasonable administrative fee for consolidated billing, not to exceed 10%.

4. Costs and Expenses. In addition to the fees set forth above, the Client shall reimburse the Firm for all pre-approved out-of-pocket costs and expenses actually incurred by the Firm in connection with the legal services provided by the Firm. Out-of-pocket costs and expenses include, but are not necessarily limited to, travel expenses, and reproduction and postage costs associated with representation of the Client in regulatory or other legal proceedings. Reproduction and postage costs otherwise incurred in the normal course of business are considered Firm overhead and will not directly be charged to the Client.

5. Billing and Payment. The Firm shall provide monthly invoices to the Client for all fees and expenses. The invoice shall be itemized to include, at a minimum, the time spent by each service provider, the total time spent by each service provider, a description of services performed, and a description and itemization of costs and expenses. The Finn shall bill the Client in minimum increments of 1/1 oth of an hour. Invoices shall be considered due and payable upon receipt, and shall be overdue after 30 days ofreceipt.

6. Notices. All notices, invoices, reports or other communication required herein shall be properly given if delivered via electronic mail, or other mutually acceptable means, to the following addresses:

Client:

Firm:

Pioneer Community Energy
Attention: Sam Kang
[email protected]
Braun Blaising Smith Wynne, P.C.

Attention: Scott Blaising
[email protected]

7. Independent Contractor. The Firm is and shall be considered an independent contractor with respect to the performance of services under this Agreement.

8. Joint Representation and Conflict Waiver.
(a) The Firm currently represents several clients that have operational CCA programs. The Firm also represents the California Community Choice Association, an association ofCCA programs. (See Exhibit A, which reflects the Firm's current list of clients.) Together with the Client, these CCA clients shall be referred to below as "CCA Clients." The Firm anticipates that it will from time to time provide joint representation of the CCA Clients before the CPUC, whether directly or indirectly through a coalition or other organizational structure. This section generally describes the contemplated joint representation and requests written consent to the Firm's joint representation. This section also describes potential conflicts and requests written consent to the Firm's continuing representation in such circumstances. 3 (b) The Firm does not believe that the Firm's joint representation of the CCA Clients presently involves any actual conflicts of interest. The Client should be aware, however, that such representation may involve potential conflicts and that the interests and objectives of each of the participants individually on certain issues may, at some time in the future, become inconsistent with the interests and objectives of the other participants. The Firm's joint representation has implications, which the Client should consider. For example, rather than vigorously asserting a single participant's interest on an issue, it is likely that the Firm will balance interests between the participants represented. Because individual participants may have different talents, energy, personal goals, and financial resources, sole representation of one participant could result in more aggressive advocacy, and hence more favorable treatment, for that participant compared to the more even-handed approach the Firm may follow in representing multiple interests. Joint representation may also result in the loss of the attorney-client privilege for communications between you and members of the Firm, because anything disclosed by one participant on a matter of common interest could be disclosed to a jointly represented client in a civil proceeding between the two participants. (c) The Firm will make every effort during the course of joint representation to confirm that the participants continue to have a commonality of interest in connection with the positions asserted. If interests diverge during the course of joint representation, further disclosure and waiver of the conflict, or withdrawal from representation, could be necessary. (d) In addition to the joint representation described above, the Firm also represents numerous public agencies in California on diverse matters of energy law and regulation. Therefore, it is possible that, while the Firm is representing the Client, certain types of conflicts may arise in matters unrelated to the present engagement for which the Firm requests the Client's consent and waiver now. Present or future clients, including clients who rely upon the Firm for general representation, may ask the Firm to represent them in transactions or litigation adverse to the Client. The Firm would decline the other representation if the Firm believes there is a risk of misuse of the Client's confidential information. (e) By signing this Agreement, the Client confirms (i) that the Client has been informed as to the nature of potential conflicts that may arise as a result of the Firm's joint representation and the Firm's representation of other clients; (ii) that the Client has been provided a reasonable opportunity to seek the advice of independent counsel regarding potential conflicts and waiver thereof; (iii) that the Client understands an actual conflict may arise in the future that would require an additional disclosure and waiver, or, alternatively, withdrawal by the Firm; (iv) that the Client agrees that the Firm may represent other clients as described herein, including clients in unrelated matters adverse to the Client; and (v) that the Client hereby waives any claim of conflict of interest arising from such representation.

9. Insurance
(a) Malpractice Insurance. Without limiting the provisions of this Agreement relating to indemnification and defense, the Firm, at its expense, shall maintain in full force and effect during the period of performance of this Agreement and for three years thereafter, professional malpractice insurance that covers the services provided pursuant to this Agreement in the amount of not less than $1,000,000, with an insurance carrier authorized to do business in California.
4 (b) Other Insurance. The Firm, at its expense, shall also maintain during the period of performance of this Agreement and for three years thereafter, insurance as follows:
(I) General liability: (with coverage at least as broad as ISO form CG 00 01 10 01) coverage in an amount not less than $2,000,000 general aggregate and $1,000,000 per occurrence for general liability, bodily injury, personal in jury, and property damage.
(2) Automobile liability: (with coverage at least as broad as ISO form CA 00 01 10 01, for "any auto") coverage in an amount not less than $1,000,000 per accident for personal injury, including death, and property damage.
(3) Workers' compensation and employer's liability: coverage shall comply with the laws of the State of California.
(c) Primary. The Firm's insurance is primary to any other insurance available to the Client with respect to any claim arising out of this Agreement. Any insurance maintained by the Client shall be excess of the Firm's insurance and shall not contribute with it.

The Firm's endorsement of insurance shall include a waiver of any rights of subrogation against the Client, and its directors, officers, employees and agents. ( d) Indemnification. To the fullest extent permitted by applicable law, the Firm shall indemnify, defend, and hold harmless the Client and its members, officers, officials, agents, employees and volunteers from and against any and all liabilities, claims, actions, causes of action, demands, damages and losses whatsoever against any of them, including any injury to or death of any person or damage to property or other liability of any nature, whether physical, emotional, consequential or otherwise, arising out of or related to the negligence or willful misconduct of the Firm or the Firm's employees, officers, officials, agents or independent contractors in the performance of this Agreement. Such costs and expenses shall include reasonable attorneys' fees of counsel of the Client's choice, expert fees and all other costs and fees of litigation. The acceptance of the services provided under this Agreement by the Client shall not operate as a waiver of the right of indemnification. The provisions of this section shall survive the completion of the services or termination of this Agreement.

10. Miscellaneons.
(a) This Agreement shall be governed by and construed and enforced in accordance with the laws of the State of California, exclusive ofconflict oflaws provisions. (b) This Agreement constitutes the entire agreement between the Parties concerning the subject matter hereof.
(c) This Agreement may not be modified or amended without the express written agreement of the Parties.
5 ( d) This Agreement may be executed in any number of counterparts, including through facsimile signatures, and upon execution by the Parties, each executed counterpart shall have the same force and effect as an original document and as if the Firm and the Client had signed the same document. Any signature page of this Agreement may be detached from any counterpart of this Agreement without impairing the legal effect of any signatures thereon, and may be attached to another counterpart of this Agreement identical in form but having attached to it one or more signature pages. (e) This Agreement may be scanned and stored in electronic format. Neither Party shall object to the admissibility of an electronic version of this Agreement on the basis that such was not originated or maintained in documentary form.

11. Signature. In witness whereof, the Parties have caused this Agreement to be executed by their duly authorized representatives.

Client
Title: Executive Director
Approved as to form:
~~~ Grego~. Stepanicich
General Counsel
6 Firm
Scott Blaising
Title: Principal/Shareholder
Date: June 4, 2021
Exhibit A
Representative List of Clients
Braun Blaising Smith Wynne, P.C.
(April 2021)
Balancing Authority of Northern California (BANC)
California Choice Energy Authority (Ca/Choice)
Cities of Commerce, Lancaster, Pico Rivera, Palmdale, Pomona, Rancho Mirage, San Jacinto, and Santa Barbara
California Community Choice Association (CalCCA}
California Community Power
California Municipal Utilities Association (CMUA)
Central Coast Community Energy
Clean Power Alliance of Southern California
City of Cerritos
City of Colton
City of Corona
East Bay Community Energy
Eastside Power Authority
City of Escondido
Friant Power Authority
City oflndio
Kirkwood Meadows Public Utilities District
Lamb Energy (City of Coachella)
Lathrop Irrigation District
City of Los Angeles, Department of Water and Power
Marin Clean Energy
Merced Irrigation District.

Minter Field Airport District
City of Moreno Valley
City of Needles
Orange Cove Irrigation District
City of Pasadena
City of Pittsburg (Pittsburg Power Company)
Peninsula Clean Energy Authority
Pioneer Community Energy
Port of Stockton
Power and Water Resources Pooling Authority (PWRPA)
City of Rancho Cucamonga
City of Redding
Redwood Coast Energy Authority
City of Roseville
Sacramento Municipal Utility District (SMUD)
Salt River Project
San Diego Community Power
Seattle City Light
City of San Jose
City of Shasta Lake
Silicon Valley Clean Energy
Sonoma Clean Power Authority
Southern California Public Power Authority
Turlock Irrigation District
City of Victorville

Page 1 of 4 ends

Staff Report – Item 2
To: The Governing Board
From: Lee Ewing, Legislative and Regulatory Affairs Manager Item 2: Review of the PCIA
Date: 9/18/2025

RECOMMENDATION
Receive an overview of the current state of the PCIA, or Power Charge Indifference Adjustment, including an overview of its purpose and calculation, anticipated changes to PCIA rates in 2026, and Pioneer advocacy efforts.

BACKGROUND
The PCIA is a fee charged by investor-owned utilities (IOUs) in California to all customers, including those who receive generation service from a Community Choice Aggregator (CCA) or Electric Service Provider (ESP). In the past, the PCIA has been known as an “exit fee” but this is a misnomer. The PCIA recovers the IOUs’ above-market costs for power contracts or resources that were acquired prior to a customer’s departure from an alternative energy provider. Generation customers of Pioneer receive a PCIA rate from PG&E that is intended to recover the above-market costs for generation procured by PG&E on behalf of those customers before they departed the IOU’s generation service.

ANALYSIS & DISCUSSION
PG&E’s PCIA is set annually in its Energy Resource Recovery Account (ERRA) forecast proceedings (ERRA Forecast). The PCIA includes above-market costs related to power supply commitments that the IOUs made many years ago. Above-market means the cost of the resource is higher than the value of that resource in the market. These resources include Utility-Owned Generation (UOG) (e.g., nuclear, natural gas, hydroelectric plants) and long-term renewable energy contracts with third parties.

The PCIA is intended to leave all customers indifferent to customers departing for CCA service or other alternatives. Customers are assigned “vintages” based on the year they moved to CCA service and are responsible for the above-market costs incurred on their behalf before they switched service. Bundled customers, or customers who take up both generation and transmission and distribution (T&D) services from an IOU, are always assigned the current year as their vintage.

The PCIA is established every year in the ERRA Forecast proceeding for the following rate year (i.e., the 2025 ERRA Forecast proceeding will establish the 2026 PCIA rates). The PCIA is comprised of both (1) the utility’s forecasted indifference amount for the next year and (2) a true-up to reconcile the current year’s PCIA revenue collection with actual generation costs and revenues. The true-up mechanism and yearly cadence of proceedings are intended to ensure that the PCIA revenue collection matches the actual above-market costs of the PCIA resources as much as possible.

The indifference amount component of the PCIA is the difference in the target year between the cost of the IOU’s supply portfolio and the market value of the portfolio.

Agenda Item: 2 Agenda Date: 9/18/2025

Page 2 of 4 ends

A low indifference amount and subsequent PCIA savings can result from either the cost of the portfolio going down or the value going up. The portfolio value is calculated using Market Price Benchmarks (MPBs) for resource adequacy (RA), renewable portfolio standard (RPS), and energy attributes, which have experienced extreme variability in recent years. In determining the PCIA rates for 2026 in the current ERRA Forecast proceeding, an indifference amount will be forecasted for 2026 and recalculated for 2025 to true up PG&E’s PCIA revenue requirement.

Bundled customers are required to pay the market value of RA and RPS attributes retained by the IOU to meet bundled customer compliance requirements. That payment for the market value of resource attributes is credited to the PCIA. When the current market value of IOU power portfolios is lower than what the utility originally paid, the PCIA goes positive, and departed customers pay their share of the difference. If the value of IOU portfolios is higher than what the utility originally paid, the PCIA goes negative, and departed customers receive a share of the credit.

Over the past decade, CCA customers have experienced dramatic increases in the PCIA to the tune of hundreds of millions of dollars as the market value of IOU resources declined. More recently, in 2024 and 2025, IOU portfolio values increased and even overtook portfolio costs. As market value increased, IOU bundled customers were hit with significant generation rate increases to provide the value back to departed customers who were owed.

Agenda Item: 2 Agenda Date: 9/18/2025

Page 3 of 4 ends

In recent years, the indifference amount has not only varied from positive to negative but also changed significantly in total magnitude, from over $2.5 billion to a few hundred million in PG&E’s case, as shown in the “PG&E Indifference Amount Revenue Requirement” graph above. These dramatic swings in the PCIA have led the California Public Utilities Commission (CPUC) to reconsider the current PCIA methodology.

THE PCIA IN 2026
Contrary to the recent trend, the PCIA rate is expected to increase significantly in 2026 due, in large part, conditions in the market for RA, RPS, and energy attributes. Both the realized and forecasted values of these attributes have decreased since last year, leading to a decrease in the PCIA portfolio market value that will increase both the indifference amount forecasted for 2026 and the true-up of the 2025 revenue requirement.

There will also be a corresponding decrease to PG&E’s bundled generation rates because of the reduced market prices, further narrowing Pioneer’s competitiveness with PG&E’s bundled generation rates.

While the market conditions that are anticipated to drive the increase the PCIA in 2026 are not directly attributable to regulators, certain actions by the CPUC have exacerbated the upward pressure. In particular, the CPUC changed the way it calculates the value of RA attributes for PCIA resources in reaction to historically low PCIA rates in 2025 caused, in part, by high 2024 RA market prices. The CPUC now values RA using up to four years of historical transactions (as opposed to the prior one-to-two-year transaction period), diluting the impact of any single year. Most concerning is that the CPUC plans to apply the new methodology to the true-up of the 2025 revenue requirement, increasing the 2025 PCIA true-up that will be collected through 2026 PCIA rates.

PCIA ADVOCACY
Currently, there are several open CPUC proceedings that will have an impact on future PCIA rates. First, as indicated above, PG&E filed its 2026 ERRA Forecast application in May and a decision on the application is anticipated in mid-December. This case will determine both the 2026 forecasted indifference amount and the true-up of 2025 PCIA rates, which together comprise the 2026 PCIA rates. While market conditions will put upward pressure on PCIA rates in 2026, through CalCCA, we are contesting several issues identified in PG&E’s application that could help mitigate this impact. For example, PG&E is proposing to effectively apply zero value for the RA attributes of the battery storage resources in its PCIA portfolio. Again, the value of RA attributes for these resources is included in the overall portfolio market value to offset PCIA resource costs, lowering the PCIA Agenda Item: 2 Agenda Date: 9/18/2025

Page 4 of 4 ends

rates. If CalCCA can convince the CPUC to reject PG&E’s proposal, it could lower the 2026 revenue requirement to be collected through PCIA rates by over $450 million.

Second, PG&E also submits annual ERRA Compliance applications, which are a review of its prior years generation activities and bookkeeping for compliance and accuracy. Unlike the ERRA Forecast, the ERRA Compliance proceedings can take years to complete and do not typically generate the same level of controversy or raise issues with the same level of monetary impact on the PCIA. However, CalCCA’s review of PG&E’s ERRA Compliance applications frequently identifies errors and occasional activities that are not in compliance with Commission decisions or rules, which, if corrected, will lower PCIA rates or improve transparency into PG&E’s practices regarding the PCIA. The proceeding for PG&E’s 2024 ERRA compliance activities is currently underway and CalCCA has already identified several errors in PG&E’s application that will benefit Pioneer customers.

Finally, the CPUC opened a rulemaking in February 2025 to consider structural changes to the PCIA. The CPUC bifurcated the rulemaking into two tracks, the first an expedited proceeding to address the RA valuation changes identified above. This first track was expedited with the explicit intent to apply to changes to the 2025 true-up, which, as explained above, will increase the 2026 PCIA rates. The CPUC issued a Final Decision on track one in June 2025. Although disappointing, CCA advocacy in track one limited the historical period for capturing RA transactions, thereby limiting the reduction to the RA valuation of the CPUC’s changes. CalCCA has requested that the CPUC reconsider applying these methodology changes to the 2025 true-up, but it is not expected that the CPUC will grant this request.

The second track will be a more wholistic review of the PCIA framework with the goals of improving utility ERRA cost forecasting, mitigating rate volatility, and ensuring indifference among bundled and departed customers.

The second track is expected to begin in early 2026 and is scheduled to proceed into early 2028. Pioneer is currently working with CalCCA and other CCAs to develop proposals to raise in Track 2 and we will have to fight proposals raised by other parties to proceed with the proceeding, including the IOUs. Proposals currently under consideration by CCAs range from the dramatic (rethinking the PCIA structure) to the minutiae (tweaks to current the framework), but each comes with its own advantages and disadvantages from both a PCIA impact and strategic perspective.

STRATEGIC PLAN
The recommendation supports the Be Fiscally Strong & Resilient goal.

FISCAL IMPACT
There is no fiscal impact from the recommendation.

ATTACHMENTS
There are no attachments to the report.

Page 1 of 2 ends

Staff Report – Item 3
To: The Governing Board
From: Gina Stassi-Vanacore, Director of Communications
Item 3: Adopt a Resolution to Allow for the Chief Executive Officer to Initiate the Expansion Process to Allow for the Addition of Unincorporated Madera County and the Cities of Colusa, Madera, and Chowchilla
Date: 9/18/2025

RECOMMENDATION
Adopt a Resolution to allow for the Chief Executive Officer to initiate the expansion process to allow for the addition of Unincorporated Madera County and the Cities of Colusa, Madera, and Chowchilla.

EXPANSION COMMITTEE RECOMMENDATION
At the July 9, 2025, Expansion Committee meeting, the Committee received a presentation by staff about the ongoing interest of several like-minded communities in joining Pioneer Community Energy (“Pioneer”). The Committee recommended Board approval of limited expansion of the October 2027 service launch, provided that doing so is financially and strategically prudent.

BACKGROUND
On June 9, 2025, the California Public Utilities Commission (“CPUC”) certified Addendum No. 3 to the Pioneer’s Community Choice Implementation Plan and Statement of Intent (“Implementation Plan”) for an October 2027 expansion into 13 new territories (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).

Since that time, several other communities have reached out to Pioneer to express interest in joining Pioneer.

These communities include Colusa County (and the cities of Colusa and Williams), Madera County, Amador County, Shasta County, Lassen County, and Plumas County.

Staff has conducted informational briefings with staff and some elected officials in each of the communities.

Staff also communicated that any additional expansion above and beyond what already has been approved by the CPUC must be approved first by the Pioneer Governing Board.

ANALYSIS & DISCUSSION
Staff have found varying degrees of readiness among interested territories. For example, the City of Colusa has a strong desire to join Pioneer and already has provided access to PG&E data to conduct an Impact Assessment Study. The County of Madera, with support from its Economic Development Commission, also has expressed a strong interest in joining, with a desire to have the incorporated cities within Madera County (Madera and Chowchilla) join Pioneer at the same time. Others like Lassen, Plumas, Shasta,and Amador Counties are still in a fact-finding and research phase.

Among the primary considerations for the Board related to expansion are 1) does expansion make financial sense for Pioneer and its customers, and 2) ensuring sufficient power resources to serve the expansion.

As part of the expansion process and as standard practice, Pioneer would co-commission with each of the expansion territories an Impact Assessment Study. The study will evaluate projected costs compared to current Plf)NEER

COMMUNITY ENERGY
Agenda Item: 3 Agenda Date: 9/18/2025

Page 2 of 2 ends

rates to ensure existing ratepayers are not subsidizing future ratepayers. The study is the first step in the expansion process.

Relative to sufficient power resources, it should be noted that during the 2024 expansion effort, staff issued a Request for Offers (“RFO”) for energy, resource adequacy, and renewable energy credits to ensure Pioneer could procure the needed capacity to serve the expanded load. Subsequently, staff has completed several Power Purchase Agreements (PPAs) and is confident the resources will be available for additional expansion in October 2027.

Time is of the Essence
To include these four communities in the October 2027 launch, an Addendum to Pioneer’s Implementation Plan and Statement of Intent and Amendment to Pioneer’s Joint Exercise of Powers Agreement must be adopted by the Board and submitted to the CPUC before the end of the year.

No Obligation
Board approval of the recommendation does not commit either Pioneer or potential new members to expansion.

STRATEGIC PLAN
The report supports the strategic priority to “Be Fiscally Strong & Resilient.”

FISCAL IMPACT
Pioneer, along with new member applicants, will conduct an Impact Assessment Study to determine the financial feasibility of proposed expansion. The maximum fiscal impact would be $60,000.

ATTACHMENTS

1. Adopt a Resolution to allow for the Chief Executive Officer to initiate the expansion process to allow for the addition of Unincorporated Madera County and the Cities of Colusa, Madera, and Chowchilla.

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 September 18, 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, Pioneer Community Energy has the authority to aggregate electric load to purchase and supply electricity for customers within its jurisdiction; and WHEREAS, Unincorporated Madera County, the Cities of Colusa, Madera, and Chowchilla have expressed an interest in joining Pioneer Community Energy; and WHEREAS, the Governing Board will consider expansion of Pioneer Community Energy’s service territory only when it is financially and strategically prudent; and WHEREAS, the initiation of the expansion process does not bind Pioneer Community Energy to expansion of its service territory.

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 authorizes the Chief Executive Officer to initiate the expansion process to allow for the expansion of the Cities of Colusa, Madera, and Chowchilla and Unincorporated Madera County.

3. This Resolution shall take effect immediately upon its adoption.

In the matter of: ADOPT A RESOLUTION TO ALLOW

FOR THE CHIEF EXECUTIVE OFFICER TO INITIATE

THE EXPANSION PROCESS TO ALLOW FOR THE

ADDITION OF UNINCORPORATED MADERA COUNTY

AND THE CITIES OF COLUSA, MADERA, AND
CHOWCHILLA.
379324.1 Page 1 of 3
Staff Report – Item 4
To: The Governing Board
From: Brad Koehn, Director of Finance and Administration Item 4: Adopt Resolution to Approve an Update to the Net Energy Metering (NEM) Policy Date: 9/18/2025

RECOMMENDATION
Adopt Resolution to Approve an Update to the Net Energy Metering (NEM) Policy

BACKGROUND
Pioneer adopted a Net Energy Metering (NEM) Policy April 2018 and updated the Policy May 2018. This Policy governs Pioneer’s process for the NEM customers whose interconnection applications received and processed by Pacific Gas and Electric (‘PG&E’) before April 15, 2023. Customers with these solar installations are frequently referred to as NEM 1.0 or NEM 2.0 (NEM) customers.

The California Public Utilities Commission (“CPUC”) directed the Investor-Owned Utilities (“IOU’s”), including PG&E, to implement a new billing structure for renewable system interconnection applications (i.e., solar, wind, fuel cells) received on and after April 15, 2023. The implementation CPUC direction, referred to as the Solar Billing Plan (“SBP” SBP also may be referred to as Net Billing Tariff, “NBT” or “NEM 3.0”). The SBP modified the ‘netting’ aspect of a customer’s generation and usage which resulted in an increased ‘pay back’ time for new solar only installations but increased the customer benefit (comparatively) for solar + battery installations. To retain customers that would be automatically enrolled in PG&E’s SBP, Pioneer adopted its own Solar Billing Plan Policy to offer customers a SBP choice. NEM customers, as their energy contracts end (typically 20 years after installation), will transition to SBP.

The proposed NEM policy update is separate from Pioneer’s SBP policy and is only applicable to customers enrolled as NEM 1.0 and NEM 2.0 customers.

The updates to the NEM policy are intended to remove unnecessary text, improve clarity, and ease the administration of the NEM program which should minimize processing errors.

ANALYSIS & DISCUSSION
Besides removing unnecessary text and improved clarity there are other components of the NEM Policy that have been updated. Those components or Policy changes are discussed below.

Net Surplus Compensation (NSC)
The NSC rate is a 12-month rolling average of the ‘wholesale’ energy rate and is calculated monthly by PG&E. Pioneer adds half a cent to the PG&E NSC rate when calculating a Pioneer’s customers credit at the time of the annual true up. The Policy now identifies what NSC month (April) will be used for calculating a customer’s credit. From time to time two different NSC months were used at the annual true-up because of a customer’s billing cycle. This will provide consistency in the calculation for all customers.

Plf)NEER

COMMUNITY ENERGY
Agenda Item: 4 Agenda Date: 9/18/2025

Page 2 of 3 ends

Eliminate Process that Forfeited Credits for Non-Aggregated Accounts Pioneer’s process at the annual true-up was in alignment with PG&E’s process (CPUC’s direction to investor-owned utilities) for customers that on an annual basis were net consumers, but at the annual true-up period had generated a credit on their bill. These customers did not receive a NSC payment but instead forfeited their credit. Pioneer has the authority to set its own rates including how it sets and administers the NSC rate. Therefore, the updated Policy now provides a NSC payment for customers that have a credit at the time of the annual true-up period even if the customer was a net consumer on an annual basis. Aggregated customers are the exception as State Statute prohibits NSC payments to aggregated customers even for CCA’s. The number of customers, amounts, and the NSC rate itself will vary from year to year, but this change could positively impact around 10,000 accounts. Looking back at the past 3 years, the payments to those customers that had forfeited amounts would have been around $300,000.

Annual NSC Payment
The existing Policy provided either a bill credit or payment to a customer depending on whether the amount was below or above $25 dollars. Unfortunately, for the payments between $25 dollars and $50 dollars, up to 18% of those payments were returned to Pioneer. This resulted in customers not receiving the full benefit of their solar generation.

The updated Policy provides a NSC credit to the customer’s bill for all payments less than $50 and a payment issued to customers with an NSC balance of $50 dollars or more. This modification should ensure that more customers receive the full benefit of their solar generation even if they generate a relatively small credit amount at the annual true-up period.

Closed and Terminated NEM accounts
Outside of the annual true-up period, NEM customers’ accounts will be closed or terminated because of relocation or choosing to return to PG&E service. Any of those customers that have a NEM credit on their bill at the time the account is closed are issued an NSC payment. Although statistics can vary from year to year, it is not unusual for returned/uncashed payments to be a third of the total issued payments. To avoid the expense of issuing payments that are uncashed and to better ensure a correct address is on file and that the payment is received by the customer; the updated Policy would require customers to request a review and reconciliation of their Pioneer account within 90 days of the end of their Pioneer service for a Cash-Out payment or payments will be subject to forfeiture. This reconciliation and settlement will follow Pioneer’s Annual True Up process and any reconciled Cash-Out payment resulting in a check issued to the address provided by the customer.

Pioneers Regulatory Counsel (Braun Blaising & Wynne, P.C.) and General Counsel (Colantuono, Highsmith & Whatley, PC) have reviewed and provided input for the updated Policy.

STRATEGIC PLAN
Establishment of a revised NEM Policy is consistent with the Strategic Priority to Provide an Exceptional Customer Experience and to Achieve Operational Optimization.

Agenda Item: 4 Agenda Date: 9/18/2025

Page 3 of 3 ends

FISCAL IMPACT
Adopting the revised NEM Policy will improve the NEM customers investment in solar systems by increasing the number of customers that receive a NSC bill credits instead of a payment that is uncashed. Adopting the revised NEM Policy will also improve the customer experience for customers that may have forfeited a NSC payment because they were on an annual basis a net consumer. This cost to Pioneer will vary from year to year but estimated to cost approximately $300 thousand for the Fiscal Year 2025-26. Administration of the NEM program will be more streamlined, and Pioneer will save payment issuance fees by a reduction in payments issued.

ATTACHMENTS

1. Net Energy Metering (NEM) Service Policy with marked changes

2. Resolution to Approve an Update to the Net Energy Metering Policy

PIE)NEER

COMMUNITY ENERGY
APPLICABILITY:

P-G&-€-N EM Services:

NET ENERGY METERING (NEM} SERVICE POLICY
(Commonly known as NEM 1.0 and NEM 2.0)
Pioneer is responsible for providing generation services and related charges to its Net Energy Metering (NEM) customers. NEM customers will continue to be PG&E customers and PG&E will continue providing delivery, transmission and other services ("non-generation services"), including charges for such services. NEM customers remain a PG&E customer for non-generation services without interruption, therefore, their PG&E NEM rates for non-generation services are not affected by being a Pioneer customer. For generation services, the rates of Pioneer NEM customers shall be based on applicable rate schedules established by Pioneer's Governing Board.

Pioneer NEM customers are subject to the conditions and billing procedures of PG&E for their non-generation services, as described in PG&e's electric Schedule NeM1 and related PG&e tariff options.

Many NEM customers will receive an annual "true-up" statement from PG&E for these non-generation services. Customers are encouraged to review PG&E's most up-to-date NEM tariff documentation, which is available from PG&E.

This Net Energy Metering (NEM) Service Policy is applicable to a customer who uses an eligible Renewable Electrical Generation Facility, as defined and within the capacity limits described in PG&E's Electric Schedule NEM, that is located on the customer's owned, leased, or rented premises, is interconnected and operates in parallel with PG&E's transmission and distribution systems, and is intended primarily to offset part or all of the customer's own electrical requirements (hereinafter "eligible customer-generator" or "customer").

Pursuant to PG&e's NeM program, this rate schedule is available on a first come, first served basis to customers that provide PG&e 1Nith a completed PG&e NeM Application and comply with all PG&e NeM requirements, as described in PG&e's electric Schedule NeM. This includes customers served by NeMV (Virtual Net energy Metering), NeMVMASH (Virtual Net energy Metering for Multifamily Affordable Housing), NeMA (NeM Aggregation) and Multiple Tariff facilities, as described by PG&e's electric Schedule NeM.

TERRITORY: The Pioneer Community Energy (Pioneer) service area located in PG&E service territory.

NET SURPLUS COMPENSATION (NSC} RATE: Pioneer's NSC rate shall be $0.005/kWh above PG&E's current rate until such time it is re-set by its Governing Board . ,i, (http://www.pge.com/tariffs/ERS.St,HML#ERS),
379336.1 Page 3

PIG)NEER

COMMUNITY ENERGY
RATES: All generation rates charged under this schedule will be in accordance with the eligible NEM customer's "otherwise-applicable Pioneer rate schedule" (OAS)±. An eligible NEM customer served under this schedule is responsible for all charges from its OAS, including monthly minimum charges, customer charges, meter charges, facilities charges, demand charges and surcharges, and all other charges owed to Pioneer or PG&E._ Charges for energy (kWh) supplied by Pioneer will be based on the net metered usage, in accordance with the applicable Pioneer rate schedule(s).

PIONEER CUSTOMER MONTHLY ACCOUNTING OF CREDITS AND CHARGES: Pioneer NEM customers will be credited and charged, as follows:

1. For NEM customer's with Non-Time of Use fFQY-}-Rates:

Any net consumption or production shall be charged and credited each billing cycle, as follows:
a) If the eligible NEM customer is a "Net Consumer," having more usage than generation over a billing cycle, the eligible NEM customer will be charged in accordance with the eligible NEM customer's OAS rate.

Net Consumer Calculation
If: the difference between kWh generated and kWh consumed= Net Consumption kWh,
Then: Net Consumption kWh multiplied by OAS rate= Net Consumption$ charged b) If the eligible NEM customer is a "Net Generator," having more generation than usage over a billing cycle, any net energy production (kWh) shall be valued at the OAS rate. The calculated value of any net energy production shall be credited to the monthly bill., as described in Section 3.

Net Generator Calculation
If: the difference between kWh generated and kWh consumed= Net Generation kWh,
Then: Net Generation kWh multiplied by OAS rate= Net Generation$ credited

2. For NEM customers with Time of Use (TOU) Rates:
a) If the eligible NEM customer is a Net Consumer (as defined above) during any discrete TOU period, the net kWh consumed during such period shall be charged in accordance with applicable TOU period-specific rates/charges, as described in the eligible NEM customer's OAS. 379336.1
TOU Net Consumer Calculation
If: For discrete TOU period, the difference between kWh generated and kWh consumed during TOU period = Net Consumption kWh for TOU period, Then: Net Consumption kWh for TOU period multiplied by TOU period-specific rates/charges= Net Consumption $ charged

Page 4 ends

PIG)NEER

COMMUNITY ENERGY
379336.1 Page 5

PIC,NEER

COMMUNITY ENERGY
b) If the eligible NEM customer is a Net Generator (as defined above) during any discrete TOU period, the net kWh produced during such period shall be valued in consideration of the applicable TOU period-specific rates/charges, as described in the eligible NEM customer's OAS.

The calculated value of any net energy production during a specific TOU period shall be credited_ to the monthly bill., as described in Section 3.

TOU Net Generator Calculation
If: For discrete TOU period, if the difference between kWh generated and kWh consumed during TOU period = Net Generation kWh for TOU period, Then: Net Generation kWh for TOU period multiplied by TOU period-specific rates/charges= Net Generation $ credited

3. Monthly Settlement of Pioneer's Electric Generation Charges/Credits:

For each billing cycle, NEM customers will receive a statement in their monthly PG&E bills. The statement will indicate amounts for Pioneer's Net Consumption charged and Net Generation credited.
a) Monthly Net Credit Balance
If accrued credits for Net Generation are in excess of accrued Net Consumption charges for the monthly billing cycle, the net credit balance will be carried forward and applied against future charges in subsequent monthly billing cycles, until the end of the customer's annual cycle, as described in Section 4 below.

If: the difference bet'l.'een Net Generation credits and Net Consumption charges Net Generation Credit Balance,
Then: Net Generation Credit Balance is carried forward to be applied against future charges
b) Monthly Net Charges
If accrued credits for Net Generation are less than accrued Net Consumption charges, the net charges will be billed as a balance due for that monthly billing cycle. The balance reflected on the bill shall be due and must be paid during each monthly billing cycle.

If: if the difference between Net Generation credits and Net Consumption charges Net Consumption Charges,
Then: Net Consumption charges are due and will be billed on that billing cycle.

4. Pioneer Annual Cash-Out:

Cash-Out Eligibility: Any credit balance (OAS or retail value) eligible for participation in Pioneer's cash-out program will be determined annually, as-a-fas of the final date of the NEM customer's March-April~ billing cycle at the April NSC rate. Only Net Generators, as measured over the preceding twelve (12) calendar months of Pioneer service (or the portion of such period during which the customer received service from Pioneer), will be eligible for Pioneer's cash out program ..

The credit ({OAS} retail value) balance ({OAS} or retail value) is based on the excess generated kWh during the established annual cycle or potentially generated in a period less than the annual cycle and the excess generated kWh will be converted to a cash-out balance using the NSC rate (may be considered as the wholesale or avoided cost rate). After the customer is paid the annual cash-out. t+he customer's priorassociated credit ({OAS} retail value) balance ({OAS} or retail value) on the 379336.1 Page 6

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customer's bill will be set to zero.
i:or Net Generators, the potential cash out balance will be determined in the follm..,ing manner: the difference between aggregate k\Nh generation and aggregate k1Nh consumption resulting in net 379336.1 Page 7
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k1Nh generation, as measured over the preceding t>.velve (12) calendar months (or the portion of such period during which the customer received service from Pioneer), shall be multiplied by Pioneer's NSC rate. The resultant product shall be the amount eligible for Pioneer's annual cash out program, pursuant to the provisions below.

At the close of each March-April-Af}f-U billing cycle of each year, all current Pioneer NEM customers who are Net Generators with a NSC Net Surplus credit balance, will be eligible for a NSC bill credit or required to may a NSC issued a NSC paymentcompensation. totaling $25 or more, will be issued a direct payment by check for this balance. Such checks shall be sent to each eligible customer's billing address. Upon issuance of such payment, the customer's associated credit balance will be set to zero.

The NSC credit balance, will be first applied to any outstanding Pioneer charges and any remaining NSC balance if less than $50.00 will be issued in the form of a customer bill credit while paymentsNSC balances of $50.00 or more will be issued as a payment directly to the customer.

The maximum NSC amount payable shall be $5,000.
!=or customers with Net Surplus Generation totaling less than $25, such balances will be carried forward and shall be applied to offset future Pioneer charges.

Annual Cash Out Calculation
lfi Aggregate kWh generation for preceding 12 month period minus aggregate kWh consumption Net kWh generation,
TheA: Net kWh generation multiplied by NSC rate ($0.005/kWh more than PG&E's NEM NSC) Net Surplus Compensation (NSC),
U; NSC is equal to or greater than $25, Pioneer will send customer a check for NSC and set credit amount and charges to zero,
NSC is less than $25, Pioneer will place a credit the customer's bill for the NSC amount which will be carried forward to be applied against future charges.

For customers with Net Consumption, as measured over the preceding t>.t,·elve (12) calendar months of Pioneer service (or the portion of such period during which the customer received service from Pioneer), Pioneer 'Nill apply any remaining generation credits against Pioneer charges, until such credits are exhausted, resulting in a zero credit balance. Any remaining charge balance shall be due and payable.

E><haustion of Accrued Credits Calculation
If: Aggregate kWh generation for preceding 12 month period is less than aggregate k11'/h consumption Net kWh consumption,
Them Net kWh consumption shall be calculated pursuant to the applicable provisions of Section 1. a) or 2. a), above Net k1Nh Consumption$,
Them Net kWh consumption amount shall be charged and billed.

Customers v.•ho close their electric account through PG&E or move outside of the Pioneer service area prior to the March April billing cycle of each year, are also eligible for the annual Pioneer cash out process. Such processes will be administered in consideration of the provisions described in this section, with any potential cash out amounts distributed to such customers via check.

NSC is not available for unoccupied or non-operational facilities. 379336.1 Page 8
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NEM CUSTOMER RETURN TO PG&E BUNDLED SERVICE AND ACCOUNT CLOSURES~ 379336.1 Page 9

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Pioneer NEM customers may return to PG&E bundled service, at any time. Customers should be advised that PG&E will perform an account true up at the time of a return to PG&E bundled service, and that PG&E's standard terms for transitional electric generation rates apply to customer returns with less than six months of advance notice, if they have been a Pioneer customer for 60 days or me-re-,
If a Pioneer NEM customer opts out of the Pioneer program and returns to PG&E bundled service, that customer may request to cash out any remaining generation credits, subject to the provisions described above, in this policy, provided that the request is received by Pioneer within ninety (90) calendar days of the customer's return to PG&E seni'ice.

Pioneer customers with NEM service may opt-out and return to PG&E service at any time, subject to Pioneer and PG&E's terms and conditions for return to PG&E service. Customers are advised that PG&E may perform a True-Up of their account for any PG&E charges at the time of return to PG&E service. Customers returning to PG&E service or closing their PG&E account must request a review and reconciliation of their Pioneer account within 90 days of the end of their Pioneer service for a Cash-Out payment or payments will be subject to forfeiture. If requested, +this reconciliation and settlement will follow Pioneer's Annual Cash Out process and any reconciled Cash-Out payment will resulti-Ag in a check issued to the address provided by the customer.

UNCLAIMED PAYMENTS
If Cash-eOut payments remain unclaimed, Pioneer will follow the requirements of Government Code Section 50050-50057 et. seq. regarding the handling of unclaimed funds.

AGGREGATED NEM
Per the California Public Utilities Code Section 2827(h)(4)(B), aggregated NEM customers are "permanently ineligible to receive net surplus electricity compensation." Therefore, any excess accrued credits over the course of a year under an aggregated NEM account are ineligible for Pioneer's annual Cash-Out, as stated in Section 4. Rate schedules such as NEMA (Net Metering Aggregation), NEMFC (Net Energy Metering Fuel Cell), NEMBIO (Net Energy Metering Biagas) and RES-BCT (Renewable Energy Self-Generation Bill Credit Transfer) are not eligible. All other NEM rules apply to aggregated NEM accounts.
379336.1 Page 10
379331.1
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 September 18, 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, the Board of Pioneer Community Energy desires to update its Policy on Net Energy Metering (NEM); and
WHEREAS, the updated NEM Policy will only be applicable to NEM customers whose interconnection applications were received and processed before April 15, 2023 (also known as NEM 1 and NEM 2 customers); and
WHEREAS, the updated NEM Policy has removed unnecessary text, improved clarity, and streamlined administration; and
WHEREAS, the updated NEM Policy clearly identifies the Net Surplus Compensation (NSC) month that will be used to calculate the annual true-up NSC credit, and WHEREAS, the Pioneer NEM program will expand its benefit to non-aggregated NEM net consumers that have a credit balance at the annual true-up period by providing an NSC payment; and
In the matter of: RESOLUTION APPROVING AN

UPDATE TO THE NET ENERGY METERING

SERVICE (NEM) SERVICE POLICY
Resolution 2025- ___
September 18, 2025
2 379331.1
WHEREAS, the updated NEM Policy provides the annual true-up NSC payment, if less than $50, will be credited directly to a customer’s bill (invoice), thereby increasing customer benefit by avoiding lost and uncashed payments; and
WHEREAS, under the updated NEM Policy, a customer with a terminated or closed account may request a reconciliation of their NEM account within 90 days of account closure, which should allow for updated customer address and thereby minimize or avoid uncashed and returned payments to Pioneer.

BE IT RESOLVED, the Governing Board of Pioneer Community Energy, State of California, hereby approves the attached Updated Net Energy Metering Service (NEM) Policy.

This Resolution shall take effect immediately upon its adoption.

Exhibit A: Net Energy Metering (NEM) Service Policy

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NET ENERGY METERING (NEM) SERVICE POLICY
(Commonly known as NEM 1.0 and NEM 2.0)
APPLICABILITY:

NEM Services:

Pioneer is responsible for providing generation services and related charges to its Net Energy Metering (NEM) customers. NEM customers will continue to be PG&E customers and PG&E will continue providing delivery, transmission, and other services (“non-generation services”), including charges for such services. NEM customers remain a PG&E customer for non-generation services without interruption, therefore, their PG&E NEM rates for non-generation services are not affected by being a Pioneer customer. For generation services, the rates of Pioneer NEM customers shall be based on applicable rate schedules established by Pioneer’s Governing Board.

Pioneer NEM customers are subject to the conditions and billing procedures of PG&E for their non-generation services. Many NEM customers will receive an annual “true-up” statement from PG&E for these non-generation services. Customers are encouraged to review PG&E’s most up-to-date NEM tariff documentation, which is available from PG&E.

This Net Energy Metering (NEM) Service Policy is applicable to a customer who uses an eligible Renewable Electrical Generation Facility, as defined and within the capacity limits described in PG&E’s Electric Schedule NEM, that is located on the customer’s owned, leased, or rented premises, is interconnected and operates in parallel with PG&E’s transmission and distribution systems, and is intended primarily to offset part or all of the customer’s own electrical requirements (hereinafter “eligible customer-generator” or “customer”).

TERRITORY: The Pioneer Community Energy (Pioneer) service area located in PG&E service territory.

NET SURPLUS COMPENSATION (NSC) RATE: Pioneer’s NSC rate shall be $0.005/kWh above PG&E’s current rate until such time it is re-set by its Governing Board.

RATES: All generation rates charged under this schedule will be in accordance with the eligible NEM customer’s “otherwise-applicable Pioneer rate schedule” (OAS). Charges for energy (kWh) supplied by Pioneer will be based on the net metered usage, in accordance with the applicable Pioneer rate schedule(s).

PIONEER CUSTOMER MONTHLY ACCOUNTING OF CREDITS AND CHARGES: Pioneer NEM customers will be credited and charged, as follows:

1. For NEM customers with Non-Time of Use Rates:

Any net consumption or production shall be charged and credited each billing cycle, as follows:
a) If the eligible NEM customer is a “Net Consumer,” having more usage than generation over a billing cycle, the eligible NEM customer will be charged in accordance with the eligible NEM customer’s OAS rate.

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Net Consumer Calculation
If: the difference between kWh generated and kWh consumed = Net Consumption kWh,
Then: Net Consumption kWh multiplied by OAS rate = Net Consumption $ charged b) If the eligible NEM customer is a “Net Generator,” having more generation than usage over a billing cycle, any net energy production (kWh) shall be valued at the OAS rate. The calculated value of any net energy production shall be credited to the monthly bill.

Net Generator Calculation
If: the difference between kWh generated and kWh consumed = Net Generation kWh,
Then: Net Generation kWh multiplied by OAS rate = Net Generation $ credited

TOU Net Consumer Calculation
If: For discrete TOU period, the difference between kWh generated and kWh consumed during TOU period = Net Consumption kWh for TOU period, Then: Net Consumption kWh for TOU period multiplied by TOU period-specific rates/charges = Net Consumption $ charged
b) If the eligible NEM customer is a Net Generator (as defined above) during any discrete TOU period, the net kWh produced during such period shall be valued in consideration of the applicable TOU period-specific rates/charges, as described in the eligible NEM customer’s OAS.

The calculated value of any net energy production during a specific TOU period shall be credited to the monthly bill.

3. Monthly Settlement of Pioneer’s Electric Generation Charges/Credits:

For each billing cycle, NEM customers will receive a statement in their monthly PG&E bills. The statement will indicate amounts for Pioneer’s Net Consumption charged and Net Generation credited.
a) Monthly Net Credit Balance
If accrued credits for Net Generation are in excess of accrued Net Consumption charges for the monthly billing cycle, the net credit balance will be carried forward and applied against future charges in subsequent monthly billing cycles, until the end of the customer’s annual cycle, as described in Section 4 below.

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b) Monthly Net Charges
If accrued credits for Net Generation are less than accrued Net Consumption charges, the net charges will be billed as a balance due for that monthly billing cycle. The balance reflected on the bill shall be due and must be paid during each monthly billing cycle.

4. Pioneer Annual Cash-Out:

Cash-Out Eligibility: Any credit balance (OAS or retail value) eligible for participation in Pioneer’s cash-out program will be determined annually, as of the final date of the NEM customer’s March-April billing cycle at the April NSC rate. The credit balance (OAS or retail value) is based on the excess generated kWh during the established annual cycle or potentially generated in a period less than the annual cycle and the excess generated kWh will be converted to a cash-out balance using the NSC rate (may be considered as the wholesale or avoided cost rate). After the customer is paid the annual cash-out, the customer’s prior credit balance (OAS or retail value) on the customer’s bill will be set to zero.

At the close of each March-April billing cycle of each year, all current Pioneer NEM customers with a NSC credit balance will be eligible for a NSC bill credit or issued a NSC payment. The NSC credit balance will be first applied to any outstanding Pioneer charges and any remaining NSC balance if less than $50.00 will be issued in the form of a customer bill credit while NSC balances of $50.00 or more will be issued as a payment directly to the customer.

The maximum NSC amount payable shall be $5,000.

NSC is not available for unoccupied or non-operational facilities.

NEM CUSTOMER RETURN TO PG&E BUNDLED SERVICE AND ACCOUNT CLOSURES Pioneer customers with NEM service may opt-out and return to PG&E service at any time, subject to Pioneer and PG&E’s terms and conditions for return to PG&E service. Customers are advised that PG&E may perform a True-Up of their account for any PG&E charges at the time of return to PG&E service. Customers returning to PG&E service or closing their PG&E account must request a review and reconciliation of their Pioneer account within 90 days of the end of their Pioneer service for a Cash-Out payment or payments will be subject to forfeiture. If requested, this reconciliation and settlement will follow Pioneer’s Annual Cash Out process and any reconciled Cash-Out payment will result in a check issued to the address provided by the customer.

UNCLAIMED PAYMENTS
If Cash-Out payments remain unclaimed, Pioneer will follow the requirements of Government Code Section 50050-50057 et. seq. regarding the handling of unclaimed funds.

AGGREGATED NEM
Per the California Public Utilities Code Section 2827(h)(4)(B), aggregated NEM customers are “permanently ineligible to receive net surplus electricity compensation.” Therefore, any excess accrued credits over the course of a year under an aggregated NEM account are ineligible for Pioneer’s annual Cash-Out, as stated in Section 4. Rate schedules such as NEMA (Net Metering Aggregation), NEMFC (Net Energy Metering Fuel Cell), NEMBIO (Net Energy Metering Biogas) and RES-BCT (Renewable Energy Self-Generation Bill Credit Transfer) are not eligible. All other NEM rules apply to aggregated NEM accounts.

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Staff Report – Item 5
To: The Governing Board
From: Gina Stassi-Vanacore, Director of Communications
Item 5: Adopt a Resolution Authorizing the Chief Executive Officer to Execute an Agreement with PaulosAnalysis to Provide an Online Incentive Finder Tool for Customers, for An Amount Not To Exceed $75,000 for a One-Year Term, with the Option of Two One-Year Extensions Date: 9/18/2025

RECOMMENDATION
Adopt a resolution authorizing the Chief Executive Officer to execute an agreement with PaulosAnalysis to provide an online Incentive Finder Tool for customers, for an amount not to exceed $75,000 for a one-year term, with the option of two one-year extensions.

BACKGROUND
At the June 25, 2025, meeting of Pioneer Community Energy (“Pioneer”) Community Advisory Committee (“CAC”), there was significant discussion about the need to help customers find additional ways to save money and access savings for energy efficient appliances. This discussion was consistent with past conversations that focused on customer savings.

Research shows that several other Community Choice Aggregators (“CCAs”) have online tools on their websites that provide customers additional offerings that help them save money. These offerings include local, state, and federal incentives for home and transportation upgrades; rebates on appliances, solar, and electric vehicles; and customized rebate lists with privacy-protected searches.

Staff reached out to other CCAs to gauge the success of these tools and found them to be very popular.

Additionally, staff found that most CCAs with this type of tool contract with a specialized consultant to develop, implement, and maintain a tool that finds and prioritizes incentive programs with the fewest application hurdles and available funding.

A Request for Proposal (“RFP”) for the development of an Incentive Finder Tool was issued on August 4, 2025, with responses due on September 4, 2025. A total of five RFPs were received and evaluated by the staff, and Pioneer selected PaulosAnalysis based on its capabilities, history of success providing a similar tool for several other CCAs, depth of its database, and cost.

Details about the proposed tool and its integration were shared with the CAC at its August 27, 2025, meeting, and the CAC approved taking a proposal for the Incentive Finder Tool to the Governing Board.

ANALYSIS & DISCUSSION
Pioneer’s Customer Care team is increasingly being asked to help customers find additional ways to save money to offset the rising cost of electricity.

The proposed Incentive Finder Tool will provide the Customer Care team with additional needed information and important added value for customers through a simple, centralized way to find, research and claim rebates, tax credits, and other incentives. The Tool also reflects a responsiveness to customer needs.

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Agenda Item: 5 Agenda Date: 9/18/2025

Page 2 of 2 ends

Additionally, partnering with PaulosAnalysis to create a Pioneer-branded Incentive Finder Tool further enhances our website and our offerings. This is particularly important, as the website is many customers’ preference for finding information.

Pioneer will oversee the program’s development, facilitation, and management of the Incentive Finder Tool to ensure quality control, alignment with Pioneer’s brand, and measurable customer impact.

Partnering with PaulosAnalysis on the Incentive Finder Tool ensures that Pioneer is contracting with a qualified consultant with the background and experience needed to develop and implement an online asset that is hosted and integrated on Pioneer’s existing website, with a target launch window of December 2025. PaulosAnalysis also will collaborate on marketing and outreach efforts to maximize customer awareness and program utilization and monitor the tool’s performance. With an ongoing partnership, adjustments can be made as needed to maximize reach and performance. Tracking customer success metrics will inform future program development.

Staff had prior knowledge of PaulosAnalysis through their efforts with other CCAs and Govcentives, offering incentives to help customers make their homes and transportation cleaner and more efficient. They understand that many of the incentives are income-based and location-specific, making it confusing for customers to know which ones are relevant to them and developed a web tool that connects customers to incentives they are specifically eligible for. Their Finder already is in use by Ava Community Energy, MCE Clean Energy, and Orange County Power Authority, with others in development.

Success indicators for Pioneer include web page traffic; increased positive sentiment toward Pioneer, and stronger positioning as a trusted community partner. Customers can realize cost savings through identification and utilization of energy efficiency products, reducing both appliance purchase costs and ongoing energy bills.

While the primary goal is customer value and engagement, the Incentive Finder Tool may indirectly drive revenue through increased customer retention, higher participation in Pioneer programs, and potential partnerships with incentive providers. We also believe the Incentive Finder Tool can evolve over time to interface more directly with the Marketplace.

STRATEGIC PLAN
The recommendation supports the Quality in Service and Operational Optimization priorities.

FISCAL IMPACT
The fiscal impact of this proposal is $75,000 in the 2025-26 fiscal year, with the possibility of two one-year contract extensions.

ATTACHMENT
1) Resolution authorizing the Chief Executive Officer to execute an agreement with PaulosAnalysis to provide an online Incentive Finder Tool for customers, for an amount not to exceed $75,000 for a one-year term, with the option of two one-year extensions 411087.1
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 September 18, 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, Pioneer Community Energy (“Pioneer”) is a locally owned not-for-profit electricity provider committed to offering competitive rates, exceptional service, and a choice in energy options to residents and businesses in its service territory; and WHEREAS, a strategic priority of Pioneer’s Governing Board is to Provide an Exceptional Customer Experience, the objectives of which include to “Utilize Technology to Improve the Customer Experience” and “Increase Customer Understanding;” and WHEREAS, Pioneer emphasizes expanding customer engagement and education, increasing access to clean energy technologies, promoting innovation through digital tools and data-driven services, and enhancing operational efficiency; and
WHEREAS, to advance these objectives, Pioneer has made significant investment in its online presence and resources, as well as programs to assist customers; and WHEREAS, Pioneer seeks to develop an online Incentive Finder Tool to serve as an online resource for customers to access cost and energy savings initiatives and complement existing programs; and
In the matter of: RESOLUTION AUTHORIZING THE

CHIEF EXECUTIVE OFFICER TO EXECUTE AN

AGREEMENT WITH PAULOSANALYSIS TO PROVIDE

AN ONLINE INCENTIVE FINDER TOOL FOR

CUSTOMERS, FOR AN AMOUNT NOT TO EXCEED
$75,000 FOR A ONE-YEAR TERM WITH THE

POSSIBILITY OF TWO ONE-YEAR EXTENSIONS
Resolution No. ___
September 18, 2025
2 411087.1
WHEREAS, the Incentive Finder Tool would provide customers increased information about federal, state, and regional energy incentives and offers personalized recommendations based on customer interest and needs; and provides multilingual, multi-channel support to ensure inclusivity; and
WHEREAS, on August 4, 2025, Pioneer issued a Request for Proposals (“RFP”) to find a qualified contractor to develop, implement, and maintain an online Incentive Finder Tool in alignment with Pioneer’s mission, strategic priorities, and branding; and WHEREAS, PaulosAnalysis has demonstrated past success on several similar types of projects that can help customer education efforts and was ranked as the preferred vendor of choice by the Pioneer staff RFP panel; and
WHEREAS, Pioneer desires to execute an agreement with PaulosAnalysis to develop, implement, and maintain an online Incentive Finder Tool to provide customers with access to information that can help increase opportunities for customer savings; and WHEREAS, Pioneer anticipates that the Incentive Finder Tool will evolve to include further enhancements and cross-promotion with the existing Marketplace; and WHEREAS, the agreement’s scope of work includes collaborating with Pioneer to maximize customer awareness and program utilization, monitoring tool performance and customer outcomes, and comprehensive monthly reporting; and
WHEREAS, Pioneer’s Fiscal Year 2025-26 budget includes sufficient resources to accommodate the proposed agreement with PaulosAnalysis and no budgetary adjustment is required.

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 Chief Executive Officer is authorized to execute an agreement with PaulosAnalysis to develop and manage an online incentive finder tool, in substantially the form attached, for a one-year term effective on October 1, 2025, for an amount not-to-exceed $75,000 with any minor clerical or clarifying changes proposed by the Chief Executive Officer and approved by General Counsel. The Chief Executive Officer is further authorized to approval any extensions of the agreement pursuant to the terms of the agreement.

3. This resolution shall take effect immediately.

Exhibit A: Consultant Services Agreement with PaulosAnalysis - 1 -
Approved for use: 1/1/2025
369617.2
Administering Agency: Pioneer Community Energy
Contract No. _____________
Contract Description: Incentive Finder Tool

CONSULTANT SERVICES AGREEMENT
THIS AGREEMENT is made at Rocklin, California, as of October 1, 2025 (the “Effective Date”), by and between Pioneer Community Energy, (““Pioneer”“), and PaulosAnalysis (“Consultant”), who agree as follows:

1. Services. Subject to the terms and conditions set forth in this Agreement, Consultant shall provide the services described in Exhibit A. Consultant shall provide said services at the time, place, and in the manner specified in Exhibit A. Pioneer shall have the right to request, in writing, changes in the scope of services. Any such changes mutually agreed upon by the parties, and any corresponding increase or decrease in compensation, shall be incorporated by written amendment to this Agreement. Consultant shall not be reimbursed for any expenses incurred for work performed outside the scope of services in Exhibit A unless prior written approval is given by Pioneer through a fully executed written amendment.

2. Payment. Pioneer shall pay Consultant for services rendered pursuant to this Agreement at the time and in the amount set forth in Exhibit B. The payment specified in Exhibit B shall be the only payment made to Consultant for services rendered pursuant to this Agreement. Consultant shall submit all billings for said services to Pioneer in the manner specified therein, or, if no manner be specified, then according to the usual and customary procedures which Consultant uses for billing clients similar to Pioneer. Pioneer shall not withhold applicable taxes or other payroll deductions from payments made to Consultant except as otherwise required by law. Consultant shall be solely responsible for calculating, withholding, and paying all taxes. Notwithstanding any other terms of this Agreement, no payments shall be made to Consultant until Pioneer is satisfied that the services are satisfactory. The amount of the contract shall not exceed Seventy-Five Thousand Dollars ($75,000) in a 1-year term.

3. Facilities, Equipment and Other Materials, and Obligations of Pioneer. Unless otherwise specified in Exhibit C, Consultant shall, at its sole cost and expense, furnish all facilities, equipment, and other materials which may be required for furnishing services pursuant to this Agreement.

4. Consultant’s Representations. Consultant represents that it is fully qualified to perform the services described in Exhibit A by virtue of its experience and the training, education and expertise of its principals and employees. Consultant further represents that it is willing to accept responsibility for performing such services in accordance with the terms and conditions in this Agreement. Consultant shall perform in accordance with generally accepted professional practices and standards as well as the requirements of applicable federal, state and local laws, it being understood that acceptance of Consultant’s work by Pioneer shall not operate as a waiver or release.

Consultant shall indemnify and hold harmless Pioneer, its officers, agents, employees and volunteers from and against any and all claims or expenses caused or occasioned directly or indirectly by Consultant’s failure to so perform.
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369617.2

5. Exhibits. All exhibits referred to herein will be attached hereto and by this reference incorporated herein. In the event of any material discrepancy between the provisions of this Agreement and its exhibits, the provisions of this Agreement shall prevail.

6. Time for Performance. Time is of the essence. Failure of Consultant to perform any services within the time limits set forth in Exhibit A shall constitute material breach of this contract.

7. ’Licenses, Permits, Etc. Consultant represents and warrants to Pioneer that it has all licenses, permits, qualifications, and approvals of whatsoever nature, which are legally required for Consultant to practice its profession. Consultant represents and warrants to Pioneer that Consultant shall, at its sole cost and expense, keep in effect or obtain at all times during the term of this Agreement, any licenses, permits, and approvals which are legally required for Consultant to practice its profession at the time the services are performed.

8. Time. Consultant shall devote such time to the performance of services pursuant to this Agreement as may be reasonably necessary for the satisfactory performance of Consultant’s obligations pursuant to this Agreement. Neither party shall be considered in default of this Agreement to the extent performance is prevented or delayed by any cause, present or future, which is beyond the reasonable control of the party.

9. Hold Harmless and Indemnification Agreement. At all times during the performance of this agreement, Consultant agrees to protect, defend, and indemnify Pioneer in accordance with the provisions contained in Exhibit D.

10. Insurance. Consultant shall file with Pioneer concurrently herewith a Certificate of Insurance, in companies acceptable to Pioneer, with a Best’s Rating of no less than A-:VII, for the coverage shown in Exhibit D. All costs of complying with these insurance requirements shall be included in Consultant’s fee(s). These costs shall not be a “reimbursable” expense under any circumstances.

11. Relationship of Parties.

A. Consultant is, and shall at all times remain as to Pioneer, a wholly independent contractor.

Pioneer shall have the right to control Consultant only insofar as the results of Consultant’s services rendered pursuant to this Agreement. Pioneer shall not have the right to control the means by which Consultant accomplishes services rendered pursuant to this Agreement.

B. Except as Pioneer may specify in writing, Consultant shall have no authority, express or implied, to act on behalf of Pioneer in any capacity whatsoever as an agent. Consultant shall have no authority, express or implied pursuant to this Agreement to incur any debt, obligation, or liability on behalf of Pioneer or to otherwise bind Pioneer to any obligation whatsoever.

Consultant, its officers, employees and agents shall not represent to any person or party that it or they are acting as agents of Pioneer or that it or they have the power to bind or commit Pioneer.

C. Neither Pioneer nor any of its agents shall have control over the conduct of Consultant or any of Consultant’s employees, except as set forth in this Agreement. Consultant shall not represent that it is, or that any of its agents or employees are, in any manner employees of Pioneer.

12. Assignment Prohibited. Consultant may assign its rights and obligations under this Agreement only upon the prior written approval of Pioneer, said approval to be in the sole discretion of Pioneer. Except as otherwise provided herein, Consultant shall not subcontract any services to be performed without amending this Agreement. Consultant shall be responsible to Pioneer for all services to be performed under this Agreement.
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369617.2

13. Personnel.

A. Consultant shall assign only competent personnel to perform services pursuant to this Agreement. In the event that Pioneer, in its sole discretion, at any time during the term of this Agreement, desires the removal of any person or persons assigned by Consultant to perform services pursuant to this Agreement, including those members of the Project Team as explained below, Consultant shall remove any such person immediately upon receiving notice from Pioneer of the desire of Pioneer for removal of such person or persons.

B. Notwithstanding the foregoing, if specific persons are designated as the “Project Team” in Exhibit A, Consultant agrees to perform the work under this Agreement with those individuals identified. Reassignment or substitution of individuals or subcontractors named in the Project Team by Consultant without the prior written consent of Pioneer shall be grounds for termination of the Agreement by Pioneer, and payment shall be made pursuant to Section 17 (Termination) of this Agreement only for that work performed by Project Team members.

C. Pioneer shall pay Consultant for work performed by its subconsultants, if any, only as set forth in Exhibit B. Consultant shall be liable and accountable for any and all payments, compensation, and federal and state taxes to all subconsultants performing services under this Agreement. Pioneer shall not be liable for any payment, compensation, or federal and state taxes for any subconsultants.

14. Notification of Organizational Changes. Consultant shall notify Pioneer, in writing, of any change in name, ownership or control of Consultant’s firm or of any subconsultant. Change of ownership or control of Consultant’s firm may require an amendment to this Agreement.

15. Standard of Performance. Consultant shall perform all services required pursuant to this Agreement in the manner and according to the standards observed by a competent practitioner of the profession in which Consultant is engaged in the geographical area in which Consultant practices its profession. All products of whatsoever nature which Consultant delivers to Pioneer pursuant to this Agreement shall be prepared in a substantial first class and workmanlike manner and conform to the standards or quality normally observed by a person practicing in Consultant’s profession. Consultant shall keep itself fully informed of and in compliance with all local, state, and federal laws, rules, and regulations in any manner affecting the performance of this Agreement, including all Cal/OSHA requirements, the conflict-of-interest provisions of California Government Code section 1090, and the Political Reform Act (Government Code § 81000 et seq.).

16. Prevailing Wages. Consultant is aware of the requirements of California Labor Code section 1720, et seq., and 1770, et seq., as well as California Code of Regulations, Title 8, section 16000, et seq., (“Prevailing Wage Laws”), which require the payment of prevailing wage rates and the performance of other requirements on certain “public works” and “maintenance” projects including, but not limited to, the design and preconstruction phases of a covered public works project. This Agreement is subject to the Prevailing Wage Laws for all work performed under this Agreement for which the payment of prevailing wages is required under state law. In particular, Consultant acknowledges that prevailing wage determinations are available for work performed under this Agreement. Consultant shall defend, indemnify, and hold Pioneer, its elected officials, officers, employees, and agents free and harmless from any claim or liability arising out of any failure or alleged failure of Consultant to comply with the Prevailing Wage Laws.

17. Termination.
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A. Pioneer shall have the right to terminate this Agreement at any time by giving notice in writing of such termination to Consultant. In the event Pioneer shall give notice of termination, Consultant shall immediately cease rendering service upon receipt of such written notice, pursuant to this Agreement. In the event Pioneer shall terminate this Agreement:
1) Consultant shall deliver copies of all writings prepared by it pursuant to this Agreement. The term “writings” shall be construed to mean and include: handwriting, typewriting, printing, Photostatting, photographing, digital original and copies, and every other means of recording upon any tangible thing any form of communication or representation, including letters, words, pictures, sounds, or symbols, or combinations thereof.
2) Pioneer shall have full ownership and control of all such writings delivered by Consultant pursuant to this Agreement.
3) Pioneer shall pay Consultant the reasonable value of services rendered by Consultant to the date of termination pursuant to this Agreement not to exceed the amount documented by Consultant and approved by Pioneer as work accomplished to date; provided, however, that in no event shall any payment hereunder exceed the amount of the Agreement specified in Exhibit B, and further provided, however, Pioneer shall not in any manner be liable for lost profits which might have been made by Consultant had Consultant completed the services required by this Agreement. In this regard, Consultant shall furnish to Pioneer such financial information as in the judgment of Pioneer is necessary to determine the reasonable value of the services rendered by Consultant. Pioneer shall have the benefit of such work as may have been completed up to the time of such termination. The foregoing is cumulative and does not affect any right or remedy, which Pioneer may have in law or equity. 4) Notwithstanding the foregoing, should Consultant fail to perform any of its obligations hereunder within the time and in the manner provided or otherwise violate any of the terms of this Agreement, Consultant shall be compensated as above, provided there shall be deducted from such amount the amount of damage if any, sustained by Pioneer by virtue of Consultant’s breach of this Agreement.

B. Consultant may terminate its services under this Agreement upon thirty (30) working days’ advance written notice to Pioneer. In the event of such termination, Consultant shall deliver copies of all writings to Pioneer and shall be entitled to compensation as set forth above.

Pioneer shall have the benefit of such work as may have been completed up to the time of such termination

18. Contract Term. The term of this Agreement shall commence at 12:00 a.m. on October 1, 2025 and shall terminate at 11:59 p.m. on September 30, 2026 with the option of two 1-year extensions upon agreement of the parties unless terminated earlier in accordance with Section 17 of this Agreement.

19. Non-Discrimination. Consultant shall not discriminate against any employee or applicant for employment because of race, sex (including pregnancy, childbirth, or related medical condition), creed, national origin, color, disability as defined by law, disabled veteran status, Vietnam veteran status, religion, age (40 and above), medical condition (cancer-related), marital status, ancestry, sexual orientation, or any other unlawful basis. Employment actions to which this provision applies shall include, but not be limited to, the following: employment, upgrading, demotion, or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay or other forms of compensation; or in terms, conditions or privileges of employment, and selection for training. - 5 - Approved for use: 1/1/2025
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Consultant agrees to post in conspicuous places, available to employees and applicants for employment, the provisions of this nondiscrimination clause.

20. Records. Consultant shall maintain, at all times, complete detailed records with regard to work performed under this Agreement in a form acceptable to Pioneer for a minimum of three (3) years, or for any longer period required by law, from the date of final payment to Consultant under this Agreement, and Pioneer shall have the right to inspect such records at any reasonable time.

Notwithstanding any other terms of this agreement, no payments shall be made to Consultant until Pioneer is satisfied that work of such value has been rendered pursuant to this agreement. However, Pioneer shall not unreasonably withhold payment and, if a dispute exists, the withheld payment shall be proportional only to the item in dispute. In addition, pursuant to Government Code Section 8546.7, if the amount of public funds expended under this Agreement exceeds ten thousand dollars, all such documents and this Agreement shall be subject to the examination and audit of the State Auditor, at the request of Pioneer or as part of any audit of Pioneer, for a period of three (3) years after final payment under this Agreement.

21. Ownership of Information. All professional and technical information developed under this Agreement and all work sheets, reports, and related data shall become the property of Pioneer, and Consultant agrees to deliver reproducible copies of such documents to Pioneer on completion of the services hereunder. No such written products shall be the subject of a copyright application by Consultant.

22. Waiver. No provision, covenant, or condition of this Agreement shall be deemed to have been waived by Pioneer or Consultant unless in writing signed by one authorized to bind the party asserted to have consented to the waiver. One or more waivers by one party of any major or minor breach or default of any provision, term, condition, or covenant of this Agreement shall not operate as a waiver of any subsequent breach or default by the other party.

23. Conflict of Interest. Consultant represents that it has no known relationships with third parties, Pioneer Board members, or employees of Pioneer which would (1) present a conflict of interest with the rendering of services under this Agreement under California Government Code section 1090, the Political Reform Act (Government Code section 81000 et seq.), or other applicable law, (2) prevent Consultant from performing the terms of this Agreement, or (3) present a significant opportunity for the disclosure of confidential information. Consultant certifies that no official or employee of Pioneer, nor any business entity in which an official of Pioneer has an interest, has been employed or retained to solicit or aid in the procuring of this Agreement. In addition, Consultant agrees that no such person will be employed in the performance of this Agreement without immediately notifying Pioneer.

24. Campaign Contributions. This Agreement is subject to Government Code section 84308, as amended by Senate Bill 1439 (2022), Senate Bill 1181 (2024), and Senate Bill 1243 (2024).

Consultant shall disclose any contribution to an elected or appointed Pioneer official’s campaign or committee in an amount of more than five hundred dollars ($500) made within 12 months preceding the Commencement Date, by Consultant, its, her, or his agent, or another party affiliated with Consultant. Consultant shall provide a signed copy of the attached Campaign Contribution Disclosure Form, Exhibit E, to Pioneer prior to, or concurrent with, Consultant's execution of this Agreement and no later than the Commencement Date.

25. Entirety of Agreement. This Agreement contains the entire agreement of Pioneer and Consultant with respect to the subject matter hereof, and no other agreement, statement, or promise made by any party, or to any employee, officer or agent of any party, which is not contained in this Agreement, shall be binding or valid.
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26. Alteration. No waiver, alteration, modification, or termination of this Agreement shall be valid unless made in writing and signed by all parties, except as expressly provided in Section 19, Termination.

27. Governing Law & Venue. This Agreement is executed and intended to be performed in the State of California, and the laws of that State shall govern its interpretation and effect. Any legal proceedings on this Agreement shall be brought under the jurisdiction of the Superior Court of County of Placer, State of California, and Consultant hereby expressly waives those provisions in California Code of Civil Procedure §394 that may have allowed it to transfer venue to another jurisdiction.

28. Attorneys’ Fees. If legal action shall be necessary to enforce any term, covenant or condition contained in this Agreement, each party shall pay its own costs, including any accountants’ and attorneys’ fees expended in the action.

29. Notification. Any notice or demand desired or required to be given hereunder shall be in writing and deemed given when personally delivered or deposited in the mail, postage prepaid, and addressed to the parties as follows:

PIONEER COMMUNITY ENERGY: CONSULTANT:

Pioneer Community Energy PaulosAnlaysis
Attn: Eric Acedo Attn: Bentham Paulos
2510 Warren Drive Suite B 1331 Peralta Ave.

Rocklin, CA 95677 Berkeley CA 94702
[email protected] [email protected] Phone: (916) 758-8943 Phone: (510) 912-3001
Any notice so delivered personally shall be deemed to be received on the date of delivery, and any notice mailed shall be deemed to be received five (5) days after the date on which it was mailed.

30. Multiple Phase Projects. Pursuant to Government Code section 1097.6, Consultant’s duties and services under this Agreement shall not include preparing or assisting Pioneer with any portion of the Pioneer’s preparation of a request for proposals, request for qualifications, or any other solicitation regarding a subsequent or additional contract with Pioneer. Pioneer shall at all times retain responsibility for public contracting, including with respect to any subsequent phase of this project. Consultant’s participation in the planning, discussions, or drawing of project plans or specifications, if any, shall be limited to conceptual, preliminary, or initial plans or specifications.

Consultant shall cooperate with the Pioneer to ensure that all bidders for a subsequent contract on any subsequent phase of this project have access to the same information, including all conceptual, preliminary, or initial plans or specifications prepared by Consultant, if any, pursuant to this Agreement.

31. Remedies Non-Exclusive. Each right, power and remedy provided for herein or now or hereafter existing at law, in equity, by statute, or otherwise shall be cumulative and shall be in addition to every other right, power, or remedy provided for herein or now or hereafter existing at law, in equity, by statute, or otherwise. The exercise, the commencement of the exercise, or the forbearance from the exercise by any party of any one or more of such rights, powers or remedies shall not preclude the simultaneous or later exercise by such party of any or all of such other rights, powers or remedies.
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32. Confidentiality. All data, documents, discussion, or other information developed or received by Consultant for performance of this Agreement are deemed confidential and Consultant shall not disclose it without prior written consent by Pioneer. Pioneer shall grant such consent if disclosure is legally required. All Pioneer data shall be returned to Pioneer upon the termination or expiration of this Agreement.

33. Successors & Third-Party Beneficiaries. This Agreement shall be binding on the successors and assigns of the parties. Except as expressly stated herein, there is no intended third-party beneficiary of any right or obligation assumed by the parties.

34. Severability. If any term or provision of this Agreement or the application thereof to any person or circumstance shall, to any extent, be invalid or unenforceable, then such term or provision shall be amended to, and solely to the extent necessary to, cure such invalidity or unenforceability, and shall be enforceable in its amended form. In such event, the remainder of this Agreement, or the application of such term or provision to persons or circumstances other than those as to which it is held invalid or unenforceable, shall not be affected, and each term and provision of this Agreement shall be valid and be enforced to the fullest extent permitted by law.

35. No Presumption Against Drafter. Each party had an opportunity to consult with an attorney in reviewing and drafting this agreement. Any uncertainty or ambiguity shall not be construed for or against any party based on attribution of drafting.

36. Counterparts; Electronic Signatures. This Agreement may be signed in one or more counterparts, each of which shall be deemed an original, but all of which together shall be deemed one and the same instrument. The parties acknowledge and agree that this Agreement may be executed by electronic signature, which shall be considered as an original signature for all purposes and shall have the same force and effect as an original signature. Without limitation, “electronic signature” shall include faxed or emailed versions of an original signature, electronically scanned and transmitted versions (e.g., via pdf) of an original signature, or a digital signature. - 5 - 369617.3
Executed as of the day first above stated:

PIONEER COMMUNITY ENERGY
By: _____________________________
Printed Name/Title:

Approved as to Form – General Counsel:

By: _____________________________
Printed Name/Title:

PAULOS ANALYSIS
By: _____________________________
Name: _____________________________
Title: Principal
*If Consultant is a corporation, this agreement must be signed by two corporate officers: (1) the chairperson, president, or any vice president; and (2) the secretary, any assistant secretary, the chief financial officer, or any assistant treasurer. (Civ. Code § 313.), unless an authenticated corporate resolution is attached delegating authority to a single officer or other officers to bind the corporation.

Exhibits
A. Scope of Services
B. Payment for Services Rendered
C. Facilities, Equipment and Other Obligations of Pioneer D. Hold Harmless Agreement and Insurance Requirements
E. Campaign Contribution Disclosure Form

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Pioneer Community Energy Board of DirectorsSeptember 18, 2025

Pioneer Community Energy Board of Directors
September 18, 2025