San Diego Community Power Board of Directors
October 27, 2022

AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 1 AGENDA
Special Meeting of the Board of Directors of
San Diego Community Power (SDCP)
October 27, 2022
4:00 p.m.

The meeting will proceed as a teleconference meeting in compliance with waivers to certain provisions of the Brown Act provided for under Government Code section 54953(e)(1)(A), in relation to the COVID-19 State of Emergency and recommended social distancing measures.

There will be no location for in-person attendance. In compliance with the Brown Act, SDCP is providing alternatives to in-person attendance for viewing and participating in the meeting. Further details are below.

Note: Any member of the public may provide comments to the Board of Directors on any agenda item. When providing comments to the Board, it is requested that you provide your name and city of residence for the record. Commenters are requested to address their comments to the Board as a whole through the Chair. Comments may be provided in one of the following manners:

1. Providing Oral Comments During Meeting. To provide comments during the meeting, join the Zoom meeting by computer, mobile phone, or dial-in number. On Zoom video conference by computer or mobile phone, use the “Raise Hand” feature. This will notify the moderator that you wish to speak during a specific item on the agenda or during non-agenda Public Comment.

Members of the public will not be shown on video but will be able to speak when called upon.

If joining the meeting using the Zoom dial-in number, you can raise your hand by pressing *9.

Comments will be limited to three (3) minutes. Please be aware that the Chair has the authority to reduce equally each speaker's time to accommodate a large number of speakers.

2. Written Comments. Written public comments must be submitted prior to the start of the meeting by using this (web form). Please indicate a specific agenda item when submitting your comment. All written comments received prior to the meeting will be provided to the Board members in writing. In the discretion of the Chair, the first ten (10) submitted comments shall be stated into the record of the meeting. Comments read at the meeting will be limited to the first 400 words. Comments received after the start of the meeting will be collected, sent to the Board members in writing, and be part of the public record.

If you have anything that you wish to be distributed to the Board, please provide it via [email protected] and it will be distributed to the Members.

The public may participate using the following remote options:

Teleconference Meeting Webinar https://zoom.us/j/94794075133 Telephone (Audio Only) (669) 900-6833 or (346) 248-7799 | Webinar ID: 947 9407 5133 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 Call to Order
Roll Call

ACTION ITEM

1. Approval of Findings to Continue Holding Remote/Teleconference Meetings Pursuant to Assembly Bill 361
Recommendation: Find and determine that the Board has reconsidered the circumstances of the COVID-19 State of Emergency; the State of Emergency remains in effect; state or local officials continue to impose or recommend social distancing measures; and meetings of SDCP legislative bodies may be held remotely in compliance with Government Code section 54953(e) for the next 30 days.

PUBLIC COMMENTS ON CLOSED SESSION ITEMS

CLOSED SESSION

2. PUBLIC EMPLOYEE PERFORMANCE EVALUATION PURSUANT TO GOVERNMENT CODE SECTION 54957
Title: Chief Executive Officer

3. CONFERENCE WITH LABOR NEGOTIATORS PURSUANT TO GOVERNMENT CODE SECTION 54957.6
Agency designated representative(s): Ryan Baron, General Counsel Unrepresented employee: Chief Executive Officer

REPORT FROM CLOSED SESSION

ADJOURNMENT
Compliance with the Americans with Disabilities Act
SDCP Board of Directors meetings comply with the protections and prohibitions of the Americans with Disabilities Act. Individuals with a disability who require a modification or accommodation, including auxiliary aids or services, in order to participate in the public meeting may contact (888) 382-0169 or [email protected]. Requests for disability-related modifications or accommodations require different lead times and should be provided at least 72-hours in advance of the public meeting.

Availability of Board Documents
Copies of the agenda and agenda packet are available at https://sdcommunitypower.org/resources/meeting-notes/. Late-arriving documents related to a Board meeting item which are distributed to a majority of the Members prior to or during the Board meeting are available for public review as required by law. Previously, public records were available for inspection at the City of San Diego Sustainability Department, located at 1200 Third Ave., Suite 1800, San Diego, CA 92101. However, due to the Governor’s Executive Orders N-25- AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 3 20 and N-29-20 and the need for social distancing, in-person inspection is now suspended. Public records, including agenda-related documents, can instead be requested electronically at [email protected] or by mail to SDCP, 815 E Street, Suite 12716, San Diego, CA 92112. The documents may also be posted at the above website.

AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 1 AGENDA
Regular Meeting of the Board of Directors of
San Diego Community Power (SDCP)
October 27, 2022
5:00 p.m.

The meeting will proceed as a teleconference meeting in compliance with waivers to certain provisions of the Brown Act provided for under Government Code section 54953(e)(1)(A), in relation to the COVID-19 State of Emergency and recommended social distancing measures. There will be no location for in-person public attendance. In compliance with the Brown Act, SDCP is providing alternatives to in-person public attendance for viewing and participating in the meeting. Further details are below.

Note: Any member of the public may provide comments to the Board of Directors on any agenda item.

When providing comments to the Board, it is requested that you provide your name and city of residence for the record. Commenters are requested to address their comments to the Board as a whole through the Chair. Comments may be provided in one of the following manners:

1. Providing Oral Comments During Meeting. To provide comments during the meeting, join the Zoom meeting by computer, mobile phone, or dial-in number. On Zoom video conference by computer or mobile phone, use the “Raise Hand” feature. This will notify the moderator that you wish to speak during a specific item on the agenda or during non-agenda Public Comment.

Members of the public will not be shown on video but will be able to speak when called upon. If joining the meeting using the Zoom dial-in number, you can raise your hand by pressing *9.

Comments will be limited to three (3) minutes. Please be aware that the Chair has the authority to reduce equally each speaker's time to accommodate a large number of speakers.

2. Written Comments. Written public comments must be submitted prior to the start of the meeting by using this (web form). Please indicate a specific agenda item when submitting your comment.

All written comments received prior to the meeting will be provided to the Board members in writing. In the discretion of the Chair, the first ten (10) submitted comments shall be stated into the record of the meeting. Comments read at the meeting will be limited to the first 400 words.

Comments received after the start of the meeting will be collected, sent to the Board members in writing, and be part of the public record.

If you have anything that you wish to be distributed to the Board, please provide it via [email protected] and it will be distributed to the Members.

The public may participate using the following remote options:

Teleconference Meeting Webinar https://zoom.us/j/94794075133 Telephone (Audio Only) (669) 900-6833 or (346) 248-7799 | Webinar ID: 947 9407 5133 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 Welcome
Call to Order
Roll Call
Pledge of Allegiance
Special Presentations and Introductions
Report from Closed Session (If held)
Items to be Added, Withdrawn, or Reordered on the Agenda Public Comments
Opportunity for members of the public to address the Board on any items not on the agenda but within the jurisdiction of the Board. Members of the public may provide a comment in either manner described above.

Consent Calendar
All matters are approved by one motion without discussion unless a member of the Board of Directors requests a specific item to be removed from the Consent Calendar for discussion. A member of the public may comment on any item on the Consent Calendar in either manner described above.

1. Approval of Findings to Continue Holding Remote/Teleconference Meetings Pursuant to Assembly Bill 361

2. Approval of March 4, 2022, July 28, 2022, August 25, 2022 Meeting Minutes

3. Approval of Amended Community Advisory Committee (CAC) Operating Guidelines

4. Receive and File Treasurer’s Report for Period Ending August 31, 2022

5. Receive and File Update on Back Office Operations

6. Receive and File Update on Regulatory and Legislative Affairs

7. Receive and File Update on Marketing and Public Relations Items Removed from the Consent Calendar
Regular Agenda
The following items call for discussion or action by the Board of Directors. The Board may discuss and/or take action on any item listed below if the Board is so inclined.

8. Approval of the Chief Executive Officer (CEO) Contract Amendment Recommendation: Approve the Chief Executive Officer (CEO) Contract Amendment

9. Receive and File June 30, 2022 Fiscal Year-end Audited Financial Statement Recommendation: Receive and File the June 30, 2022 Fiscal Year-end Audited Financial Statement

10. Update on the Community Advisory Committee (CAC) Quarterly Report AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 3 Recommendation: Receive and file the Community Advisory Committee (CAC) Quarterly Report

11. Approval of the Integrated Resource Plan (IRP)
Recommendation: Approve the Integrated Resource Plan (IRP) Director Initiated Items
Reports by Chief Executive Officer and General Counsel
SDCP Management and General Counsel may briefly provide information to the Board and the public.

The Board may engage in discussion if the specific subject matter of the report is identified below, but the Board may not take any action other than to place the matter on a future agenda. Otherwise, there is to be no discussion or action taken unless authorized by law.

Director Comments
Board Members may briefly provide information to other members of the Board and the public, ask questions of staff, request an item to be placed on a future agenda, or report on conferences, events, or activities related to SDCP business. There is to be no discussion or action taken on comments made by Directors unless authorized by law.

Adjournment
Compliance with the Americans with Disabilities Act
SDCP Board of Directors meetings comply with the protections and prohibitions of the Americans with Disabilities Act. Individuals with a disability who require a modification or accommodation, including auxiliary aids or services, in order to participate in the public meeting may contact (888) 382-0169 or [email protected]. Requests for disability-related modifications or accommodations require different lead times and should be provided at least 72-hours in advance of the public meeting.

Availability of Board Documents
Copies of the agenda and agenda packet are available at https://sdcommunitypower.org/resources/meeting-notes/. Late-arriving documents related to a Board meeting item which are distributed to a majority of the Members prior to or during the Board meeting are available for public review as required by law. Public records, including agenda-related documents, can be requested electronically at [email protected] or by mail to SDCP, PO BOX 12716, San Diego, CA 92112. The documents may also be posted at the above website. Such public records are also available for inspection, by appointment, at San Diego Community Power, 2488 Historic Decatur Road, Suite 250, San Diego, CA 92106. Please contact [email protected] to arrange an appointment.

SAN DIEGO COMMUNITY POWER
Staff Report – Item 1
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Ryan Baron, General Counsel
Subject: Findings to Continue Holding Remote/Teleconference Meetings Pursuant to Assembly Bill 361
Date: October 27, 2022
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Find and determine that the Board has reconsidered the circumstances of the COVID-19 State of Emergency; the State of Emergency remains in effect; state or local officials continue to impose or recommend social distancing measures; and meetings of SDCP legislative bodies may be held remotely in compliance with Government Code section 54953(e) for the next 30 days.

BACKGROUND
As more fully described in the staff report for the October 28, 2021 meeting related to AB 361, the State of California has adopted AB 361, which allows public agencies to hold fully or partially virtual meetings under certain circumstances without being required to follow certain Brown Act teleconferencing requirements. Under AB 361, a legislative body holding a fully or partially virtual meeting pursuant to AB 361 must make certain findings at least every thirty (30) days to continue holding such meetings.

If the Board desires to continue allowing Directors and members of SDCP committees to participate remotely pursuant to AB 361, the Board must reconsider the COVID-19 State of Emergency, find that the proclaimed State of Emergency remains in effect, and find either: (1) that state or local officials continue to impose or recommend measures to promote social distancing; or (2) that as a result of the COVID-19 emergency, meeting in person would present imminent risks to the health or safety of attendees.

ANALYSIS AND DISCUSSION
Based on the continued COVID-19 State of Emergency and continued required or recommended social distancing measures, as initially described in the staff report for October 28, 2021 meeting relating to AB 361, the Board may make the findings necessary to continue allowing Board members and members of all SDCP committees to participate remotely pursuant to AB 361.

FISCAL IMPACT
None.

ATTACHMENTS
None.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 1 SAN DIEGO COMMUNITY POWER (SDCP)

BOARD OF DIRECTORS
815 E Street, Suite 12716
San Diego, CA 92112
SPECIAL MEETING (12:30 P.M.)

MINUTES
March 4, 2022
This meeting was conducted utilizing teleconferencing and electronic means consistent with Government Code Section 54953, as amended by Assembly Bill 361, in relation to the COVID-19 State of Emergency and recommended social distancing measures.

The Board minutes are prepared and ordered to correspond to the Board Agenda. Agenda Items can be taken out of order during the meeting.

The Agenda Items were considered in the order presented.

WELCOME

CALL TO ORDER
Chair Mosca (Encinitas) called the SDCP Board of Directors meeting to order at 12:34 p.m.

ROLL CALL
PRESENT: Chair Mosca (Encinitas), Vice Chair Padilla (Chula Vista), Director Dedina (Imperial Beach) and Director Sotelo-Solis (National City)
Director Lawson-Remer (San Diego County) and Director LaCava (San Diego) joined during Closed Session.

ABSENT: Director Baber (La Mesa)
Also Present: General Counsel Ryan Baron
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 PUBLIC COMMENTS ON CLOSED SESSION ITEMS
There were no public comments.

CLOSED SESSION

ACTION ITEM

1. Public Employee Appointment Pursuant to Government Code Section 54957 Title: Chief Executive Officer

2. Conference with Labor Negotiators Pursuant to Government Code Section 54957.6 Agency Designated Representatives: Cindy Krebs, Alliance Resource Consulting Unrepresented Employee: Chief Executive Officer

REPORT FROM CLOSED SESSION
General Counsel Ryan Baron reported there were no reportable actions.

ADJOURNMENT
Chair Mosca (Encinitas) adjourned the meeting at 5:45 p.m.

Kimberly Isley
Assistant Board Clerk
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 1 SAN DIEGO COMMUNITY POWER (SDCP)

BOARD OF DIRECTORS
2488 Historic Decatur Road, Suite 250
San Diego, CA 92106

MINUTES
July 28, 2022
This meeting was conducted utilizing teleconferencing and electronic means consistent with Government Code Section 54953, as amended by Assembly Bill 361, in relation to the COVID-19 State of Emergency and recommended social distancing measures.

The Board minutes are prepared and ordered to correspond to the Board Agenda. Agenda Items can be taken out of order during the meeting.

The Agenda Items were considered in the order presented, except for Item No. 9 which was heard prior to Item No. 8.

WELCOME

CALL TO ORDER
Chair Mosca (Encinitas) called the SDCP Board of Directors meeting to order at 5:02 p.m.

Chair Mosca welcomed the new Administrative Assistant, Sandra Vences.

PLEDGE OF ALLEGIANCE
Chair Mosca (Encinitas) led the Pledge of Allegiance.

ROLL CALL
PRESENT: Chair Mosca (Encinitas), Vice Chair Padilla (Chula Vista) (arrived at 5:09 p.m.) Director Dedina (Imperial Beach), Director Baber (La Mesa), Director Sotelo-Solis (National City), and Director LaCava (San Diego) ABSENT: San Diego County
Also Present: Chief Executive Officer (“CEO”) Burns, General Counsel Baron, Executive Assistant to the CEO/Assistant Board Clerk Isley
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 ITEMS TO BE ADDED, WITHDRAWN, OR REORDERED ON THE AGENDA There were no items to be added, withdrawn, or reordered.

PUBLIC COMMENTS
There were no public comments.

CONSENT CALENDAR

1. Approval of Findings to Continue Holding Remote/Teleconference Meetings Pursuant to Assembly Bill 361
Approved.

2. Approval of February 24, 2022 Meeting Minutes
Approved.

3. Receive and File Treasurer’s Report for Period Ending 5/31/22 Received and filed.

4. Approval of Updated Procurement Policy for Procurement of Good and Services Resolution No. 2022-09 was adopted.

5. Approval of Amendment to Professional Services Agreement with Futura Energy Group for up to $235,000 for Services in FY2023
Approved.

6. Update on Back Office Metrics/Dashboard and Marketing/Public Relations Received and filed.

7. Approval of the Budget Policy
Approved.

ACTION: Motioned by Director LaCava (San Diego) and seconded by Director Dedina (Imperial Beach) to approve Consent Calendar Items 1 through 7. The motion carried by the following vote:

Vote: 5-0
Yes: Chair Mosca (Encinitas), Director Dedina (Imperial Beach), Director Baber (La Mesa), Director Sotelo-Solis (National City), Director LaCava (San Diego) No: None
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 3 Abstained: None

Absent: Chula Vista and San Diego County

REGULAR AGENDA

8. Approval of Community Advisory Committee (CAC) Appointment for Chula Vista.

Policy Manager Sarria provided a brief overview of the purpose of the CAC and described the application and appointment process.

Vice Chair Padilla (Chula Vista) introduced the new Chula Vista CAC member, Anthony Sclafani.

Anthony Sclafani gave a brief overview of his professional background and expressed his desire to serve the community.

Curtis Dowds inquired about public participation at CAC meetings.

Board questions and comments ensued.

ACTION: Motioned by Vice Chair Padilla (Chula Vista) and seconded by Director LaCava (San Diego) to approve the appointment of Anthony Sclafani as a Chula Vista representative of the Community Advisory Committee. The motion carried by the following vote:

Vote: 6-0
Yes: Chair Mosca (Encinitas), Vice Chair Padilla (Chula Vista), Director Dedina (Imperial Beach), Director Baber (La Mesa), Director Sotelo-Solis (National City), Director LaCava (San Diego)
No: None
Abstained: None

Absent: San Diego County

9. Quarterly Update on Community Advisory Committee
Policy Manager Sarria and CAC Chair Price provided an update on the CAC’s proceedings, efforts, and accomplishments.

Following Board questions and comments, no action was taken.

10. Update on Regulatory and Legislative Affairs
Director of Data Analytics and Account Services Utouh and Ty Tosdal, Attorney, Tosdal APC, provided an update on San Diego Gas and Electric’s (SDG&E) June 1, 2022, rate adjustment.

Matthew Vasilakis, Climate Action Campaign, spoke regarding concerns with SDG&E’s efforts to undermine SDCP.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 4 Curtis Dowds spoke regarding SDG&E’s efforts to undermine SDCP and inquired about the format of the Joint Rate Mailer that shows a side by side comparison of SDG&E’s and SDCP’s rates.

Following Board questions and comments, no action was taken.

11. SDCP Election Regarding Voluntary Allocation of Renewable Energy from SDG&E Managing Director Power Services Vosburg explained that SDCP had the opportunity to secure voluntary allocations of Power Charge Indifference Adjustment (“PCIA”) eligible renewable resources from SDG&E at the Market Price Benchmark, and elections could be made to receive long-term (10+ years) and short-term (<10 years) allocations. Managing Director Power Services Vosburg reviewed the key factors to consider regarding voluntary allocations and summarized the recommended voluntary allocation elections.

Board questions and comments ensued.

Curtis Dowds inquired about whether SDCP would get credit for the amount of local renewable energy it produced.

ACTION: Motioned by Director Sotelo-Solis (National City) and seconded by Chair Mosca (Encinitas) to approve staff’s recommended long-term (one hundred percent) and short-term (zero percent) elections for voluntary allocation of renewable energy from SDG&E and authorize the CEO to: (i) notify SDG&E of SDCP’s long-term and short-term voluntary allocation elections; and (ii) execute SDG&E’s pro-forma contracts associated with long-term transactions for renewable energy and Renewable Energy Certificates in substantially similar form as approved to form by legal counsel. The motion carried by the following vote:

Vote: 6-0
Yes: Chair Mosca (Encinitas), Vice Chair Padilla (Chula Vista), Director Dedina (Imperial Beach), Director Baber (La Mesa), Director Sotelo-Solis (National City), Director LaCava (San Diego)
No: None
Abstained: None

Absent: San Diego County

REPORTS BY MANAGEMENT AND GENERAL COUNSEL
CEO Burns reviewed SDCP’s vision statement, mission statement, and core values and reported on community engagement events SDCP attended, SDCP’s Community Power Plan, new SDCP partnerships, Community Choice Aggregation innovation workshops, and SDCP lunch and learn events. CEO Burns provided an overview of the plan for SDCP for the next 90 days.

Board questions and comments ensued.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 5 DIRECTOR COMMENTS
There were no comments.

ADJOURNMENT
Chair Mosca (Encinitas) adjourned the meeting at 6:20 p.m.

Megan Wiegelman, CMC
Interim Board Clerk
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 1 SAN DIEGO COMMUNITY POWER (SDCP)

BOARD OF DIRECTORS
2488 Historic Decatur Road, Suite 250
San Diego, CA 92106

MINUTES
August 25, 2022
This meeting was conducted utilizing teleconferencing and electronic means consistent with Government Code Section 54953, as amended by Assembly Bill 361, in relation to the COVID-19 State of Emergency and recommended social distancing measures.

The Board minutes are prepared and ordered to correspond to the Board Agenda. Agenda Items can be taken out of order during the meeting.

The Agenda Items were considered in the order presented.

WELCOME

CALL TO ORDER
Chair Mosca (Encinitas) called the SDCP Board of Directors meeting to order at 5:02 p.m.

Chair Mosca (Encinitas) introduced the following new SDCP staff members:

Kenny Key, Senior Contract Manager, Power Services
Victoria Abrenica, Public Outreach Associate
Tacko Diaite-Koumba, Senior Settlements Manager, Power Services Chair Mosca thanked Tom Summers and Edward Lopez for their service on the SDCP Community Advisory Committee (“CAC”).

PLEDGE OF ALLEGIANCE
Chair Mosca (Encinitas) led the Pledge of Allegiance.

ROLL CALL
PRESENT: Chair Mosca (Encinitas), Alternate Director McCann (Chula Vista), Director Baber (La Mesa), Director Sotelo-Solis (National City), Director LaCava (San Diego), and Director Lawson-Remer (San Diego County)
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 ABSENT: Imperial Beach
Also Present: Chief Executive Officer (“CEO”) Burns, General Counsel Baron, Executive Assistant to the CEO/Assistant Board Clerk Isley

ITEMS TO BE ADDED, WITHDRAWN, OR REORDERED ON THE AGENDA There were no items to be added, withdrawn, or reordered.

PUBLIC COMMENTS
David Peterson spoke regarding the power procurement bid evaluation criteria and solar battery farms.

CONSENT CALENDAR
Director LaCava requested Consent Calendar Item 4 be pulled for separate consideration.

1. Approval of Findings to Continue Holding Remote/Teleconference Meetings Pursuant to Assembly Bill 361
Approved.

2. Approval of Amendment to Professional Services Agreement with Neyenesch Printers Inc. for up to $2,174,000 for Services in FY2023 Approved.

3. Adopt Resolution 2022-12 updating the San Diego Community Power (“SDCP”) Conflict of Interest Code
Resolution No. 2022-12 was adopted.

4. REMOVED

5. Community Advisory Committee Update
Received and filed.

6. Update on Back Office Metrics/Dashboard
Received and filed.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 3 ACTION: Motioned by Alternate Director McCann (Chula Vista) and seconded by Director Sotelo-Solis (National City) to approve Consent Calendar Items 1 through 6, except for Item 4. The motion carried by the following vote:

Vote: 6-0
Yes: Chair Mosca (Encinitas), Alternate Director McCann (Chula Vista), Director Baber (La Mesa), Director Sotelo-Solis (National City), Director LaCava (San Diego), and Director Lawson-Remer (San Diego County)
No: None
Abstained: None

Absent: Imperial Beach

4. Approval of Delegation of Signatory Authority to Chief Financial Officer and Managing Director of Power Services
Director LaCava (San Diego) recommended the following amendments to the proposed Resolution:
• Add to paragraph C., “The Chief Financial Officer and Managing Director Power Services would still be required to follow all of the procurement requirements set forth in the applicable policy or delegation and only in the absence of the CEO.”; • Add to paragraph D., “The signatory authority would apply to all SDCP agreements where the CEO has delegated authority, including the Energy Risk Management Policy, Procurement Policy, and such other policies, resolutions and Board actions where the Board has authorized the CEO to enter into an agreement.” Board questions and comments ensued.

ACTION: Motioned by Director LaCava (San Diego) and seconded by Chair Mosca (Encinitas) to adopt Resolution No. 2022-10 providing signatory authority to the Chief Financial Officer and Managing Director Power Services for agreements and resolutions in the absence of the Chief Executive Officer, with the following amendments: (1) add to paragraph C., “The Chief Financial Officer and Managing Director of Power Services would still be required to follow all of the procurement requirements set forth in the applicable policy or delegation and only in the absence of the CEO.”; and (2) Add to paragraph D., “The signatory authority would apply to all SDCP agreements where the CEO has delegated authority, including the Energy Risk Management Policy, Procurement Policy, and such other policies, resolutions and Board actions where the Board has authorized the CEO to enter into an agreement.” – WITHDRAWN Director LaCava (San Diego) withdrew the motion.

Chair Mosca (Encinitas) stated the item would be continued to the SDCP Board of Directors meeting on Thursday, September 22, 2022.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 4 REGULAR AGENDA

7. Update on the Phase 3 Residential Media and Outreach Campaign Marketing and Communications Manager Hommel provided an update on the Phase 3 Residential Media and Outreach Campaign, highlighting pre and post enrollment notices, “My Reasons” and “Oh Yeah And” messaging campaigns, media flighting, metrics, public outreach events, and key takeaways and future implications.

Following Board questions and comments, no action was taken.

8. Update on Regulatory and Legislative Affairs
Policy Manager Sarria introduced Amy Costa, CEO and Founder of Full Moon Strategies and SDCP’s lobbyist. Amy Costa gave a brief summary of her professional background.

Policy Manager Sarria, Senior Regulatory Analyst Gunther, and SDCP Lobbyist Costa provided an update on Assembly Bill 2838, Senate Bill 1020, the Governor’s climate proposals, the Inflation Reduction Act of 2022, the California Energy Commission (“CEC”) Load Management Standards, and the California Public Utilities Commission (“CPUC”) Order Instituting Rulemaking to Advance Demand Flexibility Through Electric Rates.

Following Board questions and comments, no action was taken.

9. Approval of the 2021 Power Source Disclosure Program Annual Reports and Power Content Label
Managing Director Power Services Vosburg provided background on the requirements for the Power Source Disclosure and Power Content Label and reviewed the 2021 Power Source Disclosure Program Annual Reports and Power Content Label.

Board questions and comments ensued.

ACTION: Motioned by Director Sotelo-Solis (National City) and seconded by Alternate Director McCann (Chula Vista) to adopt Resolution No. 2022-11 approving and attesting to the veracity of the 2021 Power Source Disclosure annual reports for PowerOn and Power100 and the 2021 Power Content Label. The motion carried by the following vote:

Vote: 6-0
Yes: Chair Mosca (Encinitas), Alternate Director McCann (Chula Vista), Director Baber (La Mesa), Director Sotelo-Solis (National City), Director LaCava (San Diego), and Director Lawson-Remer (San Diego County)
No: None
Abstained: None

Absent: Imperial Beach
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 5 10. Update on SDCP Staffing Plan, Organizational Structure and the Mercer Salary Study
CEO Burns provided an update on the Mercer salary study results, the proposed salary bands, the proposed Fiscal Year 2023 SDCP Organizational Chart, and the proposed Fiscal Year 2023 hiring plan.

Following Board questions and comments, no action was taken.

REPORTS BY MANAGEMENT AND GENERAL COUNSEL
CEO Burns reported on the San Diego Loyal Soccer Club Clean Energy Partnership, hosting East Bay Clean Energy on August 9-10, 2022, community engagement events, upcoming public speaking engagements, and upcoming lunch and learn events. CEO Burns provided an update on finance and human resources activities.

DIRECTOR COMMENTS
There were no comments.

ADJOURNMENT
Chair Mosca (Encinitas) adjourned the meeting at 6:33 p.m.

Megan Wiegelman, CMC
Interim Board Clerk

SAN DIEGO COMMUNITY POWER
Staff Report – Item 3
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Sebastian Sarria, Policy Manager
Via: Karin Burns, Chief Executive Officer
Subject: Approve Amended Community Advisory Committee (CAC) Operating Guidelines
Date: October 27, 2022
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Approve amended CAC operating guidelines.

BACKGROUND
To streamline the operations of the Community Advisory Committee, staff presented an initial draft of operating guidelines at the July 2020 meeting of the Board of Directors for approval after receiving feedback from the CAC. As the agency continued to mature and learn what worked best, a small update was conducted in early 2021 to adjust the timing of officer elections from calendar to fiscal years (July to June).

ANALYSIS AND DISCUSSION
At the July 2022 meeting of the CAC, staff presented an updated draft of the operating guidelines to reflect the most recent best practices. CAC members gave feedback and asked staff to return with an updated version reflecting their changes. Staff returned at the October 13, 2022, meeting with the following changes:
• Moved “Conducting Outreach and Representing SDCP to the Community” higher in the document to reflect the CAC’s focus on community. • Added responsibilities to the role of Vice Chair to include working on the ad hoc work plan committee every year as well as collaborating with staff to develop monthly and quarterly staff reports for Board meetings. • Added a new section on the Powers of the CAC, as reflected in the SDCP Joint Powers Authority (JPA) Agreement.
• Added more information on the process for the CAC to suggest Board agenda items.

The CAC voted to recommend that the Board adopt these latest changes, which are found in Attachment A.

COMMITTEE REVIEW
Please see the section above.

FISCAL IMPACT
N/A

ATTACHMENTS
Attachment: Draft CAC Operating Guidelines
Effective Date: 1
Community Advisory Committee
Operating Guidelines
Consistent with section 5.10.3 of the San Diego Community Power (SDCP) Joint Powers Agreement, the purpose of the Community Advisory Committee (CAC) is to “advise the Board of Directors and provide for a venue for ongoing citizen support and engagement in the strategic direction, goals, and programs” of SDCP.

This document provides policies and procedures for the CAC on how the committee operates and interacts with SDCP staff and the Board. The following powers and procedures are included:
• Powers of the CAC
• Conducting Outreach and Representing SDCP to the Community • Running CAC meetings
• Interacting with SDCP Staff
• Interacting with SCDP Board of Directors
• Interacting with the Media
• Communications with External Agencies
• Adding Agenda Items to Board of Directors Meetings
• Adding Agenda Items to Community Advisory Committee Meetings • Requesting Information to Support CAC Work
• Creating Ad-Hoc or Subcommittees
• Creating and Updating the Work Plan
• Resignation or Removal
To view the tasks that the CAC is responsible for, please view their Scope of Work and Work Plan.

Powers of the CAC
The CAC is an advisory committee to the SDCP Board of Directors. The committee advises on the strategic direction, goals, and programs of SDCO. The committee is advisory only, and does not have decision-making authority and does not receive any delegation of authority from the Board.

Conducting Outreach and Representing SDCP to the Community The CAC Scope of Work states that Community Advisory Committee will, under the direction of the SDCP Board of Directors and authorized SDCP staff: “plan for and engage in community events and special projects as appropriate; and serve as an information-channel back to their communities.” The CAC Chair may speak on SDCP matters to local community organizations with prior approval of the Director of External Affairs or their designee. This includes the approval of talking points and presentation slides (if to be used). For other CAC members, they may speak as individual members of the CAC, but may not represent themselves as speaking on behalf of the CAC as a body or on behalf of SDCP as an entity.

Effective Date: 2
The following are communications guidelines for the CAC members to adhere to:

Approved Messaging and Talking Points
The Director of External Affairs and/or their designee will provide talking points that are periodically updated as information evolves. These talking points are intended to guide your conversations in the community so we may speak from the same facts, while encouraging that you make these your very own.

Media Inquiries
In alignment with the adopted CAC Operating Procedures, please forward media inquiries to SDCP Director of External Affairs or such designee for vetting and confirmation of next steps.

Speaker Requests
CAC members are encouraged to invite SDCP staff to present at community events, alert staff of opportunities to participate in community events or to request for a CAC member to speak on behalf of SDCP in the community.

Conducting Outreach
To ensure a common and cohesive communications approach, CAC members shall serve as informational channels with the communities they represent while SDCP staff serves the primary function of outreach to various groups, with the support of the CAC. It is highly important and appreciated for the CAC to report information they receive from their communities so that staff can respond with the most correct information given the technical nature of the energy industry.

Social Media
CAC members are encouraged to utilize their own social media accounts to reshare, repost, and comment on SDCP matters so the content is shared throughout their communities.

Email Addresses
CAC members may utilize non-SDCP issued email addresses when responding to external questions. To protect the CAC members’ privacy, SDCP will not publicly share these email addresses unless consent is given.

Running CAC Meetings
Meetings of the CAC will comply with the Ralph M. Brown Act (Government Code § 54950, et seq.) and the CAC will only conduct business when a quorum consisting of more than 50% of the appointed CAC members are present. Due to the stay-at-home order, meetings will be via Zoom until further notice.

The CAC may act by motions approved by a majority of the quorum present at a meeting. Motions resulting in a tie vote or less than a majority will represent a failed motion.

Responsibilities:
• Chair:
o Serve as the primary liaison with the CEO
o Serve as spokesperson for the CAC
o Support SDCP Staff with setting the CAC agenda
o Guide the CAC in developing an annual workplan consistent with the CAC scope and supported by the Board of Directors
Effective Date: 3
o Determine if meetings are required or if a meeting should be canceled o Run CAC meetings (ensure that all CAC members and community are heard, work to keep meetings to allotted time, as well as manage public comment submissions) o Determine which specific agenda items from the upcoming Board of Directors meeting will be prioritized during the CAC meeting o Represent the CAC to the Board to provide updates, submit information, or respond to Board requests
o Represent the CAC to other organizations or at events, as appropriate • Vice-Chair: Take over the CAC Chair responsibilities in the event the Chair is not available o Work with staff and the ad hoc work plan committee to deliver the annual work plan o Collaborate with staff to develop the monthly and quarterly staff reports • Secretary:
o Take attendance and meeting notes
o Work with SDCP staff to ensure meeting agendas are finalized and posted online • Members:
o Attend each meeting or inform SDCP staff and the CAC Chair if they will be late or absent
o Review any information provided in advance and come to the meeting prepared o If requested and where feasible, participate in sub- or ad-hoc working groups that may be established to cover specific topics
o Represent the interests of their communities at the CAC and share information about the CAC with their communities
• Public Comment:
o The public may provide written public comment or participate live via a virtual meeting format or in person, as designated by the Brown Act.
o To ensure public comment is heard in a timely manner, the Chair will call on staff to acknowledge any submitted public comment after presentations or staff discussion are concluded in a particular agenda item.
• SDCP CAC Liaison:
o Create a draft agenda for each meeting and finalize with CAC Chair o Notice CAC meeting according to Brown Act requirements o Support Secretary in posting the CAC meeting agenda at least 72 hours before a regular CAC meeting or 24 hours before a special meeting
o Provide general support and respond to questions during CAC meetings as needed o Communicate any CAC recommendations to the Board so they have a chance to review prior to Board of Directors meetings
The CAC will seek consensus where possible. Where consensus is not reached, the Chair will seek to communicate diverging views in delivery of the recommendation to the Board.

Election of Officers
Officers may be nominated or self-nominated and elected every July meeting by a simple majority vote of the CAC. The terms will be for each fiscal year of July 1 to June 30, with the option for officers to be re-elected for up to three terms. Representatives required for a singular function or service may be nominated or self-nominated and elected by a simple majority vote of the CAC when the need arises, for a term defined by the singular function or service.

Effective Date: 4
Interacting with SDCP Staff
The CAC Chair is the primary liaison to SDCP staff for all matters related to the CAC.

Interacting with SDCP Board of Directors
The CAC Chair is the primary liaison to the SDCP CEO and the CAC Liaison as well as the Board for all matters related to the CAC. It should also be noted that the CAC Chair may also be called upon by the Board Chair to speak on various matters.

Interacting with the Media
Any media inquiries that CAC members receive shall be redirected to the SDCP Director of External Affairs or other designated staff representative.

Communications with External Agencies
Section 5.10.3 of the SDCP JPA Agreement states that the CAC is an advisory body to the SDCP Board of Directors. Accordingly, the CAC shall not provide comments or similar communications on behalf of SDCP or the CAC to external agencies on its own. However, the CAC may provide recommendations on external matters for the Board to consider.

This provision does not limit or affect the right of individual members of the CAC to communicate with external agencies in their personal, non-CAC capacities as found outside of the CAC Scope of Work.

Adding Agenda Items to Board of Directors Meetings
There are two ways that the CAC may bring items to the attention of the Board at a Board meeting:

1. Standing Board Agenda Item: The CAC shall report to the Board of Directors during every regular meeting as a consent item. The staff report will cover the previous meeting’s operations and noteworthy conversation held by the group. On a quarterly basis, the CAC shall have an item on the Board of Directors regular agenda. The staff report shall cover major updates from the Committee as well as a verbal report from the Chair, or designee.

2. Suggesting Board Agenda Items: The CAC may suggest agenda items for a regularly scheduled Board of Directors meeting. A CAC agenda item would allow for extended discussion or action by the Board of Directors. The following procedure applies to CAC suggested Board agenda items:
a) The suggested Board agenda item is agendized for a CAC meeting and is discussed and voted on by the committee.
b) A request for an agenda item for the Board’s next regularly scheduled meeting must be provided no later than ten (10) days prior to the meeting to ensure there is adequate SDCP staff time to prepare the item, if approved. c) The CAC Chair discusses the proposed agenda item with the SDCP Chief Executive Officer, or designee.
d) An agenda item must be approved by the Chief Executive Officer in consultation with the Chair of the Board of Directors prior to being added to a Board agenda.

Adding Agenda Items to Community Advisory Committee Meetings CAC members shall suggest agenda items be added to CAC meetings by sending them to the Chair and the Chief Executive Officer (or other designated staff member assisting the CAC). This will create a Effective Date: 5
streamlined process where the Chair and SDCP staff can collect these requests and discuss them for final inclusion on the CAC agenda.

Requesting Information to Support CAC Work
The CAC may make formal requests for information from SDCP staff through the CEO or their designee (i.e. the CAC liaison) in support of the CAC’s annual workplan and agenda items, and SDCP staff shall make every reasonable effort to provide requested information in a timely fashion in order to allow the CAC to make the most informed decision possible. Formal requests are defined as those coming from the CAC through the Chair of the CAC or their designee.

All requests by the CAC for information and/or research will be channeled through the Chief Executive Officer or their designee, and any requests for information and/or research that entail substantial staff time or cost will be channeled through the Chief Executive Officer for their consideration and formal direction.

Independent of a formal request for information from the CAC, individual CAC members may request information, which will be provided in accordance with the California Public Records Act.

Creating Ad-Hoc or Subcommittees
The CAC may create ad-hoc committees or subcommittees to address issues more in depth outside of CAC meetings and bring findings or recommendations back to the full CAC.

Ad-Hoc committees are temporary committees appointed for a specific purpose, such as updating the work plan. The CAC may establish temporary ad hoc advisory committees that: (a) are composed of less than a quorum of the CAC, (b) have no continuing subject matter jurisdiction, and (c) have no meeting schedule fixed by motion or other formal action of the CAC. Such temporary ad-hoc committees are not subject to Brown Act noticing and meeting requirements.

Standing subcommittees are permanent subcommittees created to review long-term issues, such as rates or budget. Because meetings of such subcommittees must be publicly noticed and agendized consistent with the Brown Act (and therefore require SDCP staff time), CAC requests to establish subcommittees are subject to Board approval and direction.

The CAC Chair will seek volunteers during a CAC meeting to form an ad-hoc or subcommittee. The CAC Chair will work to ensure all CAC members have a chance to participate on various groups as formed throughout the year.

Creating and Updating the Work Plan
The CAC will adopt a Work Plan that aligns with the CAC scope provided by the Board of Directors. This shall be updated annually from the date that the first version is adopted. The Work Plan shall be approved the Board.

Resignation and Removal
CAC members may resign their position by sending a written resignation letter addressed to the Board of Directors.

CAC members may be removed by a majority vote of the Board of Directors, or as indicated below.

If a CAC member is absent for three (3) consecutive meetings, unless excused for good cause by the Chair of the Board, SDCP staff will contact the Member by phone or in writing and inform them of this Effective Date: 6
provision. If the member misses a fourth (4th) consecutive meeting, they may be removed through a written notification from the Chair of the Board. If a CAC member ceases to reside within the Member Agency service area from which they were appointed, the member is deemed to have resigned their CAC membership unless they are allowed, in writing, to complete their term on the CAC by their respective Director representing their jurisdiction.

SAN DIEGO COMMUNITY POWER
Staff Report – Item 4
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Eric W. Washington, Chief Financial Officer
Via: Karin Burns, Chief Executive Officer
Subject: Treasurer’s Report –Presentation of Financial Results for Fiscal Year-to-Date 2023 Period ended 8/31/22 Date: October 27, 2022
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and File Report

BACKGROUND
San Diego Community Power (SDCP) maintains its accounting records on a full accrual basis in accordance with Generally Accepted Accounting Principles (GAAP) as applicable to governmental enterprise funds.

SDCP has prepared its year-to-date financial statements for the period ended August 31, 2022, along with budgetary comparisons.

ANALYSIS AND DISCUSSION
Financial results for the period ended 8/31/22: $180.02 million in net operating revenues were reported compared to $166.74 million budgeted for the period. $167.73 million in total expenses were reported (including $163.67 million in energy costs) compared to $151.77 million budgeted for the period (including $145.73 million budgeted for energy costs). After expenses, SDCP’s change in net position of $12.29 million was for the period. The following is a summary of the actual results compared to the budget for the period ended 8/31/22.
• Net operating revenues finished $13.28 million (or 8.0 percentage points) over the budget primarily due to opt outs performing better than projected and due to higher demand from non-residential customers.
• Operating expenses finished $15.97 million (or 10.5 percentage points) over the budget primarily due to higher-than-expected energy usage and energy costs.

Financial results for the period performed under the projections presented in the year-to-date proforma. SDCP’s change in net position was -16.7% under the projection similarly and primarily due to better opt-out performance and to higher-than projected energy usage and costs.

The following is a summary to actual results compared to the fiscal year-to-date proforma.

For the period ending 8/31/22, SDCP contributed $12,291,129 to its reserves but was expecting to contribute $14,976,019 per the FY 2022-23 adopted budget. Total SDCP reserves at the end of the period were $49,277,515 and total available liquidity (including lines of credit) was $85,937,433. SDCP has a total FY 2022-23 year-end reserve target of $171,276,631, which is equivalent to 90-days of total operating expenses.

COMMITTEE REVIEW
The report was reviewed by the Financial Risk Management Committee (FRMC) on October 20, 2022.

FISCAL IMPACT
N/A

ATTACHMENTS
Attachment A: 2023 Year-to-Date Period Ended 8/31/22 Financial Statements 1 ACCOUNTANTS’ COMPILATION REPORT
Management
San Diego Community Power
Management is responsible for the accompanying financial statements of San Diego Community Power (a California Joint Powers Authority) which comprise the statement of net position as of August 31, 2022, and the related statement of revenues, expenses, and changes in net position, and the statement of cash flows for the period then ended in accordance with accounting principles generally accepted in the United States of America. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the accompanying statements nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, we do not express an opinion, conclusion, nor provide any assurance on these financial statements.

Management has elected to omit substantially all of the note disclosures required by accounting principles generally accepted in the United States of America in these interim financial statements. San Diego Community Power’s annual audited financial statements include the note disclosures omitted from these interim statements. If the omitted disclosures were included in these financial statements, they might influence the user’s conclusions about the Authority’s financial position, results of operations, and cash flows. Accordingly, these financial statements are not designed for those who are not informed about such matters.

We are not independent with respect to the Authority because we performed certain accounting services that impaired our independence.

Maher Accountancy
San Rafael, CA
September 28, 2022
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com Current assets
Cash and cash equivalents 49,277,515 $
Accounts receivable, net 82,384,452
Accrued revenue 50,996,793
Prepaid expenses 5,152,347
Other receivables 339,429
Deposits 13,732,407
Total current assets 201,882,943
Noncurrent assets
Restricted cash 7,500,000
Deposits 3,450,000
Total noncurrent assets 10,950,000
Total assets 212,832,943
Current liabilities
Accrued cost of energy 131,344,602
Accounts payable 1,791,862
Other accrued liabilities 1,478,571
State surcharges payable 363,807
Security deposits 9,124,000
Interest payable 50,197
Total current liabilities 144,153,039
Noncurrent liabilities
Other noncurrent liabilities 517,741
Bank note payable 13,340,082
Total noncurrent liabilities 13,857,823
Total liabilities 158,010,862
Restricted for collateral 2,500,000
Unrestricted 52,322,081
Total net position 54,822,081 $

NET POSITION

SAN DIEGO COMMUNITY POWER

STATEMENT OF NET POSITION
As of August 31, 2022
ASSETS

LIABILITIES
See accountants' compilation report. 2

OPERATING REVENUES
Electricity sales, net 180,004,873 $
Total operating revenues 180,004,873

OPERATING EXPENSES
Cost of energy 163,673,157
Contract services 2,505,164
Staff compensation 786,171
General and administration 568,371
Total operating expenses 167,532,863
Operating income (loss) 12,472,010

NON-OPERATING REVENUES (EXPENSES)
Investment income 19,688
Interest and financing expense (200,569)
Nonoperating revenues (expenses) (180,881)
CHANGE IN NET POSITION 12,291,129
Net position at beginning of period 42,530,952
Net position at end of period 54,822,081 $

SAN DIEGO COMMUNITY POWER

STATEMENT OF REVENUES, EXPENSES

AND CHANGES IN NET POSITION
Two Months Ended August 31, 2022
See accountants' compilation report. 3

CASH FLOWS FROM OPERATING ACTIVITIES
Receipts from customers 144,314,042 $
Other operating receipts 39,362
Payments to suppliers for electricity (90,403,120)
Payments for goods and services (1,467,680)
Payments to employees for services (704,675)
Payments for deposits and collateral (41,000,000)
Payments for state surcharges (332,586)
Net cash provided (used) by operating activities 10,445,343

CASH FLOWS FROM NON-CAPITAL FINANCING ACTIVITIES
Principal payments - loans (18,000,000)
Principal payments - note (5,000,000)
Interest and related expense payments (264,234)
Net cash provided (used) by non-capital
financing activities (23,264,234)

CASH FLOWS FROM INVESTING ACTIVITIES
Interest income received 19,688
Net change in cash and cash equivalents (12,799,203)
Cash and cash equivalents at beginning of period 69,576,718 Cash and cash equivalents at end of period 56,777,515 $ Reconciliation to the Statement of Net Position
Cash and cash equivalents (unrestricted) 49,277,515 $
Restricted cash 7,500,000
Cash and cash equivalents 56,777,515 $

SAN DIEGO COMMUNITY POWER

STATEMENT OF CASH FLOWS
Two Months Ended August 31, 2022
See accountants' compilation report. 4
Operating income 12,472,010 $
Adjustments to reconcile operating income (loss) to net cash provided (used) by operating activities
Provision for uncollectible accounts 1,817,015
(Increase) decrease in:

Accounts receivable (33,814,477)
Accrued revenue (4,057,178)
Other receivables (339,429)
Prepaid expenses (691,039)
Deposits (7,491,350)
Increase (decrease) in:

Accrued cost of electricity 74,113,098
Accounts payable 1,166,907
Other accrued liabilities 738,565
State surcharges payable 31,221
Supplier security deposits (33,500,000)
Net cash provided (used) by operating activities 10,445,343 $

SAN DIEGO COMMUNITY POWER
STATEMENT OF CASH FLOWS (continued)
Two Months Ended August 31, 2022

RECONCILIATION OF OPERATING INCOME TO NET

CASH PROVIDED (USED) BY OPERATING ACTIVITIES
See accountants' compilation report. 5
1 ACCOUNTANTS’ COMPILATION REPORT
Board of Directors
San Diego Community Power
Management is responsible for the accompanying special purpose budgetary comparison schedule of San Diego Community Power (SDCP), a California Joint Powers Authority, for the period ended August 31, 2022, and for determining that the budgetary basis of accounting is an acceptable financial reporting framework. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the accompanying statement nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management.

Accordingly, we do not express an opinion, a conclusion, nor provide any assurance on this special purpose budgetary comparison statement.

The special purpose statement is prepared in accordance with the budgetary basis of accounting, which is a basis of accounting other than accounting principles generally accepted in the United States of America. This report is intended for the information of the Board of Directors of SDCP.

Management has elected to omit substantially all of the note disclosures required by accounting principles generally accepted in the United States of America in these interim financial statements.

SDCP’s annual audited financial statements will include the note disclosures omitted from these interim statements. If the omitted disclosures were included in these financial statements, they might influence the user’s conclusions about the Authority’s financial position, results of operations, and cash flows.

Accordingly, these financial statements are not designed for those who are not informed about such matters.

We are not independent with respect to SDCP because we performed certain accounting services that impaired our independence.

Maher Accountancy
San Rafael, CA
September 28, 2022
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com 2022/23 YTD
Budget
2022/23 YTD
Actual
2022/23 YTD
Budget
Variance
(Under) Over
2022/23
YTD
Actual/
Budget %
2022/23 Annual
Budget
2022/23
Budget
Remaining
REVENUES AND OTHER SOURCES Gross Ratepayer Revenues 168,427,287 181,823,104 $ 13,395,817 108% 716,146,107 $ 534,323,003 $ Less Uncollectible Customer Accounts (1,684,273) (1,818,231) (133,958) 108% (7,161,461) (5,343,230) Total Revenues and Other Sources 166,743,014 180,004,873 13,261,859 708,984,646 528,979,773 OPERATING EXPENSES Cost of Energy 145,726,815 163,673,157 17,946,342 112% 661,638,828 497,965,671 Professional Services and Consultants 3,182,035 2,445,467 (736,568) 77% 16,881,036 14,435,569 Personnel Costs 1,205,025 786,171 (418,854) 65% 7,951,499 7,165,328 Marketing and Outreach 615,000 461,364 (153,636) 75% 4,164,167 3,702,803 General and Administrative 441,010 166,704 (274,306) 38% 2,591,363 2,424,659 Programs 364,167 - (364,167) 0% 1,395,000 1,395,000
Total Operating Expenses 151,534,052 167,532,863 15,998,811 694,621,893 527,089,030 Operating Income (Loss) 15,208,962 12,472,010 (2,736,952) 14,362,753 1,890,743 NON-OPERATING REVENUES (EXPENSES) Investment income - 19,688 19,688 - (19,688) Debt Service and Bank Fees (232,944) (200,569) 32,375 86% (1,314,922) (1,114,353) Total Non-Operating Revenues (Expenses) (232,944) (180,881) 52,063 (1,314,922) (1,134,041) CHANGE IN NET POSITION $ 12,291,129 14,976,018 $ (2,684,889) $ 13,047,831 $ 756,702 $

SAN DIEGO COMMUNITY POWER

BUDGETARY COMPARISON SCHEDULE
Two Months Ended August 31, 2022
See accountants' compilation report.

SAN DIEGO COMMUNITY POWER
Staff Report – Item 5
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Lucas Utouh, Director of Data Analytics and Account Services Via: Karin Burns, Chief Executive Officer
Subject: Update on Back-Office Operations
Date: October 27, 2022
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file update on various back-office operations.

BACKGROUND
Staff will provide regular updates to the Board of Directors regarding San Diego Community Power’s (SDCP) back-office activities centered around tracking opt actions (i.e., opt outs, opt ups and opt downs) as well as customer engagement metrics. The following is a brief overview of items pertaining to back-office operations.

ANALYSIS AND DISCUSSION
A) Phase 3 Enrollment Update
Staff is happy to report that our Phase 3 efforts for Imperial Beach, La Mesa, Encinitas, Chula Vista, San Diego and Net Energy Metering (NEM) customers with a true up month of February through September are now complete. Our cumulative count of active accounts being served under our portfolio currently stands at 723,537 as of 10/18/2022, cementing San Diego Community Power as the 2nd largest CCA by accounts served in the State of California. Net Energy Metering (NEM) customers with a true up month of October are currently in the process of being transitioned over to our service and the enrollment process for NEM customers will continue until January of 2023.

B) Customer Participation Tracking
Staff and Calpine have worked together to create a reporting summary of customer actions to opt out of SDCP service, opt up to Power100, or opt down from Power100 to PowerOn. The below charts summarize these actions accordingly as of October 16th, 2022:

I. Opt Outs
II. Opt Ups to Power100
III. Opt Downs from Power100
IV. Participation Rate.

For Phase 3, the participation rate is fluid and will change as we continue with mass enrollment across all member cities for customers on Net Energy Metering (NEM) throughout 2022. The true participation rate for this phase will be computed once all NEM and Non-NEM customers across our member cities and are fully enrolled. In the interim, we are reporting on the opt outs and eligible accounts associated with the phase on a rolling basis as of the reporting month:

E) Contact Center Metrics
Call volumes in the month of September were surprisingly lower compared to August by 24%. Even amidst the unprecedented heat wave during the first week of September, we believe this reduction in call volume was primarily a result of our social media campaigns which were meant to arm customers with all the pertinent information needed for flex alert events including tips on how to reduce electricity use while mitigating against extreme heat – like precooling your home and running major appliances outside of peak hours.

In light of the heatwave which generally increased customers’ usage as a function of cooling needs, we are anticipating higher-than-normal bills in October right before the transition from Summer and into the Winter season. Additionally, the $64.17 California Climate Credit that was applied to both August and September bills to help offset high Summer electricity charges will no longer be applied to customer bills. These factors could result in an increase of opt outs and call volume into our Contact Center from customers with high bill inquiries. Week over week, we’ve noticed that our cumulative opt outs during the period from 10/10/2022 -10/16/2022 doubled relative to our previous weeks’ opt out counts.

The chart below summarizes contact made by customers into our Contact Center broken down by month through October 16th:

Similar to other mass enrollments in other CCAs’ service territories, we are anticipating the trend of our customers calling into our Contact Center’s Interactive Voice Response (IVR) system tree and being able to self-serve their opt actions using the recorded prompts as well as utilizing our website for processing opt actions to continue accounting for over 65% of all instances. The remaining portion of customer calls are connected to our Customer Service Representatives to answer additional questions, assist with account support, or submit opt actions.

As of this latest reporting month, we still have a total of 13 Dedicated Customer Service Representatives staffed at our Contact Center. Our robust Quality Assurance (QA) procedures are firmly in place to ensure that our customers are getting a world-class customer experience when they contact us.

COMMITTEE REVIEW
N/A

FISCAL IMPACT
N/A

ATTACHMENTS
N/A
0 50
100
150
200
250
300
350
400
450
500

COUNT OF EMAILS RECEIVED
Customer Service Email Trends.

Emails Received Emails answered or escalated within 24 hours

SAN DIEGO COMMUNITY POWER
Staff Report – Item 6
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Sebastian Sarria, Policy Manager
Stephen Gunther, Senior Regulatory Analyst
Via: Karin Burns, Chief Executive Officer
Subject: Update on Regulatory and Legislative Affairs
Date: October 27, 2022
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATIONS
Review and file update on Regulatory and Legislative Affairs.

BACKGROUND
Staff will provide regular updates to the Board of Directors regarding SDCP’s regulatory and legislative engagement.

ANALYSIS AND DISCUSSION
A) Legislative Updates
Inflation Reduction Act of 2022
Staff plans to submit a joint letter with other CCAs to the U.S. Department of Treasury. The United States (US) Department of Treasury is collecting public comment that will help it implement the tax incentives found in the Inflation Reduction Act (IRA). SDCP plans to submit a joint comment letter with other CCAs by November 4th which will generally address the following questions:
• How can customers shopping for a used electric vehicle determine whether it is eligible to receive a tax credit?
• Are new regulations needed to certify that clean energy projects, like wind farms, are eligible for enhanced support when they use American-made materials?
• What kinds of data and information should be used to determine the location of energy communities where clean energy investments may qualify for additional tax incentives?
• What requirements should home energy auditors meet for their services to qualify for a tax credit?
• What kinds of technologies should qualify for expanded investment tax credits for energy storage?
B) Regulatory Updates
Disadvantaged Communities Green Tariff (DAC-GT), Community Solar Green Tariff (CSGT)
As anticipated in the regulatory and legislative affairs staff report (pages 61-64) of the September 2022 Board of Directors meeting, staff submitted a Tier 3 Implementation Advice Letter on October 12, 2022, to become a program administrator under the DAC-GT and CSGT programs. While staff anticipates that approval of the advice letter will occur in the new year, staff continues to work with San Diego Gas & Electric (SDG&E) over implementation matters related to the billing of customers. Moreover, the California Public Utilities Commission (CPUC) approved, on an interim basis at their October 6, 2022, meeting that federally recognized tribal nations are now considered disadvantaged communities (DACs) and are therefore now eligible for the DAC-GT and CSGT programs. Staff anticipates that future collaboration will occur with tribal nations in San Diego County that want to participate in these programs.

Integrated Resource Plan (IRP) Rulemaking
On September 8, 2022, the CPUC issued a Ruling within the Integrated Resource Plan (IRP) proceeding seeking comments on near-term changes and staff options on a programmatic approach to procurement. The Ruling is divided into two sections.

The section regarding near-term changes the Commission could make to encourage load serving entities (LSE) to procure resources in a difficult market environment proposed making resource baseline adjustments for two previous IRP procurement orders. This baseline adjustment would allow any resources that have come online since January 1, 2020 to count towards those requirements. In addition, the Ruling proposed two options for allocating new procurement obligations resulting from this adjustment: one that would be applied to individual LSEs with baseline resources that are not yet online, or one in which the requirements would be allocated across all LSEs collectively.

On September 26, 2022, SDCP submitted opening comments in opposition to the proposal, and emphasized flaws in the collective allocation option if the Commission were to move forward with the resource baseline adjustment. SDCP’s opening comments also included the recommendation to modify a previous decision, D.22-05-015, to base D.19-11-016 allocations on the most current version of a non-IOU LSE’s 2023 Year Ahead load forecast. This modification would allow SDCP to purchase the system resource adequacy capacity from SDG&E based on SDCP’s load after expansion to include the County of San Diego and National City rather than SDCP’s load at the time of the Decision. SDCP filed reply comments on October 6 reiterating concerns with the collective allocation baseline adjustment approach.

The Ruling also included a section proposing the need for a programmatic approach to planning and procurement. Options for such an approach are outlined in a staff paper titled, Reliable and Clean Power Procurement Program: Staff Options Paper (“Staff Paper”). The Staff Paper articulates various options for developing a new program that establishes mid-to long-term forward procurement obligations on LSEs. SDCP staff attended a CPUC workshop on the Staff Paper on September 20, 2022 and continues to work with CalCCA to analyze the various options and implications for SDCP.

The CPUC granted an extension for commenting on the Staff Paper, with opening comments now due December 12, 2022, and reply comments due on January 9, 2023.

SDG&E’s 2023 ERRA Forecast Update
Background
On May 31, 2022, SDG&E filed its 2023 Energy Resource Recovery Account (ERRA) Forecast. ERRA proceedings are used to determine fuel and purchased power costs which can be recovered in rates. Notably, Power Charge Indifference Adjustment (PCIA) rates are set in SDG&E’s ERRA forecast proceedings based on the difference between the forecasted cost of SDG&E’s generation in the target year and the forecasted market value.

Update – Opening and Reply Briefs
On October 3, 2022, SDCP along with Clean Energy Alliance (CEA), (collectively, “CCA Parties”), submitted an Opening Brief SDG&E’s Application for Approval of its 2023 Electric Procurement Revenue Requirement Forecasts, 2023 Electric Sales Forecast, and GHG Related Forecasts, submitted on May 31, 2022 (“Application”). The CCA Parties offered the following recommendations to the CPUC:

1. The Commission should reject SDG&E’s proposal for stakeholders to submit alternative sales forecasts before the ERRA forecast application or, in the alternative, require SDG&E to disclose all essential forecasting data at least two months prior to the deadline for such alternative sales forecasts.

2. SDG&E’s position that it will not incorporate proposed budgets for CCA Communities Green Tariff (“DAC-GT”) and Community Solar Green Tariff (“CSGT”) programs is inconsistent with relevant Commission precedent and the Commission should re-affirm its prior decision declaring that utilities must set aside funding for the program budgets proposed by CCAs, subject to a final Commission decision.

3. It would be unreasonable and premature to approve SDG&E’s disposition of its anticipated residual 2023 year-end PCIA Under-collection Balancing Account (“CAPBA”) balance until that balance is understood with more certainty in next year’s ERRA forecast proceeding.

4. The Commission should recognize the CCA Parties accounting framework for implementing D.19-11-016 and D.22-05-015 Modified Cost Allocation Modification (MCAM) procurement costs as just, reasonable, and consistent with applicable Commission decisions.

On October 10, 2022, the Joint CCAs submitted a Reply Brief, which pointed out SDG&E's brief failed to acknowledge the proposal for implementation of MCAM, as well as clarified other positions and responded to SDG&E's excess GTSR arguments.

October Update and Next Steps
On October 12, 2022, SDG&E filed its “October Update” which provides updated forecasts of ERRA revenue requirements, GHG data, unbundled load data and is intended to update information already presented with more current information.

SDCP is still analyzing the October Update and its implications on SDG&E’s 2023 PCIA rate. Comments on the October Update are due October 28, 2022.

COMMITTEE REVIEW
N/A

FISCAL IMPACT
N/A

ATTACHMENTS
N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 7
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Jen Lebron, Director of Public Affairs
Via: Karin Burns, Chief Executive Officer
Subject: Marketing and Public Relations Update
Date: October 27, 2022
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file update on Marketing and Public Relations activities for San Diego Community Power.

BACKGROUND
San Diego Community Power (SDCP) has engaged in a variety of public relations, marketing, and community outreach activities to drive awareness, spark engagement, and minimize opt-outs.

ANALYSIS AND DISCUSSION
SDCP participated in a record number of community events since the organization’s inception during the months of September and October.

SDCP has increased its focus on community engagement over the last two months as it develops its Community Power Plan, which will be a roadmap for the selection, development, and investment of local programs based on community needs and gaps in program offerings. To ensure the plan reflects the needs of ratepayers, SDCP engaged in a Community Needs Assessment, which included listening sessions, interviews with key stakeholders, and conducting a survey, which thousands of San Diego residents participated in.

Aside from collecting survey results, attending the following events gave SDCP an opportunity to connect with community members and answer questions they have about the organization.

Public Engagement Events
SDCP participated in the following outreach events:

September 8, 2022 - ZE Summit at Scripps Institution of Oceanography September 10, 2022 – Fully Charged Home Energy & EV Show September 11, 2022 – Spring Valley Swap Meet
September 14, 2022 – North San Diego Business Chamber Regional Connect Networking
September 16, 2022 – Mexican Independence Celebration at Mujeres Brew House September 17, 2022 – Green Summit
September 17, 2022 – San Diego Wave FC FanFest
September 18, 2022 – National City Swap Meet
September 23, 2022 – La Mesa Movie Night
September 24, 2022 - El Callejón Swap Meet
September 27, 2022- Lakeside Library Food Distribution
September 28, 2022 – Julian Library Food Distribution
September 29, 2022 – San Diego Food System Alliance
September 30, 2022 – San Diego Wave FC FanFest
October 1, 2022 – Outreach at Kimball Park
October 1, 2022 – Outreach at Imperial Beach Sports Park October 2, 2022 – Paddle for Clean Water
October 4, 2022 – Old Mission Rotary
October 5, 2022 – Outreach at Ramona Library
October 9, 2022 – Encinitas EcoFest
October 12, 2022 – Outreach at Chula Vista Public Library October 13, 2022 – Outreach at National City Public Library October 15, 2022 – Clairemont Days
October 15, 2022 – National City Filipino-American Heritage Month October 16, 2022 – SD Wave FC FanFest
October 20, 2022 – San Diego Green Drinks Presentation
October 21, 2022 – San Diego Climate Action Campaign Nexus Climate Conference October 21, 2022 – La Mesa Movies in the Park
Paid Advertising
SDCP purchased ads in print publications El Latino, The Filipino Press, San Diego Asian Journal, and San Diego en Español, to encourage historically hard-to-reach populations to provide the survey responses.

Power100 Champion Comarketing
SDCP’s newest Power100 Champion, the San Diego Wave Fútbol Club, became the first National Women’s Soccer League team to make the commitment to using 100 percent renewable energy in the facilities it controls. SDCP advertising has been prominently featured in all of the Wave’s home games at Snapdragon Stadium, including record-breaking crowds on their opening day and first playoff match.

Communications and Outreach Strategy
SDCP is in regular communication with regional media in the spirit of transparency and openness.

It is developing its communications and outreach strategies for the onboarding of new board members this winter, rate adjustments in January, and the enrollment of National City and the unincorporated areas of San Diego County next spring.

COMMITTEE REVIEW
This item was reviewed by the Community Advisory Committee on October 13, 2022.

FISCAL IMPACT
N/A

ATTACHMENTS
N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 9
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Eric W. Washington, Chief Financial Officer
Via: Karin Burns, Chief Executive Officer
Subject: Receive and File 6/30/22 Fiscal Year End Audited Financial Statement Date: October 27, 2022
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file report.

BACKGROUND
On October 1, 2019, the Founding Members of San Diego Community Power (SDCP) adopted the Joint Powers Agreement (JPA) which was amended and restated on December 16, 2021.

Section 4.6.14 of the JPA specifies the Board of Directors (Board) shall arrange for an annual independent fiscal audit.

Section 5.4 of the JPA specifies the Board shall appoint a Treasurer who shall function as the combined offices of Treasurer and Auditor and shall strictly comply with the statutes related to the duties and responsibilities specified in Section 6505.5 of the Act. The section further specifies that the Treasurer shall cause an independent audit(s) of the finances of SDCP to be made by a certified public accountant, or public accountant, in compliance with Section 6505 of the Act.

Section 7.2.2 of the JPA additionally specifies that the SDCP Board shall contract with a certified public accountant to make an annual audit of the financial statements of SDCP, which shall be conducted in accordance with the requirements of Section 6505 of the Act.

On July 1, 2021, SDCP entered into a professional services agreement with Pisenti & Brinker to perform its annual audit for FY 2020-21. On July 1, 2022, SDCP exercised an option in the professional services agreement to extend the term from June 30, 2022, to June 30, 2023, to conduct its annual audit for FY 2021-22. Pisenti & Brinker is a firm with extensive experience auditing CCA’s throughout California, as well as other local government entities.

ANALYSIS AND DISCUSSION
Pisenti & Brinker prepared a presentation describing the audit process and results.

COMMITTEE REVIEW
The report was reviewed by the Financial Risk Management Committee (FRMC) on October 20, 2022.

FISCAL IMPACT
Not applicable

ATTACHMENTS
Attachment A: Audited Financial Statements for Fiscal Year Ended June 30, 2022

SAN DIEGO COMMUNITY POWER
Staff Report – Item 10
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Victoria Abrenica, Public Outreach Associate
Via: Karin Burns, Chief Executive Officer
Subject: Receive Quarterly Report from the Community Advisory Committee Date: October 27, 2022
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file quarterly report from the San Diego Community Power (SDCP) Community Advisory Committee.

BACKGROUND
Section 5.10.3 of the SDCP Joint Powers Authority (JPA) Agreement states that the “primary purpose of the Community Advisory Committee shall be to advice the Board of Directors and provide for a venue for ongoing citizen support and engagement in the strategic direction, goals, and program of [SDCP].”
At the direction of the Chair of the SDCP Board of Directors, the Community Advisory Committee, via staff, shall provide quarterly updates during the regular meetings of the Board of Directors on a quarterly basis. The last quarterly update was provided on July 28, 2022.

ANALYSIS AND DISCUSSION
At the July 28, 2022, regular meeting of the Board of Directors, staff presented a recap of the CAC’s activities for the months of April, May, and June. This next update provides recaps for the months of July, August, and September, as demonstrated below. It should be noted that due to the ongoing activities on the development of the Community Power Plan, this was added as a standing item in order to provide ongoing updates and receive feedback on the process.
• July: The group received an update and provided input and recommendations to the board on the updated CAC Operating Guidelines. The committee received an update and provided input on SDCP’s Supplier Diversity Efforts. Rita de la Fuente, Director of External Affairs, Lucas Utouh, Director of Data Analytics and Accounts Services, and Rachel Hommel, Marketing and Communications Manager, provided updates on public relations and back-office operations. They focused specifically on the open Chula Vista CAC seat, open staffing positions, enrollment, and social media updates. Nelson Lomeli, Program Manager, provided an update on the status of the Community Power Plan.
• August: The group welcomed Anthony Sclafani to the CAC as the newest representative from Chula Vista. Officer elections were held for the positions of Chair, Vice Chair, and Secretary. Eddie Price was reelected for his third and final term as Chair, Aida Castañeda was elected as Vice Chair for her first term, and Anna Webb was reelected for her third and final term as Secretary. The group also appointed members to join an Executive Advisory Ad-Hoc Committee. The ad-hoc committee is made up of Aida Castañeda, Tara Hammond, Tony Sclafani, Peter Andersen, and David Harris. The committee met and created cohesion between the executive team and the CAC. Arup and Kearns & West held a workshop with the group, where feedback was received on the development of SDCP’s Community Power Plan. Staff also provided updates to the CAC on the recent public relations and back-office operations. Lastly, the CAC saw the departures of two of its members. Tom Summers resigned due to his residency changes from Imperial Beach. Meanwhile, Victoria Abrenica resigned due to her recent employment as SDCP’s Public Outreach Associate.
• September: The committee received an introduction to Jen Lebron, SDCP’s newest hire as Director of Public Affairs. Karin Burns, CEO of SDCP, gave a presentation to the committee on SDCP’s mission, vision, core values, and goals for 2023-2027. Lucas Utouh, Director of Data Analytics and Accounts Services, and Rachel Hommel, Marketing and Communications Manager, provided an update on public relations and back-office operations. They focused on the latest events SDCP had attended and planning to attend, as well as the latest opt-up, opt-out, and opt-down metrics. Nelson Lomeli, Program Manager, provided a brief update on the status of the development of the Community Power Plan.

Particularly, Nelson reiterated the survey currently available for everyone to complete and provide feedback on the Plan. The CAC still has two openings available to represent the city of Imperial Beach and unincorporated San Diego County.

Staff will return to the Board at the start of the first quarter of the year, which will take place in January, to report on fourth quarter activities.

FISCAL IMPACT
There is no fiscal impact associated with this action.

ATTACHMENTS
N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 11
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Stephen Gunther, Senior Regulatory Analyst
Byron Vosburg, Managing Director of Power Services
Via: Karin Burns, Chief Executive Officer
Subject: Approval of the San Diego Community Power 2022 Integrated Resource Plan
Date: October 27, 2022
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATIONS
Approve San Diego Community Power’s 2022 Integrated Resource Plan.

BACKGROUND
Public Utilities Code Section 454.52 requires all California Public Utilities Commission (CPUC) load serving entities (LSEs), including community choice aggregation (CCA) programs, file an Integrated Resource Plan (IRP) with the CPUC every two years. The IRP looks out at a multi-year horizon (2023-2035) and details the procurement plan for meeting the state’s goals of reducing greenhouse gas (GHG) emissions by 40% from 1990 levels by 2030 and increasing to a resource mix of 60% renewable energy resources by December 31, 2030.

Section 454.52(b)(3) further requires that the IRP of a CCA be submitted to its governing board for approval and shall achieve the following:
(A) Economic, reliability, environmental, security, and other benefits and performance characteristics that are consistent with the goals of achieving 40% reduction in GHG emissions from 1990 levels by 2030 and procure 50% renewable energy resources by December 31, 2030.
(B) A diversified procurement portfolio consisting of both short-term and long-term electricity and electricity-related and demand reduction products. (C) Resource Adequacy requirements.

The 2022 IRP filing is prepared using the CPUC provided Narrative Template, Resource Data Template, and the Clean Power Supply System Calculator (“CSP Tool”). The CPUC adopts a Reference System Portfolio, and each LSE is required to file an IRP based on its proportional load share within this portfolio. Two are required to be filed by each LSE consistent with a statewide GHG emission target for the electric sector using the CPUC’s Reference System Portfolio:
• 30 MMT conforming portfolio - achieves emissions that are equal to or less than SDCP’s proportional share of the 38 million metric ton (MMT) by 2030 and 30 MMT by 2035 GHG targets.
• 25 MMT conforming portfolio - achieves emissions that are equal to or less than SDCP’s proportional share of a 30 MMT by 2030 and 25 MMT by 2035 GHG targets.

In addition, LSEs are required to select a "Preferred Conforming Portfolio" (“PCP”) among all Conforming Portfolios.

The deadline for submission of SDCP’s IRP is November 1, 2022.

ANALYSIS AND DISCUSSION
SDCP developed its 2022 IRP using its assigned load forecast from the 2022 Final GHG Emission Benchmarks for LSEs as shown below:

SDCP’s Assigned Shares of GHG Reduction Benchmarks
2035 Load (GWh)
Proportion of 2035
Load within
SDG&E Territory
2035 GHG
Benchmark – 30
MMT Scenario
2035 GHG
Benchmark – 25
MMT Scenario
8,476.83 47.2% 1.072 0.863
SDCP’s two confirming portfolios achieved its proportional share of both the 2030 30 MMT GHG and 2035 25 MMT GHG Benchmarks, and as such, SDCP selected its 25 MMT Conforming Portfolio as its PCP. Based on the 25 MMT version of the CSP calculator, SDCP’s 25 MMT PCP would result in total 2030 GHG emissions of 0.837 MMT and 2035 GHG emissions of 0.631 MMT, which is well below its assigned load-proportional share of the 25 MMT benchmark.

Baseline assumptions for SDCP’s PCP aligns both with of SDCP’s objectives to be 100% renewable by 2035 and 15% Local Infill. Additionally, they include diversity in planned generation mix (solar, wind, geothermal, hydro, natural gas, battery storage, etc.) for energy and resource adequacy capacity, assumptions regarding new buildout vs. use of existing resources, and geographic regions for planned resources. Note that due to assumptions regarding curtailment built into the CPUC’s CSP Tool, SDCP’s 100% renewable portfolio is shown as 95% (net of curtailments) due to differences in assumptions, but this will in no way prevent SDCP from achieving its 100% target.

Approximately 2,885 MW of SDCP’s 2035 portfolio is composed of new resources, reflecting SDCP’s role as an active player in the State’s development of new renewable and storage resources. SDCP’s PCP focuses on combined solar/storage projects since its locale and services territory have ample sites for local projects. In the Battery Storage category, SDCP also includes the energy storage capacity associated with hybrid solar plus storage facilities. This hybrid system will allow for higher renewable utilization rates and reduce production risk.

SDCP’s 25 MMT PCP includes the procurement of the following new resources:
• New hybrid resources totaling 1,615 MW
• New wind resources totaling 550 MW
• New grid connected battery storage of 750 MW
• New long duration storage of 60 MW
SDCP’s 25 MMT PCP provides for the following overall resource mix in 2035:
• 35 MW of Large Hydro
• 100 MW of Geothermal
• 800 MW of Wind
• 150 MW of Solar
• 813 MW of Short Duration Battery Storage
• 60 MW of Long Duration Storage
• 540 MW of Natural Gas/Baseload/Other (Capacity-Only)
SDCP’s IRP is consistent with the goal of minimizing local air pollutants, with early priority on Disadvantaged Communities as defined by the CalEPA’s designation. SDCP’s contribution to air pollutants is exclusively a result of reliance on system power and an allocation of emissions from CHP resources imposed by the CSP tool, resulting in the following emissions estimates:

SDCP Portfolio Air Pollutants
2024 2026 2030 2035
NOx 372 62 59 27
SOx 40 2 2 1
PM2.5 134 19 18 8
SDCP’s IRP also includes an Action Plan detailing SDCP’s next steps to promote conformance with its portfolios, including a continued focus on Communities of Concern and implementation of local programs informed by the Community Power Plan.

COMMITTEE REVIEW
N/A

FISCAL IMPACT
The IRP is consistent with assumptions underlying SDCP’s financial pro forma projections. There are no direct fiscal impacts of adopting the IRP since it is non-binding, and future resource commitments that may be made in effectuating the plan will be subject to separate approval in accordance with SDCP’s adopted delegation of authorities.

ATTACHMENTS
San Diego Community Power 2022 Integrated Resource Plan 1 Standard LSE Plan
San Diego Community Power
2022 INTEGRATED RESOURCE PLAN
NOVEMBER 1, 2022
2 Table of Contents
I. Introduction and Executive Summary .................................................................................... 4 a. Introduction ............................................................................................................................ 4 b. Executive Summary ............................................................................................................... 8 II. Study Design ........................................................................................................................ 10 a. Objectives ............................................................................................................................. 10 b. Methodology ........................................................................................................................ 11 i. Modeling Tool(s) .................................................................................................... 11 ii. Modeling Approach ................................................................................................ 12 III. Study Results ..................................................................................................................... 14 a. Conforming and Alternative Portfolios ................................................................................ 14 b. Preferred Conforming Portfolios .......................................................................................... 20 i. 25 MMT Preferred Conforming Portfolio .............................................................. 20 c. GHG Emissions Results ....................................................................................................... 23 d. Local Air Pollutant Minimization and Disadvantaged Communities .................................. 24 i. Local Air Pollutants ................................................................................................ 24 ii. Focus on Disadvantaged Communities ................................................................... 24 e. Cost and Rate Analysis ........................................................................................................ 28 f. System Reliability Analysis ................................................................................................. 29 g. High Electrification Planning ............................................................................................... 33 h. Existing Resource Planning ................................................................................................. 33 i. Hydro Generation Risk Management ................................................................................... 34 j. Long-Duration Storage Planning ......................................................................................... 35 k. Clean Firm Power Planning ................................................................................................. 35 l. Out-of-State Wind Planning ................................................................................................. 35 m.Offshore Wind Planning....................................................................................................... 36 n. Transmission Planning ......................................................................................................... 36 IV. Action Plan......................................................................................................................... 37 a. Proposed Procurement Activities and Potential Barriers ..................................................... 37 i. Resources to meet D.19-11-016 procurement requirements ................................... 38 ii. Resources to meet D.21-06-035 procurement requirements, including: ................ 38 a. 1,000 MW of firm zero-emitting resource requirements ........................................ 38 b. 1,000 MW of long-duration storage resource requirements ................................... 39 c. 2,500 MW of zero-emissions generation, generation paired with storage, or demand response resource requirements .............................................................................. 39 3 d. All other procurement requirements ....................................................................... 40 iii. Offshore wind ......................................................................................................... 41 iv. Out-of-state wind .................................................................................................... 41 v. Other renewable energy not described above ......................................................... 42 vi. Other energy storage not described above .............................................................. 42 vii. Other demand response not described above .......................................................... 43 viii. Other energy efficiency not described above.......................................................... 43 ix. Other distributed generation not described above .................................................. 43 x. Transportation electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR) ........................................................... 44 xi. Building electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR) ........................................................... 44 xii. Other ....................................................................................................................... 44 b. Disadvantaged Communities................................................................................................ 44 c. Commission Direction of Actions ........................................................................................ 46 V. Lessons Learned ................................................................................................................... 47 Glossary of Terms ........................................................................................................................ 48 4 I. Introduction and Executive Summary
a. Introduction
Description of San Diego Community Power
San Diego Community Power (“SDCP”) is a Joint Powers Authority (“JPA”) formed by the communities of Chula Vista, Encinitas, Imperial Beach, La Mesa, and San Diego in October 2019. In November 2021, SDCP’s founding member agencies were joined by National City and the unincorporated areas of San Diego County. As a JPA, SDCP is a local government agency.

SDCP is governed by a seven-member board composed of representatives of its member local governments. Through these representatives SDCP is controlled by and accountable to the communities SDCP serves. SDCP plans to provide retail electric generation services and complementary energy programs to customers within the municipal boundaries of the following communities:
• City of Chula Vista
• City of Encinitas
• City of Imperial Beach
• City of La Mesa
• City of National City
• City of San Diego
• County of San Diego
SDCP commenced retail electric service to its first phase of customer enrollments in March 2021. As of June 2022, SDCP successfully completed the majority of its planned phase-in activities of its founding five member agencies, with service to National City and the unincorporated areas of the County of San Diego expected to commence in April 2023. Net Energy Metering customers are being enrolled into SDCP as of their month of true up. Following the completion of upcoming expansion activities in 2023, SDCP expects to serve approximately 930,000 service accounts, which are expected to consume about 8,400 gigawatt hours (“GWh”) per year.
5 Figure 1: Service Area Map
As of June 30, 2022, SDCP served approximately 629,900 residential accounts and 70,800 commercial and industrial accounts based on meter count. SDCP provides retail generation service to a variety of customer classes, including residential, small, and medium commercial accounts, large industrial consumers, and agricultural and pumping facilities. SDCP’s service area has a population of 1,811,684, the majority of which live in households or work at businesses that receive generation service from SDCP. In 2021, SDCP had a peak load of 751 (“megawatts”) MW, and a total 2021 energy usage of 2,129 GWh.

At launch, SDCP’s governing board approved a minimum 50 percent renewable energy supply portfolio for all participating customers with a 100 percent renewable retail service option available on a voluntary basis. These retail service offerings have been named “PowerOn” and “Power100,” respectively. The minimum quantity of renewable energy delivered to SDCP customers is expected to increase over time, moving to 85 percent by 2030.

SDCP’s Mission
SDCP was formed for the express purpose of empowering its member communities to choose the generation resources that reflect their specific values and needs. SDCP was established to procure and develop electrical energy for customers in participating jurisdictions, address climate change by reducing energy-related greenhouse gas emissions, promote electrical rate price stability and affordability, and foster local economic benefits such as job creation, local energy programs and local power development while prioritizing equity. Consistent with Public Utilities Code Sections 366.2(a)(5) and 454.52 (b)(3),1 all procurement by SDCP, including the 1 Pub. Util. Code, §§ 366.2(a)(5)(CCAs are solely responsible for all generation procurement activities absent other arrangements authorized by statute); 454.52 (b)(3) (CCA’s IRPs must be approved by board and provided to Commission for certification).

Source: https://www.sdge.com/customer-choice/community-choice-aggregation/active-ccas 6 portfolios set forth in this integrated resource plan (“IRP”), must comply with policy direction provided by SDCP’s governing board.

Introduction to SDCP’s IRP
In accordance with the requirements of California Public Utilities Code (“PUC”) Sections 454.51 and 454.52 and California Public Utilities Commission (“Commission”) Decision (“D.”) D.22- 02-004, Administrative Law Judge’s Ruling Finalizing Load Forecasts and Greenhouse Gas Emissions Benchmarks for 2022 Integrated Resource Plan Filings, 2 and guidance provided by
the Commission’s Energy Division3, SDCP is providing its load-serving entity (“LSE”)-specific IRP to the Commission for certification and use in the Commission’s statewide planning process.

In addition to this narrative, SDCP’s IRP includes the following documents:
• SDCP’s 2030 38 MMT & 2035 30 MMT Resource Data Template and Clean System Power Calculator
• SDCP’s 2030 30 MMT & 2035 25 MMT Resource Data Template and Clean System Power Calculator
• SDCP’s IRP Verification
As directed in D.22-02-0044 and the Final Ruling, SDCP studied two Conforming Portfolios in this IRP. The first Conforming Portfolio achieves emissions that are equal to or less than the SDCP’s proportional share of the 38 million metric ton (“MMT”) greenhouse gas (“GHG”) target by 2030 and 30 MMT by 2035 (“30 MMT”). The second Conforming Portfolio achieves emissions that are equal to or less than SDCP’s proportional share of 30 MMT by 2030 and 25 MMT by 2035 (“25 MMT”). SDCP intends to exceed its proportional share of both the 2030 30 MMT GHG and 2035 25 MMT GHG Benchmarks, so SDCP only provides one Preferred Conforming Portfolio (“PCP”). This PCP is submitted in two sets of Resource Data Templates (“RDTs”) and Clean System Power calculators (“CSPs”) for each 2035 GHG target, per the Final Ruling, and the outputs of the RDTs and CSPs are discussed separately below. 5 Projecting resource needs over the planning horizon covered by the IRP is a fluid process and SDCP expects changes over time. The future resources identified in SDCP’s IRP represent SDCP’s current good-faith projection of the resource mix that will be procured over the IRP planning horizon. Such projections are based on best available information regarding planning directives, SDCP policy, resource availability, and other key considerations. The resources 2 Rulemaking (“R.”) 20-05-003, Administrative Law Judge’s Ruling Finalizing Load Forecasts and Greenhouse Gas Emissions Benchmarks for 2022 Integrated Resource Plan Filings ("Final Ruling"), June 15, 2022.
3 Energy Division Guidance can be accessed at: https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/long-term-procurement-planning/2022-irp-cycle-events-and-materials. 4 D.22-02-004 at 2.
5 Final Ruling at 12; Ruling Paragraph 2.
7 identified in future iterations of SDCP’s IRP may change due to new information and evolving circumstances, and the ultimate resource mix that SDCP actually procures (in future years) may differ from what is reflected in this plan due to a number of variables, including availability of supply, technology changes, price of supply, and/or other market or regulatory considerations.

Examples of future regulatory changes include the upcoming “Slice of Day” framework for the Resource Adequacy (“RA”) program,6 as well as structural, programmatic changes to the IRP program.7 Though the impact of these changes is uncertain at this time, they have the potential to materially reshape how capacity and energy are valued for reliability purposes, and in turn, such changes may impact SDCP’s future procurement decisions. Through its relevant staff and involvement and membership in the California Community Choice Association (“CalCCA”), SDCP will continue to monitor and engage in Commission proceedings and incorporate pertinent planning and procurement adaptations as necessary.

Board Approval of IRP
In compliance with Public Utilities Code Section 454.52(b)(3), this IRP was formally submitted to SDCP’s governing board for approval based on the IRP’s compliance with Sections 454.51 and 454.52 and all relevant council-adopted procurement requirements of SDCP’s governing board. On October 27, 2022, SDCP’s governing board carried a motion by vote to formally approve this IRP and adopt SDCP’s 30 MMT and 25 MMT PCP. In approving this IRP narrative, SDCP’s board also makes the following determinations regarding SDCP’s PCP:
• SDCP’s PCPs are expected to achieve economic, reliability, environmental, security, and other benefits and performance characteristics that are consistent with the goals set forth in Section 454.52(a)(1)(A-I).
• SDCP’s PCPs include a diversified procurement portfolio consisting of both short-term and long-term electricity and electricity-related and demand reduction products. • SDCP’s PCPs achieve the resource adequacy requirements established pursuant to Public Utilities Code Section 380.
• SDCP’s PCPs are consistent with the procurement timing, resource mix, and operational attributes of the Commission’s Preferred System Portfolio (“PSP”).8 • SDCP’s PCPs are compliant with all SDCP board-adopted procurement directives.

SDCP’s governing board meeting details are available on SDCP’s website. 9 6
Decision 22-06-050.
7 See Rulemaking 20-05-003, Administrative Law Judge’s Ruling Seeking Comments on Staff Paper on Procurement Programs and Potential Near-Term Actions to Encourage Additional Procurement (September 8, 2022), Attachment A.
8 In Decision 22-02-004 at 105 and Ordering Paragraph (“OP”) 8, the Commission adopted the 30 MMT Core Portfolio with 2020 IEPR Demand and High Electric Vehicle (“EV”) Penetration Scenario.
9 SDCP Board Meeting Materials, available at https://sdcommunitypower.org/resources/meeting-notes/ 8 Request for Certification
SDCP respectfully requests that the Commission certify this IRP.

As both the Legislature and the Commission have recognized, the Legislature has granted community choice aggregators (“CCA”) broad authority to procure resources on behalf of their respective customers, an authority limited only where “other generation procurement arrangements have been expressly authorized by statute.”10 Likewise, the Legislature has granted CCAs autonomy in setting their own rates and managing interactions with their customers.11 SDCP understands that the Commission has three primary interests in the CCA IRP process:
• Ensuring that CCA IRPs provide requisite procurement information needed by the Commission to develop its statewide plan.12
• Ensuring that CCAs’ current and planned procurement is consistent with the RA requirements established pursuant to PUC Section 380.5.13 • Ensuring that CCAs’ current and planned procurement satisfies the CCA’s share of renewables integration resources identified in the Commission’s PSP, and that the CCA either self-provides or pays for investor-owned utility (“IOU”) procurement to support its share of any renewable integration shortfall.14
SDCP has prepared its IRP with these interests in mind, and thanks the Commission for recognizing and preserving CCA procurement autonomy as well as the benefits of a collaborative planning approach with CCA organizations in its certification review of SDCP’s IRP.
b. Executive Summary
This narrative provides a detailed description of the development and content of SDCP’s conforming portfolios and the PCP, each portfolio’s compliance with applicable requirements, and an action plan detailing SDCP’s next steps to promote conformance with such requirements. 10 PUC Section 366.2(a)(5).
11 D.05-12-041 at 9-11 (“Nothing in the statute directs the CPUC to regulate the CCA’s program except to the extent that its programs may affect utility operations and the rates and services to other customers. For example, the statute does not require the CPUC to set CCA rates or regulate the quality of its services… We are confident that existing law protects CCA customers. Entities of local government, such as CCAs, are subject to numerous laws that will have the effect of protecting CCA customers and promoting accountability by CCAs…”). 12 D.19-04-040 at 17-18 (“The Commission’s portfolio aggregation and evaluation process, which relies of fulfillment of IRP filing requirements by LSEs, is the only process capable of assessing the overall needs of the CAISO grid and meeting the statewide GHG, reliability, and least-cost goals collectively. While LSEs may use their IRP process to meet local planning needs as well, the statewide planning function is the statutorily required process . . . .”). 13 Section 454.52(b)(3)(C).
14 Section 454.51.
9 SDCP developed its IRP through the following steps:
• SDCP compiled data for its existing energy contracts, RA capacity contracts, and its share of capacity for allocated Cost Allocation Mechanism (“CAM”) resources. • For each IRP planning year, SDCP identified its short positions relative to known planning targets and its assigned load forecast.
• SDCP populated the Resource Data Template with all current contracts. • SDCP compiled detailed information on projects for which it is currently negotiating power purchase agreements, including information regarding project status and timing. • SDCP identified future contracts it expects to secure for new solar, storage, biomass and wind generation. SDCP prioritized the selection of future resources to ensure that SDCP’s overall portfolio of new resources is consistent with the PSP resource attribute/category mix, procurement timing, and SDCP’s proportional share of planned new procurement.
• SDCP added generic future contracts with existing resources, including large hydroelectric generators, to help fill its remaining open positions. • SDCP added planned purchases of an additional 10,470 GWh in 2035 to create a portfolio which far surpasses the emissions requirement for both benchmarks. SDCP used this portfolio as its “25 MMT PCP”.
• SDCP used the Commission’s Clean System Power Calculator Tool to verify its GHG emissions associated with the resulting portfolio to ensure that these emissions were lower than SDCP’s assigned share of the 25 MMT and 30 MMT GHG Benchmarks. • SDCP checked its 25 MMT PCP for reliability by comparing the total portfolio net qualifying capacity (“NQC”) against SDCP’s RA requirements for the month of September during each year of the planning period. SDCP further established that its planned incremental capacity procurement exceeded its pro rata share of the related incremental capacity procurement obligation.

SDCP reached the following findings regarding its 25 MMT PCP:
• SDCP’s 25 MMT PCP includes the procurement of the following new resources:
o New hybrid resources totaling 1,615 MW
o New wind resources totaling 550 MW
o New grid connected battery storage of 750 MW
o New long duration storage of 60 MW
• SDCP’s 25 MMT PCP provides for the following overall resource mix in 2035:
o 35 MW of Large Hydro
o 0 MW of Biomass
o 100 MW of Geothermal
o 0 MW of Small Hydro
o 800 MW of Wind
o 150 MW of Solar
o 813 MW of Short Duration Battery Storage
o 60 MW of Long Duration Storage
o 540 MW of Natural Gas/Baseload/Other (Capacity-Only)
10 SDCP’s 25 MMT PCP is consistent with procurement timing, resource quantities, and general resource attributes identified in the PSP.
• SDCP’s 25 MMT PCP, when analyzed in the 25 MMT RDT and CSP, would have 2030 emissions of 0.84 MMT and 2035 emissions of 0.63 MMT, which is less than SDCP’s assigned share of 2030 and 2035 emissions.
• SDCP’s 25 MMT PCP, when analyzed in the 30 MMT RDT and CSP, would have 2030 emissions of 0.61 MMT and 2035 emissions of 0.45 MMT. This is less than SDCP’s assigned share of 2030 and 2035 emissions.
• SDCP’s 25 MMT PCP meets all relevant reliability metrics under both the 30 MMT and 25 MMT scenarios.
• SDCP’s 25 MMT portfolio provides approximately SDCP’s load-proportional share of renewable integration resources under both the 30 MMT and 25 MMT scenarios. • SDCP’s 25 MMT portfolio is also consistent with the Commission’s PSP and can be used in either a 25 MMT or 30 MMT consolidated statewide portfolio.

To implement its PCP, SDCP is adopting the action plan described in Section IV, below. This action plan consists of the following steps:
• SDCP will periodically solicit offers for new renewable generation and storage projects.

These resources are typically secured through long-term power purchase agreements.

SDCP expects to secure power purchase agreements for new projects in multiple solicitations conducted over the next several years.
• Periodically throughout the year, SDCP will solicit offers for short-term renewable energy, resource adequacy, system energy, and other products needed to balance the portfolio and adhere to position limits established through SDCP’s risk management policy and practices. These solicitations may take the form of formal request for offers, bilateral discussions, and/or transactions arranged through broker markets. • SDCP will continue to procure resources to meet any remaining assigned requirements from D.21-06-035, as well as the specific sub-categories from that decision. • SDCP will continue to develop a strategic plan for customer energy programs, called the Community Power Plan (“CPP”) to provide a decision-making framework to guide SDCP’s program strategy, selection and development of local programs based on community needs and gaps in program offerings. This framework will also address how SDCP can best serve disadvantaged communities within its service territory.

II. Study Design
a. Objectives
SDCP had the following objectives in performing the analytical work to develop its IRP:

1. Verify SDCP’s 25 MMT PCP is lower than the GHG Benchmarks for SDCP’s proportional share of the 30 MMT and 25 MMT GHG reduction benchmark, as determined using the Commission’s emissions calculator. 11 2. Identify a 25 MMT PCP that achieves economic, reliability, environmental, security, and other benefits and performance characteristics that are consistent with the goals set forth in Section 454.52(a)(1) (A-I).

3. Identify diverse and balanced 25 MMT PCP that includes both short-term and long-term electricity products as well as electricity-related demand reduction products.

4. Identify a 25 MMT PCP that achieves the resource adequacy requirements established pursuant to PUC Section 380 and provide SDCP’s share of system reliability and renewable integration resources.

5. Identify a 25 MMT PCP that complies with all of SDCP’s Board-adopted procurement directives.

6. Identify a 25 MMT PCP that is compliant with SDCP’s obligations under the Renewables Portfolio Standard (“RPS”) program.

7. Identify a 25 MMT PCP that is cost-effective and minimizes rate impacts on SDCP’s customers.
b. Methodology
i. Modeling Tool(s)
In developing its planned portfolios, SDCP made use of the modeling performed by the Energy Division using RESOLVE and SERVM and incorporated into the RDTv3 and CSP templates as a starting point. After studying this modeling and its conclusions, SDCP used its own experience and expertise in procurement to construct models to quantify portfolio targets for renewable energy content, capacity, and portfolio GHG emissions, as well as physical and financial positions to ensure adherence to SDCP’s currently effective risk management policies and business practices.

SDCP uses proprietary models to assess annual, monthly, and hourly open positions, taking account of forecasted hourly electric loads and expected deliveries from SDCP’s resource portfolio. SDCP uses a proprietary financial model to project power supply costs and incorporates existing and planned procurement into an overall financial assessment of revenues, costs, and cash flows. SDCP also utilizes a commercially available energy trading and risk management system to monitor positions, market exposure, credit exposure, value-at-risk, and other risk management metrics.

For new resource selection, SDCP relied upon the modeling and assumptions in the Preferred System Portfolio, and on SDCP’s ongoing and recent procurement experience, which provides insight into resource availability and cost. The mix of new resources selected in the Preferred System Portfolio is similar to the mix SDCP would select based on its procurement experience.

GHG emissions were assessed using the Commission’s Clean System Power tool for the 30 MMT and 25 MMT variations.

14 (“PCAP”) Planning Reserve Margin.
19 SDCP used technology-specific Effective Load Carrying Capacity (“ELCC”) factors provided by the Commission to assess the contribution of each resource to system reliability. SDCP’s portfolios were designed to ensure that current incremental resource adequacy capacity obligations from D.21-06-035 are met.

Calculating GHG Emissions
SDCP calculated the emissions associated with its 25 MMT PCP using the Commission’s 25 MMT and 30 MMT Clean System Power calculators. The assigned load forecast and default load shapes and behind the meter adjustments were used for this assessment, along with the planned supply portfolios. The results were checked against the assigned GHG benchmarks included in the Clean System Power tools.

III. Study Results
a. Conforming and Alternative Portfolios
As required by the Commission, SDCP is submitting two conforming portfolios – a 30 MMT Conforming Portfolio which achieves SDCP’s share of the 38 MMT by 2030 and 30 MMT by 2035 GHG targets (referred to as the “30 MMT Conforming Portfolio”); and a 25 MMT Conforming Portfolio that achieves SDCP’s share of the 30 MMT by 2030 and 25 MMT by 2035 GHG targets (referred to as the “25 MMT Conforming Portfolio”). SDCP is not submitting alternative portfolios. Please note, SDCP has used the same Conforming Portfolio to achieve both its 30 MMT and 25 MMT Conforming Portfolios. The portfolio inputs are the same but the outputs in the CSP and ELCC reliability section of the RDT will differ based on the 25 MMT and 30 MMT targets.

SDCP’s 30 MMT Conforming Portfolio
SDCP provides a summary of SDCP’s 2035 30 MMT Portfolio below, identifying resources by type and distinguishing between the following procurement categories:
• Existing resources (energy and capacity) that SDCP owns or contracts with, consistent with definitions provided in the Resource Data Template. • Existing resources (energy and capacity) that SDCP plans to contract with in the future. • Existing resources (capacity) that SDCP partially pays for through CAM. • New Resources (energy and capacity) that are under development that SDCP is planning to procure.
• Future new resources (energy and capacity) that SDCP is planning to procure.

In summary, to meet SDCP’s projected 2035 energy demand of 8,476.83 GWh, SDCP has selected a 2035 30 MMT Conforming Portfolio composed primarily of the following resources:
19 See Workshop: Reliability Filing Requirements for Load Serving Entities’ 2022 Integrated Resource Plans-Results of PRM and ELCC Studies (July 29, 2022) at Slide 31. 15 • Existing solar (owned or under contract) – 549 MW20 • Existing wind (owned or under contract) – 146 MW21
• Existing wind (planned procurement) – 250 MW
• Existing hydro (planned procurement) – 35 MW
• New solar (future resources) – 1,425 MW
• New wind (future resources) – 550 MW
• New geothermal (future resource) – 100 MW
• New short duration storage (future resources) – 750 MW • New long duration storage (future resources) – 60 MW
Additionally, SDCP’s 2035 30 MMT Conforming Portfolio includes capacity-only resources composed primarily of the following resources:
• CAM, Demand Response and Energy Efficiency Allocations – 626 MW • Existing natural gas, baseload, and other (planned procurement) – 95 MW SDCP’s portfolio includes a mix of existing and new resources. Approximately 2,885 MW of SDCP’s 30 MMT portfolio is composed of new resources, reflecting SDCP’s role as an active player in the State’s development of new renewable and storage resources. Furthermore, SDCP’s 30 MMT portfolio is comprised of a mix of resources in which SDCP can minimize customer rate impacts while still achieving the State’s GHG-reduction targets.

SDCP’s 30 MMT Conforming Portfolio Is Consistent with the Preferred System Plan The new resources included in SDCP’s 30 MMT Conforming Portfolio are consistent with the PSP 2035 new resource mix. The Commission adopted the PSP, which established the 38 MMT GHG target by 2030 and 30 MMT GHG target by 2035 and adopted the resources in Tables 5 and 6 of D.22-02-004.22
The Decision identifies planned use of resources in the following categories: Biomass, Geothermal, Wind, Wind on New-Out-of-State Transmission, Offshore Wind, Utility-Scale Solar, Battery Storage, pumped (Long-Duration) Storage, Shed Demand Response.

As demonstrated in the following table, SDCP’s 30 MMT portfolio is generally consistent with SDCP’s proportional share of new procurement for each of the “resource types” identified in D.22-02-004:
20 Estimated capacity of SDCP’s ~56% share of long-term VAMO allocation of existing solar resources from SDG&E.
21 Estimated capacity of SDCP’s ~56% share of long-term VAMO allocation of existing wind resources from SDG&E.
22 D.22-02-004 at 101-105. Note the Decision references Tables 6 and 7, but this was presumably a typographical error since there was no foregoing Table 7. Thus, SDCP understands the Decision to be referencing Tables 5 and 6.

17 SDCP’s proportional share of the PSP New Resources and the resources reflected in SDCP’s 30 MMT Portfolio are relatively aligned.

There are slight differences for in-state wind. Due to limited locations in state for siting new wind resources, SDCP does not believe it practical to plan around new in-state wind resources in its portfolio design and instead focuses on out-of-state or offshore wind for more viable long-term reliability planning and to help reduce siting delays in bringing projects online. That said, SDCP will continue to advocate for and pursue offtake from new, in-state, and re-powered in-state wind projects and has open Request for Proposals (“RFPs”) for viable projects.

SDCP’s 30 MMT Portfolio focuses on combined solar/storage projects since its locale and services territory have ample sites for local projects. In the Battery Storage category, SDCP also includes the energy storage capacity associated with hybrid solar plus storage facilities. This hybrid system will allow for higher renewable utilization rates and reduce production risk.

SDCP’s 25 MMT Conforming Portfolio
SDCP provides a summary of SDCP’s 25 MMT Conforming Portfolio (by 2035), identifying resources by type and distinguishing between the following procurement categories:
• Existing resources (energy and capacity) that SDCP owns or contracts with, consistent with definitions provided in the Resource Data Template. • Existing resources (energy and capacity) that SDCP plans to contract with in the future. • Existing resources (capacity) that SDCP partially pays for through CAM. • New Resources (energy and capacity) that are under development that SDCP is planning to procure.
• Future new resources (energy and capacity) that SDCP is planning to procure.

In summary, to meet SDCP’s projected 2035 energy demand of 8,476.83 GWh, SDCP has selected a 2035 25 MMT Conforming Portfolio composed primarily of the following resources:
• Existing solar (owned or under contract) – 549 MW23
• Existing wind (owned or under contract) – 146 MW24
• Existing wind (planned procurement) – 250 MW
• Existing hydro (planned procurement) – 35 MW
• New solar (future resources) – 1,425 MW
• New wind (future resources) – 550 MW
• New geothermal (future resource) – 100 MW
• New short duration storage (future resources) – 750 MW 23 Estimated capacity of SDCP’s ~56% share of long-term VAMO allocation of existing solar resources from SDG&E.
24 Estimated capacity of SDCP’s ~56% share of long-term VAMO allocation of existing wind resources from SDG&E.
18 • New long duration storage (future resources) – 60 MW Additionally, SDCP’s 2035 25 MMT Conforming Portfolio includes capacity-only resources composed primarily of the following resources:
• CAM, Demand Response and Energy Efficiency Allocations – 626 MW • Existing natural gas, baseload, and other (planned procurement) – 95 MW SDCP’s portfolio includes a mix of existing and new resources. Approximately 2,885 MW of SDCP’s 2035 portfolio is composed of new resources, reflecting SDCP’s role as an active player in the State’s development of new renewable and storage resources. Furthermore, SDCP’s 2035 portfolio is comprised of a mix of resources in which SDCP can minimize customer rate impacts while still achieving the State’s GHG-reduction targets.

SDCP’s 25 MMT Conforming Portfolio Is Consistent with the Preferred System Plan The new resources included in SDCP’s 25 MMT Conforming Portfolio are consistent with the PSP new resource mix. The Commission adopted the PSP portfolio, which established the 38 MMT GHG target by 2030 and 30 MMT GHG target by 2035 and adopted the resources in Tables 5 and 6.25 Subsequently, the Commission required load serving entities to also prepare a Conforming Portfolio meeting 30 MMT GHG by 2030 and 25 MMT GHG by 2035.26 SDCP’s 25 MMT Conforming Portfolio meets this latter requirement.

The Decision identifies planned us of resources in the following categories: Biomass, Geothermal, Wind, Wind on New-Out-of-State Transmission, Offshore Wind, Utility-Scale Solar, Battery Storage, pumped (Long-Duration) Storage, Shed Demand Response.

As demonstrated in the following table, SDCP’s 25 MMT portfolio is generally consistent with SDCP’s proportional share of new procurement for each of the “resource types” identified in D.22-02-004 and the Final Ruling:
25 D.22-02-004 at 101-105. Note the Decision references Tables 6 and 7, but this was presumably a typographical error since there was no foregoing Table 7. Thus, SDCP understands the Decision to be referencing Tables 5 and 6.
26 Final Ruling at 9-10.

20 As with the 30 MMT portfolio, SDCP’s 25 MMT Portfolio focuses on hybrid solar/storage projects since its locale and services territories have ample sites for local projects. In the Battery Storage category, SDCP also includes hybrid solar plus storage systems. This hybrid system will allow for higher renewable utilization rates and reduce production risk. b. Preferred Conforming Portfolios
i. 25 MMT Preferred Conforming Portfolio
As discussed above, SDCP has used the same Conforming Portfolio to achieve both its 30 MMT and 25 MMT Conforming Portfolios. SDCP intends to meet or exceed its 25 MMT GHG Benchmark and has selected the 25 MMT Conforming Portfolio as its Preferred Conforming Portfolio (“25 MMT PCP”). The following provides a description of this portfolio.

SDCP’s 25 MMT PCP consists of a combination of:
• Gas
• Biomass
• Geothermal
• Wind
• Wind on New-Out-of-State Transmission
• Offshore Wind
• Utility-Scale Solar
• Battery Storage
• Pumped (Long-Duration) Storage
As stated above, in accordance with Section 454.51(b)(3), SDCP’s governing board has determined that the resource mix in the 25 MMT PCP achieves “economic, reliability, environmental, security, and other benefits and performance characteristics that are consistent with the goals set forth in [Section] 454.51(a)(1)].” These benefits and characteristics are discussed as follows.

GHG Reduction Goals
SDCP’s 25 MMT PCP achieves results and performance characteristics consistent with the Section 454.52(a)(1)(A) goal of meeting the Commission’s 25 MMT GHG reduction benchmark (30 MMT GHG by 2030).27 The 2035 emissions from SDCP’s 25 MMT PCP are equivalent to SDCP’s load-proportional share of the 25 MMT by 2035 emissions target. SDCP’s proportional share of the 25 MMT GHG target in 2030 is 1.052 MMT and in 2035 is 0.863. According to the Commission’s emissions calculator, SDCP’s 25 MMT PCP would account for 0.837 MMT in 2030 emissions and 0.634 MMT in 2035 emissions, which is substantially less than the GHG Benchmark requirements.
27 See D.22-02-004 at 105; Final Ruling.
21 Renewable Energy
SDCP’s 25 MMT PCP achieves results and performance characteristics consistent with the Section 454.52(a)(1)(B) goal of ensuring that portfolios are composed of at least 60% eligible renewable resources. In 2035, SDCP’s 25 MMT PCP portfolio would consist of 95% eligible renewable generation (net of modeled curtailments), which exceeds the 60% requirement and is consistent with SDCP’s mission to provide its communities with clean energy and reduce GHG emissions.

Enable Each Electrical Corporation to Fulfill Its Obligation to Serve Customers at Just and Reasonable Rates
As a public not-for-profit agency, SDCP must set rates to recover costs associated with debt service, the purchase of power, and operational costs at a minimum. It is in the interest of SDCP and its customers for SDCP to design rates that meet SDCP’s legally mandated revenue requirements as well as its targeted reserves, while maintaining rate competitiveness and stability. As detailed in Section III.e., below, SDCP is committed to serving its customers at reasonable rates. In addition to setting rates that are competitive with SDG&E, SDCP works to minimize rate volatility by constructing a balanced and conservatively hedged power supply portfolio and minimizing rate changes to once per year when possible.

Minimizing Bill Impact
SDCP’s 25 MMT PCP achieves results and performance characteristics consistent with the Section 454.52(a)(1)(D) goal of minimizing the impact of planned procurement on ratepayers’ bills. SDCP’s 25 MMT PCP portfolio consists primarily of renewable resources that have benefitted from increasing economies of scale over the past several years. While the Covid-19 pandemic caused supply chain disruptions to many renewable projects, SDCP expects that price projects post-pandemic for such projects will continue to drop for the foreseeable future.

SDCP’s recent procurement and development experience indicates that lithium-ion battery storage is cost effective and commercially viable relative to other capacity products available in the market. While global pandemic and supply chain disruption have caused significant project development delays and price volatility in commodity and supply markets, SDCP is optimistic that these impacts will subside in the next couple of years as supply chains regain form and with the help of the incentives and tax credits available under the Inflation Reduction Act.28 SDCP prioritizes cost competitiveness, reliability, use of renewable energy, and local resource development. SDCP anticipates that bill impacts will be minimized during its planned portfolio transition as new hybrid solar generation and storage projects secured via long-term contract generally have lower net costs than prices paid in the short-term renewable energy markets.

Coupling new solar with battery storage increases the capacity value of the projects, displacing the need to buy expensive resource adequacy products, and provides limited dispatchability for the solar generation, minimizing the risk of energy value degradation over time. Further, SDCP’s 25 MMT PCP minimizes exposure to volatile natural gas prices as well as bill impacts that may result from periodic spikes in fossil fuel prices. 28 Inflation Reduction Act of 2022, H.R.5376, 117th Cong. 22 Ensuring System and Local Reliability
SDCP’s 25 MMT PCP achieves results and performance characteristics consistent with the Section 454.52(a)(1)(E) goal of ensuring system and local reliability. The 25 MMT PCP meets system resource adequacy requirements as detailed in Section III.f. Additionally, SDCP’s 25 MMT PCP will ensure local reliability by prioritizing procurement of local RA resources.

Ensure that at least 65% of RPS Procurement is From Long-Term Contracts Consistent with Section 454.52(a)(1)(F), SDCP is on pace to meet the requirement that 65% of its RPS procurement must come from contracts of 10 years (long-term or more for each compliance period). For the current compliance period, SDCP has procured 93% from long-term contracts.

Strengthen the Diversity, Sustainability, and Resilience of the Bulk Transmission and Distribution Systems, and Local Communities
SDCP’s 25 MMT PCP achieves results and performance characteristics that strengthen the diversity, sustainability and resilience of the bulk transmission and distribution systems, as well as local communities, meeting Section 454.52(a)(1)(G). SDCP’s 25 MMT PCP relies on procurement from a variety of resource types as well as significant storage resources. SDCP carefully evaluates the long-term generation load-matching and congestion risks of new resources and weighs its options in the context of its existing supply and net demand on an hourly basis for the full duration of any contract period.

As described below, SDCP is actively pursuing the procurement of capacity to meet the sub-category requirements of D.21-06-035, which includes long-duration storage, clean-firm resources like geothermal, and resources to replace the Diablo Canyon Power Plant.

Additionally, SDCP has recently procured demand response capacity resources, providing additional system diversity. Finally, SDCP’s 25 MMT PCT plans for a significant portion of offshore wind to add more diversity to transmission and distribution systems.

Demand-Side Energy Management
SDCP’s 25 MMT PCP achieves results and performance characteristics consistent with the Section 454.52(a)(1)(H) goal of enhancing demand-side energy management. SDCP continues to explore and pursue demand-side management programs such as demand response, energy efficiency, and behind the meter energy storage solutions.

Minimizing Localized Air Pollutants with Emphasis on Disadvantaged Communities (“DACs”)
SDCP’s 25 MMT PCP achieves results and performance characteristics consistent with the Section 454.52(a)(1)(l) goal of minimizing localized air pollutants and other GHG emissions with early priority on disadvantaged communities. SDCP’s 25 MMT PCP relies primarily on renewable generation and hydroelectric generation, and this portfolio is expected to exhibit low GHGs and localized air pollution emissions. SDCP’s 25 MMT PCP minimizes SDCP’s reliance on unspecified system power, instead opting for renewable and hydroelectric generation procurement/development whenever feasible.
23 Results from the CSP tool indicate the following localized air pollutants associated with SDCP’s 25 MMT PCP using the 25 MMT CSP for year 2035:
• NOx: 27 tonnes/year
• PM 2.5: 8 tonnes/year
• SO2: 1 tonnes/year
These emissions are expected to result from the planned use of system energy and biomass energy in the 25 MMT PCP, as well as emissions from Combined Heat and Power (“CHP”) resources and system energy assigned to the SDCP portfolio by the CSP tool. In evaluating new biomass resources, SDCP will prioritize development of any resources with emissions outside of DACs to the greatest practical extent.

Operation of SDCP’s 25 MMT PCP
The majority of SDCP’s 25 MMT PCP consists of solar and hybrid solar/storage facilities. This helps the portfolio have emissions well below its assigned load-proportional share of the 25 MMT benchmark. Due to a large portion of the portfolio being hybrid projects with storage, these emission reductions do not come at the expense of reliability. Additionally, the added storage component allows for increased demand response and capacity which should help further help grid reliability.
c. GHG Emissions Results
SDCP used its load-based proportional share of the 30 and 25 MMT GHG Benchmarks to determine the emissions compliance for its 25 MMT PCP under both 30 MMT and 25 MMT emissions scenarios. SDCP’s assigned load proportional share of the 30 MMT benchmark is

1.383 MMT in 2030 and 1.072 MMT in 2035. Based on the 30 MMT version of the CSP calculator, SDCP’s 25 MMT PCP would result in total 2030 GHG emissions of 0.613 MMT and 2035 GHG emissions of 0.446 MMT, well below SDCP’s assigned share of the 30 MMT GHG reduction benchmark.

SDCP’s assigned load-proportional share of the 25 MMT benchmark is 1.052 MMT in 2030 and

0.863 MMT in 2035. Based on the 25 MMT version of the CSP calculator, SDCP’s 25 MMT PCP would result in total 2030 GHG emissions of 0.837 MMT and 2035 GHG emissions of

0.631 MMT, which is well below its assigned load-proportional share of the 25 MMT benchmark.

26 Figure 2: Map of DACs within SDCP’s Service Area
Within these DACs, SDCP estimates a population of approximately 202,422 (CES 4.0 census data). In May 2022, CalEPA updated the definition of DACs to include DACs in CES 3.0 that became ineligible under CES 4.0, as well as federally recognized tribal areas. SDCP is still analyzing this data and the additional customers to be served. Moreover, before serving federally recognized tribal areas, SDCP will need to engage with tribes on whether they want their generation to be served by SDCP or SDG&E.

Moving forward, SDCP is looking to add more census tracts beyond those identified by CES 4.0.

CES is a useful tool for a statewide assessment, however a statewide assessment leaves out disadvantaged communities at a local or regional level. The City of San Diego, one of SDCP’s members, has developed a citywide assessment of disadvantaged communities, or Communities of Concern. The City of Chula Vista, another member city, has also developed a similar assessment. SDCP identifies Communities of Concern as those highlighted by the cities of San Diego and Chula Vista, and defaults to the DAC definition in other jurisdictions where a citywide assessment has not been conducted.

In developing its IRP, SDCP carefully considered the impact of its resource procurement on DACs and Communities of Concern. SDCP conducts regular outreach with community-based organizations and through monthly public meetings with its Community Advisory Committee to solicit input on procurement policies and strategies that inform the IRP process. As detailed in SDCP’s Action Plan in Section IV.b, SDCP has launched a CPP to develop a framework for community investment decisions informed by a community needs assessment and targeted community engagement.

Power Procurement in DACs
SDCP does not currently procure electricity directly from any natural gas or other fossil fuel power plants. Further, SDCP does not own any thermal generation facility adjacent to any identified DACs. However, SDCP recognizes the need to help mitigate the impacts of air 27 pollution in regions of the state where communities have been disproportionately impacted by the existing generating fleet and the need for economic development in areas with high unemployment and poverty. SDCP has to-date signed two long-term procurement contracts for hybrid solar/storage projects that are in or near DAC areas.

SDCP additionally evaluated its indirect impacts on disadvantaged communities throughout the state. SDCP’s portfolio includes 39% system power in 2024, and this declines to only 11% in 2035. While SDCP strives to reduce its dependence on resources that emit GHGs and other local pollutants, SDCP must also balance that goal against reliability and affordability, which is what SDCP has strived to do in its Preferred Conforming Portfolio. Further, as noted in the previous section, SDCP’s reliance on system power will decrease substantially over the planning period due to SDCP’s aggressive GHG reduction goals.

SDCP also implements a feed-in tariff (“FIT”) program to help facilitate the development of local qualifying, small-scale, distributed renewable generating and energy systems. With a program capacity of 6 MW, SDCP encourages developers to submit proposals that are new resources at less than 1 MW in size. To promote economic development in DACs, SDCP provides bonus pricing per MWh to projects that are sited within a Community of Concern. The program offers a bonus pricing incentive for the first five (5) years of the contract on top of the base price for projects sited within a Disadvantaged Community, as defined by the California Office of Environmental Health Hazard Assessment, or within a very low to low access census tract found in the City of San Diego’s Climate Equity Index, or as the top 25% scoring areas within the City of Chula Vista’s Climate Equity Index at the time of FIT application submittal.

The geographical eligibility of Communities of Concern may expand as SDCP member cities enact their own Climate Equity Index or other related index to identify designated census tracts.

LSE Activities and Programs Impacting DACs
As a relatively new CCA, much of SDCP’s activities and programs benefitting DACs are currently in the planning phase, as detailed in Section IV.b. However, many qualifying SDCP customers located in DACs have access to several affordable rate options and programs. While not specific to DACs, SDCP’s customers still qualify and participate in the same electricity discount programs that they may already have participated in with SDG&E such as California Alternate Rates for Energy (“CARE”) and Family Electric Rate Assistance (“FERA”), and the Low-Income Home Energy Assistance Program (“LIHEAP”). CARE customers save approximately 30-35% on their total bill.

SDCP customers with a qualifying medical condition or a need for certain medical devices may qualify for the medical baseline allowance program, which gives residential customers with qualified medical devices or conditions a higher usage baseline at the lowest rate available on their rate schedule.

SDCP customers on CARE or FERA with outstanding bills that are past due can also qualify for debt forgiveness through the Arrearage Management Plan (“AMP”). AMP is a 12-month payment plan that forgives 1/12 of your debt after each on-time payment of the current month’s 28 bill and protects you from disconnections. After twelve on-time payments, a customer’s debt will be fully forgiven up to a maximum of $8,000.

On September 29, 2021, SDCP filed its Tier 2 Advice Letter (“AL”) with the Commission requesting a capacity transfer from SDG&E under the Disadvantaged Communities - Green Tariff (“DAC-GT”) and Community Solar Green Tariff (“CSGT”) based on the disadvantaged communities located within founding member agencies of SDCP. The Commission accepted and approved SDCP’s capacity transfer request on October 29, 2021. SDCP submitted its implementation advice letter on October 12, 2022, seeking approval of the proposed programs and obtaining the status of a program administrator. As part of the implementation advice letter, SDCP is also seeking additional capacity transfer from disadvantaged communities located in National City, a new member city that was added to SDCP’s joint powers authority (“JPA”) after SDCP submitted AL 4-E.

The DAC-GT program allows customers who reside within a disadvantaged community and are eligible for the CARE/FERA programs to receive 100% solar energy at a 20% discount on the electricity and delivery portion of their otherwise applicable tariff. The CSGT program is similar but differs where at least one community sponsor is needed to represent the local generating resource, as it must be located in a disadvantaged community and within 5 miles of the disadvantaged community where subscribing customers reside. Moreover, the CSGT program requires the sponsor to promote workforce development for the new build project. Both programs incentivize the development of new, local generation and will require extensive community engagement to educate and subscribe customers. e. Cost and Rate Analysis
SDCP’s 25 MMT PCP is reasonable from a cost perspective. In selecting resources for its portfolios, SDCP carefully considered the cost implications of specific resource selections and procurement timing. This analysis was informed by SDCP’s procurement experience and the standard assumptions and results of the Commission’s RESOLVE/SERVM modeling.

In general, SDCP sought to balance the need to procure resources with enough lead time to meet SDCP’s LSE-specific procurement targets and the Commission-identified overall system new resource requirements with the potential cost-saving benefits of waiting to procure renewable and storage resources with downward sloping cost projections. SDCP also recognizes that future resource costs are highly uncertain, and technological advancement can happen unexpectedly; SDCP’s procurement cycle is designed to take advantage of technological and cost improvements by incrementally adding new resource commitments over time.

SDCP’s PCPs takes advantage of the fact that, compared to the IOUs, CCAs significantly shorter generation project development timelines, in part due to the fact that CCAs do not require Commission approval of such projects. These shorter timelines result in significant direct savings and give SDCP more flexibility to time its procurement activities in a way that takes advantage of falling renewable generation prices or other cost-effective procurement opportunities that may arise over time.
29 f. System Reliability Analysis
SDCP’s 25 MMT PCP is expected to be reliable and will contribute SDCP’s fair share to system reliability needs under both the 30 MMT and 25 MMT analyses.

SDCP 30 MMT Analysis
The effective capacity of SDCP’s 25 MMT PCP under the 30 MMT emission analysis is provided in the following “System Reliability Progress Tracking Table” from the 30 MMT Resource Data Template dashboard. The net qualifying capacity for the month of September is shown for each year in the following table:

31 As demonstrated in Table 8, SDCP’s 25 MMT PCP under the 30 MMT emissions scenario contributes 2,003 MW of peak monthly NQC in 2035. Of this total, 1,264 MW are related to new renewable and hybrid resources as well as new short- and long-duration storage resources.

SDCP’s 25 MMT PCP includes planned contracts with existing resources, which are expected to include resources within the existing natural gas generator fleet, for a total of 507 MW of NQC.

This balanced portfolio of flexible capacity works to effectively and reliably integrate a renewables-heavy portfolio, thus exceeding SDCP’s share of any system-wide renewable integration resource requirements.

SDCP 25 MMT PCP
The effective capacity of SDCP’s 25 MMT PCP is provided in the following “System Reliability Progress Tracking Table” from the 25 MMT Resource Data Template dashboard. The net qualifying capacity for the month of September is shown for each year in the following table:

35 j. Long-Duration Storage Planning
The Commission’s PSP included 1,000 MW of new long-duration storage to be operational by 2028, and SDCP includes 60 MW in its 25 MMT PCP. SDCP chose to include more long-duration storage to be at or above the PSP share since SDCP’s PCP relies primarily on solar-hybrid projects in its PCP. This value also exceeds SDCP’s long-duration storage requirement under D.21-06-035 since SDCP expects to contract with a diverse portfolio of long-duration technologies and developers to ensure successful development of this nascent resource type and to support substantial commitments to solar and shorter duration battery resources.

SDCP believes that long-duration storage will be a key piece of its carbon reduction strategy.

This resource will allow for a fuller utilization of renewable resources and help to mitigate the pricing volatility caused by the CAISO’s evening net ramp rate. SDCP plans to investigate long-term storage resources for installation in 2026. SDCP acknowledges this may be an aggressive timeline because this resource space is not fully mature, but SDCP believes that such technologies are important to their long-term goals.
k. Clean Firm Power Planning
SDCP includes 100 MW of clean firm power in its 25 MMT PCP. Despite a thin supply of projects and limited recent development investment in eligible resource types, both the result of little activity in this resource area of project development prior to D.21-06-035, SDCP has taken efforts to meet its D.21-06-035 clean-firm requirement. SDCP released a Clean Firm RFO entitled “Clean Firm Energy Resource” in July 2022 and has since been in negotiation with two parties who responded to that solicitation. SDCP has been active otherwise in the market to pursue additional bilateral opportunities and to promote development of a diverse portfolio of clean firm resources within its service territory and neighboring counties.

SDCP’s experience procuring for D.21-06-035 has provided insights regarding the specific sub-category requirements required by that Decision. Specifically, D.21-06-035 required certain long lead time (“LLT”) resources and resources to replace Diablo Canyon Power Plant. These resources only count if they meet relatively narrow attributes directed by that Decision. SDCP’s experience has been that for some of these categories there are very few resource developers with the experience and ability to bring projects online, and even fewer with the ability to bring such projects online in the timeline directed by the Commission. l. Out-of-State Wind Planning
The Commission’s PSP calls for 4,636 MW of new out-of-state wind generation (“OOS Wind”) to be developed and operational by 2035. SDCP’s 25 MMT PCP includes 211 MW of OOS Wind, which is based on the expectation that new transmission will be constructed to access relatively low-cost wind resources in New Mexico. The share of new OOS Wind in SDCP’s planned portfolio may increase and may also include Wyoming wind resources, depending upon the pace of transmission development. SDCP understands that the transmission projects needed to connect OOS Wind to the CAISO grid require significant lead-times; however, SDCP is currently contracting with OOS Wind developers that deliver necessary wind energy directly to 36 California. Additional transmission planning is required to deliver this OOS wind from Wyoming and New Mexico; those efforts are underway and, should they be approved, SDCP expects to pursue offtake from these regions in the interest of diversifying its energy supply portfolio with resources that complement what will otherwise be a very solar-heavy mix.

Therefore, SDCP has reflected OOS Wind in both of its portfolios. m. Offshore Wind Planning
The Commission’s PSP calls for 4,707 MW of new offshore wind generation to be developed and operational by 2035. Since California has little experience with offshore wind development, SDCP conservatively planned procurement over the planning horizon for this category, with a focus on areas with existing transmission capacity in the Central Coast or current plans to develop capacity and infrastructure for offshore wind (e.g., in and around Humboldt County).

Additionally, though expected to provide benefits in comparison to existing wind resources, it is unclear what exact resource and reliability benefits offshore wind may provide and at what cost.

Therefore, SDCP has planned conservative offshore wind procurement in both of its portfolios.

SDCP chose to procure 300 MW of offshore wind in 2032 located in Morro Bay. The choice to procure offshore wind in Morro Bay revolved around the presence of existing transmission infrastructure and the proximity to SDCP’s service territory. SDCP believes this resource will be a huge benefit to its portfolio because of its high ELCC value and hourly generation profile shape.
n. Transmission Planning
In identifying resource locations for all portfolios, SDCP was guided by the following considerations:
• SDCP has a general preference for resources located within its service area and the community it serves, but more generally, within Southern California. • SDCP prefers projects located in areas that can utilize existing transmission infrastructure with minimal upgrade/modification costs.
• SDCP prefers low-impact renewable energy projects that provide economic benefit to DACs, subject to community interest in siting projects within such locations.

Unlike the IOUs, SDCP is not a transmission and distribution (“T&D”) system operator. SDCP does not enjoy the benefits of a granular knowledge of SDG&E T&D system, and SDCP is not best positioned to identify optimal resource locations. In practice, SDCP relies on consultants and project developers to conduct the research and technical studies necessary for siting potential generation projects. SDCP evaluates projects offered by developers based on a variety of criteria, including transmission availability, nodal prices and potential for congestion, project viability, environmental, workforce, and other factors. As such, SDCP generally utilized the PSP selected candidate resources as a guide for likely resource locations in its 25 MMT PCP. These should be treated as general expectations based on the aforementioned considerations, not definitive selections – actual project locations will be selected during SDCP’s future solicitation processes.
37 As discussed in prior sections, SDCP is very nimble in administering resource planning processes. More specifically, if SDCP’s expected resource locations become infeasible due to various constraints, or if the Commission’s modeling efforts happen to indicate that certain resource locations are no longer feasible/desirable, then SDCP would ultimately locate and contract for alternative resources that fall in preferred locations.

At this point in its development process, SDCP relies upon project developers, through its competitive RFP process, to plan the interconnection locations for specific projects. Projects that align with, or require minimal incremental augmentation to, existing or planned transmission upgrades are preferred.

As SDCP scopes and designs a portfolio of local renewable energy resources, staff will work with member agencies and local landowners to identify potential project sites that not only are consistent with local zoning regulations and climate action plans but also reduce the cost of necessary interconnection upgrades.

IV. Action Plan
a. Proposed Procurement Activities and Potential Barriers SDCP has a well-established procurement process that it will use to steadily achieve its 25 MMT PCP between now and 2035. SDCP’s procurement process includes the following key activities:
• Identification of planned resources by type, desired online date, and capacity. • Planning for procurement activities in consideration of SDCP’s risk management policy; resource acquisition lead times including, where applicable, development timelines; staff capacity; and financial considerations.
• Design and administration of resource solicitations. For new resources, these typically take the form of periodic RFP processes, while for existing resources, procurement activity is more frequent and routinized.
• Careful negotiation of contract terms to ensure positive outcomes for SDCP customers with appropriate risk mitigation.
• Ongoing contract management, including monitoring of development milestones and generator performance, as applicable.
• Conduct and participate in joint CCA solicitation processes in order to expand procurement opportunities available to SDCP.

With respect to procurement of the specific resources within its PCP, SDCP intends to:
• Periodically solicit offers for new renewable generation and storage projects. These resources are typically secured through long-term power purchase agreements. SDCP expects to secure power purchase agreements for new projects in multiple solicitations conducted over the next several years.
38 o For example, SDCP currently has an open solicitation entitled Long-Term California RPS-Eligible Renewable Energy RFP31 for resources coming online between January 1, 2023 and December 31, 2026.
• Conduct one or more competitive solicitation(s) specifically for long duration storage. • Continue procurement of resources to meet any remaining assigned requirements from D.21-06-035, as well as the specific sub-categories from that decision. • Solicit offers periodically throughout the year for short-term renewable energy, resource adequacy, system energy, and other products needed to balance the portfolio and adhere to position limits established through SDCP’s risk management policy and practices.

These solicitations may take the form of formal request for offers, bilateral discussions, and/or transactions arranged through broker markets.
i. Resources to meet D.19-11-016 procurement requirements SDCP does not have any D.19-11-016 obligations as it was not in existence at the time of the Decision. However, consistent with CPUC Decision 22-05-015, which implemented the “Modified Cost Allocation Mechanism” or “MCAM,” SDCP has contracted to purchase from SDG&E the share of Resource Adequacy attributes associated with its 2022 load share. ii. Resources to meet D.21-06-035 procurement requirements, including:
a. 1,000 MW of firm zero-emitting resource requirements Consistent with Ordering Paragraph 4 of D.21-06-035 and formalized via CPUC approval of SDG&E Advice Letter 3967-E, SDCP and SDG&E mutually agreed to reallocate resource requirements within D.21-06-035 to reflect load forecasts that were revised subsequent to those that were incorporated into the analysis supporting D.21-06-035. SDCP’s resulting portion of firm zero-emitting resources to be procured is 39.7 MW.

SDCP is actively engaged with two suppliers that participated in its July 2022 Clean Firm RFO, which targeted eligible resources expected to achieve COD no later than 2028 and likely to be geothermal or bioenergy fueled. In order to ensure compliance with D.21-06-035 and to promote development of a diverse portfolio of clean firm resources within its service territory and neighboring counties, SDCP continues pursuit of additional bilateral opportunities to contract with eligible resources.

A potential barrier, also noted in Section III.k., is that there has been little development of new geothermal and commercially scalable bioenergy generation resources in recent years. SDCP is optimistic that D.21-06-035 will increase the number of potential projects and market participants involved in the development of eligible resources such that SDCP and all other LSEs can meet the very specific requirements of D.21-06-035. 31 https://sdcommunitypower.org/wp-content/uploads/2022/10/Final-2022-San-Diego-Community-Power_Long-Term-Renewable-RFP_10-3-2022-.pdf 39 b. 1,000 MW of long-duration storage resource requirements Consistent with Ordering Paragraph 4 of D.21-06-035 and formalized via CPUC approval of SDG&E Advice Letter 3967-E, SDCP and SDG&E mutually agreed to reallocate resource requirements within D.21-06-035 to reflect load forecasts that were revised subsequent to those that were incorporated into the analysis supporting D.21-06-035. SDCP’s resulting portion of long-duration storage resources under D.21-06-035 is 39.7 MW.

SDCP has extensive market insight and experience contracting with energy storage resources from its 2020 Renewable Energy RFP and its 2021 Request for Information for Local Renewable Energy and Energy Storage Request for Information (“Local RFI”)32. SDCP expects to launch a solicitation targeting short- and long-duration standalone energy storage projects upon conclusion of its currently open 2022 Renewable Energy RFP.

Current barriers to procurement of long-duration storage resources are the lack of diversity of commercially viable and scalable technologies beyond lithium-based battery storage facilities and the pandemic and supply chain disruptions currently impacting said lithium-based storage development capacity and timelines.
c. 2,500 MW of zero-emissions generation, generation paired with storage, or demand response resource requirements
Consistent with Ordering Paragraph 4 of D.21-06-035 and formalized via CPUC approval of SDG&E Advice Letter 3967-E, SDCP and SDG&E mutually agreed to reallocate resource requirements within D.21-06-035 to reflect load forecasts that were revised subsequent to those that were incorporated into the analysis supporting D.21-06-035. SDCP’s resulting portion of zero-emissions generation, generation paired with storage, or demand response resources is 98.9 MW.

SDCP expects to meet its zero-emitting resource requirements predominantly via contracts with hybrid solar-and-storage resources. SDCP expects to exceed its share with resources under contract and, in order to ensure compliance in the event of project delays and to further support development of additional zero-emissions generation, SDCP continues pursuit of additional opportunities to contract with eligible resources, both via formal solicitation (e.g., 2022 Renewable Energy RFP and 2021 Local RFI) and via bilateral market outreach and discussions.

Current barriers to procurement are the pandemic and supply chain disruptions currently impacting the development capacity and timelines related both to solar and lithium storage technologies.
32 https://sdcommunitypower.org/wp-content/uploads/2021/08/SDCP-2021-Local-RFI-Announcement.pdf

41 mandates via an upcoming short- and long-duration energy storage solicitation, additional all-source or targeted Renewable Energy RFOs as appropriate, and ongoing bilateral market outreach and negotiations.
iii. Offshore wind
SDCP believes offshore wind will be a vital part of its portfolio in the future. This clean energy, high-ELCC factor resource has a forecasted shape that is highly desirable in that it will complement SDCP’s hourly portfolio shape.

SDCP does have concerns about the ability for offshore wind to interconnect into the CAISO’s existing transmission system. In CPUC’s Modeling Assumptions for the 2022-2023 Transmission Planning Process staff report, it was noted that some of the Morro Bay substation constraints had to be relaxed or changed to the proposed Morro Bay 500kV substation which ties to the Diablo-Gates 500kV line to accommodate enough offshore wind deliverability. With Diablo Canyon being extended to at least 2030, there is concern whether enough interconnection capability is available for offshore wind at scale.

SDCP has an open solicitation at this time (Long-Term California RPS-Eligible Renewable Energy RFP) for resources coming online between January 1, 2023 and December 31, 2026. This solicitation includes offshore wind and, should any resources be projected to achieve COD before 2027, SDCP looks forward to evaluating and pursuing such opportunities in its review and negotiation phases.

With respect to its PCP, SDCP prioritized the selection of future resources to ensure that its overall portfolio of new resources is consistent with the PSP resource attribute/category mix, procurement timing, and SDCP’s proportional share of planned new procurement. For the 25 MMT PCP, SDCP identified future contracts it expects to secure for new offshore wind. SDCP anticipates that additional procurement efforts beyond its current 2022 Renewable Energy RFP may be necessary. If so, SDCP will redouble efforts to secure energy supply from offshore wind resources via its own renewable solicitations, whether all-source or specifically targeted, and potentially by partnering with other CCAs or procurement entities as appropriate to support development of largescale offshore wind capacity.
iv. Out-of-state wind
SDCP values a diverse portfolio of renewable resources and currently utilizes out-of-state wind in its clean energy portfolio. As SDCP wishes to increase its total quantity of out-of-state resources under contract, several key obstacles appear to be present. First, is having the necessary import capability. Second is the risk that as the demand for renewable energy grows from California, so will the size of projects and the possible pushback from residents and political action groups. Third, SDCP understands that the transmission projects needed to connect OOS Wind to the CAISO grid require significant lead-times. Additional transmission planning is required to deliver this OOS wind from Wyoming and New Mexico. 42 SDCP prioritized the selection of future resources to ensure that SDCP’s overall portfolio of new resources is consistent with the PSP resource attribute/category mix, procurement timing, and SDCP’s proportional share of planned new procurement. For the 25 MMT PCP, SDCP identified future contracts it expects to secure for new out-of-state wind.

SDCP has an open solicitation at this time (Long-Term California RPS-Eligible Renewable Energy RFP) for resources coming online between January 1, 2023 and December 31, 2026. This solicitation includes out-of-state wind. If additional procurement efforts are required, then SDCP will periodically solicit competitive proposals for new out-of-state wind generation projects. v. Other renewable energy not described above
The vast majority of SDCP’s upcoming procurement efforts are described in Sections IV.a.i through IV.a.iv. In order to complement its robust portfolio of commercially viable, wholesale resources, most of which are outlined above, SDCP expects to support and pursue development of less mature resource technologies via pilot projects, targeted procurement programs, and design and development of an integrated network of distributed energy resources throughout SDCP’s service territory and neighboring communities. SDCP is currently in the early stages of scoping these programs, which it intends to shape and begin to implement in the next six to twelve months. While these efforts will be less time- and cost-effective on a MWh-for-MWh basis that larger wholesale projects, they are wholly consistent with SDCP’s mission to invest in local resources that provide immediate local benefits and reduce costs associated with construction of additional transmission lines while supporting innovative renewable and carbon-free resources. vi. Other energy storage not described above
SDCP believes harnessing existing renewable generation through storage will be key to meeting the State’s long-term carbon reduction goals and plan to continue to research and invest in energy storage technologies. As previously discussed, SDCP has a strong desire to use existing technologies to lessen the potential project cost and the likelihood of non-compliance. In June 2022, SDCP’s Board of Directors adopted a goal for 15% of SDCP capacity to be sourced from new, distributed infill storage/solar plus storage resources within Member Agencies by 2035.

SDCP plans to release a competitive solicitation in late 2022 specifically for new short- and long-duration energy storage projects, from which it should garner significant insight into the status of various energy storage technologies.

Current barriers to procurement of energy storage resources are the lack of diversity of commercially viable and scalable technologies beyond lithium-based battery storage facilities and the pandemic and supply chain disruptions currently impacting said lithium-based storage development capacity and timelines.
43 vii. Other demand response not described above
SDCP has already contracted with demand response (“DR”) providers for short-term DR contracts and continues to explore innovative capacity and energy products, both short- and long-term, with DR providers.

Barriers to procurement of DR resources include i) relatively high customer high acquisition costs given the quantity in which they must be aggregated to provide material benefit to SDCP and the reliability of the CAISO grid more broadly; ii) the regulatory uncertainty regarding Resource Adequacy, specifically the capacity value that DR resources will provide and any limitations with respect to how much DR capacity any one LSE can include in its resource portfolio; iii) current data latency issues where CCAs have to wait until close of the billing cycle, usually within 28-30 days after power flow, to receive the interval data from SDG&E. CCAs would prefer to receive the interval data at T+2 (i.e. 2 days after power flow) to better inform Estimated Settlement Quality Meter Data processes to allow CCAs to better forecast their load and effectively offer useful demand response programs.
viii. Other energy efficiency not described above
SDCP plans to explore in the near future how it can promote and invest in energy efficient technologies and behaviors. SDCP is currently analyzing various funding mechanisms and opportunities to administer energy efficiency programs for its communities, which will be informed by SDCP’s CPP, discussed in more detail in Section IV.b. In addition, SDCP coordinates closely with its member agencies to support the implementation of their respective climate action plans, which will guide future energy efficiency programs and initiatives, including potential updates to building energy codes.
ix. Other distributed generation not described above
SDCP’s JPA includes a prioritization of distributed energy resources and as such SDCP plans to explore opportunities to utilize distributed generation. In addition, in June 2022, SDCP’s Board of Directors adopted a goal for 15% of SDCP’s energy to be sourced from new, distributed infill storage/solar plus storage resources within SDCP’s member agencies by 2035. SDCP has an active RFI entitled “Local Renewable Energy and Energy Storage RFI”33 with a rolling submission deadline. In addition, as described in Section IV.b., below, SDCP is implementing DAC-GT and CSGT programs, which will specifically target DAC and low-income communities and support distributed generation in DACs. SDCP also implements a FIT program to help facilitate the development of local qualifying, small-scale, distributed renewable generating and energy systems less than 1 MW in size. The main barrier to such projects is opposition from small groups of local interested citizens that want to stall or fully prevent new development in many regions of San Diego County, which impacts SDCP’s mission to help developed new clean distributed energy resources. SDCP hopes that its mission and commitment to foster local 33 Available at https://sdcommunitypower.org/wp-content/uploads/2021/08/SDCP-2021-Local-RFI-Announcement.pdf. 44 economic benefits such as job creation, local energy programs and local power development while prioritizing equity will help projects overcome these barriers. x. Transportation electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR) SDCP plans to explore in the near future how SDCP can facilitate increased transportation electrification beyond what is included in the Integrated Energy Policy Report. SDCP coordinates closely with its member agencies to support the implementation of their respective climate action plans, which will guide future transportation electrification strategies and initiatives. Moreover, SDCP’s CPP will inform programmatic investments in the community, including potential transportation electrification programs. It is too early in the planning process to fully understand the barriers to such investments for transportation electrification. Once the CPP is completed SDCP will have a better understanding of its community’s needs. Such understanding will inform the opportunities, programs, and investments as they weigh against potential barriers to implementation.
xi. Building electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR)
SDCP plans to explore in the near future how they can facilitate increased investment in building electrification beyond what is included in the Integrated Energy Policy Report. SDCP coordinates closely with its member agencies to support the implementation of their respective climate action plans, which will guide future building electrification strategies and initiatives.

Moreover, SDCP’s CPP will inform programmatic investments in the community, including potential building electrification programs. It is too early in the planning process to fully understand the barriers to such investments for building electrification. Once the CPP is completed SDCP will have a better understanding of its community’s needs. Such understanding will inform the programs, opportunities, and investments as they weigh against potential barriers to implementation.
xii. Other
SDCP does not have any additional procurement to address. b. Disadvantaged Communities
SDCP is deeply committed to promoting equity through the services and programs it provides, and as such, Justice, Equity, Diversity & Inclusion is one of SDCP’s six core values. As noted in Section III.d.ii., while SDCP utilizes the statewide assessment tool, CES 4.0, to identify DACs within its service territory, SDCP also leverages the work of its member agencies in identifying additional Communities of Concern based on local and regional criteria. Communities of Concern have been defined as the top 25% scoring areas from CES, known as DACs, as well as the additional census tracts identified by the Cities of San Diego and Chula Vista through their Climate Equity Index (“CEI”) reports. Specifically, the City of San Diego identified these census 45 tracts as areas with very low, low, and moderate access to opportunity, whereas the City of Chula Vista defined them as the top 25% scoring areas within its own analysis. If other member agencies were to identify additional census tracts as the cities of San Diego and Chula Vista have done, SDCP would recognize those designations under the umbrella of Communities of Concern.

In alignment with this mission to prioritize investment and benefits within Communities of Concern, SDCP is developing a strategic plan for customer energy programs, called the CPP.

The CPP will provide a decision-making framework to guide SDCP’s program strategy, selection and development of local programs based on community needs and gaps in program offerings for which SDCP could invest in as it matures as an agency. As part of the development of the CPP, SDCP is conducting a community needs assessment, partnering with local community-based organizations (“CBOs”) to assist in community engagement. SDCP is utilizing multiple engagement methods, such as listening sessions, a survey instrument, interviews, attendance at community events, and workshops, to gather input from a large cross section of its customers.

SDCP issued an RFP in November 2021 looking for firms to conduct a community needs assessment and develop the CPP. Four proposals were received in December 2021. With the assistance of two representatives from SDCP’s Community Advisory Committee (“CAC”), one firm with strong experience in community engagement and development of a similar plan for another CCA was selected.

As of September 2022, SDCP has completed several activities within the initial phase of the CPP project, the community needs assessment, including:
• Six listening sessions with nearly 200 community members with compensation to community-based organizations and participants
• Six pop-up events in partnership with several libraries in unincorporated San Diego County, engaging over 100 community members
• Focused conversations with stakeholders from six interest groups working with/serving community members
• Five listening workshops with over 40 participants from local businesses, key accounts, and the general public
• One-hour workshop with 13 CAC members
• Launched a community-wide needs assessment survey available in English, Spanish, and Filipino (Tagalog) and promoted with a paid social media campaign with multi-lingual ads targeting unincorporated San Diego County, National City, and SDCP’s Communities of Concern
The CPP will include a market assessment of existing programs and program delivery mechanisms to understand the universe of programs available for implementation. The final CPP will illustrate the opportunities related to addressing the needs of customers with a focus on SDCP’s Communities of Concern and will recommend an initial five-year program suite. Before 46 the CPP is considered for adoption by SDCP’s Board of Directors, SDCP will solicit feedback and input from the community on the draft plan to ensure proper alignment.

Ultimately the CPP will allow SDCP to successfully deliver programs that, per it’s JPA, are centered around equity, and best serve the needs of its local communities while supporting regional sustainability efforts.

As noted in Section III.d.ii., SDCP is making strides to minimize both direct and indirect impacts to DACs. First, SDCP is substantially reducing its reliance on system power over the planning period and is committed to aggressive GHG reductions. Additionally, SDCP is implementing its DAC-GT and CSGT programs, which will specifically target DAC and low-income communities and provide both renewable energy and discounted electric rates. Finally, SDCP’s FIT program promotes economic development in DACs by offering bonus pricing per MWh to projects that are sited within a Community of Concern.
c. Commission Direction of Actions
SDCP encourages the Commission to adopt durable rules and processes to bring greater stability to the regulatory framework within which SDCP and other suppliers must plan and operate.

Frequent rule changes disrupt SDCP’s ability to execute long-term planning activities and adopted planning elements while minimizing customer costs. Such regulatory changes can also result in disproportionately high costs and administrative burdens, which would prompt related customer rate increases – certain regulatory changes may necessitate duplicative procurement efforts and/or stranded investments that are expected to impact a larger portion of SDCP’s portfolio.

For example, the Commission is currently considering a programmatic approach to the IRP and a Slice of Day reform of the RA Program. Each of these changes on their own represent significant regulatory uncertainty, which leads to market uncertainty. These changes together represent a complex, wholesale change to the regulatory landscape, which LSEs cannot reasonably account for in planning. The Commission should be cognizant that the scope of these reforms and how they may have broad, and somewhat unpredictable, impacts to the market.

These market changes will likely alter planned procurement over the long term and may reduce the accuracy of LSE’s IRP plans. With this in mind, SDCP encourages the Commission to develop a transition process for such changes that provides specific guidance, achievable timetables, and limited penalties to reduce market uncertainties and limit negative impacts on LSEs acting in good faith.

In addition, SDCP recommends the Commission consider the implications of load departure from IOUs within all of these processes and provide additional guidance. Relying on bilateral negotiations between IOUs and CCAs when CCAs expand service has resulted in situations in which the IOUs have too much discretion over the outcomes when there is anticipated load growth that is not included in existing methodologies.
47 V. Lessons Learned
SDCP recognizes the improvements made to the data templates relative to the 2020 planning cycle, including consolidation of the new and baseline templates and enhancements to better capture the full range of resources in LSE existing and planned portfolios. SDCP believes that additional improvements in the data templates can be made, and SDCP looks forward to further discussions with Energy Division staff in this regard. SDCP’s experience completing the Resource Data Template and the Clean System Power tools leads to the following observations and suggestions:

There is considerable time required/spent to complete necessary templates, and this remains a concern of SDCP and other LSEs. SDCP requests that Energy Division staff consider whether all requested data is necessary/critically important to the IRP process, and if not, SDCP respectfully requests that any/all non-critical data requirements be eliminated from future processes. SDCP also found that the directions and guidance provided by the Commission and staff for this IRP cycle seemed to lack clarity and consistency in certain key respects. Again, SDCP recognizes that the IRP process is evolving, but there is room for improvement in providing clear and consistent instructions in a timely manner.

Finally, SDCP’s experience procuring for D.21-06-035 has provided insights regarding the specific sub-category requirements required by that Decision. Specifically, D.21-06-035 required certain LLT resources and resources to replace Diablo Canyon Power Plant. These resources only count if they meet relatively narrow attributes directed by that Decision. SDCP’s experience has been that for some of these categories there are very few resource developers with the experience and ability to bring projects online, and even fewer with the ability to bring such projects online in the timeline directed by the Commission. SDCP encourages the Commission to avoid prescriptive resource procurement requirements in future procurement orders, in favor of other methods of incentivizing load serving entities to bring needed resources to the grid.
48 Glossary of Terms
Alternative Portfolio: LSEs are permitted to submit “Alternative Portfolios” developed from scenarios using different assumptions from those used in the Preferred System Plan with updates. Any deviations from the “Conforming Portfolio” must be explained and justified.

Approve (Plan): the CPUC’s obligation to approve an LSE’s integrated resource plan derives from Public Utilities Code Section 454.52(b)(2) and the procurement planning process described in Public Utilities Code Section 454.5, in addition to the CPUC obligation to ensure safe and reliable service at just and reasonable rates under Public Utilities Code Section 451.

Balancing Authority Area (CAISO): the collection of generation, transmission, and loads within the metered boundaries of the Balancing Authority. The Balancing Authority maintains load-resource balance within this area.

Baseline resources: Those resources assumed to be fixed as a capacity expansion model input, as opposed to Candidate resources, which are selected by the model and are incremental to the Baseline.

Baseline resources are existing (already online) or owned or contracted to come online within the planning horizon. Existing resources with announced retirements are excluded from the Baseline for the applicable years. Being “contracted” refers to a resource holding signed contract/s with an LSE/s for much of its energy and capacity, as applicable, for a significant portion of its useful life. The contracts refer to those approved by the CPUC and/or the LSE’s governing board, as applicable. These criteria indicate the resource is relatively certain to come online. Baseline resources that are not online at the time of modeling may have a failure rate applied to their nameplate capacity to allow for the risk of them failing to come online.

Candidate resource: those resources, such as renewables, energy storage, natural gas generation, and demand response, available for selection in IRP capacity expansion modeling, incremental to the Baseline resources.

Capacity Expansion Model: a capacity expansion model is a computer model that simulates generation and transmission investment to meet forecast electric load over many years, usually with the objective of minimizing the total cost of owning and operating the electrical system. Capacity expansion models can also be configured to only allow solutions that meet specific requirements, such as providing a minimum amount of capacity to ensure the reliability of the system or maintaining greenhouse gas emissions below an established level.

Certify (a Community Choice Aggregator Plan): Public Utilities Code 454.52(b)(3) requires the CPUC to certify the integrated resource plans of CCAs. “Certify” requires a formal act of the Commission to determine that the CCA’s Plan complies with the requirements of the statute and the process established via Public Utilities Code 454.51(a). In addition, the Commission must review the CCA Plans to determine any potential impacts on public utility bundled customers under Public Utilities Code Sections 451 and 454, among others.

Clean System Power (CSP) methodology: the methodology used to estimate GHG and criteria pollutant emissions associated with an LSE’s Portfolio based on how the LSE will expect to rely on system power on an hourly basis.
49 Community Choice Aggregator: a governmental entity formed by a city or county to procure electricity for its residents, businesses, and municipal facilities.

Conforming Portfolio: the LSE portfolio that conforms to IRP Planning Standards, the 2030 LSE-specific GHG Emissions Benchmark, use of the LSE’s assigned load forecast, use of inputs and assumptions matching those used in developing the Reference System Portfolio, as well as other IRP requirements including the filing of a complete Narrative Template, a Resource Data Template and Clean System Power Calculator.

Effective Load Carrying Capacity: a percentage that expresses how well a resource is able avoid loss-of-load events (considering availability and use limitations). The percentage is relative to a reference resource, for example a resource that is always available with no use limitations. It is calculated via probabilistic reliability modeling, and yields a single percentage value for a given resource or grouping of resources.

Effective Megawatts (MW): perfect capacity equivalent MW, such as the MW calculated by applying an ELCC % multiplier to nameplate MW.

Electric Service Provider: an entity that offers electric service to a retail or end-use customer, but which does not fall within the definition of an electrical corporation under Public Utilities Code Section 218.

Filing Entity: an entity required by statute to file an integrated resource plan with CPUC.

Future: a set of assumptions about future conditions, such as load or gas prices.

GHG Benchmark (or LSE-specific 2030 GHG Benchmark): the mass-based GHG emission planning targets calculated by staff for each LSE based on the methodology established by the California Air Resources Board and required for use in LSE Portfolio development in IRP.

GHG Planning Price: the systemwide marginal GHG abatement cost associated with achieving a specific electric sector 2030 GHG planning target.

Integrated Resources Planning Standards (Planning Standards): the set of CPUC IRP rules, guidelines, formulas and metrics that LSEs must include in their LSE Plans.

Integrated Resource Planning (IRP) process: integrated resource planning process; the repeating cycle through which integrated resource plans are prepared, submitted, and reviewed by the CPUC Long term: more than 5 years unless otherwise specified.

Load Serving Entity: an electrical corporation, electric service provider, community choice aggregator, or electric cooperative.

Load Serving Entity (LSE) Plan: an LSE’s integrated resource plan; the full set of documents and information submitted by an LSE to the CPUC as part of the IRP process.

Load Serving Entity (LSE) Portfolio: a set of supply- and/or demand-side resources with certain attributes that together serve the LSE’s assigned load over the IRP planning horizon.

Loss of Load Expectation (LOLE): a metric that quantifies the expected frequency of loss-of-load events per year. Loss-of-load is any instance where available generating capacity is insufficient to serve electric demand. If one or more instances of loss-of-load occurring within the same day regardless of duration 50 are counted as one loss-of-load event, then the LOLE metric can be compared to a reference point such as the industry probabilistic reliability standard of “one expected day in 10 years,” i.e. an LOLE of 0.1.

Maximum Import Capability: a California ISO metric that represents a quantity in MWs of imports determined by the CAISO to be simultaneously deliverable to the aggregate of load in the ISO’s Balancing Authority (BAA) Area and thus eligible for use in the Resource Adequacy process. The California ISO assess a MIC MW value for each intertie into the ISO’s BAA and allocated yearly to the LSEs. A LSE’s RA import showings are limited to its share of the MIC at each intertie.

Net Qualifying Capacity (NQC): Qualifying Capacity reduced, as applicable, based on: (1) testing and verification; (2) application of performance criteria; and (3) deliverability restrictions. The Net Qualifying Capacity determination shall be made by the California ISO pursuant to the provisions of this California ISO Tariff and the applicable Business Practice Manual.

Non-modeled costs: embedded fixed costs in today’s energy system (e.g., existing distribution revenue requirement, existing transmission revenue requirement, and energy efficiency program cost).

Nonstandard LSE Plan: type of integrated resource plan that an LSE may be eligible to file if it serves load outside the CAISO balancing authority area.

Optimization: an exercise undertaken in the CPUC’s Integrated Resource Planning (IRP) process using a capacity expansion model to identify a least-cost portfolio of electricity resources for meeting specific policy constraints, such as GHG reduction or RPS targets, while maintaining reliability given a set of assumptions about the future. Optimization in IRP considers resources assumed to be online over the planning horizon (baseline resources), some of which the model may choose not to retain, and additional resources (candidate resources) that the model is able to select to meet future grid needs.

Planned resource: any resource included in an LSE portfolio, whether already online or not, that is yet to be procured. Relating this to capacity expansion modeling terms, planned resources can be baseline resources (needing contract renewal, or currently owned/contracted by another LSE), candidate resources, or possibly resources that were not considered by the modeling, e.g., due to the passage of time between the modeling taking place and LSEs developing their plans. Planned resources can be specific (e.g., with a CAISO ID) or generic, with only the type, size and some geographic information identified.

Qualifying capacity: the maximum amount of Resource Adequacy Benefits a generating facility could provide before an assessment of its net qualifying capacity.

Preferred Conforming Portfolio: the conforming portfolio preferred by an LSE as the most suitable to its own needs; submitted to CPUC for review as one element of the LSE’s overall IRP plan.

Preferred System Plan: the Commission’s integrated resource plan composed of both the aggregation of LSE portfolios (i.e., Preferred System Portfolio) and the set of actions necessary to implement that portfolio (i.e., Preferred System Action Plan).

Preferred System Portfolio: the combined portfolios of individual LSEs within the CAISO, aggregated, reviewed and possibly modified by Commission staff as a proposal to the Commission, and adopted by the Commission as most responsive to statutory requirements per Pub. Util. Code 454.51; part of the Preferred System Plan.

Short term: 1 to 3 years (unless otherwise specified).
51 Staff: CPUC Energy Division staff (unless otherwise specified).

Standard LSE Plan: type of integrated resource plan that an LSE is required to file if it serves load within the CAISO balancing authority area (unless the LSE demonstrates exemption from the IRP process).

Transmission Planning Process (TPP): annual process conducted by the California Independent System Operator (CAISO) to identify potential transmission system limitations and areas that need reinforcements over a 10-year horizon.

GLOSSARY OF TERMS
AB – Assembly Bill
AL - Advice Letter
ALJ – Administrative Law Judge
ARB – Air Resources Board
AReM – Alliance for Retail Energy Markets
BayREN - Bay Area Regional Energy Network
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.

CALSEIA – California Solar Energy Industries
CALSLA – California City County Street Light Association CAM – Cost Allocation Mechanism
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.

CARE – California Alternative Rates for Energy
CBE – Communities for a Better Environment
CCA – Community Choice Aggregator
CCSF – City and County of San Francisco
CEC – California Energy Commission
CEE – Coalition for Energy Efficiency
CLECA – California Large Energy Consumers Association
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.

DACC – Direct Access Customer Coalition
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.

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. SVCE settles its CAISO load at the PG&E DLAP as SVCE 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.

DRP – Distributed Resource Plans
DWR – Department of Water Resources – DWR manages California’s water resources, systems, and infrastructure in a responsible, sustainable way.

ECR – Enhanced Community Renewable
ED – Energy Division
EE – Energy Efficiency
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.

ES – Energy Storage
ESA – Energy Storage Agreement
ESP – Energy Service Provider - An energy entity that provides service to a retail or end-use customer.

EV – Electric Vehicle
FCR – Flexible Capacity Requirements
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.

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.

GTSR – Green Tariff Shared Renewables
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.

ICA – Integration Capacity Analysis
IDER – Integrated Distributed Energy Resources
IDSM – Integrated Demand-Side Management
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.

IMD – Independent Marketing Division
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.

LCE – Lancaster Choice Energy
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.

LNBA – Locational Net Benefits Analysis
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.

LSE – 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.

LTPP – Long-Term Procurement Rulemaking
MCE – Marin Clean Energy
MTR – Mid-Term Reliability
MEO – Marketing Education and Outreach
MW – Megawatt – measure of power. A megawatt equals 1,000 kilowatts or 1 million watts.

MWH – Megawatt-hour – measure of energy
NAESCO – National Association of Energy Service Companies NBC – Non-Bypassable Charge
NDA – Non-Disclosure Agreement
NEM – Net Energy Metering – A program in which solar customers receive credit for excess electricity generated by solar panels.

NRDC – Natural Resources Defense Council
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.

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.

OSC – Order to Show Cause
ORA – Office of Ratepayer Advocates
PA – Program Administrator (for EE Business Plans)
PAC – Public Agency Coalition
PAM – Portfolio Allocation Methodology
PCE – Peninsula Clean Energy Authority
PCC1 – 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.

PG&E – Pacific Gas & Electric
PHC – Prehearing Conference
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.

PPA – Power Purchase Agreement – A contract used to purchase the energy, capacity and attributes from a renewable resource project.

PRP – Priority Review Project
PRRR – Progress on Residential Rate Reform
PUC – Public Utilities Code
PURPA – Public Utilities Regulatory Policy Act
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.

RAM – Renewables Auction Mechanism
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.

RES-BCT – Renewables Energy Self-Generation Bill Credit Transfer RFO – Request for Offers
RICA – Renewables Integration Cost Adder
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.

SB – Senate Bill
SCE – Southern California Edison
SCP – Sonoma Clean Power Authority
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.)
SUE – Super User Electric
SVCE – Silicon Valley Clean Energy
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.

TE – Transportation Electrification
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.

TM – Tree Mortality
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.

VAMO – Voluntary Allocation, Market Offer
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.