Automatic Non-Default Termination Event. An “Automatic Non-Default Termination Event” under Clean Energy Purchase Contract No. 2 will occur if the Project Participant makes a Remarketing Termination Election with respect to any Reset Period.
Remedies and Termination
Upon the occurrence of a default by the Project Participant described in (b) above, the Clean Energy Purchase Contracts will automatically terminate and all amounts due to CCCFA will be immediately due and payable. Upon the occurrence of the other defaults described above, the non-defaulting party may terminate the Clean Energy Purchase Contracts and/or declare all amounts due to it to be immediately due and payable. During the existence of a default, the non-defaulting party may exercise all other rights and remedies available to it at law or in equity, including without limitation mandamus, injunction and action for specific performance, to enforce any covenant, agreement or term of the Clean Energy Purchase Contracts.
In addition to the remedies described above, during the existence of any default by the Project Participant, CCCFA may suspend its performance under the Clean Energy Purchase Contracts and discontinue the supply of all or any portion of the Electricity otherwise to be delivered to the Project Participant under the Clean Energy Purchase Contracts.
If CCCFA exercises its right to discontinue Electricity deliveries to the Project Participant, such service may only be reinstated, as determined by CCCFA, upon (a) payment in full by the Project Participant of all amounts then due and payable under its Clean Energy Purchase Contracts and (b) unless otherwise agreed to by CCCFA, payment in advance by the Project Participant at the beginning of each month (for such time period as CCCFA deems appropriate) of amounts estimated by CCCFA to be due from the Project Participant for the future delivery of Electricity for such month. If the Project Participant fails to accept the Electricity tendered for delivery under the Clean Energy Purchase Contracts, CCCFA has the right to sell the Electricity to third parties.
Assignment
The provisions of the Clean Energy Purchase Contracts are binding on the successors and assigns of such contract. Neither party may assign the Clean Energy Purchase Contracts to another party without the prior written consent of the other party, except that CCCFA may assign its interests to secure its obligations under the Indenture. Prior to assigning all or any part of its interest in the Clean Energy Purchase Contracts, the Project Participant is required to deliver to CCCFA a Rating Confirmation from each rating 66 agency then rating the Bonds. CCCFA shall terminate any applicable Assignment Agreement concurrently with the assignment of the Clean Energy Purchase Contracts.
Project Participant Credit Enhancement
Debt Service Reserve Account. Upon the failure of the Project Participant to make a payment under the Clean Energy Purchase Contracts, the Trustee shall, on the last Business Day of the month, withdraw from the Debt Service Reserve Account and deposit into the Debt Service Account an amount equal to any deficiency that exists therein as a result of such nonpayment. The Debt Service Reserve Requirement is approximately equal to the largest two consecutive monthly Scheduled Debt Service Deposits during the Initial Interest Rate Period. Upon such a transfer, the Trustee will notify the Electricity Supplier to remarket Electricity, and the Electricity Supplier will then have the option, but not the requirement, to purchase Receivables from CCCFA.
Purchase of Call Receivables. Under the Electricity Purchase, Sale and Service Agreements, the Electricity Supplier may transfer Call Receivables purchased by the Electricity Supplier to J. Aron, and J.
Aron has agreed to accept the transfer of any such Call Receivables purchased by the Electricity Supplier as a credit against amounts owed by the Electricity Supplier thereunder; provided that for any Call Receivables purchased by the Electricity Supplier at its option, J. Aron’s obligation to purchase and accept the transfer of such Call Receivables is subject to it having provided its prior written consent to the purchase of such Call Receivables by the Electricity Supplier. To the extent J. Aron has purchased Call Receivables for amounts owed by the Project Participant under Clean Energy Purchase Contract No. 2 for the purchase of Assigned Electricity, J. Aron may transfer all or a portion of such Receivables to the relevant PPA Seller to which such non-payment by the Project Participant for the Assigned Electricity delivered under Clean Energy Purchase Contract No. 2 relates.
Purchase of Put Receivables. If the Electricity Supplier Put Receivables Account has been funded, then upon final maturity of the Bonds or the occurrence of an Early Termination Payment Date under the Master Power Supply Agreements, the Trustee will put to the Electricity Supplier sufficient Put Receivables, which the Electricity Supplier is required to purchase, to ensure the amounts in the Debt Service Reserve Account equal the Debt Service Reserve Requirement and the amounts in the Commodity Reserve Account equal the Minimum Amount. The Electricity Supplier Put Receivables Account is established with the Master Custodian under the Master Electricity Supplier Custodial Agreement, and if J.
Aron elects to fund the Electricity Supplier Put Receivables Account, it must do so in an amount equal to the Put Receivables Funding Requirement. Any amount on deposit in the Electricity Supplier Put Receivables Account may be used only to pay any amounts due from the Electricity Supplier under the Receivables Purchase Provisions in respect of Put Receivables. The provisions described in this caption are collectively referred to herein as “Project Participant Credit Enhancement.”
CALIFORNIA COMMUNITY CHOICE FINANCING AUTHORITY
General
CCCFA is a joint powers authority formed pursuant to the Act and the joint powers agreement (the “JPA Agreement”) made among those public agencies which are its members. CCCFA was incorporated and organized in 2021. As of the date of this Official Statement the members of CCCFA are Ava Community Energy Authority, Central Coast Community Energy, Clean Power Alliance of Southern California, Marin Clean Energy, and Silicon Valley Clean Energy Authority (each, a “Founding Member”) and the Project Participant, [Desert Community Energy], Orange County Power Authority, Peninsula Clean Energy Authority, [Redwood Coast Energy Authority], San Diego Community Power, the City of San José through its community choice aggregator program known as San José Clean Energy, Sonoma Clean Power 67 Authority and Valley Clean Energy Alliance (each an “Associate Member” and, together with the Founding Members and any additional members which may later be added as parties to the JPA Agreement, a “Member”).
Each Member is a community choice aggregator, and a public agency as defined in the Act, which operates a community choice aggregation program with the authority to group retail electricity customers to solicit bids, broker, and contract for electricity and energy services for those customers, and to enter into agreements for services to facilitate the sale and purchase of electricity and other related services, and to study, promote, develop, conduct, operate and manage energy-related programs.
CCCFA was formed for, among other purposes, the purpose of financing energy prepayments which can be financed with tax advantaged bonds for the benefit of its Members.
Powers and Authority
Under the provisions of the Act, CCCFA has all of the powers common to the Members, and any and all power in connection with the financing or refinancing of energy prepayments that can be financed with tax advantaged bonds and other obligations, including: (i) the purchase and sale of electric energy and associated capacity and environmental attributes, (ii) the design, acquisition, maintenance, or operation of any Public Capital Improvement (as defined in the Act) or other facility or improvement, or the leasing thereof, (iii) the provision of working capital, and (iv) any other project, program, public capital improvement or purpose authorized by the Act or other law to be undertaken, financed, or refinanced by CCCFA, in connection with the financing or refinancing of energy prepayments that can be financed with tax advantaged bonds and other obligations (a “Prepayment Project”). CCCFA shall have the power to issue, incur, sell and deliver bonds in accordance with the provisions of the Act and other applicable laws for the purpose of acquiring, undertaking, financing, or refinancing one or more Prepayment Projects.
Under the provisions of the JPA Agreement and the Act, CCCFA has (among others) the following powers:
(a) to acquire, purchase, finance, operate, maintain, utilize and/or dispose of one or more Prepayment Projects and any facilities, programs or other authorized costs relating thereto; (b) to make and enter contracts (including without limitation interest rate, commodity, basis and similar hedging contracts intended to hedge payment, rate, cost or similar exposure); (c) to employ agents and employees;
(d) to acquire, manage, maintain or operate any building, works or improvements; (e) to acquire, hold, lease or dispose of property;
(f) to incur debts (including without limitation through the issuance or incurrence of bonds), liabilities or obligations (which shall not constitute debts, liabilities, or obligations of any of the Members);
(g) to sue and be sued in its own name;
(h) to receive gifts, contributions and donations of real or personal property, funds, services and other forms of assistance from any source;
68 (i) to receive, collect, invest and disburse moneys; (j) to apply for, accept, and receive all licenses, permits, grants, loans or other aids from any federal, state, or local public agency;
(k) to make and enter into service agreements relating to the provision of services necessary to plan, implement, operate and administer energy-related programs; (l) to defend, hold harmless, and indemnify, to the fullest extent permitted by law, each Member from any liability, claims, suits, or other actions; (m) to exercise any other power and take any other action permitted by law to accomplish the purposes of the JPA Agreement.
The JPA Agreement shall continue in full force and effect until terminated as provided in therein; provided, however, the JPA Agreement cannot be terminated while either (a) any bonds of CCCFA, including the Bonds, remain outstanding, or (b) CCCFA is the owner, lessor or lessee of any real or personal property financed from the proceeds of any bonds.
Governance and Management
Board of Directors
CCCFA is governed by a Board of Directors (the “Board”) consisting of one director for each Founding Member. The Board shall have the authority to provide for the general management and oversight of the affairs, property and business of CCCFA. The Board may appoint a part-time or full-time General Manager and may appoint one or more part-time or full-time Assistant General Managers. The General Manager would be responsible for the day-to-day operation and management of CCCFA. The names of the current directors of CCCFA are listed on the roster page at the front of this Official Statement.
Management
The Board has not appointed a General Manager or Assistant General Manager. CCCFA’s current management team consists of Garth Salisbury as Treasurer-Controller and David Ruderman of Colantuono, Highsmith & Whatley, PC as General Counsel.
CCCFA Projects
CCCFA previously issued its bonds (a) on September 23, 2021 to purchase prepaid electricity from Morgan Stanley Energy Structuring, L.L.C. (“MSES”), which is delivered to its Members, Ava Community Energy Authority (formerly East Bay Community Energy Authority) and Silicon Valley Clean Energy Authority, (b) on November 24, 2021 to purchase prepaid electricity from Aron Energy Prepay 5 LLC, which is delivered to its Member, Marin Clean Energy, (c) on July 12, 2022 to purchase prepaid electricity from MSES, which is delivered to its Member, Ava Community Energy Authority, (d) on January 4, 2023 to purchase prepaid electricity from Aron Energy Prepay 15 LLC, which is delivered to the Project Participant, (e) on January 27, 2023 to purchase prepaid electricity from MSES, which is delivered to its Member, Silicon Valley Clean Energy Authority, (f) on February 23, 2023 to purchase prepaid electricity from Aron Energy Prepay 14 LLC, which is delivered to its Member, Clean Power Alliance of Southern California, (g) on June 15, 2023 to purchase prepaid electricity from Aron Energy Prepay 16 LLC, which is delivered to its Member, Clean Power Alliance of Southern California, (h) on August 16, 2023 to purchase prepaid electricity from MSES, which is delivered to its Member, Ava Community Energy 69 Authority, (i) on October 26, 2023 to purchase prepaid electricity from Aron Energy Prepay 22 LLC, which is delivered to its Member, Central Coast Community Energy, (j) on December 15, 2023 to purchase prepaid electricity from Aron Energy Prepay 21 LLC, which is delivered to its Member, Marin Clean Energy, (k) on January 25, 2024 to purchase prepaid electricity from MSES, which is delivered to its Member, Silicon Valley Clean Energy Authority, (l) on August 27, 2024 to purchase prepaid electricity from Aron Energy Prepay 41 LLC, which is delivered to its Member, Clean Power Alliance of Southern California, and (m) on October 10, 2024 to purchase prepaid electricity from Aron Energy Prepay 43 LLC, which is delivered to its Member, Peninsula Clean Energy Authority, (n) on November 4, 2024 to purchase prepaid electricity from MSES, which is delivered to its Member, the City of San José, (o) on November 14, 2024 to purchase prepaid electricity from Royal Bank of Canada, which is delivered to its Member, Clean Power Alliance of Southern California, (p) on November 20, 2024 to purchase prepaid electricity from Energy Prepay IV, LLC, which is delivered to its Member, San Diego Community Power, (q) on November 27, 2024 to purchase prepaid electricity from Aron Energy Prepay 45 LLC, which is delivered to its Member, Sonoma Clean Power Authority, (r) on December 20, 2024 to purchase prepaid electricity from Aron Energy Prepay 46 LLC, which is delivered to its Member, Clean Power Alliance of Southern California, (s) on March 13, 2025 to purchase prepaid electricity from Aron Energy Prepay 44 LLC, which is delivered to its Member, Valley Clean Energy Alliance, (t) on June 18, 2025 to purchase prepaid electricity from Aron Energy Prepay 52 LLC, which is delivered to its Member, Marin Clean Energy, (u) on July 25, 2025 to purchase prepaid electricity from Energy Prepay III, LLC, which is delivered to its Member, San Diego Community Power, (v) on September 26, 2025 to purchase prepaid electricity from Energy Prepay VIII, LLC, which is delivered to its Member, Ava Community Energy Authority, (w) on October 14, 2025 to purchase prepaid electricity from Aron Energy Prepay 53 LLC, which is delivered to its Member, Ava Community Energy Authority, (x) on November 3, 2025 to purchase prepaid electricity from Energy Prepay IX, which is delivered to its Member, Silicon Valley Clean Energy Authority, (y) on December 19, 2025 to purchase prepaid electricity from Aron Energy 62, LLC, which is delivered to its Member, Peninsula Clean Energy Authority, (z) on January 27, 2026 to purchase prepaid electricity from MSES, which is delivered to its Member, the City of San Jose, (aa) on February 27, 2026 to purchase prepaid electricity from Energy Prepay X, LLC, which is delivered to its Member, Clean Power Alliance of Southern California, (bb) on March 19, 2026 to purchase prepaid electricity from Aron Energy 60, LLC, which is delivered to its Member, San Diego Community Power, and (cc) on March 19, 2026 to purchase prepaid electricity from Energy Prepay XI, LLC, which is delivered to its Member, Orange County Power Authority. Each series of bonds is secured by a separate bond indenture. CCCFA may issue future bonds to purchase prepaid electricity supplies for sale to participating municipal utilities, with the revenues from such sales pledged to the payment of such bonds. Such revenues will not be pledged, nor may such revenues be used, to pay amounts due with respect to the Bonds.
In furtherance of its corporate and public purposes, CCCFA intends to acquire and finance supplies of electricity on a prepaid basis for sale to other community choice aggregators. CCCFA is currently developing additional Clean Energy Projects under transaction and financing structures that are expected to be generally similar to the structure of the Clean Energy Project. CCCFA can give no assurance as to the timing or terms of these projects or that they will be completed. A range of factors that are outside of the control of CCCFA, including the final negotiation of transaction documents, the approval of commodity supply contracts by the prospective project participants, changes in market prices and rates, the receipt of bond ratings, and other factors could result in these transactions not being completed.
Any additional Clean Energy Projects that may be undertaken by CCCFA will be separate and distinct transactions, and the bonds issued to finance these projects will be payable solely from the commodity sales and other revenues pledged for their payment. In no event will the Revenues and Trust Estate pledged to the payment of the Bonds be used to pay any other bonds of CCCFA. 70 Separate Obligations
THE BONDS, ANY FUTURE BONDS THAT MAY BE ISSUED BY CCCFA AND ANY
FUTURE CONTRACTS THAT CCCFA MAY ENTER INTO TO ACQUIRE ADDITIONAL ENERGY OR ELECTRICITY ARE AND WILL BE SEPARATE AND DISTINCT OBLIGATIONS OF CCCFA.
ANY FUTURE BONDS OR CONTRACTS WILL NOT BE SECURED BY OR PAYABLE FROM THE
REVENUES PLEDGED BY THE INDENTURE TO THE PAYMENT OF THE BONDS, AND THE
BONDS WILL NOT BE SECURED BY OR PAYABLE FROM THE REVENUES DERIVED FROM ANY FUTURE PROJECT, CLEAN ENERGY PROJECT OR CONTRACT OF CCCFA.
Limited Liability
CCCFA DOES NOT HAVE THE POWER TO LEVY AD VALOREM PROPERTY TAXES.
ALL BONDS ISSUED BY CCCFA ARE PAYABLE SOLELY FROM THE REVENUES AND
RECEIPTS DERIVED FROM ITS ACTIVITIES PURSUANT TO ITS STATUTORY PURPOSES AND POWERS AND IN ACCORDANCE WITH THE APPLICABLE FINANCING DOCUMENTS. THE
BONDS ARE PAYABLE SOLELY FROM AND SECURED SOLELY BY THE TRUST ESTATE PLEDGED PURSUANT TO THE INDENTURE.
COMMUNITY CHOICE AGGREGATORS
General
Section 331.1 of the Public Utilities Code provides for the establishment of “community choice aggregators” (a “CCA”). A CCA may be established by any city, county, or city and county whose governing board elects to combine the loads of its residents, businesses, and municipal facilities in a community-wide electricity buyers’ program, and by any group of cities, counties, or cities and counties whose governing boards have elected to combine the loads of their programs, through the formation of a joint powers agency established under Joint Powers Act, provided in either case that the entity is not within the jurisdiction of a local publicly owned electric utility that provided electrical service as of January 1, 2003. “Local publicly owned electric utility” means a municipality or municipal corporation operating as a “public utility” and certain municipal utility districts, public utility districts, irrigation districts, or joint powers authorities that include one or more of these agencies and that owns generation or transmission facilities or furnishes electric services over its own or its members’ electric distribution systems.
Community Choice Service Model
Once a community forms or joins a CCA, the CCA is the default energy provider in that community. The CCA procures energy for customers in that community, but the investor-owned utility for that community continues to provide transmission, distribution and billing services to customers. Revenues from the sale of energy by the CCA are delivered by the investor-owned utility to the CCA as they are received over the course of the billing period.
Service Contract Requirements and Registration with the Public Utilities Commission CCAs are required to have an operating service agreement with the applicable investor-owned utility prior to furnishing electric service to consumers within its jurisdiction. The service agreement must include performance standards that govern the business and operational relationship between the CCA and the investor-owned utility. CCAs are also required to register with the California Public Utilities Commission (the “PUC”), which may require additional information to ensure compliance with basic consumer protection rules and other procedural matters. Once notified of a CCA program, the applicable 71 investor-owned utility is required to transfer all applicable accounts to the CCA within a 30-day period from the date of the close of the utility’s normally scheduled monthly metering and billing process.
Customer Participation and Opt-out Rights
Participation in a CCA is voluntary. Each local government seeking to form or join a CCA must adopt an appropriate authorizing resolution or ordinance. When a community forms or joins a CCA, customers are given advance notice and have the choice to opt-out of the CCA program prior to or after transition to the CCA, and instead receive electricity from the applicable investor-owned utility. Customers that do not opt-out are automatically enrolled in the program. Customers have the option to opt out of the program subject to a fee.
Regulatory Compliance
CCAs are “load-serving entities” and as such are required to comply with the renewable portfolio standards and reliability standards established by the PUC and the California Energy Commission (the “CEC”) and file integrated resource plans and other periodic reports with the PUC and the CEC.
Cost Recovery Related to Transfer of Customers to a CCA Although investor-owned utilities do not purchase power for CCA customers, they continue to deliver the power. Investor-owned utilities also have the obligation to provide electric service to customers that opt out of CCA service as the “provider of last resort.” In order to compensate investor-owned utilities for investments in power generation and long-term power purchase contracts associated with the loss of customers to CCAs, the PUC has established a “power charge indifference adjustment” (the “PCIA”) applicable to CCA customers. The PCIA is calculated by taking the difference between (i) the “actual portfolio cost” related to utility’s power procurement (e.g., utility-owned generation and purchased power), and (ii) the “market value of the portfolio,” which is measured by the Market Price Benchmark (the “MPB”) and the megawatt hours of generation.
The MPB is based on a PUC approved methodology for calculating the current market cost of renewables and natural gas-fueled power. If the investor-owned utility’s actual portfolio cost is above-market value, the departing load customers pay their share of the difference in the form of a PCIA based on their power consumption. The amount of the PCIA applicable to a CCA customer depends on when a customer left the investor-owned utility and what the investor-owned utility’s portfolio was at the time.
Each departing load customer pays the assigned “vintage PCIA.” For example, a customer who departed in 2019 pays the “2019 vintage PCIA” which only includes the above market costs of pre-2020 vintage power procured by the investor-owned utility.
In addition to PCIA charges, CCA customers are required to pay certain other “non-bypassable departing load charges,” including a nuclear decommissioning charge, a public purpose charge and a cost allocation charge to pay for new resources needed for ongoing system reliability.
THE COMMODITY SWAPS
Set forth below is a summary of certain provisions of the Commodity Swaps. This summary does not purport to be a complete description of the terms and conditions of the Commodity Swaps and accordingly is qualified by reference to the full text of the Commodity Swaps.
Payments of fixed and floating amounts under the Commodity Swaps described herein will be made while deliveries of Market Electricity are ongoing under the Market Electricity 72 Contracts. Deliveries under the Market Electricity Contracts will end on [_________], 20[__], and deliveries under the Assigned Electricity Contracts will begin on [__________] 1, 20[__].
Cash flows under the Commodity Swaps will become dormant with respect to Assigned Prepay Quantities delivered under the Initially Assigned PPAs. Upon the expiration or termination of any Initially Assigned PPAs, the Commodity Swaps will become active again with respect to Assigned Prepay Quantities delivered under a Replacement Assigned PPA or any Market Quantities that are remarketed.
General
CCCFA has entered into two CCCFA Commodity Swaps under which, for each Master Power Supply Agreement while the Commodity Swaps are active, CCCFA will pay a market-based index price at a specified pricing point and will receive a fixed electricity price for notional quantities that correspond to the quantities of electricity and the related delivery point under such Master Power Supply Agreement.
Under each CCCFA Commodity Swap for each calendar month that the relevant floating price of electricity at the delivery point is greater than the fixed price specified in such CCCFA Commodity Swap on an aggregate net basis for all delivery hours in such month and all delivery points, CCCFA will be obligated to pay to the Commodity Swap Counterparty (on an aggregate net basis for all hours in such month) an amount equal to the product of (x) the difference between the floating price and the fixed price for each such hour multiplied by (y) a notional quantity equal to the quantity of electricity scheduled to be delivered at the delivery point during such hour by the Electricity Supplier under the related Master Power Supply Agreement. If the fixed price specified in a CCCFA Commodity Swap is greater than the relevant floating price of electricity on an aggregate net basis for all delivery hours in such month and all delivery points, the Commodity Swap Counterparty will be obligated to pay CCCFA (on an aggregate net basis for all hours in such month) an amount equal to the product of (x) the difference between the fixed price and floating price for each such hour multiplied by (y) a notional quantity equal to the quantity of electricity scheduled to be delivered at the delivery point during such hour by the Electricity Supplier under the related Master Power Supply Agreement. If the relevant floating price for a calendar month is equal to the specified fixed price, no payment will be owed by either party to the other under such CCCFA Commodity Swap.
The Electricity Supplier has entered into two Electricity Supplier Commodity Swaps with the same Commodity Swap Counterparty under which, while the Commodity Swaps are active, the Electricity Supplier pays a fixed electricity price and receives a floating electricity price for the same notional quantities at the same pricing points.
Form of Commodity Swaps
Each of the Commodity Swaps has been entered into as a contingent price agreement under a 2002 ISDA Master Agreement with certain amendments and elections under such Master Agreement that have been agreed to by the parties. The Commodity Swaps have an initial term of two calendar months, and thereafter rolling one-month terms that renew automatically upon the payment due date of each monthly net settlement amount due thereunder through the term of the Delivery Period under the related Master Power Supply Agreement unless an early termination date occurs under such Commodity Swap.
Payment
For each month of scheduled deliveries and notional amounts, each party with a net obligation under a Commodity Swap (based on the relative values of the fixed price and relevant index prices) will pay that net obligation to the other party. Payments, if any, under the Commodity Swaps are due in the calendar month following the month to which the applicable day-ahead market prices relate, on the 24th 73 day of the month (or preceding business day) in the case of the Electricity Supplier Commodity Swaps and on the 25th day of the month (or next business day) in the case of the CCCFA Commodity Swaps.
Early Termination
Each of the Commodity Swaps will be subject to early termination under certain circumstances.
Early termination can be triggered automatically or upon the election by the non-defaulting party or non-affected party as summarized below.
No settlement or other termination payment (other than Unpaid Amounts as defined in the Commodity Swaps) will be due to any party as a result of any early termination of any Commodity Swap.
Automatic Termination of Commodity Swaps. Each of the following events would result in the automatic termination of the CCCFA Commodity Swaps and the Electricity Supplier Commodity Swaps:
• the occurrence of an Electricity Delivery Termination Date under either Master Power Supply Agreement for any reason, in which case the Commodity Swaps will terminate automatically on such date;
• delivery by CCCFA or the Commodity Swap Counterparty of a notice of termination of the CCCFA Commodity Swaps results in the automatic termination of the Electricity Supplier Commodity Swaps, and delivery by the Electricity Supplier or the Commodity Swap Counterparty of a notice of termination of the Electricity Supplier Commodity Swaps results in the automatic termination of the CCCFA Commodity Swaps, in each case on the Early Termination Date specified in such notice (as defined in the respective Commodity Swap).
Elective Termination of the CCCFA Commodity Swaps. Each of the following events of default and termination events would provide the non-defaulting party or the non-affected party the right to terminate the CCCFA Commodity Swaps if it is not cured within the applicable cure period:
• a party becomes subject to certain insolvency events in the manner specified in the CCCFA Commodity Swaps;
• a credit support default with respect to the Commodity Swap Counterparty; • a reduction below certain specified minimum ratings in the credit rating assigned by a specified rating agency to (a) the Commodity Swap Counterparty’s senior, unsecured long-term debt obligations (not supported by third party credit enhancements), or (b) if there is no such rating, then its issuer rating (“Counterparty’s Credit Rating”); • amendment of the Indenture in breach of the Commodity Swap Counterparty’s consent rights thereunder;
• the amendment, without the Commodity Swap Counterparty’s consent, of certain provisions of the Master Power Supply Agreements relating to the termination or assignment thereof or that would (in the Commodity Swap Counterparty’s reasonable opinion) have certain effects on the terminations of the Commodity Swaps; • a party’s failure to pay any amount when due under the CCCFA Commodity Swap (notwithstanding any payments made by the Custodian under the Custodial Agreements) that is not remedied within three business days after notice; and 74 • CCCFA fails to promptly exercise its right to suspend all commodity deliveries under the Clean Energy Purchase Contracts to the Project Participant in the event it fails to pay when due any amounts owed to CCCFA thereunder.
Elective Termination of the Electricity Supplier Commodity Swaps. Each of the following events of default and termination events would provide the non-defaulting party or the non-affected party the right to terminate the Electricity Supplier Commodity Swaps if it is not cured within the applicable cure period:
• if a party becomes subject to certain insolvency events in the manner specified in the Electricity Supplier Commodity Swaps;
• a credit support default with respect to the Commodity Swap Counterparty or the Electricity Supplier;
• any reduction in the Counterparty’s Credit Rating (as defined above) below certain specified minimum ratings;
• the amendment, without the Commodity Swap Counterparty’s consent, of (a) certain provisions of the Master Power Supply Agreements relating to the termination or assignment thereof or that would (in the Commodity Swap Counterparty’s reasonable opinion) have certain effects on the termination of the Commodity Swaps or (b) certain provisions of the Receivables Purchase Provisions relating to the purchase of any Swap Deficiency Call Receivables Amount by the Electricity Supplier; • a party’s failure to pay amounts when due under the Electricity Supplier Commodity Swaps (notwithstanding any payments made by the Custodian under the Custodial Agreements) that is not remedied within one business day after notice.
Other Listed Events. The Commodity Swaps contain other listed events (including breach or repudiation, misrepresentation, illegality and certain tax and credit events) that do not give CCCFA, the Electricity Supplier or the Commodity Swap Counterparty the right to designate an early termination date, but which permit the non-defaulting party or the non-affected party to pursue such equitable remedies, including specific performance, as may be available.
Replacement of Commodity Swaps. See “THE MASTER POWER SUPPLY AGREEMENTS – Replacement of Commodity Swaps” for a description of certain provisions of the Indenture and the Master Power Supply Agreements regarding the replacement of a Commodity Swap that is terminated or subject to termination.
Commodity Swap Custodial Agreements
The Electricity Supplier will enter into a Custodial Agreement, dated as of the Initial Issue Date (the “Electricity Supplier Custodial Agreement”), with the Commodity Swap Counterparty and U.S. Bank Trust Company, National Association, as Trustee and as custodian (in such capacity, the “Custodian”), to administer payments under the Electricity Supplier Commodity Swaps. CCCFA will enter into a Custodial Agreement, dated as of the Initial Issue Date (the “CCCFA Custodial Agreement,” and together with the Electricity Supplier Custodial Agreement, the “Custodial Agreements”), with the Commodity Swap Counterparty, the Trustee and the Custodian, to administer payments under the CCCFA Commodity Swaps.
The Custodial Agreements contain provisions designed to mitigate risks to CCCFA and Bondholders resulting from a failure of the Commodity Swap Counterparty to make payments to CCCFA under the CCCFA Commodity Swaps, and mitigate risks to the Electricity Supplier resulting from a failure of the Commodity Swap Counterparty to make payments to the Electricity Supplier under the Electricity Supplier Commodity Swaps.
75 Payments made by the Electricity Supplier under the Electricity Supplier Commodity Swaps, if any, will be made to a custodial account maintained by the Custodian under the Electricity Supplier Custodial Agreement. Such amounts will not be released until the Custodian has confirmed that the amount payable to CCCFA by the Commodity Swap Counterparty under the CCCFA Commodity Swaps for such month has been paid. If the Commodity Swap Counterparty does not make a required payment under the CCCFA Commodity Swaps and such payment remains unpaid after the expiration of any grace period, the Custodian will pay the amount that the Electricity Supplier paid under the Electricity Supplier Commodity Swaps (which such amount is held in custody) to the Trustee for deposit in the Revenue Fund and that payment will be treated as a Commodity Swap Receipt. Additionally, if the Electricity Supplier Commodity Swaps terminate, the Electricity Supplier will continue to make payments to the custodial account as if the Electricity Supplier Commodity Swaps were still in effect until the earlier of (i) replacement of the Commodity Swaps in accordance with the requirements of the Master Power Supply Agreements and (ii) the occurrence of an Electricity Delivery Termination Date under the Master Power Supply Agreements, and such payments will be used to ensure that CCCFA receives deposits in the Revenue Fund as described in the preceding sentence in the event that the Commodity Swap Counterparty does not make a required payment under the CCCFA Commodity Swaps.
Payments made by CCCFA under the CCCFA Commodity Swaps, if any, will be made to a custodial account maintained by the Custodian under the CCCFA Custodial Agreement. Such amounts will be paid to the Commodity Swap Counterparty on each date when due, provided that, if prior to any such date, the Electricity Supplier has provided written notice to the Custodian to hold such payment (a “Hold Notice”) the Custodian shall withdraw such amounts only upon written confirmation from the Electricity Supplier that the amount payable to the Electricity Supplier by the Commodity Swap Counterparty under the Electricity Supplier Commodity Swaps for such month has been paid. If the Commodity Swap Counterparty does not make a required payment under the Electricity Supplier Commodity Swaps and the Custodian has received a Hold Notice, and such payment remains unpaid after the expiration of any grace period, the Custodian will pay the amount that CCCFA paid under the CCCFA Commodity Swaps (which such amount is held in custody) to the Electricity Supplier. Additionally, if the CCCFA Commodity Swaps terminate, CCCFA will continue to make payments to the custodial account as if the CCCFA Commodity Swaps were still in effect until the earlier of (i) replacement of the Commodity Swaps in accordance with the requirements of the Master Power Supply Agreements and (ii) the occurrence of an Electricity Delivery Termination Date under the Master Power Supply Agreements, and such payments will be withdrawn by the Custodian and paid to the Electricity Supplier.
THE COMMODITY SWAP COUNTERPARTY
Set forth below is certain information regarding the Commodity Swap Counterparty. CCCFA assumes no responsibility for such information and cannot guarantee the accuracy thereof. Under no circumstance is the Commodity Swap Counterparty obligated to pay any amount owed in respect of the Bonds.
[RBC to update]
Royal Bank of Canada (referred to in this section as “Royal Bank”) is a Schedule I bank under the Bank Act (Canada), which constitutes its charter and governs its operations. Royal Bank’s corporate headquarters are located at Royal Bank Plaza, 200 Bay Street, Toronto, Ontario, M5J 2J5, Canada, and its head office is located at 1 Place Ville Marie, Montreal, Quebec, H3B 3A9, Canada.
Royal Bank is a global financial institution with a purpose-driven, principles-led approach to delivering leading performance. Our success comes from the 101,000+ employees who leverage their imaginations and insights to bring our vision, values and strategy to life so we can help our clients thrive and communities prosper. As Canada’s biggest bank, and one of the largest in the world based on market 76 capitalization, we have a diversified business model with a focus on innovation and providing exceptional experiences to our more than 19 million clients in Canada, the U.S. and 27 other countries.
Royal Bank had, on a consolidated basis, as at January 31, 2026, total assets of C$2,342.4 billion (approximately US$1,719.3 billion1
), equity attributable to shareholders of C$139.8 billion (approximately US$102.6 billion1
) and total deposits of C$1,542.2 billion (approximately US$1,132 billion1). The foregoing figures were prepared in accordance with International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board (IASB) and have been extracted and derived from, and are qualified by reference to, Royal Bank’s unaudited Interim Condensed Consolidated Financial Statements included in its quarterly Report to Shareholders for the fiscal period ended January 31, 2026.
The senior long-term debt2 of Royal Bank has been assigned ratings of A (stable outlook) by S&P Global Ratings, A1 (stable outlook) by Moody’s Investors Service and AA- (stable outlook) by Fitch Ratings. The legacy senior long-term debt3 of Royal Bank has been assigned ratings of AA- by S&P Global Ratings, Aa1 by Moody’s Investors Service and AA by Fitch Ratings. Royal Bank’s common shares are listed on the Toronto Stock Exchange and the New York Stock Exchange under the trading symbol “RY.” Its preferred shares are listed on the Toronto Stock Exchange.
On written request, and without charge, Royal Bank will provide a copy of its most recent publicly filed Annual Report on Form 40-F, which includes audited Consolidated Financial Statements, to any person to whom this Official Statement is delivered. Requests for such copies should be directed to Investor Relations, Royal Bank of Canada, by writing to 200 Bay Street, South Tower, Toronto, Ontario, M5J 2J5, Canada, or by calling 416-842-2000, or by visiting rbc.com/investorrelations4 .
The delivery of this Official Statement does not imply that there has been no change in the affairs of Royal Bank since the date hereof or that the information contained or referred to herein is correct as at any time subsequent to its date.
__________________
1 As at January 31, 2026: C$1.00 = US$0.734
2 Includes senior long-term debt issued on or after September 23, 2018 which is subject to conversion under the Canadian Bank Recapitalization (Bail-in) regime. 3 Includes senior long-term debt issued prior to September 23, 2018 and senior long-term debt issued on or after September 23, 2018 which is excluded from the Bail-in regime. 4 This website URL is an inactive textual reference only, and none of the information on the website is incorporated in this Official Statement. The foregoing information regarding the Commodity Swap Counterparty has been obtained from sources CCCFA believes to be reliable, but CCCFA assumes no responsibility for the content thereof.
CONTINUING DISCLOSURE
CCCFA
CCCFA will enter into a Continuing Disclosure Undertaking (the “Undertaking”) for the benefit of the beneficial owners of the Bonds to send certain information annually and to provide notice of certain events to the MSRB’s EMMA system for municipal securities disclosures, pursuant to the requirements of Section (b)(5) of Rule 15c2-12 (“Rule 15c2-12”) adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as amended.
A failure by CCCFA to comply with the Undertaking will not constitute an event of default under the Indenture or the Bonds and Beneficial Owners of the Bonds shall only be entitled to the remedies for any such failure described in the Undertaking. A failure by CCCFA to comply with the Undertaking must be reported in accordance with Rule 15c2-12 and must be considered by any broker, dealer or municipal securities dealer before recommending the purchase or sale of the Bonds in the secondary market. 77 Consequently, such a failure may adversely affect the transferability and liquidity of the Bonds and their market price.
The Undertaking and commitments of CCCFA described under this heading and in APPENDIX E hereto to furnish the above-described documents and information are agreements and commitments solely of CCCFA, and the Underwriter has no responsibility to ensure that CCCFA complies with any such Undertaking or commitment. In addition, the Underwriter makes no representation that any such documents or information will be furnished, or that any such documents or information so furnished will be accurate or complete, or sufficient for the purposes for which they may be used.
CCCFA has previously entered into continuing disclosure undertakings pursuant to Rule 15c2-12.
CCCFA has adopted a written policy that sets forth procedures for compliance with the federal tax and continuing disclosure requirements applicable to its bonds. The policy includes, among other things, procedures that are intended to promote CCCFA’s compliance with the Undertaking.
During the five-year period preceding the date of this Official Statement, CCCFA has determined that certain financial information relating to one of its project participants for its fiscal year ended June 30, 2021 and unaudited financial statements for its fiscal year ended December 31, 2023 were filed late.
CCCFA subsequently filed such information and unaudited financial statements on the Municipal Securities Rulemaking Board Electronic Municipal Market Access System (“EMMA”). CCCFA has engaged BLX Group to assist with its continuing disclosure obligations.
Project Participant
Pursuant to its Clean Energy Purchase Contracts, the Project Participant has agreed to provide to CCCFA certain annual operating and financial information, which information will enable CCCFA to comply with the Undertaking. Failure of the Project Participant to provide such information is not a default under the Clean Energy Purchase Contracts, but any such failure entitles CCCFA to take such actions and to initiate such proceedings as shall be necessary to cause the Project Participant to comply with its undertaking as set forth in the Clean Energy Purchase Contracts.
LITIGATION
There are no legal proceedings pending against CCCFA relating to the issuance, sale or delivery of the Bonds which could adversely affect the Clean Energy Project. In addition, there is no litigation pending or, to the knowledge of CCCFA, threatened against or affecting CCCFA or in any way questioning or in any manner affecting the validity or enforceability against CCCFA of the Bonds, the Clean Energy Purchase Contracts, the Master Power Supply Agreements, the CCCFA Commodity Swaps, the Receivables Purchase Provisions, the Investment Agreements, the Custodial Agreements, the Indenture, or the pledge of the Trust Estate under the Indenture.
The Project Participant reports that there is no litigation pending or, to its knowledge, threatened against it questioning or in any manner affecting the validity or enforceability of the Clean Energy Purchase Contracts.
FINANCIAL STATEMENTS
CCCFA’s audited financial statements for the [fiscal year ended December 31, 2024] are available on the MSRB’s EMMA system described above, and are hereby incorporated by reference into this Official Statement.
78 The Project Participant’s audited financial statements for the fiscal years ended June 30, 2025 and 2024 are attached hereto as APPENDIX B. Sorren CPAs P.C. has provided its consent for the inclusion of the Project Participant’s audited financial statements for the fiscal years ended June 30, 2025 and 2024 in this Official Statement.
Pursuant to the Undertaking described under “CONTINUING DISCLOSURE” above, CCCFA has agreed to file its audited financial statements and the audited financial statements of the Project Participant, commencing with its audited financial statements for its [fiscal year ended December 31, 2025] and the Project Participant’s audited financial statements for its fiscal years ended June 30, 2026 and 2025, on the MSRB’s EMMA system described above.
MUNICIPAL ADVISOR
PFM Financial Advisors LLC, Los Angeles, California (the “Municipal Advisor”), has served as financial advisor to the Project Participant in connection with Clean Energy Project and the Bonds. Among other responsibilities, the Municipal Advisor has provided advice and recommendations to the Project Participant with respect to the structure, timing, terms of and similar matters relating to the Bonds, bond market conditions, costs of issuance and other matters relating to the Bonds and the Clean Energy Project.
An affiliate of the Municipal Advisor has also provided advice and recommendations to CCCFA, and has served as CCCFA’s “qualified independent representative” with respect to the CCCFA Commodity Swaps.
The Municipal Advisor has reviewed this Official Statement, but has not audited, authenticated or otherwise verified the information set forth herein, and makes no guaranty, warranty or representation with respect to the accuracy and completeness of the information contained in this Official Statement. The Municipal Advisor’s fees are contingent upon the sale and delivery of the Bonds.
UNDERWRITING
Goldman Sachs & Co. LLC, as Underwriter (the “Underwriter”), pursuant to the purchase contract relating to the Bonds between CCCFA and the Underwriter, has agreed, subject to certain conditions, to purchase the Bonds from CCCFA at an aggregate purchase price of $[_____________] (representing the principal amount of the Bonds, plus original issue premium of $[_____________], less underwriter’s discount of $[___________]). The obligation of the Underwriter to purchase the Bonds is subject to certain terms and conditions set forth in the purchase contract. The Underwriter is obligated to purchase all the Bonds if any are purchased. The Bonds may be offered and sold to certain dealers and others at prices lower than the initial offering prices, and such initial offering prices may be changed from time to time by the Underwriter. The Underwriter has no obligations other than those that are set forth in the purchase contract. The payment of the Bonds is not guaranteed by the Underwriter.
Goldman Sachs & Co. LLC (together with its affiliates) is a full service financial institution engaged in various activities, which may include sales and trading, commercial and investment banking, advisory, investment management, investment research, principal investment, hedging, market making, brokerage and other financial and non-financial activities and services. Goldman Sachs & Co. LLC and its affiliates have provided, and may in the future provide, a variety of these services to CCCFA and to persons and entities with relationships with CCCFA, for which they received or will receive customary fees and expenses.
In the ordinary course of its various business activities, Goldman Sachs & Co. LLC and its affiliates, officers, directors and employees may purchase, sell or hold a broad array of investments and actively trade securities, derivatives, loans, Electricity, currencies, credit default swaps and other financial instruments for their own accounts and for the accounts of their customers, and such investment and trading 79 activities may involve or relate to assets, securities and/or instruments of CCCFA (directly, as collateral securing other obligations or otherwise) and/or persons and entities with relationships with CCCFA.
Goldman Sachs & Co. LLC and its affiliates may also communicate independent investment recommendations, market color or trading ideas and/or publish or express independent research views in respect of such assets, securities or instruments and may at any time hold, or recommend to clients that they should acquire, long and/or short positions in such assets, securities and instruments.
CERTAIN RELATIONSHIPS
The Electricity Supplier, which is also the lender under the Funding Agreement, the Receivables Purchaser and a party to the Electricity Purchase, Sale and Service Agreements and the Electricity Supplier Commodity Swaps, is wholly owned by J. Aron. J. Aron is the sole member of the Electricity Supplier, the electricity seller under the Electricity Purchase, Sale and Service Agreements, and is a wholly-owned subsidiary of GSG. The payment obligations of J. Aron to the Electricity Supplier under the Electricity Purchase, Sale and Service Agreements are unconditionally guaranteed by GSG under the EPSSA Guaranty. Goldman Sachs & Co. LLC, an Underwriter of the Bonds, is also a wholly owned subsidiary of GSG.
None of the Electricity Supplier, J. Aron nor GSG has guaranteed or is responsible for the payment of the Bonds. The obligations of the Electricity Supplier are limited to those set forth in the Master Power Supply Agreements, the Receivables Purchase Provisions and the Electricity Supplier Commodity Swaps.
The obligations of J. Aron are limited to those set forth in the Electricity Purchase, Sale and Service Agreements. None of the Electricity Supplier, J. Aron nor GSG takes any responsibility for the information set forth in this Official Statement other than the information set forth under the caption “GSG, J. ARON AND THE ELECTRICITY SUPPLIER.”
RATING
Moody’s Investors Service, Inc. is [expected] to assign a municipal bond rating of “[Aa2]” to the Bonds.
CCCFA has furnished to each rating agency that is expected to rate the Bonds certain information, including information not included in this Official Statement, about CCCFA and the Bonds. Generally, a rating agency bases its ratings on that information and on independent investigations, studies and assumptions made by each rating agency. A securities rating is not a recommendation to buy, sell or hold securities. There is no assurance that a rating, once obtained, will continue for any given period of time or that it will not be revised downward or withdrawn entirely if, in the opinion of the rating agency, circumstances so warrant. Any such downward revision or withdrawal could have an adverse effect on the marketability or market price of the Bonds. CCCFA has not undertaken any responsibility after issuance of the Bonds to assure the maintenance of the ratings applicable thereto or to oppose any revision or withdrawal of such ratings.
TAX MATTERS
In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to CCCFA, based upon an analysis of existing laws, regulations, rulings and court decisions, and assuming, among other matters, the accuracy of certain representations and compliance with certain covenants, interest on the Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 (the “Code”) and is exempt from State of California personal income taxes. Bond Counsel is of the further opinion that interest on the Bonds is not a specific preference item for purposes of the 80 federal individual alternative minimum tax. Bond Counsel observes that interest on the Bonds included in adjusted financial statement income of certain corporations is not excluded from the federal corporate alternative minimum tax. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the Bonds. A complete copy of the proposed form of opinion of Bond Counsel is set forth in APPENDIX F hereto.
To the extent the issue price of any maturity of the Bonds is less than the amount to be paid at maturity of such Bonds (excluding amounts stated to be interest and payable at least annually over the term of such Bonds), the difference constitutes “original issue discount,” the accrual of which, to the extent properly allocable to each Beneficial Owner thereof, is treated as interest on the Bonds which is excluded from gross income for federal income tax purposes and exempt from State of California personal income taxes. For this purpose, the issue price of a particular maturity of the Bonds is the first price at which a substantial amount of such maturity of the Bonds is sold to the public (excluding bond houses, brokers, or similar persons or organizations acting in the capacity of Underwriter, placement agents or wholesalers).
The original issue discount with respect to any maturity of the Bonds accrues daily over the term to maturity of such Bonds on the basis of a constant interest rate compounded semiannually (with straight-line interpolations between compounding dates). The accruing original issue discount is added to the adjusted basis of such Bonds to determine taxable gain or loss upon disposition (including sale, redemption, or payment on maturity) of such Bonds. Beneficial Owners of the Bonds should consult their own tax advisors with respect to the tax consequences of ownership of Bonds with original issue discount, including the treatment of Beneficial Owners who do not purchase such Bonds in the original offering to the public at the first price at which a substantial amount of such Bonds is sold to the public.
Bonds purchased, whether at original issuance or otherwise, for an amount higher than their principal amount payable at maturity (or, in some cases, at their earlier call date) (“Premium Bonds”) will be treated as having amortizable bond premium. No deduction is allowable for the amortizable bond premium in the case of bonds, like the Premium Bonds, the interest on which is excluded from gross income for federal income tax purposes. However, the amount of tax-exempt interest received, and a Beneficial Owner’s basis in a Premium Bond, will be reduced by the amount of amortizable bond premium properly allocable to such Beneficial Owner. Beneficial Owners of Premium Bonds should consult their own tax advisors with respect to the proper treatment of amortizable bond premium in their particular circumstances.
The Code imposes various restrictions, conditions and requirements relating to the exclusion from gross income for federal income tax purposes of interest on obligations such as the Bonds. CCCFA has made certain representations and covenanted to comply with certain restrictions, conditions and requirements designed to ensure that interest on the Bonds will not be included in federal gross income.
Inaccuracy of these representations or failure to comply with these covenants may result in interest on the Bonds being included in gross income for federal income tax purposes, possibly from the date of original issuance of the Bonds. The opinion of Bond Counsel assumes the accuracy of these representations and compliance with these covenants. Bond Counsel has not undertaken to determine (or to inform any person) whether any actions taken (or not taken), or events occurring (or not occurring), or any other matters coming to Bond Counsel’s attention after the date of issuance of the Bonds may adversely affect the value of, or the tax status of interest on, the Bonds. Accordingly, the opinion of Bond Counsel is not intended to, and may not, be relied upon in connection with any such actions, events or matters.
Although Bond Counsel is of the opinion that interest on the Bonds is excluded from gross income for federal income tax purposes and is exempt from State of California personal income taxes, the ownership or disposition of, or the accrual or receipt of amounts treated as interest on, the Bonds may otherwise affect a Beneficial Owner’s federal, state or local tax liability. The nature and extent of these other tax consequences depends upon the particular tax status of the Beneficial Owner or the Beneficial 81 Owner’s other items of income or deduction. Bond Counsel expresses no opinion regarding any such other tax consequences.
Current and future legislative proposals, if enacted into law, clarification of the Code or court decisions may cause interest on the Bonds to be subject, directly or indirectly, in whole or in part, to federal income taxation or to be subject to or exempted from state income taxation, or otherwise prevent Beneficial Owners from realizing the full current benefit of the tax status of such interest. The introduction or enactment of any such legislative proposals, or clarification of the Code or court decisions may also affect, perhaps significantly, the market price for, or marketability of, the Bonds. Prospective purchasers of the Bonds should consult their own tax advisors regarding the potential impact of any pending or proposed federal or state tax legislation, regulations or litigation, as to which Bond Counsel expresses no opinion.
The opinion of Bond Counsel is based on current legal authority, covers certain matters not directly addressed by such authorities, and represents Bond Counsel’s judgment as to the proper treatment of the Bonds for federal income tax purposes. It is not binding on the Internal Revenue Service (“IRS”) or the courts. Furthermore, Bond Counsel cannot give and has not given any opinion or assurance about the future activities of CCCFA, or about the effect of future changes in the Code, the applicable regulations, the interpretation thereof or the enforcement thereof by the IRS. CCCFA has covenanted, however, to comply with the requirements of the Code.
Bond Counsel’s engagement with respect to the Bonds ends with the issuance of the Bonds, and, unless separately engaged, Bond Counsel is not obligated to defend CCCFA or the Beneficial Owners regarding the tax-exempt status of the Bonds in the event of an audit examination by the IRS. Under current procedures, the Beneficial Owners would have little, if any, right to participate in the audit examination process. Moreover, because achieving judicial review in connection with an audit examination of tax-exempt bonds is difficult, obtaining an independent review of IRS positions with which CCCFA legitimately disagrees may not be practicable. Any action of the IRS, including but not limited to selection of the Bonds for audit, or the course or result of such audit, or an audit of bonds presenting similar tax issues, may affect the market price for, or the marketability of, the Bonds, and may cause CCCFA or the Beneficial Owners to incur significant expense.
Payments on the Bonds generally will be subject to U.S. information reporting and possibly to “backup withholding.” Under Section 3406 of the Code and applicable U.S. Treasury Regulations issued thereunder, a non-corporate Beneficial Owner of Bonds may be subject to backup withholding with respect to “reportable payments,” which include interest paid on the Bonds and the gross proceeds of a sale, exchange, redemption, retirement or other disposition of the Bonds. The payor will be required to deduct and withhold the prescribed amounts if (i) the payee fails to furnish a U.S. taxpayer identification number (“TIN”) to the payor in the manner required, (ii) the IRS notifies the payor that the TIN furnished by the payee is incorrect, (iii) there has been a “notified payee underreporting” described in Section 3406(c) of the Code or (iv) the payee fails to certify under penalty of perjury that the payee is not subject to withholding under Section 3406(a)(1)(C) of the Code. Amounts withheld under the backup withholding rules may be refunded or credited against a Beneficial Owner’s federal income tax liability, if any, provided that the required information is timely furnished to the IRS. Certain Beneficial Owners (including among others, corporations and certain tax-exempt organizations) are not subject to backup withholding. The failure to comply with the backup withholding rules may result in the imposition of penalties by the IRS.
APPROVAL OF LEGAL MATTERS
The validity of the Bonds and certain other legal matters are subject to the approving opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to CCCFA. A complete copy of the proposed form of the opinion of Bond Counsel is contained in APPENDIX F to this Official Statement. 82 Certain legal matters will be passed upon for CCCFA by its General Counsel; for the Project Participant by Chapman and Cutler LLP; for the Electricity Supplier by its counsel, Sheppard, Mullin, Richter & Hampton LLP; for GSG by its counsel, Sullivan & Cromwell LLP; for the Funding Recipient by its counsel, Cleary Gottlieb Steen & Hamilton LLP; and for the Underwriter by its counsel, Nixon Peabody LLP.
CCCFA will receive an opinion from counsel to the Project Participant on the date of original delivery of the Bonds, to the effect that the Clean Energy Purchase Contracts have been duly authorized, executed and delivered by the Project Participant and constitutes the legal, valid and binding obligation of the Project Participant enforceable in accordance with its terms. The enforceability of the Clean Energy Purchase Contracts may be limited by or subject to applicable bankruptcy, insolvency, moratorium, reorganization, other laws affecting creditors’ rights generally and by general principles of equity, public policy and commercial reasonableness.
MISCELLANEOUS
Any statements in this Official Statement involving matters of opinion, estimates or forecasts, whether or not expressly so stated, are intended as such and not as representations of fact. The Appendices attached hereto are an integral part of this Official Statement and must be read in conjunction with the foregoing material. This Official Statement is not to be construed as a contract or agreement between CCCFA and the purchasers or owners of the Bonds.
The delivery of this Official Statement has been duly authorized by the Board of Directors of CCCFA.
CALIFORNIA COMMUNITY CHOICE FINANCING AUTHORITY
By: __________________________________________
A-1
APPENDIX A
—
THE PROJECT PARTICIPANT
PIONEER COMMUNITY ENERGY
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B-1
APPENDIX B
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AUDITED FINANCIAL STATEMENTS OF THE PROJECT PARTICIPANT FOR FISCAL YEARS ENDED JUNE 30, 2025 AND 2024
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C-1
APPENDIX C
—
DEFINITIONS OF CERTAIN TERMS
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APPENDIX D
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SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE
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E-1
APPENDIX E
—
FORM OF CONTINUING DISCLOSURE UNDERTAKING
FOR THE PURPOSE OF PROVIDING
CONTINUING DISCLOSURE INFORMATION
UNDER SECTION (B)(5) OF RULE 15C2-12
[closing date]
This Continuing Disclosure Undertaking (the “Agreement”) is executed and delivered by California Community Choice Financing Authority (“CCCFA”) in connection with the issuance of its $[_____________] Clean Energy Project Revenue Bonds Series 2026[__] (Green Bonds) (the “Bonds”).
The Bonds are being issued pursuant to a Trust Indenture, dated as of [_______] 1, 2025 (the “Indenture”), between CCCFA and U.S. Bank Trust Company, National Association, as trustee.
In consideration of the issuance of the Bonds by CCCFA and the purchase of such Bonds by the beneficial owners thereof, CCCFA covenants and agrees as follows:
1. Purpose of This Agreement. This Agreement is executed and delivered by CCCFA as of the date set forth below, for the benefit of the beneficial owners of the Bonds and in order to assist the Participating Underwriter in complying with the requirements of the Rule (as defined below). CCCFA represents that it will be the only “obligated person” within the meaning of the Rule with respect to the Bonds at the time the Bonds are delivered to the Participating Underwriter and that no other person is expected to become so committed at any time after the issuance of the Bonds.
2. Definitions.
a. The terms set forth below shall have the following meanings in this Agreement, unless the context clearly otherwise requires.
“Annual Financial Information” means the financial information and operating data described in Exhibit I.
“Annual Financial Information Disclosure” means the dissemination of disclosure concerning Annual Financial Information and the dissemination of the Audited Financial Statements as set forth in Section 4.
“Audited Financial Statements” means collectively, the audited financial statements of CCCFA and the Project Participant, each prepared pursuant to the standards and as described in Exhibit I. “Business Day” means any day other than (a) a Saturday or Sunday, or (b) a day on which commercial banks in New York, New York or the cities in which are located the designated corporate trust offices of the Dissemination Agent or the designated operational office of CCCFA are authorized by law or executive order to close.
“Commission” means the United States Securities and Exchange Commission. “Dissemination Agent” means any agent designated as such in writing by CCCFA and which has filed with CCCFA a written acceptance of such designation, and such agent’s successors and assigns.
E-2
“Electricity Supplier” means Aron Energy Prepay 66 LLC and its successors and permitted assigns.
“EMMA” means the MSRB through its Electronic Municipal Market Access system for municipal securities disclosure or through any other electronic format or system prescribed by the MSRB for purposes of the Rule.
“Exchange Act” means the Securities Exchange Act of 1934, as amended. “Final Official Statement” means the Final Official Statement dated [_______], 2026, relating to the Bonds.
“Financial Obligation” means (a) a debt obligation, (b) a derivative instrument entered into in connection with, or pledged as security or a source of payment for, an existing or planned debt obligation, or (c) a guarantee of an obligation or instrument described in clause (a) or (b) of this definition; provided, however, the term Financial Obligation does not include municipal securities as to which a final official statement has been provided to the MSRB consistent with the Rule. “Ledger Event” has the meaning assigned to such term in Exhibit C to the Master Power Supply Agreements.
“Master Power Supply Agreements” means the Master Power Supply Agreements dated as of [____________], 2026 between the Electricity Supplier and CCCFA. “Monthly Ledger Report” means the copies of the ledgers maintained by the Electricity Supplier pursuant to Exhibit C of the Master Power Supply Agreements and delivered each month to CCCFA pursuant to Section 9(b)(i) of such Exhibits.
“MSRB” means the Municipal Securities Rulemaking Board. “Non-Private Business Sales Ledger” and “Private Business Sales Ledger” have the meanings assigned to such terms in Exhibit C to the Master Power Supply Agreements. “Participating Underwriter” means each broker, dealer or municipal securities dealer acting as an underwriter in the primary offering of the Bonds. “Reportable Event” means the occurrence of any of the Events with respect to the Bonds set forth in Exhibit II.
“Reportable Events Disclosure” means dissemination of a notice of a Reportable Event as set forth in Section 5.
“Rule” means Rule 15c2-12 adopted by the Commission under the Exchange Act, as the same may be amended from time to time.
“Undertaking” means the obligations of CCCFA pursuant to Sections 4 and 5. b. Capitalized terms used and not otherwise defined herein shall have the meanings assigned to them in the Indenture.
E-3
3. CUSIP Numbers. The CUSIP Numbers of the Bonds are as follows:
MATURITY
([__] 1)
PRINCIPAL
AMOUNT
CUSIP
NUMBER
$
CCCFA will include the CUSIP Numbers (or applicable CUSIP Number) in all disclosures described in Sections 4 and 5 of this Agreement.
4. Annual Financial Information Disclosure. Subject to Section 9 of this Agreement, CCCFA hereby covenants that it will disseminate or cause to be disseminated on its behalf its Annual Financial Information and the Audited Financial Statements (in the form and by the dates set forth in Exhibit I) to EMMA in such manner and format and accompanied by identifying information as is prescribed by the MSRB or the Commission at the time of delivery of such information and by such time so that such entities receive the information by the dates specified. If any part of the Annual Financial Information can no longer be generated because the operations to which it is related have been materially changed or discontinued, CCCFA will disseminate a statement to such effect as part of the Annual Financial Information for the year in which such event first occurs.
If any amendment or waiver is made to this Agreement, the Annual Financial Information for the year in which such amendment is made (or in any notice or supplement provided to EMMA) shall contain a narrative description of the reasons for such amendment and its impact on the type of information being provided.
5. Reportable Events Disclosure. Subject to Section 8 of this Agreement, CCCFA hereby covenants that it will disseminate in a timely manner (not in excess of ten business days after the occurrence of the Reportable Event) Reportable Events Disclosure to EMMA in such manner and format and accompanied by identifying information as is prescribed by the MSRB or the Commission at the time of delivery of such information. References to “material” in Exhibit II refer to materiality as it is interpreted under the Exchange Act. MSRB Rule G-32 requires all EMMA filings to be in word-searchable PDF format. Notwithstanding the foregoing, notice of optional or unscheduled redemption of any Bonds or defeasance of any Bonds need not be given under this Agreement any earlier than the notice (if any) of such redemption or defeasance is given to the Bondholders pursuant to the Indenture.
6. Consequences of Failure of CCCFA to Provide Information. CCCFA shall give notice in a timely manner to EMMA of any failure to provide Annual Financial Information Disclosure when the same is due hereunder.
In the event of a failure of CCCFA to comply with any provision of this Agreement, the beneficial owner of any Bond may seek mandamus or specific performance by court order, to cause CCCFA to comply with its obligations under this Agreement. The beneficial owners of 25% or more in principal amount of the Bonds outstanding may challenge the adequacy of the information provided under this Agreement and seek specific performance by court order to cause CCCFA to provide the information as required by this Agreement. A default under this Agreement shall not be deemed an Event of Default under the Indenture, E-4
and the sole remedy under this Agreement in the event of any failure of CCCFA to comply with this Agreement shall be an action to compel performance.
7. Amendments; Waiver. Notwithstanding any other provision of this Agreement, CCCFA by resolution authorizing such amendment or waiver, may amend this Agreement, and any provision of this Agreement may be waived, if:
(a)
(i) The amendment or waiver is made in connection with a change in circumstances that arises from a change in legal requirements, including without limitation pursuant to a “no-action” letter issued by the Commission, change in law, or change in the identity, nature, or status of CCCFA, or type of business conducted; or
(ii) This Agreement, as amended, or the provision, as waived, would have complied with the requirements of the Rule at the time of the primary offering, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; and
(b) The amendment or waiver does not materially impair the interests of the beneficial owners of the Bonds, as determined either by parties unaffiliated with CCCFA (such as the Trustee), or by approving vote of Bondholders pursuant to the terms of the Indenture at the time of the amendment.
In the event that the Commission, the MSRB or other regulatory authority shall approve or require Annual Financial Information Disclosure or Reportable Events Disclosure to be made to a central post office, governmental agency or similar entity other than EMMA or in lieu of EMMA, CCCFA shall, if required, make such dissemination to such central post office, governmental agency or similar entity without the necessity of amending this Agreement.
8. Termination of Undertaking. The Undertaking of CCCFA shall be terminated hereunder if CCCFA no longer has any legal liability for any obligation on or relating to repayment of the Bonds under the Indenture. CCCFA shall give notice to EMMA in a timely manner if this Section is applicable.
9. Dissemination Agent. CCCFA may, from time to time, appoint or engage a Dissemination Agent to assist it in carrying out its obligations under this Agreement, and may discharge any such Dissemination Agent with or without appointing a successor Dissemination Agent.
10. Additional Information. Nothing in this Agreement shall be deemed to prevent CCCFA from disseminating any other information, using the means of dissemination set forth in this Agreement or any other means of communication, or including any other information in any Annual Financial Information Disclosure or notice of occurrence of a Reportable Event, in addition to that which is required by this Agreement. If CCCFA chooses to include any information from any document or notice of occurrence of a Reportable Event in addition to that which is specifically required by this Agreement, CCCFA shall have no obligation under this Agreement to update such information or include it in any future disclosure or notice of occurrence of a Reportable Event. If the name of CCCFA is changed, CCCFA shall disseminate such information to EMMA.
11. Beneficiaries. This Agreement has been executed in order to assist the Participating Underwriter in complying with the Rule; however, this Agreement shall inure solely to the benefit of CCCFA, the Dissemination Agent, if any, and the beneficial owners of the Bonds, and shall create no rights in any other person or entity.
E-5
12. Recordkeeping. CCCFA shall maintain records of all Annual Financial Information Disclosure and Reportable Events Disclosure, including the content of such disclosure, the names of the entities with whom such disclosure was filed and the date of filing such disclosure.
13. Assignment. CCCFA shall not transfer its obligations under the Indenture unless the transferee agrees to assume all obligations of CCCFA under this Agreement or to execute an Undertaking under the Rule.
14. Governing Law. This Agreement shall be governed by the laws of the State of California.
CALIFORNIA COMMUNITY CHOICE FINANCING AUTHORITY
By____________________________________________
Its
E-6
EXHIBIT I
ANNUAL FINANCIAL INFORMATION AND TIMING AND AUDITED
FINANCIAL STATEMENTS
“Annual Financial Information” means financial information and operating data with respect to the Clean Energy Project, including:
(a) with respect to the Project Participant updated information under the headings [“Customers – General,” “Customers – Cumulative Opt-Out Rate and Customer Retention,” “Service Rates – Current and Historical Rate Information,” “Sources of Energy – Energy Purchases,” and “Financial Information – Revenues from Energy Sales and Operating Expenses”] set forth in APPENDIX A to the Official Statement; (b) the quantities of Electricity from the Clean Energy Project sold by CCCFA, whether to Project Participant or others; and
(c) such other information and data as CCCFA may deem necessary in order to comply with the requirements of the Rule.
“Audited Financial Statements” means the audited financial statements of CCCFA and the Project Participant, in each case for the most recent fiscal year (commencing with the fiscal year ended December 31, 2025 for CCCFA, and commencing with the fiscal year ended June 30, 2026 for the Project Participant), in each case prepared in accordance with generally accepted accounting principles as promulgated to comply with governmental entities from time to time (or such other accounting principles as may be applicable to CCCFA and the Project Participant, as the case may be, in the future pursuant to applicable law).
All or a portion of the Annual Financial Information and the Audited Financial Statements set forth above may be included by reference to other documents which have been submitted to EMMA or filed with the Commission. If the information included by reference is contained in a final official statement, the final official statement must be available on EMMA. The final official statement need not be available from the Commission. CCCFA shall clearly identify each such item of information included by reference.
Annual Financial Information with respect to the Project Participant will be submitted to EMMA by 200 days after end of the Project Participant’s fiscal year, commencing with its fiscal year ending June 30, 2026.
Annual Financial Information with respect to CCCFA (i.e., the information described in clauses (b) and (c) of the definition of Annual Financial Information) will be submitted to EMMA by 200 days after end of CCCFA’s fiscal year, commencing with its fiscal year ending December 31, 2025.
Audited Financial Statements as described above should be filed at the same times as the Annual Financial Information for the Project Participant and CCCFA. If Audited Financial Statements are not available when such Annual Financial Information is filed, unaudited financial statements shall be included.
Audited Financial Statements will be submitted to EMMA no later than 30 days after availability to CCCFA.
If any change is made to the Annual Financial Information as permitted by Section 4 of the Agreement, CCCFA will disseminate a notice of such change as required by Section 4.
E-7
EXHIBIT II
EVENTS WITH RESPECT TO THE BONDS
FOR WHICH REPORTABLE EVENTS DISCLOSURE IS REQUIRED
1. Principal and interest payment delinquencies
2. Non-payment related defaults, if material
3. Unscheduled draws on debt service reserves reflecting financial difficulties
4. Unscheduled draws on credit enhancements reflecting financial difficulties
5. Substitution of credit or liquidity providers, or their failure to perform
6. Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax status of the security, or other material events affecting the tax status of the security
7. Modifications to the rights of security holders, if material
8. Bond calls, if material, and tender offers
9. Defeasances
10. Release, substitution or sale of property securing repayment of the securities, if material
11. Rating changes
12. Bankruptcy, insolvency, receivership or similar event of CCCFA. ∗
13. The consummation of a merger, consolidation, or acquisition involving CCCFA or the sale of all or substantially all of the assets of CCCFA, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material
14. Appointment of a successor or additional trustee or the change of name of a trustee, if material
15. Incurrence of a Financial Obligation of CCCFA, if material, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of CCCFA, any of which affect security holders, if material ∗ This event is considered to occur when any of the following occur: the appointment of a receiver, fiscal agent or similar officer for CCCFA in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of CCCFA, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of CCCFA.
E-8
16. Default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a Financial Obligation of CCCFA, any of which reflect financial difficulties
17. The receipt by CCCFA of a Monthly Ledger Report that includes a credit to any Non-Private Business Sales Ledger or any Private Business Sales Ledger that has not been reversed within twelve months of the date of such credit, if such outstanding amount within any twelve-month period is greater than $5 million
18. The receipt by CCCFA of a Monthly Ledger Report that shows that a Ledger Event has occurred
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F-1
APPENDIX F
—
FORM OF OPINION OF BOND COUNSEL
__________, 2026
California Community Choice Financing Authority
San Rafael, California
California Community Choice Financing Authority
Clean Energy Project Revenue Bonds, Series 2026[__] (Term Rate) (Final Opinion)
Ladies and Gentlemen:
We have acted as bond counsel to the California Community Choice Financing Authority (the “Issuer”) in connection with the issuance of $[_____________] aggregate principal amount of California Community Choice Financing Authority Clean Energy Project Revenue Bonds, Series 2026[__] (Term Rate) (the “Bonds”), issued pursuant to a Trust Indenture, dated as of [__________] 1, 2026 (the “Indenture”), between the Issuer and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). The Indenture provides that the Bonds are issued for the purpose of financing the Cost of Acquisition of the Clean Energy Project. Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the Indenture.
In such connection, we have reviewed the Indenture, the Master Power Supply Agreements, the Clean Energy Purchase Contracts, the Commodity Swap, the Seller Swap (as defined in the Master Power Supply Agreements), the Tax Certificate and Agreement, dated the date hereof (the “Tax Certificate”), of the Issuer, opinions of counsel to the Issuer and the Trustee, certificates of the Issuer, the Trustee and others, and such other documents, opinions and matters to the extent we deemed necessary to render the opinions set forth herein.
The opinions expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such opinions may be affected by actions taken or omitted or events occurring after original delivery of the Bonds on the date hereof. We have not undertaken to determine, or to inform any person, whether any such actions are taken or omitted or events do occur or any other matters come to our attention after original delivery of the Bonds on the date hereof. Accordingly, this letter speaks only as of its date and is not intended to, and may not, be relied upon or otherwise used in connection with any such actions, events or matters. Our engagement with respect to the Bonds has concluded with their issuance, and we disclaim any obligation to update this letter. We have assumed the genuineness of all documents and signatures provided to us and the due and legal execution and delivery of each such document by each party thereto other than the Issuer and that each such document constitutes a valid and binding agreement of such party. We have assumed, without undertaking to verify, the accuracy of the factual matters represented, warranted or certified in the documents, and of the legal conclusions contained in the opinions, referred to in the second paragraph hereof. Furthermore, we have assumed compliance with all covenants and agreements contained in the Indenture, the Master Power Supply Agreements, the Clean Energy Purchase Contracts, and the Tax Certificate, including (without limitation) covenants and agreements compliance with which is necessary to assure that future actions, omissions or events will not cause interest on the Bonds to be included in gross income for federal income tax purposes. We call attention to the fact that the rights and obligations under the Bonds, the Indenture, the Master Power Supply Agreements, the Clean Energy Purchase Contracts, the F-2
Commodity Swap, the Seller Swap, and the Tax Certificate and their enforceability may be subject to bankruptcy, insolvency, receivership, reorganization, arrangement, fraudulent conveyance, moratorium and other laws relating to or affecting creditors’ rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against governmental entities such as the Issuer in the State of California. We express no opinion with respect to any indemnification, contribution, liquidated damages, penalty (including any remedy deemed to constitute a penalty), right of set-off, arbitration, judicial reference, choice of law, choice of forum, choice of venue, non-exclusivity of remedies, waiver or severability provisions contained in the foregoing documents, nor do we express any opinion with respect to the state or quality of title to or interest in any of the property described in or as subject to the lien of the Indenture or the accuracy or sufficiency of the description contained therein of, or the remedies available to enforce liens on, any such property. Our services did not include financial or other non-legal advice. Finally, we undertake no responsibility for the accuracy, completeness or fairness of the Official Statement or other offering material relating to the Bonds and express no view with respect thereto.
Based on and subject to the foregoing, and in reliance thereon, as of the date hereof, we are of the following opinions:
1. The Bonds constitute the valid and binding limited obligations of the Issuer.
2. The Indenture has been duly executed and delivered by, and constitutes the valid and binding agreement of, the Issuer. The Indenture creates a valid pledge, to secure the payment of the principal of and interest on the Bonds, of the Trust Estate, subject to the provisions of the Indenture permitting the application thereof for the purposes and on the terms and conditions set forth in the Indenture, including without limitation the pledge of the Commodity Reserve Account and the amounts and investments on deposit therein in favor of the Commodity Swap Counterparty and the Project Participant.
3. Interest on the Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 and is exempt from State of California personal income taxes. Interest on the Bonds is not a specific preference item for purposes of the federal individual alternative minimum tax. We observe that interest on the Bonds included in adjusted financial statement income of certain corporations is not excluded from the federal corporate alternative minimum tax. We express no opinion regarding other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the Bonds.
Faithfully yours,
ORRICK, HERRINGTON & SUTCLIFFE LLP
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G-1
APPENDIX G
—
BOOK-ENTRY SYSTEM
The Depository Trust Company (“DTC”), New York, New York, will act as securities depository for the Bonds. The Bonds will be issued as fully-registered securities registered in the name of Cede & Co. (DTC’s partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully-registered bond certificate will be issued for each maturity of the Bonds, each in the aggregate principal amount of such maturity, and will be deposited with DTC. If, however, the aggregate principal amount of any maturity of the Bonds exceeds $500 million, one certificate will be issued with respect to each $500 million of principal amount and an additional certificate will be issued with respect to any remaining principal amount of such maturity.
DTC, the world’s largest securities depository, is a limited-purpose trust company organized under the New York Banking Law, a “banking organization” within the meaning of the New York Banking Law, a member of the Federal Reserve System, a “clearing corporation” within the meaning of the New York Uniform Commercial Code, and a “clearing agency” registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC’s participants (“Direct Participants”) deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book-entry transfers and pledges between Direct Participants’ accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly owned subsidiary of The Depository Trust & Clearing Corporation (“DTCC”). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly (“Indirect Participants”). DTC has a Standard & Poor’s rating of AA+. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com
Purchases of Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the Bonds on DTC’s records. The ownership interest of each actual purchaser of each Bond (“Beneficial Owner”) is in turn to be recorded on the Direct and Indirect Participants’ records.
Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners.
Beneficial Owners will not receive certificates representing their ownership interests in Bonds, except in the event that use of the book-entry system for the Bonds is discontinued.
To facilitate subsequent transfers, all Bonds deposited by Direct Participants with DTC are registered in the name of DTC’s partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership.
DTC has no knowledge of the actual Beneficial Owners of the Bonds; DTC’s records reflect only the identity of the Direct Participants to whose accounts such Bonds are credited, which may or may not be G-2
the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers.
Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of Bonds may wish to take certain steps to augment transmission to them of notices of significant events with respect to the Bonds, such as redemptions, tenders, defaults, and proposed amendments to the Bond documents. For example, Beneficial Owners of Bonds may wish to ascertain that the nominee holding the Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of the notices be provided directly to them.
Redemption notices shall be sent to DTC. If less than all of the Bonds within a maturity of the Bonds are being redeemed, DTC’s practice is to determine by lot the amount of the interest of each Direct Participant in such maturity to be redeemed.
Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Bonds unless authorized by a Direct Participant in accordance with DTC’s MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to CCCFA of securities as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.’s consenting or voting rights to those Direct Participants to whose accounts such Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy).
Redemption proceeds and payments of principal and interest on the Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC’s practice is to credit Direct Participants’ accounts upon DTC’s receipt of funds and corresponding detail information from CCCFA or the Trustee on the payable date in accordance with their respective holdings shown on DTC’s records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in “street name,” and will be the responsibility of such Participant and not of DTC, CCCFA or the Trustee, subject to any statutory or regulatory requirements as may be in effect from time to time.
Payment of redemption proceeds and principal and interest to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of CCCFA or the Trustee, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to Beneficial Owners will be the responsibility of Direct and Indirect Participants.
DTC may discontinue providing its services as depository with respect to the Bonds at any time by giving reasonable notice to CCCFA or the Trustee. Under such circumstances, in the event that a successor depository is not obtained, Bond certificates are required to be printed and delivered.
CCCFA may decide to discontinue use of the system of book-entry-only transfers through DTC (or a successor securities depository). In that event, Bond certificates are required to be printed and delivered to DTC.
The information in this section concerning DTC and DTC’s book-entry system has been obtained from sources that CCCFA believes to be reliable, but CCCFA takes no responsibility for the accuracy thereof.
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H-1
APPENDIX H
—
REDEMPTION PRICE OF THE BONDS
The following table sets forth the Redemption Price of the Bonds (being the Amortized Value of the Bonds, but excluding accrued interest which is payable from the amounts required to be on deposit in the Debt Service Account) upon an extraordinary mandatory redemption in whole following an Early Termination Payment Date under the Master Power Supply Agreements, as of the redemption dates shown below during the Initial Interest Rate Period. For any extraordinary mandatory redemption in part, the Redemption Price of the Bonds to be redeemed will be the Amortized Value of such Bonds, plus accrued interest to the redemption date.
REDEMPTION DATE REDEMPTION PRICE * REDEMPTION DATE REDEMPTION PRICE* * Amortized Value of the Bonds as of each Redemption Date. [This Page Intentionally Left Blank]
I-1
APPENDIX I
—
SCHEDULE OF TERMINATION PAYMENTS
The following table sets forth the Schedule of Termination Payments under the Master Power Supply Agreements as of the specified Early Termination Payment Dates during the Initial Interest Rate Period. The Early Termination Payment Date is the Business Day preceding the date listed below.
DATE * TERMINATION PAYMENTS DATE* TERMINATION PAYMENTS
* If any Early Termination Payment Date is not a Business Day, the Termination Payments are due on the preceding Business Day.
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J-1
APPENDIX J
—
SECOND PARTY OPINION REGARDING GREEN BONDS DESIGNATION
K-1
APPENDIX K
—
CERTAIN INFORMATION REGARDING [_________]
[TO BE PROVIDED]
[Remainder of Page Intentionally Left Blank]
Staff Report – Item 3
To: The Governing Board
From: Brad Koehn, Director of Finance and Administration Item 3: Proposed Fiscal Year 2026-27 Budget
Date: 5/21/2026
RECOMMENDATION
Receive a presentation on the Proposed Fiscal Year 2026-27 Budget and provide direction as appropriate. The Recommended Budget will be brought to the Board for approval at the June 18, 2026 Board meeting.
AUDIT & FINANCE COMMITTEE REVIEW
The Audit & Finance Committee members received a staff presentation of the Proposed FY 2026-27 Budget at the May 11, 2026 meeting. The members provided feedback on the presentation which, along with the Board feedback received today, will be incorporated in the Recommended Budget that will be presented to the Board in June.
BACKGROUND
The Proposed Budget is the first review of Pioneer Community Energy’s (“Pioneer”) operating budget by the Governing Board (“Board”) with staff incorporating feedback and recommendations from this review into the FY 2026-27 Recommended Budget for adoption at the June Board meeting. The FY 2026-27 Budget is effective July 1, 2026.
Rate Reductions
Pioneer enters the new Fiscal Year with a rate structure that has been lowered consecutively three times: a rate reduction in July 2024; a second rate reduction in March 2025; and finally, effective March 2026, a rate reduction of 16%. Effective April 2026, a temporary Power Charge Indifference Adjustment (“PCIA”) offset credit was authorized by the Board for customers that exceed 7 million kWh usage with the goal of retaining large load customers, whose departure would adversely impact all customers because of stranded energy costs.
Preparation for Expansion
Expansion into an additional 16 communities with service beginning in October 2027 requires a significant ramping up of resources to have a successful launch. Lessons have been learned from the previous expansion to El Dorado County and later, in 2024, the Grass Valley and Nevada City expansion: recognizing that a successful expansion launch necessitates multiple communication ‘touches’ through various channels and that Pioneer in-person meetings have been critical in educating future customers about the transition to Pioneer.
ANALYSIS & DISCUSSION
The rate reductions and the upcoming expansion are two very important factors in the development of the FY 26-27 Budget. Fortunately, over the last few fiscal years, Pioneer’s Reserves have been built up to a position where Pioneer can navigate these two factors while continuing to offer a lower generation rate than PG&E. At the same time, the exceptionally high PCIA that PG&E charges Pioneer’s customers in 2026 is a competitive challenge. The 2026-27 Budget does rely on a $28 million drawdown of Reserves to accommodate the 16% rate reduction and PCIA offset bill credit. The Proposed Budget projects total revenues of $199.1 million (a Plf)NEER
COMMUNITY ENERGY
Agenda Item: 3 Agenda Date: 5/21/2026
decrease of $46.5 million from the original FY 25-26 Budget) and total power expenses at $203.3 million (a decrease of $17.8 million from the original FY 25-26 Budget).
The table below summarizes the proposed budget at a high level:
FY 2025-26 FY 2026-27 Variance
$ in Millions Adopted Budget Proposed Budget $ %
Revenues $245.59 $199.15 ($46.44) -18.9%
Power Supply $221.15 $203.28 ($17.87) -8.1%
Contribution Margin $24.44 ($4.13) ($28.58) -116.9%
Operating Expenses $21.90 $22.83 $0.93 4.2%
Operating Margin $2.54 ($26.96) ($29.50) -1161.2%
Non-Operating Net Expenses $2.4 $1.10 ($1.30) -54.2%
Contribution To Net Position $0.14 ($28.06) ($28.20) -20029.0% Revenues
Pioneer receives most of its revenue through
rates ($187.4 million). Revenues reflect the
rate change effective March 2026 and the
PCIA Offset Credit effective April 2026. The
budget assumes no changes to rates. There
is a forecasted $8.7 million contribution from
Congestion Revenue Rights (“CRRs”) and the
Battery Optimization efforts. CRRs are
financial instruments that are issued to
Pioneer from CAISO that are intended to
offset/manage variability in congestion
costs. CRRs are acquired primarily for
offsetting integrated forward market
congestion costs that occur in the day-ahead
market and are charged to Pioneer by
CAISO. The Battery Optimization effort
optimizes battery charge and discharge for
the Yellow Pine Solar/Battery project.
Interest earnings are Pioneer’s third revenue
generator; while only reflective of just under
3% of revenue, the $5.6 million in interest
gains generated from Pioneer’s increased
cash position and higher interest rates are
still notable. Pioneer does not receive any
subsidies from our member agencies.
Energy Sales
(Net)
93%
CRR's &
Battery
Optimization
4%
Interest
Earnings
3%
Revenues: $199.1 million
Agenda Item: 3 Agenda Date: 5/21/2026
Expenses
Pioneer’s power supply costs represent the most
significant expenses, reflecting 89% of total
expenses. The majority of remaining expenses
include compensation, consultant services and
other operating expenses (such as rent, lease,
utilities, insurance, CalCCA membership,
software and professional development), which
overall comprise a much smaller portion of the
budget.
Notable Operating Expense Adjustments
Power Supply Costs
Power supply costs decreased by about $17.8 million compared to the prior fiscal year original budget, as energy market prices have declined, especially Resource Adequacy. Consistent with prior fiscal years, an extreme weather event contingency of $10 million is also included in the power supply budget.
Projected Expansion Costs
Preparation for the planned expansion to 16 new communities during the Fall of 2027 has also had an impact on the proposed budget:
1. Office Facility Expansion - Expanded facility capacity has been acquired, with tenant improvements currently underway, to serve both Board meeting and office space needs since the 2510 Warren Drive facility is at capacity. The proposed budget programmed office furniture for the new workspaces and Board room with furniture, along with needed IT and audio/visual equipment. In addition, lease and utility costs for the new facility are included, which wasn’t needed in the prior fiscal year.
2. New Personnel
a. Power Resources - The expansion will also increase Pioneer’s energy load, with customer accounts anticipated to more than double. This increased demand will require increased staffing capacity to secure and manage new energy/RA/REC contracts to serve the new customers. b. Communications - The significant increase in new customers will also require additional dedicated staff capacity (as well as increased marketing and communication resources) to introduce Pioneer to its existing and future customers and support their needs. c. HR/Administration - With a growing team, dedicated internal human resources and administrative support are also increasingly important.
3. Communication Division – Pioneer will need to be introduced itself to the new customers in the 16 communities. This will require a variety of approaches to reach those customers through direct mail, advertisements, social media and also in-person introductions in group and community settings.
Power Supply,
89%
Financing
Consultant Costs, 1%
Services, 4%
Operating
Expenses, 2%
Compensation, 4%
Expenses: $227.2 million
Agenda Item: 3 Agenda Date: 5/21/2026
Personnel
Fiscal Year 2025-26 ended the year with 26 full-time positions and one part-time position. The Fiscal Year 2026- 27 Budget proposes an addition of the following 7 full-time positions resulting in a total of 33 full-time positions and 5 part-time/seasonal positions:
a) Power Resources or Data Manager
b) Community Outreach Specialist (2)
c) Communications Coordinator (2)
d) Director of Human Resources
e) Executive Assistant (January 2027 start)
This staff increase in the Power Procurement, Communications and Customer Care Divisions is requested to prepare Pioneer and its future customers for a successful launch. The Director of Human Resources would provide the needed human resources expertise needed for a growing organization. The Executive Assistant would provide support to the CEO and also transition some tasks from the Board Clerk to provide capacity for serving 16 additional communities and future Board members.
The FY 26-27 salary and benefit cost for the addition of the seven positions is estimated to be $1.65 million.
The organizational chart on the following page illustrates the changes in the Proposed Budget:
Agenda Item: 3 Agenda Date: 5/21/2026
General Counsel
Chief Operating
Officer
Legil>IO~ve &
Reg ulOtOf)'
Monoger
LoglslObVO&
Regulatory
AtlolyS! II
Loglsla &
Regulatory
Anclyst I
log is lativo &:
Ragulatofy
In m
Progrcms
Monc,gor
ColCCA
(AC2Vococy Sones)
Logisla o/
Rogulotary Logo!
Counsol
Sta te
Lobtlyist
Vonous Program
Contrcctors
Po'/1/0r ~soureos
Monagor
l F><lwftr
Rasourcos
MOl'yS! II
Monc,gor. Quam:.
Analysis&
odol g
Power Supply
Contn:lc
Manager
Power Resources/
OClto Manager
Scho<lufng
Coordinator
PoWor
Procurement
Consul ng
CRR8rakor
Bo ry
Op ·mization
Sorvica
Governing Board
Chief Executive Officer Financial Auditor
Executive
Assistant
Board Clerk/
Executive Assistant
Director of Finance
& Administration
Director of Huma.n
Resources
lnformo Ion
Tocnndlogy
Motyl:!I
lnformo ion
TocMology
Sorviais
Custoc:1101
Sorvloos
ln!0<mo ion
TocMology
Auditor
LEGEND:
Control or
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Agenda Item: 3 Agenda Date: 5/21/2026
Division Comparisons
The budget comparison between Fiscal Year 2025-26 and Fiscal Year 2026-27 by Division and in aggregate for Compensation, Consultant Services and Operating Expenses has significant swings in both the positive and negative directions. This is especially the case when comparing the 25-26 Mid-Year Adjusted Budgeted to the Proposed Budget. The Notable Operating Expense Adjustments that are discussed above are key drivers of those swings but there are other contributing factors such as increased costs for insurance, and certain CalCCA shared regulatory costs. In addition, Fiscal Year 25-26 had significant transfers between Divisions and between Division budget categories to fund the tenant improvements for the new facility that had not been known when the Budget was first adopted. The additional Division for Human Resources absorbs certain Human Resources costs that had previously lived in Administration and the Finance Divisions.
Financing Highlights
Line of Credit
Pioneer has established with Columbia Bank a Line of Credit for the purpose of issuing Letters of Credit to energy suppliers (including CAISO) when collateral is required, as well as to satisfy the Financial Security Requirement (FSR) required by the CPUC. The Letters of Credit allow Pioneer to avoid using cash as collateral thereby improving Pioneer’s liquidity position and increasing interest earnings. Appropriations of $1.1 million has been programmed for the Line and Letter of Credit costs.
Power Prepay
On October 20, 2022, the Board authorized Pioneer to execute a 30-Year Energy Prepayment Transaction (“Prepay”), which enables tax-exempt entities like Pioneer to bundle certain long-term power agreements into a long-term financial transaction for a discount on the associated power costs. Since additional power agreements under the Prepay will be included in the upcoming year, the estimated savings will increase from almost $1.7 million in Fiscal Year 25-26 to $2.1 million in Fiscal Year 26-27. These savings are reflected as a reduction to Power Supply costs. Pioneer is also preparing for a second Power Prepay Bond that could go to 0 5
10 15
20 25
30 Pioneer
(Proposed -
Expansion
Load)
3CE VCE AVA Pioneer
(Current)
SVCE Pioneer
(Proposed -
Current
Load)
PCE MCE SCP
# of Full-Time Employees per TWh of Load
• oata Pioneer
Pioneer
Pioneer
gathered (Proposed w/ 3CE VCE AVA
(Current)
SVCE (Proposed w/ PCE MCE SCP
May 2026 Expansion Load) current Load)
FTEs 33 52 9 ! 101 26 ! 67 I 33 62 118 54
TWh 3.8 5.5 0.7 ! 7.3 1.8 ' 3.9 '
' 1.8 3.4 6.1 2.1 .......... . ................ , .. -......... . ...................... , ... _. .. ...............
I ' Ratio 8.7 9.5 13.4 13.8 14.3 17.2 18.1 18.2 19.4 25.9 Agenda Item: 3 Agenda Date: 5/21/2026
market during the summer, depending on market conditions. The sizing of this Bond will be greater than the first Prepay Bond and Pioneer could realize multi-million dollar power savings in the Fiscal Year 2026-27 that could mitigate some portion of the projected contribution from reserves.
Reserves
At the June 2025 meeting, the Board revised the Reserve target from 160 days of liquidity to 270 days of liquidity. Pioneer achieved the new reserve target during the past fiscal year. Staff estimates, using Fiscal Year 26-27 proposed budget expenses to calculate the days of liquidity on hand, that Fiscal Year 25-26 will end with close to 287 days. The current projection for the end of Fiscal Year 26-27 (assuming existing rates and power expenses) is that Pioneer, even with the drawdown of Reserves, would still be over 240 days of liquidity by June 2027.
Pioneer’s healthy Reserve position allows Pioneer to weather the upcoming fiscal year while still maintaining customer generation rates that are at a discount to PG&E. mPOWER
Pioneer’s non-CCA mPOWER program was closed to new applications on August 31, 2021. Staff is working with Placer County to appropriately program a Fiscal Year 26-27 Budget for mPOWER. The mPOWER program is fully funded by assessments of the property owners that received improvements and is legally separate and distinct from the CCA energy operations funded by ratepayers. Ongoing assessment revenue, bond servicing costs and administration costs will continue until the last Bond is paid in full. The mPOWER budget will be included in the Recommended Budget to the Board in June.
FISCAL IMPACT
The Proposed FY 2026-27 Budget includes total revenues of $199.1 million and total expenses of $227.2 million and an expected drawdown of Reserves of $28.0 million. Projected June 30, 2027 days of liquidity is estimated to be 241 days.
ATTACHMENTS
1. Draft Proposed Fiscal Year 2026-27 Budget Summary
Attachment 1
Plf)NEER
COMMUNITY ENERGY
PIONEER COMMUNITY ENERGY (CCA)
Fiscal Year 2026-27 Proposed Budget Summary ------------------------------------------------------------- FY2025-26
FY2025-26 FY2026-27 Variance from Variance from
$ in Thousands
Adopted Midyear Budget Proposed Budget FY 26 Adopted Budget FY 26 Midyear Budget Revenues Budget
$ % $ %
Energy Sales (Net) $234,389,000 $215,101,717 $187,273,257 ($47,115,743) -20.1% ($27,828,460) -12.9% Green l 00 Sales $217,000 $147,684 $152,299 ($64,701) -29.8% $4,615 3.1% CRR & Batt ery Opt im izat ion $10,000,000 $8,700,000 $8,700,000 ($1,300,000) -13.0% $0 0.0% Less Uncollectable Account s ($3,167,181) ($2,905,867) ($2,530,245) $636,936 -20.1% $375,622 -12.9% Total Energy Revenues $241,438,819 $221,043,534 $193,595,311 ($47,843,508) -19.8% ($27,448,223) -12.4% Investment gains (losses) $4,150,000 $5,550,000 $5,550,000 $1,400,000 33.7% $0 0.0% Total Revenues $245,588,819 $226,593,534 $199,145,311 ($46,443,508) -18.9% ($27,448,223) -12.1% Energy Expenses
Power Supply $221,145,000 $206,171,746 $203,278,925 ($17,866,075) -8.1% ($2,892,821) -1.4% Operating Margin $24,443,819 $20,421,788 ($4,133,614) ($28,577,433) -116.9% ($24,555,402) -120.2% FY2025-26 Variance from Variance from FY2025-26 FY2026-27 OPERA TING EXPENSES Adopted
Midyear Budget Proposed Budget
FY 26 Adopted Budget FY 26 Midyear Budget
By Division Budget $ % $ %
Administration Total .............................................................. $2,466,750 ......... $2,783,800 ............ $2,481,591 ................ ~;-4,~:-i; .. 0.6% ....... ($302,209) . -10.9% Human Resouces Total ..................... $776,400 ............. $776,400 .................................. $776,400 ··· Finance Total ................................................................. .. .. ....... $2, 189,970. ......... $2,048,770 . ............ $2,173,614 .............. ($16,356) ... -0.7% ......... $124,844 .. 6.1% Power Procurement Total ..................................................... $5,046,280. . ... $3,858,280 . ...... ~<1,!:l!0,~~~ .............. 1$76,0871 .. -1.5% .... $1,111,913 .. 28.8% . Legislative. & .Regulatory Total ............................................ $1,310,507 ......... $1,300,507 ............ $1,498,804 . ............ $188,297 . 14.4% ......... $198,297 . 15.2% Customer Care Total ............................................................. $3,805,722 ......... $3,720,722 ............ $4,571,153 ...... p (l~,<1~~ ... 20.1% .. $850,431 22.9% Communications Total ... ........ ........ . ......... .. ....... $2,454,999 ......... $1,774,999 ............ $4,508,769 ......... $2,053,770 ... 83.7% ..... $2,733,770··· 154.0% Programs Total $4,628,776 $2,152,494 $1,848,953 ($2,779,823) -60.1% ($303,541) -14.1% By Expense Type Aggregation of all Divisions
Compensation $6,605,477 $6,215,477 $8,776,456 $2,170,979 32.9% $2,560,979 41.2% I Consultant Services $9,651,344 $7,712,824 $8,927,966 ($723,378) -7.5% $1,215,142 15.8% Operating Expenses $5,646,183 $3,711,271 $5,125,055 ($521,128) -9.2% $1,413,784 38.1% Total Operating Expenses $21,903,004 $17,639,572 $22,829,477 $926,473 4.2% $5,189,905 29.4% Debt Service
Term Loan Debt Services $950,000 $950,000 $0 ($950,000) -100.0% ($950,000) -100.0% Addiitonal Term Loan Principal $700,000 $700,000 $0 ($700,000) -100.0% ($700,000) -100.0% Line/Letter of Credit Fees $750,000 $750,000 $1,100,000 $350,000 46.7% $350,000 46.7% Financial Security Requirement $0 $0 $0 $0 0.0% $0 0.0% Debt Service Total $2,400,000 $2,400,000 $1,100,000 ($1,300,000) -54.2% ($1,300,000) -54.2% Total Expenses $245,448,004 $226,211,318 $227,208,401 ($18,239,603) -7.4% $997,083 0.4% Contribution to/(from) Net Position $140,815 $382,216 ($28,063,091) ($28,203,905) -20029.1% ($28,445,307) -7442.2%
Staff Report – Item 4
To: The Governing Board
From: Kristoffer Antigua, Power Supply Contracts Manager Item 4: Bioenergy Market Adjusting Tariff Projects Update Date: 4/16/2026
RECOMMENDATION
Receive an update from Pioneer Community Energy (Pioneer) staff regarding projects approved for the Bioenergy Market Adjusting Tariff (BioMAT).
BACKGROUND
In December 2015, the California Public Utilities Commission (CPUC) established BioMAT in response to Senate Bill (SB) 1122 directing large investor-owned utilities (IOUs) to collectively procure 250 megawatts of renewable energy from small-scale bioenergy projects. Although BioMAT was originally limited to California’s three large IOUs, Pioneer led the passage of Assembly Bill (AB) 843 in 2021 that allowed Community Choice Aggregators (CCAs) to also participate in BioMAT. The CPUC took over two years to implement AB 843, which left Pioneer less than a year and a half to participate in the program.
The purpose of BioMAT is to allow for diversification of California’s renewable energy portfolio while addressing critical environmental challenges such as wildfires. BioMAT has three distinct categories: Category 1 (biogas), Category 2 (dairy and agricultural waste), and Category 3 (sustainable forest management). Category 3 directly reduces wildfire risk by utilizing forest biomass as fuel for the power plants. Through long-term, fixed price contracts, developers can proceed with building power plants with financial certainty and the offtakers (including CCAs) can submit their above-market contract costs to the CPUC for BioMAT cost recovery. BioMAT had a sunset date of December 31, 2025, meaning any BioMAT application received after December 31, 2025, would not be considered.
This meant that Pioneer had less than a year and half to identify projects, resolve issues with the CPUC, investor-owned utilities, and BioMAT vendors, work with developers and City/County staff, and accomplish many other things to get projects approved and in the queue before the December 31, 2025, deadline. In the fall of 2025, Pioneer worked directly with the project developers and began receiving BioMAT applications, also known as Program Participation Requests (PPRs), from them.
ANALYSIS & DISCUSSION
Pioneer received a total of six PPRs and deemed them complete before the sunset date of December 31, 2025.
As shown in Table 1 below the PPRs consisted of five projects submitted by West Biofuels, and one project submitted by Phoenix Energy. West Biofuels submitted four Category 3 projects and one Category 2 project.
Phoenix Energy submitted one Category 3 project. The West Biofuels projects are in Grass Valley, Mariposa, Marysville, Quincy, and Biggs, and the Phoenix Energy project is in Arnold.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: 4 Agenda Date: 4/16/2026
Table 1
In January 2026, Pioneer and West Biofuels executed a BioMAT Power Purchase Agreement (BioMAT PPA) for the Mariposa project. The other five projects, submitted during the Final Period of BioMAT, remained “in queue” during the Final Period that ended on March 31, 2026. The Final Period allowed PPRs submitted on or before December 31, 2025 to remain eligible and be considered for a BioMAT PPA award as long as the remaining capacity allocations have not been exhausted. On April 1, 2026, Pioneer was notified that the five PPRs were conditional winners for a BioMAT PPA award and could proceed with a BioMAT PPA. Pioneer staff are actively working with West Biofuels and Phoenix Energy on executing the BioMAT PPAs and expect to execute the five BioMAT PPAs in April 2026.
As shown in Table 2 below, the total estimated annual cost for all six BioMAT PPAs is approximately $19.4 million and when reduced by the expected BioMAT subsidies totaling $17.0 million, it results in an expected net cost to Pioneer of $2.4 million.
Table 2
STRATEGIC PLAN
The recommendation supports the following strategic goals:
1. Be a Community Partner
2. Be Fiscally Strong and Resilient
3. Achieve Operational Optimization
FISCAL IMPACT
The net cost of the recommendation aligns with the normal cost of energy resulting in no fiscal impact to the budget.
ATTACHMENTS
There are no attachments to this report.
BioMAT
PPR # Applicant City County Category Size Award Status COD 221-01 West Biofuels Grass Valley Nevada Cat 3 3 MW conditional winner 10/1/2027 221-02 West Biofuels Marysville Yuba Cat 3 3 MW conditional winner 4/1/2028 221-03 West Biofuels Mariposa Mariposa Cat 3 3 MW PPA awarded 10/1/2027 221-05 West Biofuels Quincy Plumas Cat 3 3 MW conditional winner 10/1/2028 221-06 West Biofuels Biggs Butte Cat 2 3 MW conditional winner 4/1/2028 223-01 Phoenix Energy Arnold Calaveras Cat 3 3 MW conditional winner 12/1/2028 PPR # Developer Project Category Size BioMAT Price
Estimated Cost
per Year
Estimated BioMAT
Subsidy per Year
Estimated Net Cost
per Year
221-01 West Biofuels Grass Valley Cat 3 3 MW $ 199.72 $ 3,300,000 $ 2,900,000 $ 400,000 221-02 West Biofuels Marysville Cat 3 3 MW $ 199.72 $ 3,300,000 $ 2,900,000 $ 400,000 221-03 West Biofuels Mariposa Cat 3 3 MW $ 199.72 $ 3,300,000 $ 2,900,000 $ 400,000 221-05 West Biofuels Quincy Cat 3 3 MW $ 199.72 $ 3,300,000 $ 2,900,000 $ 400,000 221-06 West Biofuels Biggs Cat 2 3 MW $ 183.72 $ 2,900,000 $ 2,500,000 $ 400,000 223-01 Phoenix Energy Arnold Cat 3 3 MW $ 199.72 $ 3,300,000 $ 2,900,000 $ 400,000 $ 19,400,000 $ 17,000,000 $ 2,400,000
Staff Report – Item 5
To: The Governing Board
From: Gina Stassi-Vanacore, Director of Communications
Item 5: Update on 2026 Net Energy Metering/Solar Billing Plan Payments Date: 5/21/2026
RECOMMENDATION
Receive an update on 2026 Net Energy Metering/Solar Billing Plan payments
BACKGROUND
Pioneer Community Energy (“Pioneer”) adopted its Net Energy Metering (“NEM”) Policy in May 2018. The policy governs Pioneer’s process for NEM customers whose interconnection applications were received and processed by Pacific Gas and Electric (“PG&E”) before April 15, 2023. Customers with these solar installations are referred to as NEM 1.0 or NEM 2.0 customers.
On December 15, 2022, the California Public Utilities Commission established the Solar Billing Plan (“SBP” but also referred to as Net Billing Tariff, NBT or NEM 3.0). SBP directs the investor-owned utilities, including Pacific Gas & Electric (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. All NEM customers eventually will transition to SBP as their energy contracts end (typically 20 years after installation).
At its December 14, 2023 meeting, the Pioneer Board of Directors (“Board”) adopted a resolution approving a Solar Billing Plan Net Billing Tariff Policy. Pioneer’s policy is similar to PG&E’s policy, with the exception of Net Surplus Compensation (“NSC”). While PG&E plans to implement an Energy Export Credit Adjustment, or “claw back,” Pioneer will continue to pay the full NSC. Consistent with Pioneer’s NEM policy, SBP customers receive a premium for excess generation compared to PG&E.
In September 2025, the Board approved an updated NEM policy, separate from Pioneer’s SBP policy and only applicable to customers enrolled as NEM 1.0 and NEM 2.0. The policy update improves policy clarity and eases the administration of the NEM program. Policy updates include:
• Identifying April as the NSC month that will be used for calculating a customer’s credit to provide consistency in the calculation for all customers.
• Providing an 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. • Providing a benefit to net consumers or non-aggregated accounts for retail credits and Energy Export Credits.
• Providing an 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 allows more customers to receive the full benefit of their solar generation, even if they generate only a small credit amount at the annual true-up period. • Requiring customers no longer receiving Pioneer service to request a review and reconciliation of their Pioneer account within 90 days of the end of their Pioneer service. After 90 days, the 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 will be issued to the address provided by the customer.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: 5 Agenda Date: 5/21/2026
ANALYSIS & DISCUSSION
The 2026 annual NEM and SBP true-up process began in April, with all policy updates implemented.
For 2026, more than 26,000 accounts are receiving $1.25 million in checks or credits, compared to 11,470 accounts totaling $0.8 million in 2025. The year-to-year difference represents an increase of 127% in accounts receiving checks or credits. The increase in cash-outs and credits affirms that the updated policy is advantageous for customers.
Since 2018, 69,794 NEM and SBP accounts have received checks or credits totaling $5.3 million. # of accounts Amount sent
in checks
# of
accounts
Amount given
in credits
Thru 2025 30,482 $ 3,901,638.15 13,299 $ 166,732.02
2026 7,080 $ 956,906.47 18,933 $ 289,798.25
Cumulative 37,562 $ 4,858,545 32,232 $ 456,530.27
Additional account reconciliation will occur throughout the year, but staff anticipate changes will be nominal.
Notably, the number of Pioneer’s solar customers has increased significantly from 2025 to 2026, increasing from roughly 43,000 to more than 50,000.
STRATEGIC PLAN
Implementation of a revised NEM Policy is consistent with the strategic priority to Provide an Exceptional Customer Experience and to Achieve Operational Optimization.
FISCAL IMPACT
The cost of NEM and SBP cash-outs and credits varies from year to year, but the estimated cost for fiscal year 2025-26 is $1.25 million. This estimate was included in the FY 2025-26 Mid-Year Budget.
ATTACHMENTS
There are no attachments to the report.
Staff Report – Item 6
To: The Governing Board
From: Gina Stassi-Vanacore, Director of Communications
Item 6: Presentation on the Calpine Energy Solutions Community Benefits Give Back Program Date: 5/21/2026
RECOMMENDATION
Receive a presentation on the 2026 Calpine Energy Solutions Community Benefits Give Back grant program.
BACKGROUND
At its November 16, 2023 meeting, the Pioneer Community Energy (“Pioneer”) Board of Directors (“Board”) approved the extension of Pioneer’s contract with Calpine Energy Solutions (“Calpine”) for data management, billing and customer call center support for a three-year period beginning on January 1, 2024, and running through December 31, 2026.
In addition to specified services, the Calpine contract includes a grant program that allows for a three percent (3%) reinvestment into the communities Pioneer serves for each year of the contract. The amount is based on annual billing under the contract. The program is administered independently by Calpine, with some assistance from Pioneer staff.
In 2025, Calpine awarded $60,000 in grants to the following organizations: Feeding the Foothills ($25,000), KVMR radio ($25,000), and Silver Wishes ($10,000).
ANALYSIS & DISCUSSION
Calpine’s Community Benefits Give Back program is offering $70,000 in 2026, which reflects a 3% return on calendar year 2025 invoices from Calpine. Funds for this program are designated to provide financial support for IRS designated 501(c)3 non-profit organizations. Applicants must be in Pioneer’s service territory. Funding is not permitted for political action committees, trade associations, government entities, or political candidates.
A total of three to five awards ranging from $10,000 to $25,000 each are available under this program. Funding categories include research and planning related to wildfire mitigation; education; support for economically disadvantaged groups/individuals; and an “other” category for projects that do not fall into the above categories but align well with Pioneer’s mission.
Calpine will administer the program, including reviewing all applications and selecting the recipients. Pioneer will work cooperatively with Calpine to publicize funding availability and the application process to help drive application response; elevate Pioneer’s visibility; and reinforce our shared commitment to community partnership.
Applications will be available beginning June 1, 2026. Pioneer and Calpine will promote and host a joint webinar on Thursday, June 18, to answer questions. Completed applications must be received by July 13, 2026. Calpine will review all applications, and awards will be announced at Pioneer’s November 2026 Board meeting.
STRATEGIC PLAN
This effort aligns with Pioneer’s “Be a Community Partner” strategic priority.
FISCAL IMPACT
There is no fiscal impact with this report.
ATTACHMENTS
1. Community Benefits Grant Program 2026-27 Funding Application Plf)NEER
COMMUNITY ENERGY
Community Benefits Grant Program
2026-2027 Funding Application
As part of its ongoing commitment to local communities, Calpine Community Energy, in partnership with Pioneer Community Energy, is pleased to provide local financial support through its 2026 -2027 Community Benefits Grant Program. Qualifying entities must be IRS designated 501(c)3 non-profit organizations serving Pioneer’s service territory. Please note that funding is not permitted for political action committees, trade associations, government entities or political candidates. Awards will range from $10,000 to $25,000.
PLEASE SUBMIT YOUR APPLICATION BY 5PM PST JULY 13TH TO :
[email protected]
Evaluation Criteria
501(C)3 NON-PROFIT
ORGANIZATION’S IMPACT AND VISIBILITY IN PIONEER’S TERRITORY
EXTENT TO WHICH LOCAL COMMUNITY BENEFITS WILL BE DELIVERED IN ALIGNMENT WITH GRANT GOALS OF
SUPPORTING ECONOMICALLY DISADVANTAGED GROUPS/INDIVIDUALS, WORKFORCE DEVELOPMENT, RESEARCH/PLANNING FOR WILDFIRE MITIGATION, EDUCATION, AND OTHER ELIGIBLE ACTIVITIES.
TELL US ABOUT YOU
Name of Organization
Applicant’s Name
Applicant’s Title Organization Website
Phone Number
Street Address
EIN/Tax ID #
Organization Description/Mission (500 word maximum)
Email
Funding Amount Requested
¢.~~!~;ENERGY [ ]
'===============--
Plf)NEER
COMMUNITY ENERGY
FUNDING CATEGORY
Support for Economically Disadvantaged Groups/
Individuals
Research/Planning for Wildfire Mitigation
Education Workforce Development
Other (Please Specify)
Required Attachments:
A DETERMINATION LETTER FOR YOUR ORGANIZATION OR YOUR FISCAL SPONSOR IF WORKING WITH A FISCAL SPONSOR, YOUR FISCAL SPONSOR WILL NEED TO PROVIDE:
FISCAL SPONSORSHIP LETTER TAKING RESPONSIBILITY FOR YOUR ORGANIZATION’S FISCAL ADMINISTRATION.
LETTER OF REQUEST AUTHORIZING YOUR ORGANIZATION TO APPLY TO THE COMMUNITY BENEFITS GRANT FOR THE AMOUNT YOU ARE REQUESTING.
BUDGET OF PROPOSED PROJECT, PROGRAM, OR INITIATIVE (SEE ATTACHMENT A) COUNTIES SERVED:
CITIES/COMMUNITIES SERVED:
Auburn
Unincorporated Placer
County
Grass Valley
Lincoln
Unincorporated El
Dorado County
Nevada City
Placerville
Rocklin
Colfax Loomis
Grant funds may be used to support a specific program and/or general operations. Please provide a brief de-scription of how your organization proposes to use awarded funds. If requesting general operational support, include how it will support the funding categories you’ve selected above. Please attach a budget (Attachment 1), to assist the grant selection committee in understanding the proposed use of funding. (1000 word max).
PROPOSED USE OF FUNDS
I certify that our organization provides services in Pioneer’s service area(s) I certify that no one in our organization’s leadership is directly affiliated with Pioneer. If this is not the case, please specify:
I certify that our organization is a 501(c)3 non-profit in good standing with the Internal Revenue Service
ATTESTATIONS
SIGNATURE DATE
I certify that I will ensure reporting requirements are complete if selected to receive funding.
Attachment A. Sample Budget
ITEM(S) BUDGETED ($)
ACTUAL
(TO BE COMPLETED
ONE-YEAR POST
AWARD)
DIRECT COSTS
(HARD COSTS SUCH AS
SUPPLIES, EQUIPMENT,
PRINTING, ETC.)
STAFF LABOR COSTS
(NUMBER OF HOURS,
JOB TITLES, AND
HOURLY RATE OF ALL
STAFF THAT WILL WORK
ON THE PROJECT)
OTHER
(ANY COSTS THAT DO
NOT FIT INTO THE
ABOVE CATEGORIES)
Staff Report – Item IV-B
To: The Governing Board
From: Donald Eckert Jr., Chief Executive Officer
Item IV-B: CEO Report
Date: 5/21/2026
PERSONNEL
With regrets, Lee Ewing, Manager of Legislative and Regulatory Affairs, is leaving Pioneer with his last day May 14th. Lee brought extensive experience and expertise to his role and will be missed. The Pioneer team wishes him the best in his next endeavor.
An offer was accepted for the Programs Manager and look forward to introducing our newest employee to the Board at the June meeting.
The following are active recruitments:
• Manager of Legislative and Regulatory Affairs
• Customer Care Coordinator
CHIEF EXECUTIVE OFFICER AGREEMENTS EXECUTED (NON-POWER SUPPLY) The following agreements have been conducted by the Chief Executive Officer, consistent with the authority delegated by the Board:
• Consultant Services Agreement with Ultimate Building Maintenance for janitorial services at the Pioneer offices for a one-year term and optional one-year extensions for up to five years, effective April 9, 2026, for an annual total not to exceed $43,200. • Amendment No. 1 to Consultant Services Agreement of 4/29/2025 with Energy Mission Control dba FuSE Carbon Technologies adding Solar RECs program, effective February 18, 2026, FuSE will retain a commission equal to 10% of all Credits (CO2e) generated by Partner; FuSE agrees to revenue share 50% of the 10% commission with Pioneer for any Credits generated by its member agencies. FuSE will pay the amount of any sales price received by FuSE for sale of RECs to third parties less total fees payable by Pioneer ($4 for each REC assessed on the firs 300 RECs sold during each calendar quarter and $2 for REC assessed on all RECs in excess of 300 RECs sold during the same calendar quarter). • Consultant Services Agreement with Capital Network Solutions for managed Information Technology services and non-disclosure agreement for a one-year term, effective July 1, 2026, for an annual total not to exceed $99,000.
CITY OF SOUTH LAKE TAHOE UPDATE
Staff will be meeting with Liberty Utilities in early June. In parallel, staff is working through the various customer billing, regulatory, and power supply issues.
At the May 12th El Dorado Board of Supervisors meeting, the Board of Supervisors directed county staff to explore the Community Choice Aggregator option for the Tahoe area and appointed an Ad Hoc Committee with Supervisor Parlin and Supervisor Laine leading the effort.
The issue of the Tahoe region having to find a new power source due to the migration of existing power sources to service the growing data center market in Nevada has made national news including Fortune Magazine and Bloomberg.
Plf)NEER
COMMUNITY ENERGY
Agenda Item: IV-B Agenda Date: 5/21/2026
CALCCA ANNUAL CONFERENCE
The 2026 annual conference was held in Sacramento and included a celebration of CalCCA’s 10-year anniversary. I would like to thank our Board Chair and Vice Chair for attending. Pioneer’s Board Chair also kicked off the event with welcoming comments. Pioneer was a co-host of the event along with Valley Clean Energy and wanted to thank Gina and her team for their contributions to making the event very successful.
The 2027 conference will be in San Diego.
CHIEF EXECUTIVE OFFICER POWER SUPPLY CONTRACTS EXECUTIED There is no activity to report this month.
PRESENTATIONS AND RELEVANT MEETINGS ATTENDED BY THE CHIEF EXECUTIVE OFFICER
1. Participated in weekly/monthly CalCCA Board and Committee meetings
2. Participated and presented at the annual CalCCA conference
3. Participated in a presentation by River City Bank on AI Evolution in Marketing
4. Introduction to Nevada City’s new City Manager
5. Meeting with El Dorado County Supervisor Veerkamp on potential project
ATTACHMENTS
1. Agenda Planning Document
2. Legislative and Regulatory Report
3. Communications Report
4. Programs Report
Agenda Planning Document – Pioneer Community Energy ATTACHMENT 1 5-14-26
BOARD OF
DIRECTORS
MAY 21, 2026
REGULAR MEETING
3:00 PM
(Post Agenda: May 15)
JUNE 18, 2026
REGULAR MEETING
3:00 PM
(Post Agenda: June 12)
JULY 23, 2026
REGULAR MEETING
3:00 PM
(Post Agenda: July 17)
IN THE FUTURE
Special Meeting
Closed Session
2:45 PM – Closed Session
(Labor Negotiator) EE Health & Welfare
Diablo Canyon Tour
Regular Meeting
3:00 PM
Consent 1a Minutes for Approval-APR 16, 2026 Minutes for Approval-MAY 21, 2026 Minutes for Approval-JUN 18, 2026 RES Contract Renewal – Calpine (Koehn) 1b Receive Draft Financials MAR 2026
(Koehn)
Receive Draft Financials APR 2026
(Koehn)
Receive Draft Financials MAY 2026
(Koehn)
RES Yes Energy (Kang)
1c RES goods & services agreement (2540
furniture) (Koehn)
Joint Rates Mailer (JRM)
(Stassi-Vanacore)
Contract Renewals
Contract Renewal – Amperon (Kang)
Contract Renewal – cQuant (Kang)
Contract Renewal – Maher (Koehn)
Presentation
CAISO presentation-Summer Readiness
guest: Juan Buitrago (in person)
FUTURE DATE TBD - guest: Dr. Ahmad Faruqui
Regular 2 RES Prepay Bond Transaction
(action-Eckert)
guest: Michael Berwanger (Zoom)
PH & RES FY 2026-27 Budget (action- Koehn)RES IRP (Integrated Resource Plan) (action-Kang)
JUL PCIA Hedging (action-Kang)
3 FY 2026-27 Budget overview
(discussion-Koehn)
Microgrid Incentive Program (MIP)
Update (discussion-Kang)
RES EE Health & Welfare (action-Koehn) SEP RES Expansion Planning (action- Stassi-Vanacore)
SEP Power Content Label (Stassi-Vanacore)
4 BioMAT Projects update
(discussion-Kang)
Electric Vehicle Charging Investment
(action- Stassi-Vanacore)
RES contract with MOSAIC (action-Kang)OCT-NOV Calpine contract (action-GSV) NOV Calpine Grant Award (GSV)
5 Update on 2026 NEM Annual Cash-out
(discussion- Stassi-Vanacore)
IT Audit (discussion-Koehn) State of the Power Markets (discussion-Kang)RES Large Load Policy (action-Kang) 6 Kick-off of annual Calpine Grant Award
process (discussion- Stassi-Vanacore)
guest: Jhelum Bagchi (in person)
Update on South Lake Tahoe
(discussion-Eckert)
(GOV) Administrative Recommendations
(procedural)
RES Prepay Power Supply Budget
Amendment (action-Koehn)
(GOV) Administrative Recommendations
General Function II Chief Executive Officer’s Report
REG Reports: Leg/Reg; Communications; Programs;
Chief Executive Officer’s Report
REG Reports: Leg/Reg; Communications; Programs;
Chief Executive Officer’s Report
REG Reports: Leg/Reg; Communications; Programs;
Quarterly Updates:
Strategic Plan Objectives
Sponsorship Activity
Chief Executive Officer’s Report
QTRLY Updates requested by the Board
JAN – APR – JULY – OCT
Strategic Plan Objectives
Sponsorship Activity
Informational Items
Glossary of Terms
Informational Items
Glossary of Terms
Informational Items
Glossary of Terms
17 7
7 Agenda Planning Document – Pioneer Community Energy ATTACHMENT 1 5-14-26
AUDIT/FINANCE COMMITTEE TO BE SCHEDULED
in-person & remote locations IN THE FUTURE
Gary Petersen, Chair
Richard Pearl, Vice Chair
Greg Janda
Sean Lomen
David Ring
o May 11, 2026 Minutes
GOVERNANCE COMMITTEE JUNE 4, 2026 – 3:30 PM
in-person & remote locations IN THE FUTURE
Board - Chair
Board - Vice Chair
Committee Chairs
Board Chair, Ex Officio (prior year)
o (Closed Session-Labor Negotiator) EE Health & Welfare o December 17, 2025 Minutes
o Board Governance
ENERGY PROCUREMENT REVIEW
AD HOC COMMITTEE
TO BE SCHEDULED
zoom only IN THE FUTURE
Ryan Carter, Chair
Alice Dowdin Calvillo, Vice Chair
Anthony DeMattei
Sean Lomen
o Using Put Options as a PCIA Hedge (JAN-BOARD) Annual Appointment of EPRC Members (2027)
EXPANSION
AD HOC COMMITTEE
TO BE SCHEDULED
zoom only IN THE FUTURE
Alice Dowdin Calvillo, Chair
Tom Ivy, Vice Chair
Suzanne Jones
Lori Parlin
o Selection of Officers through 2026
o City of South Lake Tahoe
COMMUNITY ADVISORY COMMITTEE
TO THE CHIEF EXECUTIVE OFFICER JUNE 24, 2026 AUGUST 26, 2026 Meets on the 4th Wednesday
(even-numbered months)
Attachment: 2 Legislative and Regulatory Update
Date: 5/21/2026
Legislative Affairs
• The 2026 Legislative Session began on Monday, January 5, 2026 and is scheduled to end on August 31, 2026. In the near term, Pioneer will meet with its lobbyists, Niemela Pappas & Associates (NPA), to discuss priorities for this session and develop Pioneer’s Legislative Platform to bring to the Board for approval. Pioneer will continue to advocate for support of biomass development, but the budget and Cap and Invest funding shortfalls will limit any available funds available to support biomass. • Pioneer held its annual Lobby Day on February 10, 2026. Pioneer’s Staff, Board Chair, and Lobbyists met with ten state legislator offices including current and future constituent representatives, and broader biomass champions. Pioneer discussed its key legislative priorities for the upcoming year including affordability concerning the Power Charge Indifference Adjustment (PCIA) and ongoing biomass development efforts. Specifically, Pioneer asked for support on the PCIA Transparency bill, AB 1761 (Rogers) and the FOREST Fund Act, AB 706 (Aguiar-Curry). • March 6, 2026 – Pioneer submitted a letter of support for AB 1761 (Rogers), a bill sponsored by CalCCA that would promote energy affordability and rate stability by improving transparency in how the PCIA charge is calculated.
• March 31, 2026 – Pioneer submitted a letter of support for SB 1138 (Padilla), a bill sponsored by CalCCA that would require the Public Utilities Commission to allow load-serving entities to transact their resource adequacy (RA) load obligation on an hourly basis. This change would be aligned with the granularity of the RA program’s new slice-of-day (SOD) structure, which requires procurement compliance at the hourly, instead of previously monthly, level. Hourly load obligation trading would grant greater flexibility in meeting RA compliance and reduce unnecessary over-procurement which would lower costs for ratepayers.
• April 16, 2026 – Pioneer staff presented the 2026 Legislative Policy and Platform (Policy Platform) to the Board of Directors. Staff received approval from the Board to take positions on the following high priority bills, which are subject to change based on future legislative developments:
o “Support” position on AB 706 (Aguiar-Curry), AB 1761 (Rogers), AB 2266 (Schultz), SB 1138 (Padilla), SB 875 (Wiener)
o “Oppose” position on SB 1295 (Stern)
• April 23, 2026 – SB 875 (Wiener), a bill that would have made procedural reforms to reduce barriers in the process of municipalization in Pacific Gas & Electric Company (PG&E) territory, failed to pass out of the Senate Energy, Utilities, and Communications committee. Since the bill is effectively dead, Pioneer removed this bill from the high priority list within our Policy Platform. • April 27, 2026 – SB 1295 (Stern), a bill that would have required load serving entities to procure distributed energy storage resources to address local reliability and grid constraint issues, was significantly amended. The procurement prescriptions were paired down and the provisions that implicated CCAs were removed. Therefore, Pioneer de-escalated this bill from a “high; oppose” to a “moderate; watch” position on our Policy Platform.
• April 28, 2026 – Pioneer submitted a letter expressing an “oppose unless amended” position for SB 2383 (Zbur), a bill that would require the California Public Utilities Commission (CPUC) to establish separate and distinct tariffs for large load energy customers. The bill would also require that all load Plf)NEER
COMMUNITY ENERGY
[Publish Date] Agenda Date: 5/21/2026
serving entities (LSEs) serving large load customers use these specified, CPUC-jurisdictional tariffs.
Pioneer elevated this bill from a “moderate; watch” to a “high; oppose unless amended” position on our Policy Platform, due to the threat to CCA ratemaking autonomy that was presented through amendments to the bill. CalCCA’s Legislative Committee and Executive Board voted to take positions on the following bills:
o “Support if amended” position on AB 1975 (Schultz): This bill would require the CPUC to develop a methodology for calculating a distribution grid utilization metric (metric) and require electrical corporations to publicly report their metrics. It would also require the CPUC to establish metric targets, and periodically update them, in a manner to encourage electrification. Lastly, the bill would authorize the CPUC to direct electrical corporations to implement programs, rate designs, or other financial performance-based incentives or disincentives correlated to achieving the metric targets. CalCCA is seeking amendments to ensure that if CCAs administer programs or rate designs that contribute towards achieving the metric targets, CCAs will also be eligible to receive financial incentives accordingly. o “Support” position on AB 2111 (Papan): Currently, the CPUC, CEC, and CAISO work in coordination to develop long-term resource and transmission plans. This bill would require the CPUC, CEC, and CAISO to update their resource and transmission planning process to facilitate longer-term and more diversified scenario planning. The goal of this process change is to increase the state’s adaptability to a range of future scenarios, as well as improve resource interconnection timelines.
o “Support” position on AB 2234 (Papan): For the purposes of CEQA exemption, this bill would expand the definition of “geothermal exploratory project” to include equipment and activities necessary to establish interconnectivity between wells and reservoirs and relax the prohibition on exploratory wells within one-half mile of existing commercial wells. CalCCA previously supported another version of this bill, AB 527 (Papan) in 2025, which passed through both houses but was vetoed by the Governor.
o “Support” position on AB 2313 (Berman): This bill would require gas corporations to establish a Gas Distribution Service Line Replacement Alternatives Program, to provide residential gas customers served by a gas distribution line that is slated for an upgrade or replacement, with a monetary incentive to deploy gas alternatives and cease gas service to avoid upgrade or replacement of the gas distribution service line.
o “Support” position on AB 2369 (Rogers): In its original form, this bill sought to require the CPUC to recognize the reliability contributions of energy-only resources, within the resource adequacy program. However, it’s since been amended to instead require the CPUC and CAISO to develop a methodology for evaluating the contribution of energy-only resources to provide charging sufficiency for energy storage.
o “Support” position on AB 2396 (Irwin): This bill would authorize CCAs to sponsor, develop, finance, construct, operate, lease, purchase, and own an eligible transmission project, regardless of whether the transmission lines are used to deliver electricity to the customers of said CCA. Specifically, it would allow CCAs to participate in public-private partnerships for transmission development, as part of the California Transmission Accelerator Revolving Fund established by SB 254 (Becker) in 2025.
[Publish Date] Agenda Date: 5/21/2026
Regulatory Affairs
Below is a summary table of the key terms and issues, followed by further details on activities since our last Board Meeting on a few ongoing priority Pioneer regulatory proceedings and matters. New updates are color-coded in green. More updates will follow at future Board meetings as regulatory proceedings and matters evolve.
Key Terms
CPUC- California Public Utilities Commission OIR- Order Instituting Rulemaking/ “Proceeding” CEC- California Energy Commission ALJ- Administrative Law Judge LSE- Load Serving Entity AL- Advice Letter
IOU- Investor-Owned Utility PD- Proposed Decision
CAISO- California Independent System Operator D.- Decision ED- Energy Division PfM- Petition for Modification
PG&E- Pacific Gas and Electric Company CalCCA- California Community Choice Association Table of Contents:
• BioMAT Implementation – R.18-07-003; R.22-10-010; R.24-01-017:........................................4 • California Climate Credit – R. 25-07-013:..................................................................................5 • Integrated Resource Planning (IRP) – R.20-05-003; R.25-06-019:...........................................6 • Renewables Portfolio Standards (RPS) – R.24-01-017; CEC OIR 21-RPS-02: ............................8 • Resource Adequacy (RA) – R.23-10-011; R.25-10-003: ............................................................9 • Large Loads (PG&E Rule 30) – A.24-11-007:........................................................................... 10 • Demand Response – R.25-09-004: .......................................................................................... 13 • PG&E Energy Resource Recovery Account (ERRA) Compliance and Forecast: ......................... 14 o 2024 ERRA Compliance – A.25-02-013: ............................................................................... 14 o 2025 ERRA Compliance – A.26-02-019 ................................................................................ 15 o 2026 ERRA Forecast – A.25-05-011:.................................................................................... 15 • PG&E General Rate Case (GRC) Phase 1 – A.25-05-009: ......................................................... 16 • PG&E General Rate Case Phase 2 – A.24-09-014: ................................................................... 18 • Provider of Last Resort (POLR) – R.21-03-011: ...................................................................... 19 • CEC Load Management Standards (LMS) – CEC 21-OIR-03; 23-LMS-01: ................................. 20 • Power Charge Indifference Adjustment (PCIA) – R.25-02-005: .............................................. 22 • Safety & Reliability OIR– R.24-05-023: ................................................................................... 24 • Disconnections – R.18-07-005: ............................................................................................... 25 • High-DER Future – R.21-06-017:............................................................................................. 27 • Distributed Energy Resources – R.22-11-013: ........................................................................ 28 • Distributed Energy Resource Interconnections (Rule 21) – R.25-08-004:............................... 29 [Publish Date] Agenda Date: 5/21/2026
• BioMAT Implementation – R.18-07-003; R.22-10-010; R.24-01-017:
a. Proceeding Overview
i. Assembly Bill (AB) 843, chaptered in 2021, enabled CCAs to access the CPUC’s Bioenergy Market Adjusting Tariff (BioMAT) program, which is a feed-in-tariff program for small-scale bioenergy projects. The implementation of AB 843 was considered in R.22-10-010, while the ongoing review and revision of the BioMAT program continues to be considered in the RPS proceedings, R.18-07-003 and R.24- 01-017.
b. Potential Impact on Pioneer
i. Pioneer is an administrator of the BioMAT program, which acts as a much-needed incentive for local bioenergy development. The regulatory implementation of the BioMAT program, specifically regarding extension of the December 31, 2025 sunset date and revisions to the pricing mechanism, affects Pioneer's ability to effectively administer the program.
c. Key Issues
i. Expeditiously implement AB 843 to allow CCA access to the BioMAT program for future subsidies for biomass procurement
ii. Advocate for ongoing CPUC review and revisions to the BioMAT program’s sunset date, to ensure CCAs will be able to continue effectively administering the program d. Status Update
i. The BioMAT program closed on the currently effective sunset date of December 31, 2025. The CPUC removed its proposed decision responding to Bioenergy Association of California’s (BAC’s) PfM requesting an extension of this sunset date from its January 15, 2026 voting meeting agenda, meaning the program has effectively ended without CPUC action.
ii. April 10, 2026 - The CPUC issued a new PD denying BAC’s PfM, requesting extension of the BioMAT program, which was originally filed in March 2025. The CPUC previously issued a PD in response to BAC’s PfM in September 2025, but the PD was ultimately withdrawn and never passed. The new PD does not address the substance of BAC’s PfM, nor address the comments that parties including the Joint CCAs filed in response, but instead primarily makes a procedural argument for why the PfM is denied.
iii. Pioneer and Redwood Coast Energy Authority (RCEA), namely the “Joint CCAs” scheduled an ex parte with Commissioners Harada and Reynolds’ offices to request for the issue of BioMAT extension to be considered in the current RPS rulemaking. e. Background Documents/ Key Decisions
i. D.20-08-04, Revising the BioMAT Program (August 27, 2020):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M346/K112/346112503.PD F
• Most notably extending the program end date to December 31, 2025 ii. D.23-11-084, Implementing AB 843 – Setting Rules to Enable CCAs to Participate in the BioMAT Program (November 30, 2023):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M521/K266/521266723.PD F
[Publish Date] Agenda Date: 5/21/2026
iii. BAC PfM to Modify D.20-08-043 (March 6, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M558/K427/558427287.PDF • BAC urges the CPUC to consider extension of BioMAT sunset date iv. PD Denying BAC PfM to Modify D.20-08-043 (September 18, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M580/K430/580430313.PDF • Ultimately withdrawn from the CPUC Voting Meeting agenda, and never passed v. Opening Comments of Joint CCAs (Pioneer and RCEA) on PD Allowing the BioMAT Program to Sunset (October 8, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M582/K487/582487980.PDF vi. PD Denying BAC PfM to Modify D. 20-08-043 (April 10, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M604/K598/604598906.PDF f. Key Dates
i. May 14, 2026 – PD Denying BAC PfM to Modify D. 20-08-043 on the consent agenda for the CPUC Voting Meeting agenda
ii. June 4, 2026 – Joint CCAs scheduled ex parte with Commissioners Harada and Reynolds’ offices regarding BioMAT extension
g. Pioneer Lead: Chau Pham
• California Climate Credit – R. 25-07-013:
a. Proceeding Overview
i. This proceeding aims to improve the California Climate Credit (CCC) as a tool for supporting ratepayer affordability. Currently, these credits are distributed by the IOUs and are funded by revenues from the state’s Cap-and-Invest (formerly known as Cap-and-Trade) program. The credits are delivered twice a year to electric customers, typically in April and October, and once a year to gas customers, typically in April.
b. Potential Impact on Pioneer
i. Although Pioneer does not directly distribute the CCC, its residential and qualifying small business electricity customers still qualify for the CCC. Therefore, it is important to keep apprised of changes to the CCC, to ensure any changes are fair and beneficial for all ratepayers.
c. Key Issues
i. Ensure modifications to the CCC are competitively neutral, including eligibility criteria and customer messaging
ii. Ensure existing customers continue receiving the Climate Credit d. Status Update
i. February 3, 2026 – A Scoping Memo and Ruling was issued that outlined a phased approach for this proceeding including, Phase 1A which contemplates immediate changes to the CCC, Phase 1B which addresses broader changes, and Phase 2 which will later address the California Air Resources Board (CARB)’s new regulations for the Cap-and-Invest program that funds the CCC.
[Publish Date] Agenda Date: 5/21/2026
ii. March 19, 2026 – D. 26-03-013 was adopted, ordering the large electric IOUs to pause distribution of the 2026 residential climate credit, so the Commission can consider when the credits should be distributed.
iii. April 30, 2026 – D. 26-04-036 was adopted, requiring the large electric utilities to distribute the residential electric climate credits in August and September starting in 2026, and the gas utilities to distribute the residential gas climate credits in February starting in 2027. The rationale for shifting the distribution timeline of the climate credits is to move it to the highest-bill months, typically occurring in summer, where the credits can have a greater impact on alleviating costs. e. Background Documents/ Key Decisions
i. Scoping Ruling (February 3, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M597/K166/597166396.PDF ii. Decision Pausing the 2026 Residential Climate Credits Distributed by the Large Electric Utilities (March 19, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M603/K306/603306591.PD F
iii. Decision Ordering Immediate Improvements to the CCC to Lower Electric and Gas Bills (May 1, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M605/K990/605990203.PD F
f. Key Dates
i. May 18, 2026 – Workshop to discuss planning for Phase 1B, to address long-term changes to the Climate Credit distribution including eligibility g. Pioneer Lead: Chau Pham
• Integrated Resource Planning (IRP) – R.20-05-003; R.25-06-019:
a. Proceeding Overview
i. This proceeding acts as the venue for long-term procurement planning, primarily through procurement mandates and compliance evaluations of LSEs' individual IRP plans. Historically, the CPUC has issued procurement mandates, most notably the mid-term reliability (MTR) orders, specifying how much and what kind of resources LSEs are obligated to buy, to ensure the state's electricity supply is reliable, cost-effective, and on track to meet greenhouse gas (GHG) reduction goals. The CPUC is currently developing a 10-year forward procurement program to support longer-term market stability, grid reliability, and GHG reduction goals. b. Potential Impact on Pioneer
i. Pioneer is required to comply with IRP procurement and filing requirements. IRP plans are due in 2-year cycles; the current cycle is 2024-2026; the next IRP plan will be due on May 5, 2026. Furthermore, CPUC-issued procurement orders have a significant impact on the procurement market that Pioneer operates in. Therefore, it is in Pioneer’s best interest to advocate for policies that ensure any CPUC-issued procurement orders preserve CCA procurement autonomy and flexibility to the highest degree possible, to ensure Pioneer can engage in fair, competitive, and cost-effective procurement. c. Key Issues
[Publish Date] Agenda Date: 5/21/2026
i. Minimize costly procurement orders coming from the IRP, especially near-term ad-hoc orders ii. Advocate for procurement planning policies that prioritize affordable baseload resources such as biomass energy
d. Status Update
i. April 6, 2026 - The direct access (DA) providers filed an application for rehearing (AfR) of the recent procurement decision ordering 6,000 MW of procurement by 2032 and a petition for modification (PfM) of a 2019 decision that capped DA service. The DA parties are asking for the CPUC to reconsider lifting the cap on DA service and if not, then consider re-allocating the procurement order to exclude them since they're not allowed to serve new load.
ii. April 21, 2026 - CalCCA filed a response to the DA parties’ AfR, asking the CPUC to reject the DA parties' request to re-allocate the procurement order to exclude them, because the procurement order was issued based on system reliability needs not individual LSEs' load growth. Additionally, any reforms to load allocation methodology should be considered in RCPPP, the long-term procurement program being contemplated, since that would be a complex process. Most of all, reopening a procurement decision would hurt LSEs who may have already locked into contracts or set their procurement strategies to meet their share. iii. May 6, 2026 - CalCCA filed comments on the DA parties’ PfM, asking the CPUC to reject the DA parties' request to recommend lifting the DA cap to the Legislature.
First, CalCCA makes a procedural argument that on the CPUC is not required to make another recommendation to the Legislature after its initial obligation was fulfilled. Additionally, CalCCA points to evidence that shows the DA parties' share of retail sales from clean energy sources and resource development is lagging behind other LSEs, which doesn't provide a compelling argument why DA parties would be better equipped to serve new large loads than LSEs.
e. Background Documents/ Key Decisions
i. ALJ Ruling Seeking Comments on Reliable and Clean Power Procurement Program (RCPPP) Staff Proposal (April 29, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M565/K140/565140721.PDF ii. ALJ Ruling Seeking Comments on Proposed 2026-2027 Transmission Planning Process (TPP) Portfolios and Need for Additional Near-Term Reliability Procurement (September 30, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M582/K082/582082526.PDF iii. R.25-06-019 Scoping Memo and Ruling (October 28, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M585/K485/585485746.PDF iv. Proposed Decision Requiring 2029-2032 Electric Resource Procurement and Transmitting 2026-2027 Transmission Planning Process (TPP) Portfolios (January 14, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M595/K083/595083681.PDF v. ALJ Ruling Setting New Requirements for Individual Integrated Resource Plans Due June 1, 2026 (January 16, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M595/K085/595085015.PDF [Publish Date] Agenda Date: 5/21/2026
vi. Revised Decision Requiring 2029-2032 Electric Resource Procurement and Transmitting 2026-2027 TPP Portfolios (February 26, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M600/K398/600398976.PD F
vii. ALJ Ruling Granting Joint Request for Extension of LSEs’ IRP Filings (March 9, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M601/K895/601895997.PDF f. Key Dates
i. August 10, 2026 – LSEs' Individual IRP Plans Due
g. Pioneer Lead: Chau Pham
• Renewables Portfolio Standards (RPS) – R.24-01-017; CEC OIR 21-RPS-02:
a. Proceeding Overview
i. This proceeding acts as the venue for the CPUC’s implementation and administration of the state's RPS program, which aims to achieve 60% renewable energy by 2030, and 100% carbon-free by 2045.
b. Potential Impact on Pioneer
i. Pioneer is required to comply with the state’s RPS goals. All retail sellers must submit an annual preliminary RPS compliance report each year on August 1, to be evaluated by the CPUC in this proceeding. RPS compliance is evaluated in multi-year periods; we are currently in compliance period 5 (2025-2027). The next RPS target is 52% by 2027. It is Pioneer's priority to ensure RPS rules maintain the highest compliance flexibility possible (allowing for banked RECs, etc) to allow for cost-effective procurement. c. Key Issues
i. Ensure any RPS rules maintain compliance flexibility to the highest degree possible ii. Advocate for fair inclusion of biomass resources in the RPS program and guidelines (this may also take place in the CEC RPS proceeding), including the ongoing administration of the BioMAT program
d. Status Update
i. March 27, 2026 - An ALJ ruling was issued identifying issues and schedule of review for 2026 RPS Procurement Plans. Minor revisions were made to the RPS Plan requirements. The annual draft RPS Plan will be due June 12, 2026. ii. May 7, 2025 - The CPUC approved Pioneer's Final 2025 RPS Procurement Plan. e. Background Documents/ Key Decisions
i. Pioneer Community Energy Draft 2025 RPS Procurement Plan (June 30, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M571/K990/571990166.PDF ii. PD on 2025 RPS Procurement Plans (November 14, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M587/K328/587328286.PDF iii. Pioneer Community Energy Final 2025 RPS Procurement Plan (January 26, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M596/K418/596418446.PDF f. Key Dates
[Publish Date] Agenda Date: 5/21/2026
i. June 12, 2026 – Draft RPS Procurement Plan is due
g. Pioneer Lead: Chau Pham
• Resource Adequacy (RA) – R.23-10-011; R.25-10-003:
a. Proceeding Overview
i. This proceeding aims to ensure the reliability of CA's electricity supply by requiring that LSEs procure sufficient resources to meet their load plus a planning reserve margin (PRM). The RA program recently implemented a slice of day (SOD) framework, ensuring LSEs are compliant every hour of the worst day of the month. b. Potential Impact on Pioneer
i. Pioneer is required to comply with RA procurement requirements and filings. Annual (year ahead) filings are due on October 31 each year and monthly (month ahead) filings are due 45 calendar days prior to the compliance month. Furthermore, RA requirements have significant impacts on the procurement market which Pioneer operates in. Therefore, Pioneer advocates for RA procurement requirements and policies that minimize adverse effects on the RA market. c. Key Issues
i. Advocate for refinements in the RA program that minimize RA requirements (based on robust modeling) to ensure adequate market availability and guard against RA price volatility
ii. Advocate for simplifying RA showings/ compliance requirements to the greatest extent possible
d. Status Update
i. December 12, 2025 - a Scoping Ruling was issued with the following items in scope for the Track 1 of the RA proceeding:
• Adoption of local and flexible requirements;
• Accreditation for long duration energy storage;
• Development of the Unforced Capacity Methodology framework; • Accreditation for wind and solar;
• SOD transactability issues;
• Residual Unit Commitment for RA resources
• Energy only resources; and
• Other time sensitive issues identified by the CPUC or parties in proposals ii. January 23, 2026 - CalCCA filed RA Track 1 proposals including 1) using data center interconnection info, instead of data center IEPR forecast, to inform RA requirements, 2) counting of energy only (EO) co-located resources under SOD, 3) ensuring local RA central procurement entity (CPE) data request is used consistently among CPEs to ensure there is no over-procurement, and support publicizing the CPE data request responses.
iii. March 3, 2026 – CalCCA filed an opening proposal on Transactability Issues, responding to ED’s Transactability Report and recommending adoption of hourly load obligation trading. CalCCA argued that the report does not accurately address the issues with the SOD framework or the affordability implications of hourly load obligation trading. CalCCA proposed the CPUC adopt hourly load obligation trading to allow LSEs to transact at the same level of granularity as the SOD requirements and [Publish Date] Agenda Date: 5/21/2026
invest in software and systems to automate the RA validation process to assist with administrative burden or adopt temporary guardrails to aid in assessing compliance. iv. March 6, 2026 – CalCCA filed opening comments on Track 1 proposals, clarifying their proposal to incorporate data center load into RA allocations based on specified development milestones, rather than forecasted load. CalCCA also sought procedural and timeline clarifications on PG&E’s proposal that voluntary changes to the effective date of an LSEs’ CPUC-approved implementation plan does not qualify as “load migration” in the annual RA allocation process. The comments also expressed views on various other party proposals, which Pioneer did not directly engage in. v. March 20, 2026 – CalCCA filed reply comments on Track 1 proposals, providing counterarguments to several parties who raised objections to the data center load allocation proposal and PG&E’s recommendation to reject the proposal to clarify use of the local RA CPE data request. CalCCA also raised objections to Cal Advocates’ long duration energy storage (LDES) counting proposal with similar concerns as multiple other parties that it likely underestimates LDES’ charging capability. vi. March 30, 2026 – CalCCA filed reply comments on Transactability Issues, responding to Vistra’s opposition to hourly load obligation trading (HLOT) and echoing environmental groups’ support of HLOT as a mechanism to promote affordability and reduce reliance on fossil fuels.
e. Background Documents/ Key Decisions
i. Issuance of OIR 25-10-003 (October 15, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M583/K934/583934825.PD F
ii. Scoping Ruling (December 12, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M590/K884/590884355.PDF iii. ALJ Ruling on ED’s Transactability Report (February 23, 2026):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=600063407 f. Key Dates
i. January 23, 2026 – Track 1 party proposals
ii. February 23, 2026 –ED report on transactability issues iii. March 3, 2026 – Party proposals on transactability issues iv. May 2026 – Proposed Decision on Track 1
v. Early July 2026 – Final Decision on Track 1
g. Pioneer Lead: Chau Pham
• Large Loads (PG&E Rule 30) – A.24-11-007:
a. Proceeding Overview
i. This is PG&E's proposed tariff to address the interconnection of non-residential customers requesting retail electric service at transmission-level voltages between 50 kilovolts (kV) and 230 kV, otherwise known as transmission-level customers.
These large loads are becoming more significant as data centers propagate. PG&E’s current electric rules are intended for distribution-level interconnections. As such, when a customer applies for transmission-level retail electric service, PG&E and the [Publish Date] Agenda Date: 5/21/2026
customer negotiate unique interconnection terms, and PG&E is required to make an “exceptional case” filing with the Commission for approval of the negotiated agreement. PG&E states that creating a uniform tariff (proposed Electric Rule 30) will streamline both the negotiation process and the approval process, resulting in faster interconnection timeline.
b. Potential Impact on Pioneer
i. New large loads, such as data centers, located in Pioneer’s service territory presents both challenges and opportunities to Pioneer. If Pioneer is going to provide generation service to these customers, it needs visibility into which ones are expected to come online in its service territory (if any) for procurement planning purposes. It will also need to have a commitment from these customers far in enough in advance for Pioneer to procure resources in advance of any compliance deadlines to serve these new loads.
c. Key Issues
i. Ensure Pioneer obtains information regarding new large loads when that information is obtained by the IOU, either before or at the time of a customer request for interconnection with the IOU’s transmission or distribution system; ii. Ensure the ability of Pioneer to adequately prepare to serve customers through timely access to information regarding large loads; and iii. Support customer choice of generation providers through ensuring IOUs and CCAs compete on a level playing field.
d. Background Documents/ Key Decisions
i. PG&E Application for Approval of Electric Rule No. 30 for Transmission-Level Retail Electric Service (Nov. 21, 2024):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=547155949 ii. Joint CCA Response to Application (Dec. 23, 2024):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M549/K797/549797836.PDF iii. PG&E Motion for Interim Implementation of Rule 30 (Jan. 24, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=555445559 iv. Joint CCA Response to Motion for Interim Implementation (Feb. 10, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=556602084 v. Scoping Ruling (March 11, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=558423070 vi. D.25-07-039, partly granting PG&E’s Motion for Interim Implementation of Rule 30 (July 28, 2025):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M574/K875/574875643.PD F
e. Status Update
i. May 8, 2026 – PG&E requested CPUC approval of a partial settlement agreement between itself, CalCCA, CalAdvocates, and Sierra Club. The relevant terms of the settlement agreement are as follows:
• Information Sharing (Under New NDA)
a. Interconnection Inquiries:
[Publish Date] Agenda Date: 5/21/2026
i. PG&E shall the same information regarding all transmission-level retail interconnection inquiries that it includes in submissions provided to the CEC at or about the same time that it provides this information to the CEC
b. Post-Application and Pre-Energization
i. Quarterly Reports regarding retail electric customers seeking to interconnect that have submitted an application for
transmission-level service
c. Post Energization
i. Annual Reports regarding facilities that have been
interconnected at the transmission-level and have been
energized
• Non-Disclosure Agreement
a. For affected CCAs, each CCA will execute a new NDA which will govern information sharing regarding interconnections for transmission level retail electric service under Electric Rule 30 or any other PG&E tariff rule
• Coordination of Service
a. CCAs are the default providers of generation service for new customers in their service areas
b. Customers will be considered enrolled with the default provider upon the customer’s execution of an interconnection agreement or eight months prior to the energization date identified in the Preliminary Engineering Study (PES) Report for the customer’s facility, whichever is earlier.
i. PG&E will provide an affected CCA notice of the energization date identified in the PES report within 3 business days of the customer’s signature of the PES report.
ii. PG&E will also provide an affected CCA notice of the execution of an interconnection agreement within 3 business days
c. Under California Public Utilities Code Section 366.2(c)(13), a transmission-level customer has a statutory 60-day opt out period after enrollment to opt out of default CCA generation service. d. Within 3 business days following the 60-day opt out period, the entity selected as the service provider shall confirm that it will provide generation service to the customer in writing to the other entity that will not be providing generation service to that customer. e. After the opt-out period, the customer cannot switch providers until at least one year after energization and after giving 18 months’ notice. f. Key Dates
i. June 20, 2025 - Intervenor Testimony
ii. August 19, 2025- Rebuttal Testimony
iii. September 22-24, 2025 - Evidentiary Heary
[Publish Date] Agenda Date: 5/21/2026
iv. October 24, 2025 - Opening Briefs
v. February 18, 2026 – Limited Opening Testimony on additional cost allocation questions in a January 9, 2026 Ruling
vi. March 13, 2026 – Rebuttal Testimony on additional cost allocation questions vii. April 1, 2026 – Evidentiary Hearings, if needed, on additional cost allocation viii. questions
ix. April 10, 2026 – Opening Briefs on additional cost allocation questions x. April 24, 2026 - Reply Briefs on all issues
xi. Late July 2026 – Proposed Decision
xii. August/September 2026 – CPUC Decision
g. Pioneer Lead: Braden Henderson
• Demand Response – R.25-09-004:
a. Proceeding Overview
i. This rulemaking will revisit and enhance the CPUC's "demand response guiding principles, policies, and data system and process requirements." In particular, the rulemaking seeks to enhance the consistency, predictability, reliability, and cost-effectiveness of demand response (DR) resources. Issues that the CPCU could address in this proceeding is dual participation of DR resources among different programs, adjustments to the DR guiding principles, and integration into other systems and process, including resource adequacy slice of day (RA SOD) and the CAISO market.
b. Potential Impact on Pioneer
i. Under the law, demand response and energy efficiency are the first resources that electric corporations use to meet their needs, so there is a statutory mandate to generally include it in the California resource mix. There could also be a specific impact on Pioneer's programs that fall under the umbrella of demand response, including the PowerShift Rewards program.
c. Key Issues
i. Pursue systems and processes that support timely and consistent Pioneer access to customer interval data, both billing-quality and non-billing-quality ii. Ensure Pioneer customers have equitable access to demand response resources iii. Ensure new policies or programs do not encroach on Pioneer rate and program autonomy
d. Status Update
i. No update.
e. Background Documents/ Key Decisions
i. Order Instituting Rulemaking (Sept. 18, 2025) (including the Demand Response Guiding Principles Staff Report):
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M582/K072/582072320.PD F
[Publish Date] Agenda Date: 5/21/2026
ii. Scoping Memo and Ruling (Feb. 12, 2026):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=599038857 f. Key Dates
i. April 15, 2026 – Opening Comments on Bridge Funding Staff Proposal Ruling ii. May 6, 2026 – Reply Comments on Bridge Funding Staff Proposal Ruling iii. Q2 2026 - Staff Proposal on Data Systems and Processes iv. Q3 2026 – Proposed Decision on IOU DR Bridge Funding v. Q4 2026 – Proposed Decision on all other issues
g. Pioneer Lead: Braden Henderson
• PG&E Energy Resource Recovery Account (ERRA) Compliance and Forecast:
o 2024 ERRA Compliance – A.25-02-013:
a. Proceedings Overview
i. Generally, the ERRA Compliance proceedings review IOU accounting for its generation costs in the previous year, which includes accounting related to the Power Charge Indifference Adjustment (PCIA) and Portfolio Allocation Balancing Account (PABA). The purpose is to ensure accuracy and compliance with legal requirements, including CPUC rules and decisions.
b. Potential Impact on Pioneer
i. Although typically not as contentious as the ERRA Forecast proceedings, PG&E's applications in the ERRA Compliance proceedings often include errors or non-compliant activities which, when corrected, result in a credit to unbundled customers via the PCIA which is incorporated in the ERRA Forecast proceedings. This proceeding is also an opportunity to review PG&E's activities related to its PCIA resources, although transparency is always a challenge.
b. Key Pioneer Issues
i. Ensure qualifying facilities and contracts were prudently administered and managed, entries in balancing and memorandum accounts were recorded appropriately, correctly, and in compliance with CPUC decisions, and whether recovery for 2024 record year costs is reasonable.
c. Status Update
i. No updates.
d. Background Documents/ Key Decisions
i. PG&E Application (February 28, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=557607577 ii. CalCCA Protest (April 4, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=561478629 iii. Scoping Ruling (May 2, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=565140242 e. Key Dates
i. Intervenors' Testimony - September 15, 2025
[Publish Date] Agenda Date: 5/21/2026
ii. Rebuttal Testimony - October 24, 2025
iii. Evidentiary Hearing - December 2, 2025
iv. Opening Briefs - January 5, 2026
v. Reply Briefs - February 6, 2026
vi. Proposed Decision - no later than 90 days after reply briefs vii. Final Decision - no sooner than 30 days after Proposed Decision f. Pioneer Lead: Chau Pham
o 2025 ERRA Compliance – A.26-02-019
a. Proceedings Overview
i. Generally, the ERRA Compliance proceedings review IOU accounting for its generation costs in the previous year, which includes accounting related to the Power Charge Indifference Adjustment (PCIA) and Portfolio Allocation Balancing Account (PABA). The purpose is to ensure accuracy and compliance with legal requirements, including CPUC rules and decisions.
b. Potential Impact on Pioneer
i. Although typically not as contentious as the ERRA Forecast proceedings, PG&E's applications in the ERRA Compliance proceedings often include errors or non-compliant activities which, when corrected, result in a credit to unbundled customers via the PCIA which is incorporated in the ERRA Forecast proceedings. This proceeding is also an opportunity to review PG&E's activities related to its PCIA resources, although transparency is always a challenge.
g. Key Pioneer Issues
i. Ensure qualifying facilities and contracts were prudently administered and managed, entries in balancing and memorandum accounts were recorded appropriately, correctly, and in compliance with CPUC decisions, and whether recovery for 2024 record year costs is reasonable.
h. Status Update
i. No updates.
i. Background Documents/ Key Decisions
i. PG&E Application (February 27, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M601/K158/601158608.PDF ii. CalCCA Protest (April 2, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M604/K016/604016143.PDF j. Key Dates
i. To be determined in a forthcoming Scoping Ruling.
k. Pioneer Lead: Chau Pham
o 2026 ERRA Forecast – A.25-05-011:
a. Proceedings Overview
i. ERRA Forecast Applications are filed annually by IOUs to forecast energy procurement-related revenue requirements, which includes forecast allocation of costs across Power Charge Indifference Adjustment (PCIA) vintages. [Publish Date] Agenda Date: 5/21/2026
b. Potential Impact on Pioneer
i. This is the proceeding in which the PCIA revenue requirement for the following rate year (i.e., 2026 in this proceeding) is established. Parties and the CPUC arrive at the revenue requirement by reducing the costs of the PCIA resources by their value and adding any over or under-collection of the PCIA from the current rate year (i.e., 2025 in this proceeding). That revenue requirement is then assigned to customer vintages depending on the vintage of the resource to develop PCIA rates. Given all of Pioneer's customers pay PCIA rates, Pioneer's goal is to ensure that its customers are only paying the costs that we actually incurred on their behalf and receiving the full value of the PCIA resources.
a. Key Pioneer Issues
i. Ensure accuracy of forecast account balances and rates, cost calculations in workpapers, and calculation of Market Price Benchmarks (MPBs) ii. Ensure costs are attributed to the proper PCIA vintage iii. Ensure costs are attributed properly between bundled and unbundled customers iv. Ensure IOU specific proposals are appropriate for an ERRA Forecast proceeding b. Status Update
i. No updates.
c. Background Documents/ Key Decisions
i. PG&E Application (May 15, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=566243428 ii. Scoping Ruling (June 20, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=574962660 iii. CalCCA Brief (October 24, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=585485747 d. Key Dates
i. A final decision in this proceeding is anticipated in December 2025, with implementation into rates beginning January 1, 2026.
e. Pioneer Lead: Chau Pham
• PG&E General Rate Case (GRC) Phase 1 – A.25-05-009:
a. Proceeding Overview
i. In four-year cycles, IOUs submit GRC applications for authority to adjust rates and charges for electric and gas service based on a future test year (TY). The revenue requirements include electric and gas distribution system costs, administrative expenses, and customer service costs.
ii. In the GRC Phase 1, the CPUC establishes the IOU's overall revenue requirement, which is later allocated in rates to different customer classes in the GRC Phase 2.
This includes establishing the operating and capital costs to be recovered for the IOU's transmission, distribution, and generation functions. b. Potential Impact on Pioneer
[Publish Date] Agenda Date: 5/21/2026
i. The costs of PG&E's Power Charge Indifference Adjustment (PCIA) generation resources will be established here and later recovered through the PCIA rates via the ERRA Forecast proceeding.
ii. This proceeding will also establish revenue requirements for PG&E programs that could benefit customers in Pioneer's service territory, including resiliency and backup power initiatives to support areas disproportionately impacted by outages. c. Key Issues
i. Ensure accuracy and reasonableness of forecast costs ii. Ensure revenue requirements are properly allocated to PCIA vintages iii. Ensure costs are properly allocated across major work categories iv. Prevent unwarranted or unreasonable increases to CCA service fees d. Status Update
i. February 13, 2026 – CalCCA filed testimony on PG&E’s application proposing the various changes that would lower the generation revenue collected through the PCIA, including, but not limited to:
• Removing hydro facilities that erroneously remain on PG&E’s books and those that are no longer used and useful in providing generation services for the benefit of customers from the Electric Generation revenue requirement while recovering any remaining balance of the original investment through a regulatory asset, with no return on rate base and
• Moving eight hydro facilities into a more recent vintage for the purposes of PCIA cost recovery to reflect the fact that the substantial proposed investments in these assets of over $2 billion would result in a significant overhaul of these facilities, supporting life extensions as well as changed functions for these assets.
ii. April 27 – May 6, 2026 – CalCCA is participating in Evidentiary Hearings. CalCCA’s witness Ryan Matley is scheduled to be cross-examined on May 13, 2026. CalCCA’s cross-examination of PG&E’s witnesses will focus on hydro facility costs, proposed investments, and the correct vintaging of those hydro investments. PG&E has hydro assets that are on the books but have not been used, as well as new investments that may require re-vintaging.
e. Background Documents/ Key Decisions
i. PG&E Phase 1 2027 Application (May 15, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=566363587 ii. PG&E Phase 1 2027 Scoping Ruling (July 31, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=575112973 f. Key Dates
i. Intervenors’ testimony - February 13, 2026
ii. Rebuttal testimony - March 31, 2026
iii. Case Management Conference
iv. Statement and Motions for Settlement - April 13, 2026 v. Evidentiary hearings - Starting April 27, 2026
[Publish Date] Agenda Date: 5/21/2026
vi. Opening briefs - June 19, 2026
vii. Reply briefs - July 10, 2026
viii. Proposed decision - March 2027
ix. Commission decision May - 2027
g. Pioneer Lead: Chau Pham
• PG&E General Rate Case Phase 2 – A.24-09-014:
a. Proceeding Overview
i. In four-year cycles, IOUs submit GRC applications for authority to adjust rates and charges for electric and gas service based on a future test year (TY). The revenue requirements include electric and gas distribution system costs, administrative expenses, and customer service costs
ii. The GRC Phase 2 is focused on the design of PG&E's rates, and includes proposals for real-time pricing rates. This follows the GRC Phase 1, which determines the cost of service.
b. Potential Impact on Pioneer
i. PG&E is proposing to escalate fees for meter data management, rate ready consolidated billing fee, and bill-ready consolidated billing fee. ii. How PG&E implements RTP and how pricing and usage data is transferred to CCAs will impact CCAs' ability to implement their own dynamic pricing programs and potential implicate their compliance with the load management standards (LMS) of the California Energy Commission (CEC).
iii. PG&E's real-time pricing (RTP) proposal would include hourly components for each of transmission, distribution, and generation. For unbundled customers, CCAs will have the option to customize the MEC and MGCC formulas or apply a modifier. PG&E says it is working with CCAs to provide options to develop more customized dynamic generation rates; however, such customizations will need to be funded by the CCAs.
If CCAs want to use a different generation marginal RTP, they may contract with another entity to develop that price and calculate their unbundled customers’ generation bill.
c. Key Issues
i. Ensure that CCAs have access to data needed to implement dynamic rates for any CCA that chooses to do so and ensure that PG&E's implementation of dynamic rates does that impede CCA ability to comply with CEC LMS rules. d. Status Update
i. March 9, 2026 – CalCCA submitted testimony recommending that the CPUC:
• Reject PG&E’s proposed 20 percent increases to its CCA Service Fees; • Order PG&E to complete a cost study to support any future recommended changes to its CCA Service Fees;
• Order PG&E to: (1) cap its revenues associated with the CCA Service Fees at the cost levels included in its forecast for these services provided in its 2027 Phase I General Rate Case (GRC) Application (A.) 25-05-009; and (2) track any revenue received above that cap and refund this amount to unbundled [Publish Date] Agenda Date: 5/21/2026
customers via PG&E’s next Energy Resource Recovery Account (ERRA) compliance proceeding;
• Reject PG&E’s proposal to update its CCA Service Fees via Tier 2 Advice Letters in the future, and instead reiterate that PG&E may only update these fees via a GRC application, and that any such update must be supported by up-to-date information regarding PG&E’s actual costs incurred in the provision of these services; and
• Order PG&E to update its Provider of Last Resort (POLR) fee for CCA customers by: (1) submitting supplemental testimony in this proceeding regarding its actual costs as the POLR to process a customer’s voluntary return to bundled service in 2026, using up-to-date data on PG&E’s processing times and labor costs; and (2) shortly after PG&E’s final implementation of its Billing Modernization Initiative (BMI) project, submitting testimony in its next GRC application regarding its actual costs as the POLR to process a customer’s voluntary return to bundled service, using up-to-date data on PG&E’s processing times and labor costs
e. Background Documents/ Key Decisions
i. PG&E Phase 2 2023 Application (Sept. 30, 2024):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=541493803 ii. PG&E Phase 2 2023 Scoping Ruling (Mar. 21, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=560273042 f. Key Dates
i. CalAdvocates Testimony -January 9, 2026
ii. Intervenors' Testimony – March 9, 2026
iii. Rebuttal Testimony – July 10, 2026
iv. Hearing - August 2026
v. Opening Briefs - Four weeks after Hearing
vi. Reply Briefs - Three weeks after Opening Briefs
vii. Proposed Decision - No later than 90 days after Reply Briefs viii. Final Decision - No sooner than 30 days after Proposed Decision g. Pioneer Lead: Chau Pham
• Provider of Last Resort (POLR) – R.21-03-011:
a. Proceeding Overview
i. Track 1 of the POLR proceeding serves to determine/ update the methodology for the financial security requirement (FSR) that CCAs have to post, to ensure the IOUs (Current POLRs) have the capital to serve customers in case of an emergency mass return. Track 2 of the proceeding gauged interest from any LSEs/ IOUs who are interested in taking on the role of POLR.
b. Potential Impact on Pioneer
i. Pioneer would like to minimize changes to the FSR methodology that could increase it. It's also important to stay up to date with any changes in the process/ timing of posting Pioneer’s FSR.
[Publish Date] Agenda Date: 5/21/2026
c. Key Issues
i. Prevent the requirement for the POLR to procure or hedge in advance of customer return
ii. Ensure modifications to the FSR are balanced and improve accuracy iii. Adjust the FSR calculation to account for risk of customer return through an unsecured credit limit
iv. Reject the adoption of PG&E’s outsized “liquidity pool” that would remove the revenue offset component of the calculation entirely
v. Ensure non-IOU LSEs are able to serve as POLR under similar rules as the IOU as POLR
d. Status Update
i. No updates.
e. Background Documents/ Key Decisions
i. Scoping Ruling (Sept. 16, 2021):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M407/K765/407765425.PDF ii. CalCCA Comments (July 5, 2022) on Ruling Requesting Comments on the FSR and Re-Entry Fee (May 2, 2022):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=490740399 iii. ED Staff Proposal (Jan. 6, 2023):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M500/K762/500762116.PDF iv. D.24-04-009 (Apr. 18, 2024) Decision Implementing SB 520 Regarding Standards for POLR:
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M529/K986/529986322.PD F
v. Phase 2 Scoping Ruling (Oct. 24, 2024):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=543727359 f. Key Dates
i. Track 2 of POLR is on pause, due to lack of substantial interest from LSEs in transferring POLR role.
g. Pioneer Lead: Chau Pham
• CEC Load Management Standards (LMS) – CEC 21-OIR-03; 26-OIR-01; 23-LMS-01:
a. Proceeding Overview
i. Docket 23-LMS-01 implements the CEC’s LMS (Calif. Code of Regulations, Title 20, sections 1621-1625), which include (among other mandates) requirements for CCAs to develop dynamic pricing by 2027. The objective of the LMS is to increase statewide demand flexibility through the development of hourly locational marginal cost-based rates. The rates will be entered into a statewide database – the MIDAS – and automation service providers will access customers’ rate information through a “Single Statewide Tool” created jointly by the IOUs, CCAs, and POUs. The statewide system of granular time and location dependent signals are intended to be used by automation-enabled loads to provide real-time load flexibility on the electric grid.
The CEC adopted the LMS Regulations on October 12, 2022, in docket 21-OIR-03. [Publish Date] Agenda Date: 5/21/2026
b. Potential Impact on Pioneer
i. The LMS rules include compliance obligations for large CCAs, like Pioneer. These compliance obligations include submission of an LMS plan and to consider adopting real-time rates. Although Pioneer's public position is that the CEC does not have authority over CCA rates, Pioneer will continue to make all reasonable efforts to comply with LMS as a show of good faith cooperation with California policies regarding dynamic rates.
c. Key Issues
i. Ensure implementation of the LMS regulations is fair and equitable to CCAs, and ii. in accordance with the regulations
iii. Ensure that the CEC respects CCA autonomy in setting their own rates iv. Ensure Pioneer maintains compliance with CEC mandates and requirements d. Status Update
i. April 9, 2026 – the CEC issued an Order Instituting Rulemaking to evaluate improvements to implementation of the LMS and expand participation among ratepayers and third-party service providers.
e. Background Documents/ Key Decisions
i. Load Management Standards: https://www.energy.ca.gov/programs-and-topics/topics/load-flexibility/load-management-standards ii. Pioneer Revised Load Management Standard Plan:
https://efiling.energy.ca.gov/GetDocument.aspx?tn=266073&DocumentContentId= 103090
f. Key Dates
i. July 1, 2025: 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.
ii. December 8, 2025: Pioneer's Revised LMS Plan will be addressed in the Energy Commission's Business Meeting.
iii. May 8, 2026: 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 iv. One year after compliance plan approval (December 8, 2026) and annual thereafter:
Submit annual reports to CEC demonstrating implementation of the Plan, as approved by the Board.
v. July 1, 2027: Offer each Pioneer customer voluntary participation in either a marginal cost-based rate, if such rate is approved by Pioneer’s Board, or a cost-effective load flexibility program identified in 20 CCR section 1623.1(b)(3). vi. Three years after compliance plan approval (December 8, 2028) and triennially thereafter: 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.
g. Pioneer Lead: Braden Henderson
[Publish Date] Agenda Date: 5/21/2026
• Power Charge Indifference Adjustment (PCIA) – R.25-02-005:
a. Proceeding Overview
i. This proceeding will consider the rules and processes related to the Energy Resource Recovery Account (ERRA) and PCIA, which are the mechanisms by which unbundled customers are assessed the costs for generation resources procured by the IOUs on their behalf. The Commission bifurcated the proceeding into two tracks - Track One is an expedited consideration of modifications to the market price benchmark (MPB) calculations and Track Two will be a more holistic review of potential changes to the ERRA and PCIA, potentially including, for example, sunsetting or revintaging resources, changes to Bundled Procurement Plans (BPPs), and incorporation of slice of day.
b. Potential Impact on Pioneer
i. In the recent ERRA forecast cases, the PCIA has been negative for certain vintages of unbundled customers, meaning they will see a credit on their bill for the value of IOU resources procured on their behalf. This has drawn the scrutiny of the IOUs, ratepayer advocates, and the CPUC, resulting in a reassessment of certain components of the PCIA calculation, particularly the RA MPB, which, given current high RA prices, has contributed to the negative PCIA. Changes to the Market Price Benchmarks (MPBs), and PCIA methodology in general, could result in shifting costs for IOU generation resources from bundled to unbundled customers. On the flipside, the wholistic nature of Track 2 provides an opportunity to fundamental revisit the PCIA structure and propose solutions to help limit exposure for CCAs and prevent unfair cost shifts between bundled and unbundled customers. c. Key Issues
i. Track 1
• Revisions to the RA MPB, which is an element of the value attributed to PCIA resources.
ii. Track 2
• How to value renewable energy certificates (REC) generated prior to January 1, 2019, and used for bundled service customer compliance, for the purpose of calculating the PCIA (Pre-2019 Banked RECs)
d. Status Update
i. December 1, 2025 - the California Community Choice Association (CalCCA) filed a Writ of Review (Writ) appealing a decision by the California Public Utilities Commission (CPUC) that will result in a shift of hundreds of millions of dollars from unbundled to bundled customers via the Power Charge Indifference Adjustment (PCIA). In its Writ, CalCCA explains that the CPUC’s arbitrary decision to change the PCIA methodology and apply that change 2025 rates violates the longstanding prohibition against retroactive ratemaking, which is intended to ensure customer certainty and stability in rates. Before the Court of Appeals determines whether to take up the appeal, the CPUC will have an opportunity to respond to the Writ and CalCCA will reply to the CPUC response.
ii. March 2, 2026 – CalCCA submitted testimony on the Pre-2019 Banked RECs issue which:
• Explains how the PCIA framework operates to ensure statutory indifference between bundled and unbundled customers, including how REC value is conveyed to customers;
[Publish Date] Agenda Date: 5/21/2026
• Demonstrates that Later Departing Customers paid for their share of Pre-2019 Banked RECs when those RECs were generated but have not received the value of those RECs when they are later used for Current Bundled Customer RPS compliance;
• Shows that failure to credit Later Departing Customers when Pre-2019 Banked RECs are used for Current Bundled Customer compliance results in a cost shift from Current Bundled Customers to Later Departing Customers; • Recommends that Pre-2019 Banked RECs be valued at the current RPS MPB – the avoided cost of procuring new RECs in the market – when used for Current Bundled Customer compliance, with the full value recorded as a vintage-specific credit to the PCIA corresponding to the year the RECs were generated; • Explains why vintage-specific crediting ensures only the correct customer vintages receive the correct values and prevents double compensation; • Concludes that CalCCA’s proposal is consistent with Commission precedent, maintains statutory indifference, and can be implemented within the existing PCIA framework; and that
• In the absence of valuation, the Commission is required pursuant to Public Utilities Code section 366.2(g) to provide an allocation to Later Departing Customers for their share of RECs used by the IOU of Pre-2019 Banked RECs, which could be achieved by reducing the Net RPS Procurement Need as measured on the Commission’s Renewable Net Short Calculation template for the LSEs serving those Later Departing Customers.
iii. A Ruling was issued March 27, 2026, with an Energy Division Staff Report presenting “alternative approaches” to the IOUs and CalCCA’s proposals for valuing Pre-2019 Banked RECs. Energy Division does propose valuing the RECs (as opposed to the IOUs proposal to value the Pre-2019 Banked RECs at zero). CalCCA is evaluating ED’s four proposed valuation methods for Pre-2019 Banked RECs: (1) Load-share weighted RPS MPB; (2) DOE statewide renewable energy contract value assigned in D.11-12-018; (3) Valuation of Pre-2019 Banked RECs at 50 percent of current RPS MPB; and (4) “adjusted weighted mechanism” to value the RECs commensurate to the departed load share. Comments on the Staff Report are due with the Track 2 Opening Briefs, due May 22, 2026.
iv. April 24, 2026 – the ALJ issued a ruling scheduling testimony on the Staff Report and making other modifications to the procedural schedule. v. In Response to a Ruling requesting comments on issues to be addressed in Track 3, CalCCA submitted comments on March 27, 2026, stating that:
• Track 3 should be scoped to accomplish the OIR’s objective of broad improvements to ERRA and PCIA rules;
• The broad scope of Track 3 necessitates that all stakeholders first have access to an equally broad range of data for meaningful participation; • The Commission should adopt the 2017 data access protocol with updates to ensure Track 3 issues and proposals can be adequately addressed; and • Track 3 should be phased to resolve the data access issues prior to addressing all other issues.
e. Background Documents/ Key Decisions
[Publish Date] Agenda Date: 5/21/2026
i. OIR to Update and Reform ERRA and PCIA Policies and Processes (Feb. 26, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=557860748 ii. Track 1 Scoping Ruling (Apr. 8, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=562084645 iii. D.25-06-049 adopted Track 1 RA MPB methodology changes (June 26, 2025):
https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=571242473 iv. Track 2 Scoping Ruling (Feb. 3, 2026):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M597/K166/597166403.PDF f. Key Dates
i. Track one is completed at the regulatory level but could be revisited depending on the outcome of the appeal brought by CalCCA.
ii. Track 2:
• May 12, 2026 – Testimony on Staff Report
• May 22, 2026 – Rebuttal Testimony on Staff Report
• May 26, 2026 – Deadline to Present Settlement on Track 2 Issues or a Motion to Request Hearings
• May 27, 2026 – ALJ Ruling on the Need for Hearing
• June 2, 2026 – Evidentiary Hearing, if needed
• June 16, 2026 – Track 2 Opening Briefs
• June 25, 2026 – Track 2 Reply Briefs
• By August 17, 2026 – Proposed Decision issues
• September 17, 2026 – CPUC Decision
iii. A schedule for Track three will be established in a forthcoming Scoping Ruling, but it is expected to be a protracted proceeding that extends into 2028. g. Pioneer Lead: Chau Pham
• Safety & Reliability OIR– R.24-05-023:
a. Proceeding Overview
i. This is a multi-track rulemaking to consider changes to policies related to safety, reliability, and resiliency of electric distribution systems. The near-term focus of this proceeding will develop processes for how the investor-owned utilities will collect and aggregate data to establish a foundation for measuring utility outages. b. Potential Impact on Pioneer
i. This proceeding is closely related to Public Safety Power Shutoff (PSPS) and Enhanced Powerline Safety Setting (EPSS) events which are of critical concern to Pioneer and its customers. Pioneer is likely to support:
• Transparency on outage causes to customers.
• Alternative approaches to reduce EPSS and PSPS events. • Protecting customers from increased costs while increasing reliability. c. Key Issues
[Publish Date] Agenda Date: 5/21/2026
i. The focus of the Rulemaking is to evaluate the safety, reliability, and resiliency of the electric distribution system. A major component of the rulemaking are outage events. The IOU’s planned outages are from scheduled maintenance, PSPS, and rotating outages during heatwaves. The IOU’s unplanned outages occur due to damage to equipment, EPSS, and by first responder request. PSPS and EPSS events are of particular concern for vulnerable areas; PSPS events have seemingly reduced in recent years but have been replaced with EPSS events. Overall, total outages events have been increasing since 2015, while outage duration peaked in 2019, outages are now leveling out or trending downward.
d. Background Documents/ Key Decisions
i. R.18-12-005, OIR to Examine Electric Utility De-Energization of Power Lines in Dangerous Conditions, Scoping Ruling (Mar. 08, 2019):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M270/K419/270419337.PDF ii. R.18-04-019, OIR to Consider Strategies and Guidance for Climate Change Adaptation, Scoping Ruling (Oct. 10, 2018):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M231/K128/231128764.PDF iii. R. 21-06-017, OIR to Modernize the Electric Grid for a High Distributed Energy Resource Future, Scoping Ruling (Nov. 15, 2021):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M422/K949/422949772.PDF e. Status Update
i. December 15, 2025 - The three IOUs submitted a Draft Customer Reliability Report Template. The report proposes to submit annual reporting of safety and reliability metrics leveraging a narrative reporting format. The submission identifies new metrics to report but the draft likely requires additional clarification on terms and metrics. Pioneer's joint party to file reply comments requesting further clarification. ii. January 26, 2025 - Pioneer's joint party has filed reply comments requesting further clarification on the IOU’s proposed metrics. The party has advocated for the IOUs to provide meaningful analysis within future reports on how customers are being impacted by outages including PSPS and EPSS events.
f. Key Dates
i. Joint IOU Report Template – December 15, 2025
ii. Opening Comments – January 9, 2026
iii. Reply Comments – January 26, 2026
iv. Proposed Decision - No later than 90 days after final submissions v. Final Decision - No sooner than 30 days after Proposed Decision g. Pioneer Lead: Braden Henderson
• Disconnections – R.18-07-005:
a. Proceeding Overview
i. Rulemaking 18-07-005 was opened in response to Senate Bill (SB) 598 to address disconnection rates for both California’s electric and gas investor-owned utilities. SB 598 requires the commission to prohibit disconnecting service for nonpayment by a residential customer dependent on life-support equipment, who is willing to enter into an amortization agreement, and who satisfies certain other conditions. The [Publish Date] Agenda Date: 5/21/2026
ruling was structured to occur in two phases; the first phase for immediate solutions to reduce disconnections, while the second phase is to evaluate the first phase results and establish long term solutions.
ii. This proceeding requires the IOUs to administer two pilot programs Arrearage Management Plan (AMP) and Percentage of Income Payment Plan (PIPP). The pilot programs are reaching the end of their initial period and are being evaluated for continuation.
b. Potential Impact on Pioneer
i. Pioneer participated in the AMP program and we may have recommendations on how this program may be improved in the event of renewal. Pioneer likely supports programs that offer assistance to low-income customers or customers facing hardship.
c. Key Issues
i. Disconnections in this proceeding are focused on the event when a utility intentionally disconnects a customer, mainly residential customer nonpayment.
Disconnections due to nonpayment are a concern to regulators, service providers, and other customers because disconnections shift cost burden onto the rest of ratepayers. Programs and pilot programs are put in place to help reduce disconnections by offering assistance to customers with financial challenges. d. Background Documents/ Key Decisions
i. SB 598 - Public Utilities: Gas and Electric Service Disconnections (Sept. 28, 2017):
https://calmatters.digitaldemocracy.org/bills/ca_201720180sb598 e. Status Update
i. November 14, 2025 - CalCCA submitted opening comments in response to the Commission’s request for feedback on the AMP, the CBO Pilot, and the PIPP pilot programs and their respective Final Evaluation Reports. CalCCA’s comments are in support of the continuation of AMP and PIPP, while IOUs have submitted opening comments against renewal of the programs.
ii. March 25, 2026 – Comments were filed following the proceeding’s public workshop.
CalCCA supports continuation of AMP, PIPP, and the current disconnection caps. The IOUs’ opening comments focus on modifying the disconnection caps to allow for more disconnections, sunset of the PIPP program, and refinements to the AMP program. Most parties are in favor of extending the AMP program and do not support continuation of the PIPP program.
iii. April 01, 2026 – Reply comments were filed in response to the comments on the commission’s rule setting workshop. All parties largely hold the positions they established in their opening comments. With most parties in favor of continuation of the AMP program, a successor proceeding is expected to result from this proceeding to have a venue for evaluating the ongoing implementation of AMP and other customer protections.
f. Key Dates
i. Public Rule Setting Workshop – March 11, 2026
ii. Opening Comments to Rule Setting Workshop– March 25, 2026 iii. Reply Comments to Rule Setting Workshop – April 01, 2026 iv. Statutory Deadline – December 31, 2026
[Publish Date] Agenda Date: 5/21/2026
g. Pioneer Lead: Braden Henderson
• High-DER Future – R.21-06-017:
a. Proceeding Overview
i. The High Distributed Energy Resource (DER) proceeding is the rulemaking in alignment with the CPUC’s Distributed Energy Resources Action Plan 2.0 which aims to leverage DER planning to help achieve California’s renewable energy targets in the 2022-2026 timeframe. The proceeding is currently conducting Track Two and Track Three.
b. Potential Impact on Pioneer
i. This proceeding’s issues include energization of new customers and distributed resources. Other CCAs (i.e., Redwood Coast Energy Authority) have faced some challenges with the interconnection of loads in their service territory, however DER interconnection may not be a priority concern for Pioneer at the moment. ii. This proceeding is actively evaluating impacts to the distribution grid for increased electric loads from emerging technology such as electric vehicles. In parallel demand response policy and changes to time-of-use (TOU) rates from shifted loads may be of concern to Pioneer.
c. Key Issues
i. For Track Three, the main priorities are grid modernization investments in the near term, the implementation of smart inverters to utilize advanced functionalities for grid services, and the better alignment of planned infrastructure investments with utility distribution planning. Overall, this effort seeks to plan for high penetration of DERs and electrification to drive down costs over time. ii. The commission has resurfaced Track Two of this proceeding. Track Two, focused on the topic of DER Orchestration, was discussed earlier in the proceeding without any resulting decisions or consensus. The Commission is exploring how IOUs, as the Distribution System Operators (DSOs), can create a DER Orchestration framework to enable value added services.
d. Background Documents/ Key Decisions
i. R. 14-08-013 – OIR Regarding Policies, Procedures and Rules for Development of Distribution Resources Plans, Scoping Ruling (Jan. 26, 2016):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M157/K902/157902794.PDF e. Status Update
i. January 2, 2025 – CalCCA submitted reply comments in response to the IOU’s electrification studies and opening comments to emphasize that the IOUs should reevaluate their assumptions and prepare updated analysis that reflects realistic use of demand flexibility programs. Included in this is also recommending the IOUs roll out pilot programs to better understand realistic adoption rates; PG&E agreed with CalCCA on this topic in their reply comments.
ii. February 6, 2026 – Following the completion of the IOU’s electrification studies, the assigned commissioner has issued a ruling defining the schedule for Track Three to include an All-Party Workshop, Workshop Report, and Party Comment. iii. March 23, 2025 – The assigned commissioner issued a ruling requesting comments on how IOUs, as the Distribution System Operators (DSOs), can create a DER [Publish Date] Agenda Date: 5/21/2026
Orchestration framework to enable value added services. Opening comments are expected to question if IOUs are the appropriate parties to operate DER markets, and if there were to be the operators, what guardrails are required. iv. April 20, 2026 – Parties filed opening comments in response to the Track 1 and Track 2 issues regarding orchestration of DERs. Most parties support the objective to implement DER orchestration. However, there is concern from non-IOU parties that the Commission should first establish policies and processes before determining implementation pathways. The Commission also released the schedule for the 2026- 2027 Distribution Planning and Execution process.
v. April 30, 2026 – Parties filed reply comments in response to the Track 1 and Track 2 issues regarding orchestration of DERs. The IOUs specifically replied in opposition to CalCCA’s comments which raised the concern that the IOUs are prematurely being recognized as the DSO. However, many other parties’ reply comments underscore that there are foundational concerns with the proceeding assuming the IOUs as the lead DSO.
f. Key Dates
i. Track Three All-Party Workshop – February 20, 2026
ii. Track Three All Party Workshop Report – March 2, 2026 iii. Tack Three Party Comment on Workshop Report - April 3, 2026 iv. Track Two Comments – April 20, 2026
v. Track Two Reply Comments – April 30, 2026
vi. Track Two Workshop – May 21, 2026
vii. Issuance of Assigned Commissioner Proposal on Track 3 Issues – Quarter 2 of 2026 viii. Proposed Decision on Track 3 – Quarter 3 of 2026
g. Pioneer Lead: Braden Henderson
• Distributed Energy Resources – R.22-11-013:
a. Proceeding Overview
i. The Commission issued OIR 22-11-013 to achieve consistency of cost effectiveness assessments, improve data access and use, and consider equipment performance standards for DER customer programs.
b. Potential Impact on Pioneer
i. The CPUC uses the Avoided Cost Calculator (ACC) to determine the primary benefits of DER across Commission proceedings. Pioneer may be inclined to follow this proceeding as the ACC calculates various costs related to items such as generation capacity, energy, and RPSs that may have an impact on electricity rates, portfolio planning, or DER program administration.
c. Key Issues
i. Currently in Phase I, the proceeding covers DER program cost-effectiveness issues, data access and use, and equipment performance standards. All of the latest updates and decisions related to the ACC fall under this proceeding. d. Background Documents/ Key Decisions
[Publish Date] Agenda Date: 5/21/2026
i. R.14-10-003 OIR to Create a Consistent Regulatory Framework for the Guidance, Planning and Evaluation of Integrated Distributed Energy Resources, Scoping Ruling (Jan. 5, 2015):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M143/K990/143990275.PDF e. Status Update
i. March 4, 2026 – The assigned commissioner issued a ruling setting the scope and schedule for Phase Three. Phase Three will be exploring the development and application of the ACC's Guiding Principles.
ii. April 29, 2026 - CPUC staff prepared a proposal on their proposed updates to the 2026 Avoided Cost Calculator. Staff also presented the proposal at a public workshop. At a high level, the proposed updates are to apply a single value to GHG emission reductions capped at the societal cost of carbon. f. Key Dates
i. ACC Update Staff Proposal Published - April of 2026
ii. Opening Comments – May 13, 2026
iii. Reply Comments - May 18, 2026
iv. Proposed Decision Adopted - August of 2026
g. Pioneer Lead: Braden Henderson
• Distributed Energy Resource Interconnections (Rule 21) – R.25-08-004:
a. Proceeding Overview
i. The purpose of this proceeding is to update and improve Rule 21 and associated interconnection procedures concerning the safety and reliability of the electric grid as distributed technologies continue to evolve, promote greater transparency and certainty around interconnection processes, and to contain costs for all ratepayers that use the electric grid.
ii. This proceeding will be conducted in multiple phases. Phase 1 will address issues related to Screens Q and R, interconnection timelines, and the interconnection process and fees for resources that are not interconnecting under the Net Billing Tariff (NBT) or Net Energy Metering (NEM) Tariff.
b. Potential Impact on Pioneer
i. Phase 1 of this proceeding is expected to impact how effectively and efficiently resources can be interconnected through Rule 21. Changes to Rule 21 may impact Pioneer’s ability to procure resources as well as implement programs. Delays in Rule 21 interconnections can have serious impacts to developer’s ability to cost effectively deploy resources, including biomass generation for Pioneer to procure.
Changes to how residential scale resources are interconnected can also affect future programs Pioneer may wish to administer.
c. Key Issues
i. The primary issue discussed in Rule 21 has been related to Screen Q, costs for interconnection studies, and timeline for interconnection applications. Most stakeholders agree that Screen Q is ineffective as almost all larger projects fail Screen Q and are then required to conduct lengthy and costly interconnection studies. Technology developers are in favor of having a faster and less costly [Publish Date] Agenda Date: 5/21/2026
process for interconnecting non-export DER technologies such as backup battery systems.
d. Background Documents/ Key Decisions
i. R.11-09-011 – OIR to Improve Distribution Level Interconnection Rules and Regulations, Scoping Ruling (Jun. 20, 2012):
https://docs.cpuc.ca.gov/PublishedDocs/EFILE/RULC/169188.PDF ii. R.17-07-007 – OIR Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21, Scoping Ruling (Oct. 2, 2027):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M196/K476/196476255.PDF e. Status Update
i. January 26, 2026 - Pioneer submitted a motion for party status to participate in this proceeding. Our primary interest will be to ensure that bioenergy resources are included in any reforms of the Rule 21 interconnection process, including reforms to address the current delays in interconnecting resources. A scoping memo providing the scope of issues and schedule for the proceeding is expected in the coming weeks.
ii. March 3, 2026 – The assigned commissioner released a scoping memo for Phase One. Phase One is prioritizing issues related to Screens Q & R, interconnection timelines, and the process for resources not interconnecting through the Net Billing Tariff (NBT) or Net Energy Metering (NEM) Tariff. These issues are significantly related to, but not limited to, the issues seen by biomass energy developers and the BioMAT program. Pioneer has been accepted as a party to the proceeding and will submit comments supporting changes to improve IOU compliance with interconnection timeline requirements.
iii. April 30, 2026 - Parties submitted opening comments regarding updates to Rule 21.
Comments responded to a set of questions defined by the Commission. Notably, the Commission requested input on compliance mechanisms that the Commission should consider for IOUs, which may influence better adherence to interconnection timelines. Pioneer submitted comments recommending the Commission adopt policies that protect interconnection customers from financial and programmatic burdens inflicted by IOU caused interconnection delays. While the IOUs were explicitly opposed to punitive measures for interconnection timeline noncompliance, many non-IOU parties brought forth proposals and concepts related to interconnection timeline compliance mechanisms for the Commission to consider.
Most parties expressed support for reevaluating the screening criteria for Rule 21, largely around Screen Q.
f. Key Dates
i. Opening Comments to Phase One Scoping Memo – April 30, 2026 ii. Reply Comments to Phase One Scoping Memo – May 29, 2026 g. Pioneer Lead: Braden Henderson
1 Attachment 3: Communications, Outreach, and Customer Care Updates Date: 05/21/2026
NOTABLE ACHIEVEMENTS – APRIL 2026
• Swift and proactive mitigation of negative and
inaccurate social media comments quickly slowed
additional postings.
• Earned media related to the CPUC approval of
expansion into Colusa County, Colusa, and Williams
had high visibility placement in both print and
broadcast media, with a comparative value of more
than $30,000.
• Community outreach efforts in current and
expansion communities resulted in nearly 200
contacts with existing and future customers and a
variety of community organizations.
WEBSITE
The Pioneer website had roughly 5,500 users in April, with the majority being new to the site. The average engagement time was just over two minutes. Top five pages visited were: 1) Home page, 2) Incentive Finder, 3) AC Tune-Up Rebate, 4) PowerShift Rewards, and 5) Contact Us.
Website visitors were roughly 58% male compared to 41% female, and the majority of users were in the 25-54 age demographic. Most users (61.3%) viewed the Pioneer website on a desktop, with only
37.8 using a mobile device.
The Incentive Finder tool continues to be very popular, with 93% of users being homeowners; 74% married and/or file taxes jointly; and just over 66% of users within the $0 - $149,000 household income range. Top incentive searches were related to:
1. Laundry Equipment Rebates
2. Home Battery Rebate (SGIP)
3. Insulation & Sealing Rebates
4. Free Energy Efficiency Kit
5. PowerShift Rewards
Statistics from website usage and Incentive Finder searches provide staff with valuable insights into customer interests, which in turn helps inform activities and program development.
CUSTOMER CARE
Call volume remained flat from month-to-month.
• 418 total calls
o Billing inquiry was the most frequent topic at 13.16%. • 96 surveys completed with a 90.6% satisfaction rate
Customer care hosted the second in a series of educational webinars on April 3, with the topic being “Net Surplus Compensation.”
Plf)NEER
COMMUNITY ENERGY
Pioneer Community Energy approved to expand
into Colusa County in 2027
NORTHERNCAI.IFORNIA - -.o,mmunl,yr.nr,gy•nnoun<m 1h,
C,,llfoml>Publl<U,Dkl<sCnmmml<ln>fll"D'wl .'ltt\'loee:q,,.Mlnnlno,C<>I.,.. '""""''"'n.v...-r,.,..,,,...,,.,nnrnJll.1111>m<.
Chatbot
• Total of 278 interactions
• 80 live conversations (down 4% from March)
o Average conversation duration was 18 minutes, 47 seconds • Rating of 4.8/5 in satisfaction surveys
HIGH VISIBILITY EARNED MEDIA VALUE AT MORE THAN $30K
SOCIAL MEDIA
Two separate posts in a local NextDoor group and Lincoln and Loomis community groups were highly critical of Pioneer and contained a link to our opt-out page. The posts generated considerable comments and calls to our call center.
Staff were alerted to the posts and quickly worked to respond both via comment and by placing paid ads in the groups encouraging customers to call us with questions. The ads were approved by the platforms and appeared within hours. The Facebook ad resulted in 213,000 impressions and a 0.11% CTR (226 link clicks). Next Door ads had a 0.26% click-thru rate (481 link clicks). Pioneer customers also weighed in to correct misinformation and provide positive perspectives on Pioneer. While the posts generated considerable attention and calls, only one customer opted out.
The press release Pioneer issued about expansion
into Colusa County and the cities of Colusa and
Williams received extensive news coverage,
appearing on multiple broadcasts for KCRA-3 and
CBS 13 News, as well as on Action News and print
publications like the Pioneer Review. With a focus on
Pioneer’s role as an energy provider and our growth
in the region, coverage was very positive.
While earned media coverage cannot be purchased,
and equivalent representation of ad time and space
would value the placement at more than $30,000.
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Net i,formec about what'sdain~::f in this ttTead, but Pi:::neer is a co'l'lmuni:y owned corrpany created to lo.,w~r energy pr cEs. The vast rr::jxityof ttosE who have Pic,neer saYe money. =o ks Mtt- solar usually : an save a lot. So before you cancel the ~entice, call l-'Ione-e-r dnd dsk 1Ait'at s cheaper tor you: Just ~(j&.t. or IJIonf!..ir and IJG&:.. lha2-ywIII 9I\'e L>e cl.II=- tu lell yw wt1c1t lht LhectlJ:::'i upliun i:,. A:, fu1 Ll1t":>e ul11t1 ddi111~ 'm yci11y tu check with P.ockrn Gty co.Jncil .:ind .:z;k for ~oll1C! .:m!;wcr:; .. . '
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Pic,nccr i::. more cx:pcrfr,c righ: row bccJu~c of the !=CIA CKJt foe PG&E Jddcd, .:ind the CPU( ai:pro\'ed. If the mayor is. s:u:iport ng it in spit;, of :ieing in the affectec area, it i~ likely Ue1..du~e lie bet e\•e~ Lha. in L·-= luny ,ur· LUrm11unily ctyy·eyd.UI~ lik.e Piur1~1 will lead :o lo""·er r.etes for everyone. If you don't share th~t vision, opt ::x.rt. This is an Intl:;rimatory post but y:x . .'re missing context. ard th..i real anger sh::uld be direi..-ted :;t PG&E .and t he CPLC. Without the ?CIA this. woulo not be the current sltua:ion. 2w ....,, ""-'Iv SI~' 6()
Across all platforms, 306 mentions were positive; 126 were neutral; 8 were negative.
Top performing posts for April:
FACEBOOK INSTAGRAM
PAID AD CAMPAIGN DRIVES PROGRAM PARTICIPTION
A paid advertising campaign launched in late April to support programs. Program participation has increased significantly year-to-year, with a 66% increase in customer participation through April. t, ~~~~~;~ner~ 7.t2-~PM '-1
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PIONEER IN THE COMMUNITY: APRIL COMMUNITY OUTREACH, PROGRAMS, EXPANSION • Present at Rocklin GRC Meeting
• Distribute information at Loomis Chamber Meeting
• Attended Placer Countywide ZEV Infrastructure Plan meeting • Attended Groundbreaking Momentum Substation, Roseville • Attended South Placer Rotary Meeting
• On-site presence at Lincoln Hills Home, Health, and Business Showcase • On-site presence at Earth Fest in Nevada City
• On-site presence at Loomis Business Expo
• Attended Placer Valley Business Summit
• On-site presence and kids activity at Placerville Kids Expo • Initiative for Cooperatives and Civic Innovation
• Social Media Monitoring and Response- Next Door
• Attended El Dorado Hills Chamber Meeting
• Attended El Dorado County Chamber Meeting
• Attended Rocklin Chamber meeting
• Attended Nevada City Chamber of Commerce meeting
• Attended Sunrise with the Chamber meeting
• Finalized sponsorships with Silver Wishes/Lincoln and Nevada City Chambers Programs Support
• Community Advisory Committee meeting
• Supported GridGen (Participate.Energy) with specific customers to keep projects moving forward • Solar RECs and GridGen: provide information to Boys and Girls Club El Dorado County • GridGen/Solar RECs: provide information and follow up with City of Rocklin, City of Auburn, City of Yuba City
• Horton Iris Garden Tour event, Loomis
Expansion
• Shared press release on CPUC approval with expansion communities • Assisted Colusa County with public relations information request • Scheduled meetings with Tuolumne County, City of Sonora, and Tuolumne County Economic Development Collaborative
Attachment: 4 Program Updates
Date: 5/21/2026
Seasonal Programs
Pioneer’s seasonal programs launched on April 1 with the AC Tune-Up Rebate; PowerShift Rewards launches on May 1. Staff created and distributed promotional materials for all programs, with an emphasis on these two.
AC Tune-Up
• Launched on April 1st
• 278 applications received during the first month (60% increase from the same time in 2025) • E-blast to business customers and presentations to local Chambers of Commerce promote program expansion to C&I customers
• Pioneer’s new customer portal, designed to make it easier for customers to track their application status and for staff to track program data, is up and running effectively.
PowerShift Rewards
• 2026 season launches on May 1
• 2,530 customers are currently enrolled
GridGen
• 45 projects completed and received final inspection
• 41 projects completed and received Permission to Operate • 107 customers in the active pipeline
• 447.83 KW of solar capacity installed
• 219,447.02 kWh of clean energy generated since program launched • Federal rebates for commercial customers expire on July 4, 2026. All expansion communities have been contacted and encouraged to participate in the program • Staff remain focused on expanding the program to commercial and industrial, and member agencies o All member agencies have received information about the program. Placer County, Rocklin, Yuba City and Newcastle/Gold Hill/Rocklin cemetery district have expressed interest o Initial data analysis being conducted for the City of Placerville Incentive Finder
• Webpage continues to be the second most visited page for three consecutive months • Customer interest in home appliance, battery and insulation rebates is strong Hourly Flex Pricing Pilot
• PG&E reported that the program is over-subscribed, so they are not proactively marketing it • The application period for the program remains open, however incentives for eligible equipment already have been allocated
• Two customers enrolled in the program (19 meters/accounts) • PG&E is filing
Community Advisory Committee (CAC)
• The Community Advisory Committee met on April 29
• The possibility of an electrical panel update program was suggested and positively received • Members were informed that staff will be recruiting additional CAC members through local chamber outreach and making committee participation available at events. The goals is to ensure representation of all Pioneer member agencies.
• Next meeting is June 24
LED Discount Lighting
• 29 local retailers are currently participating, including one national partner (Lowe’s) Plf)NEER
COMMUNITY ENERGY
Agenda Item: XX Agenda Date: 5/21/2026
• Nearly 100,000 units of inventory sold since program launch • Program remains very popular with customers and retail partners Clean Fleet Revenue
• Participating members include Rocklin and Nevada City; City of Auburn pending • Met with City of Yuba City and there is interest
Solar Renewable Energy Credits (RECs)
• Ongoing and extensive outreach to current and expansion members • Staff met with the Counties of Placer and El Dorado, Cities of Lincoln, Rocklin, Oroville, and Yuba City o Initial data analysis being conducted for the City of Placerville • Staff have initiated outreach to additional eligible entities (e.g. Special Districts, School Districts, etc.) Ice Energy
• Finalizing Participation Agreement with the City of Rocklin which includes approximately 23 units • Bank of America has three sites interested; they have sustainability mandates to reduce load and shave during peak hours. Ice Energy is expected to survey all sites.
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Pioneer Community Energy
Glossary of Terms
CAISO - California Independent System Operator - a non-profit independent system operator that oversees the operation of the California bulk electric power system, transmission lines and electricity market generated and transmitted by its members (~80% of California's electric flow). Its stated mission is to "operate the grid reliably and efficiently, provide fair and open transmission access, promote environmental stewardship and facilitate
effective markets and promote infrastructure development. CAISO is regulated by FERC and governed by a five-member governing board appointed by the governor.
CALCCA - California Community Choice Association -Association made up of Community Choice Aggregation {CCA) groups which represents the interests of California's community choice electricity providers.
CARB - California Air Resources Board - The CARB is charged with protecting the public from the harmful effects of air pollution and developing programs and actions to fight climate change in California.
CEC- California Energy Commission
CPUC - California Public Utility Commission
C&I - Commercial and Industrial - Business customers
CP - Compliance Period -Time period to become RPS compliant, set by the CPUC {California Public Utilities Commission)
DA- Direct Access - An option that allows eligible customers to purchase their electricity directly from third party providers known as Electric Service Providers (ESP).
DA Cap- the maximum amount of electric usage that may be allocated to Direct Access customers in California, or more specifically, within an Investor-Owned Utility service territory.
DA Lottery - a random drawing by which DA waitlist customers become eligible to enroll in DA service under the currently-applicable Direct Access Cap.
DA Waitlist - customers that have officially registered their interest in becoming a DA customer but are not yet able to enroll in service because of DA cap limitations.
DAC - Disadvantaged Community
DASR - Direct Access Service Request - Request submitted by C&I to become direct access eligible.
Plf)NEER
COMMUNITY ENERGY
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Demand - The rate at which electric energy is delivered to or by a system or part of a system, generally expressed in kilowatts {kW), megawatts {MW), or gigawatts {GW), at a given instant or averaged over any designated interval of time. Demand should not be confused with Load or Energy.
DER - Distributed Energy Resource -A small-scale physical or virtual asset {e.g., EV charger, smart thermostat, behind-the-meter solar/storage, energy efficiency) that operates locally and is connected to a larger power grid at the distribution level.
Distribution - The delivery of electricity to the retail customer's home or business through low voltage distribution lines.
DLAP- Default Load Aggregation Point- In the CAISO's electricity optimization model, DLAP is the node at which all bids for demand should be submitted and settled. Pioneer settles its CAISO load at the PG&E DLAP as Pioneer is in the PG&E transmission access charge area.
DR - Demand Response - An opportunity for consumers to play a significant role in the operation of the electric grid by reducing or shifting their electricity usage during peak periods in response to time-based rates or other forms of financial incentives.
DWR - Department of Water Resources - DWR manages California's water resources, systems, and infrastructure in a responsible, sustainable way.
ELCC- Effective Load Carrying Capacity -The additional load met by an incremental generator while maintaining the same level of system reliability. For solar and wind resources the ELCC is the amount of capacity which can be counted for Resource Adequacy purposes.
EPIC - Electric Program Investment Charge -The EPIC program was created by the CPUC to support investments in clean energy technologies that provide benefits to the electricity ratepayers of PG&E, San Diego Gas & Electric Company {SDG&E), and Southern California Edison Company {SCE) ERRA - Energy Resource Recovery Account - ERRA proceedings are used to determine fuel and purchased power costs which can be recovered in rates. The utilities do not earn a rate of return on these costs, and only recover actual costs. The costs are forecast for the year ahead. If the actual costs are lower than forecast, then the utility gives money back, and vice versa.
ESP- Energy Service Provider - An energy entity that provides service to a retail or end-use customer.
EV - Electric Vehicle
GHG - Greenhouse gas - water vapor, carbon dioxide, tropospheric ozone, nitrous oxide, methane, and chlorofluorocarbons (CFCs). A gas that causes the atmosphere to trap heat radiating from the earth. The most common GHG is Carbon Dioxide, though Methane and others have this effect as well.
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GRC- General Rate Case - Proceedings used to address the costs of operating and maintaining the utility system and the allocation of those costs among customer classes. For California's three large IOUs, the GRCs are parsed into two phases. Phase I of a GRC determines the total amount the utility is authorized to collect, while Phase II determines the share of the cost each customer class is responsible and the rate schedules for each class. Each large electric utility files a GRC application every three years for review by the Public Advocates Office and interested parties and approval by the CPUC.
GWh - Gigawatt-hour - The unit of energy equal to that expended in one hour at a rate of one billion watts. One GWh equals 1,000 megawatt-hours.
IEP - Independent Energy Producers - California's oldest and leading nonprofit trade association, representing the interest of developers and operators of independent energy facilities and independent power marketers.
IOU - Investor Owned Utility- A private electricity and natural gas provider.
IRP- Integrated Resource Plan -A plan which outlines an electric utility's resource needs in order to meet expected electricity demand long-term.
kW - Kilowatt - Measure of power where power (watts)= voltage (volts) x amperage (amps) and 1 kW= 1000 watts
kWh - Kilowatt-hour - This is a measure of consumption. It is the amount of electricity that is used over some period of time, typically a one-month period for billing purposes. Customers are charged a rate per kWh of electricity used.
LCFS- Low Carbon Fuel Standard -A CARB program designed to encourage the use of cleaner low-carbon fuels in California, encourage the production of those fuels, and therefore, reduce greenhouse gas emissions.
LCR - Local (RA) Capacity Requirements -The amount of Resource Adequacy capacity required to be demonstrated in a specific location or zone.
LMP - Locational Marginal Price - Each generator unit and load pocket is assigned a node in the CAISO optimization model. The model will assign a LMP to the node in both the day- ahead and real time market as it balances the system using the least cost. The LMP is comprised of three components: the marginal cost of energy, congestion, and losses. The LMP is used to financially settle transactions in the CAISO.
Load - An end use device or customer that receives power from an energy delivery system. Load should not be confused with Demand, which is the measure of power that a load receives or requires.
See Demand.
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SE - Load-serving Entity- Entities that have been granted authority by state, local law, or regulation to serve their own load directly through wholesale energy purchases and have chosen to exercise that authority.
NEM - Net Energy Metering -A program in which solar customers receive credit for excess electricity generated by solar panels.
NRDC- Natural Resources Defense Council
OIR - Order Instituting Rulemaking - A procedural document that is issued by the CPUC to start a formal proceeding. A draft OIR is issued for comment by interested parties and made final by vote of the five Commissioners of the CPUC.
MW - Megawatt - measure of power. A megawatt equals 1,000 kilowatts or 1 million watts.
MWH - Megawatt-hour- measure of energy
NP-15 - North Path 15 - NP-15 is a CAISO pricing zone usually used to approximate wholesale electricity prices in northern California in PG&E's service territory.
PCCl - RPS Portfolio Content Category 1- Bundled renewables where the energy and REC are dynamically scheduled into a California Balancing Authority (CBA) such as the CAISO. Also known as "in-state" renewables.
PCC2 - RPS Portfolio Content Category 2 - Bundled renewables where the energy and REC are from out-of-state and not dynamically scheduled to a CBA.
PCC3 - RPS Portfolio Content Category 3 - Unbundled REC PCIA or "exit fee" - Power Charge Indifference Adjustment (PCIA) is an "exit fee" based on stranded costs of utility generation set by the California Public Utilities Commission. It is calculated annually and assessed to customers of CCAs and paid to the IOU that lost those customers as a result of the formation of a CCA.
PCL - Power Content Label - A user-friendly way of displaying information to California consumers about the energy resources used to generate the electricity they sell, as required by AB 162 (Statue of 2009) and Senate Bill 1305 (Statutes of 1997).
PD- Proposed Decision -A procedural document in a CPUC Rulemaking process that is formally commented on by Parties to the proceeding. A PD is a precursor to a final Decision voted on by the five Commissioners of the CPUC.
Pnode - Pricing Node - In the CAISO optimization model, it is a point where a physical injection or withdrawal of energy is modeled and for which a LMP is calculated.
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PPA- Power Purchase Agreement -A contract used to purchase the energy, capacity, and attributes from a renewable resource project.
RA - Resource Adequacy - Under its Resource Adequacy (RA) program, the California Public Utilities Commission (CPUC) requires load-serving entities-both independently owned utilities and electric service providers-to demonstrate in both monthly and annual filings that they have purchased capacity commitments of no less than 115% of their peak loads.
RE - Renewable Energy - Energy from a source that is not depleted when used, such as wind or solar power.
REC - Renewable Energy Certificate - A REC is the property right to the environmental benefits associated with generating renewable electricity. For instance, homeowners who generate solar electricity are credited with 1 solar REC for every MWh of electricity they produce. Utilities obligated to fulfill an RPS requirement can purchase these RECs on the open market.
RPS - Renewable Portfolio Standard - Law that requires CA utilities and other load serving entities (including CCAs) to provide an escalating percentage of CA qualified renewable power (culminating at 33% by 2020) in their annual energy portfolio.
SCE - Southern California Edison
SDG&E - San Diego Gas & Electric
SGIP - Self-Generation Incentive Program - A program which provides incentives to support existing, new, and emerging distributed energy resources (storage, wind turbines, waste heat to power technologies, etc.)
TCR EPS Protocol - The Climate Registry Electric Power Sector Protocol - Online tools and resources provided by The Climate Registry to assist organizations to measure, report, and reduce carbon emissions.
Time-of-Use (TOU) Rates - The pricing of delivered electricity based on the estimated cost of electricity during a particular time-block. Time-of-use rates are usually divided into three or four time-blocks per 24-hour period (on-peak, mid-peak, off-peak and sometimes super off peak) and by seasons of the year (summer and winter). Real time pricing differs from TOU rates in that it is based on actual (as opposed to forecasted) prices that may fluctuate many times a day and are weather sensitive, rather than varying with a fixed schedule.
TURN - The Utility Reform Network - A ratepayer advocacy group charged with ensuring that California IOUs implement just and reasonable rates.
Unbundled RECs - Renewable energy certificates that verify a purchase of a MWH unit of renewable power where the actual power and the certificate are "unbundled" and sold to different buyers.
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VPP - Virtual Power Plant - A cloud-based network that leverages an aggregation of distributed energy resources (DERs) to shift energy demand or provide services to the grid. For example, thousands of EV chargers could charge at a slower speed and hundreds of home batteries could discharge to the grid during a demand peak to significantly reduce the procurement of traditional supply resources.