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Agenda packet

San Diego Community Power Board of Directors
December 14, 2023

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Agenda packet
Meeting
December 14, 2023
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San Diego Community Power Board of Directors
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Text extracted from the CCA's file for reading and search. Open the original on sdcommunitypower.org. That file is the official record.

AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 1 AGENDA
Regular Meeting of the Board of Directors of
San Diego Community Power (SDCP)
December 14, 2023
5:00 p.m.

City of San Diego Metropolitan Operations Complex (MOC II) Auditorium 9192 Topaz Way, San Diego, CA 92123
Alternate Address:

Courtyard by Marriott Oxnard Ventura
600 Esplanade Dr., Oxnard, CA 93030
The meeting will be held in person at the above date, time and location. Board of Directors Members and members of the public may attend in person. Under certain circumstances, Directors may also attend and participate in the meeting virtually pursuant to the Brown Act (Gov.

Code § 54953). As a convenience to the public, SDCP provides a call-in option and internet-based option for members of the public to virtually observe and provide public comments at its meetings. Additional details on in-person and virtual public participation are below. Please note that, in the event of a technical issue causing a disruption in the call-in option or internet-based option, the meeting will continue unless otherwise required by law, such as when a Board Member is attending the meeting virtually pursuant to certain provisions of the Brown Act.

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 of Directors as a whole through the Chair. Comments may be provided in one of the following manners:

1. Providing Oral Comments During Meeting. Anyone attending in person desiring to address the Board of Directors is asked to fill out a speaker’s slip and present it to the Clerk of the Board or the Secretary. To provide remote 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.

2. Written Comments. Written public comments must be submitted prior to the start of the meeting by using this Web Comment Form. Please indicate a specific agenda item when AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 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

WELCOME

CALL TO ORDER

ROLL CALL

PLEDGE OF ALLEGIANCE

SPECIAL PRESENTATIONS AND INTRODUCTIONS

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 November 16, 2023 Meeting Minutes

2. Receive and File Update on Programs

3. Receive and File Update on Power Services

4. Receive and File Update on Human Resources

5. Receive and File Update on Customer Operations

6. Receive and File Update on Marketing and Public Relations

7. Receive and File Update on Community Advisory Committee AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 3 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. Appointment of General Counsel and Approval of Employment Agreement Recommendation: Appoint Veera Tyagi as General Counsel effective February 1, 2024, and approve execution of an Employment Agreement in substantially the form attached hereto, with non-substantive revisions approved by the Chair and reviewed and approved as to form by General Counsel, and subject to successful completion of the employee onboarding process.

9. Receive and File Treasurer’s Report for Period Ending October 31, 2023 Recommendation:

Receive and file

10. Approve Conflict of Interest and Ethical Conduct Policy Recommendation: Approve Conflict of Interest and Ethical Conduct Policy

11. Request Approval of Regional Energy Network (REN) Application to California Public Utilities Commission CPUC
Recommendation: Request Approval of Regional Energy Network (REN) Application to CPUC

12. Receive Update on Regulatory and Legislative Affairs Recommendation: Receive and file

13. Receive Update on 2024 Rate/Power Charge Indifference Adjustment (PCIA) Projected Changes
Recommendation: Receive and file

14. Approve CDH VIDAL LLC Power Purchase Agreement (PPA) Recommendation: Approve a 20-year Power Purchase Agreement (PPA) with CDH VIDAL LLC for a 160 MW/160 MWh (4-hour) battery storage project.

15. (12/13/23 Update - Item 15 deferred to future meeting)

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.

AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 4 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.

PUBLIC COMMENTS ON CLOSED SESSION ITEMS

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, 2305 Historic Decatur Road, Suite 200, San Diego, CA 92106. Please contact [email protected] to arrange an appointment.

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

BOARD OF DIRECTORS
City of San Diego Metropolitan Operations Complex (MOC II) Auditorium 9192 Topaz Way
San Diego, CA 92123

MINUTES
November 16, 2023
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 LaCava (City of San Diego) called the SDCP Board of Directors meeting to order at 5:00 p.m.

Director Hinze (Encinitas) announced she was attending virtually under the just cause provision of AB 2449 due to a contagious illness that prevented her from attending in person and there was an individual over the age of 18 present in the room with her.

ROLL CALL
PRESENT: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas) (arrived at 5:03 p.m.), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
ABSENT: Vice Chair Lawson-Remer (County of San Diego)
Also Present: Chief Executive Officer (“CEO”) Burns, Chief Operating Officer (“COO”) Clark, Chief Financial Officer (“CFO”)/Treasurer Washington, General Counsel Baron, Board Clerk Isley
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 2 PLEDGE OF ALLEGIANCE
Chair LaCava (City of San Diego) led the Pledge of Allegiance.

SPECIAL PRESENTATIONS AND INTRODUCTIONS
Chair LaCava (City of San Diego) acknowledged the Kumeyaay Nation and all the original stewards of the land.

Chair LaCava (City of San Diego) introduced the following new SDCP staff members:

Diana Gonzalez Risk Manager
Erin Hudak, Compliance Analyst

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

PUBLIC COMMENTS
There were no public comments.

CONSENT CALENDAR
(Items 1 through 10)
Director Parent pulled item 11 suggesting further discussion.

ACTION: Motioned by Director Parent and seconded by Director McCann (Chula Vista) to approve Consent Calendar Items 1 through 10. The motion carried by the following vote:

Vote: 6-0
Yes: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
No: None
Abstained: None

Absent: None

1. Approval of October 26, 2023 Meeting Minutes
Approved.

2. Receive and File Treasurer’s Report for Period Ending September 30, 2023 Received and filed.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 3 3. Receive and File June 30, 2023 Fiscal Year-end Audited Financial Statement Received and filed.

4. Receive and File Update on Programs
Received and filed.

5. Receive and File Update on Power Services
Received and filed.

6. Receive and File Update on Human Resources
Received and filed.

7. Receive and File Update on Customer Operations
Received and filed.

8. Receive and File Update on Marketing and Public Relations Received and filed.

9. Receive and File Update on Community Advisory Committee Received and filed.

10. Receive and File Update on Legislative and Regulatory Affairs Received and filed.

11. Approval of 2023 Procurement Counsel Legal Services Request for Proposal Contracts (This item was pulled from the consent calendar and added to the regular agenda)
a. Approval of Amended and Restated Engagement Letter with Keyes and Fox LLP for up to $500,000 per year for Legal Services for Power Procurement beginning January 1, 2024
b. Approval of Engagement Letter with Perkins Coie LLP for up to $200,000 per year for Legal Services for Power Procurement beginning January 1, 2024 c. Approval of Engagement Letter with Sunridge Legal, LLP for up to $200,000 per year for Legal Services for Power Procurement beginning January 1, 2024 MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 4 REGULAR AGENDA

11. Approval of 2023 Procurement Counsel Legal Services Request for Proposal Contracts (Moved from the consent calendar to the regular agenda) There was no presentation on this item.

Board questions and comments ensued.

ACTION: Motioned by Director Parent and seconded by Director Yamane (National City) to approve the Approval of 2023 Procurement Counsel Legal Services Request for Proposal Contracts with the condition that they have a period of three years before the direction of staff to do an update for an RFP or other procurement. The motion carried by the following vote:

Vote: 6-0
Yes: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
No: None
Abstained: None

Absent: None

12. Update on Quarterly Report for the Community Advisory Committee Community Engagement Manager Crespo and Community Advisory Committee Chair Vasilakis provided a PowerPoint presentation on the update on the quarterly report for the Community Advisory Committee.

Following Board questions and comments, no action was taken.

13. Approve the Appointment of CAC Member Representing the City of Imperial Beach Community Engagement Manager Crespo provided a PowerPoint presentation on the Community Advisory Committee’s (CAC) membership terms and criteria and recommended the approval of Appointment of CAC Member Representing the City of Imperial Beach.

Board questions and comments ensued.

MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 5 ACTION: Motioned by Director Aguirre (Imperial Beach) and seconded by Director Yamane (National City) to approve the Appointment of CAC Member Representing the City of Imperial Beach. The motion carried by the following vote:

Vote: 6-0
Yes: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
No: None
Abstained: None

Absent: None

14. Approve the Update to the Energy Proposal Evaluation Criteria Director of Power Contracts Key gave a PowerPoint presentation on the Energy Proposal Evaluation Criteria.

Public Comment:

Jason Anderson, Clean Tech, submitted a letter of support before the meeting and it was posted to the San Diego Community Power’s (SDCP) website.

Board questions and comments ensued.

ACTION: Motioned by Director Parent (La Mesa) and seconded by Director McCann (Chula Vista) to approve the Update to the Energy Proposal Evaluation Criteria. This includes the clarification that any community benefit will be directed to SDCP for administration. Additionally, there is a request for staff to return with assistance in determining the scale of the community benefit. This involves proposing criteria and outlining a process for the allocation of any funds received for community benefit. The motion carried by the following vote:

Vote: 6-0
Yes: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
No: None
Abstained: None

Absent: None
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 6 15. Approve Arevon Avocet Standalone Storage Energy Storage Services Agreement (ESSA)
Director of Power Contracts Key gave a PowerPoint presentation on the Arevon Avocet Standalone Storage Energy Storage Services Agreement (ESSA).

Board questions and comments ensued.

ACTION: Motioned by Director McCann (Chula Vista) and seconded by Director Yamane (National City) to approve Arevon Avocet Standalone Storage Energy Storage Services Agreement (ESSA). The motion carried by the following vote:

Vote: 6-0
Yes: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
No: None
Abstained: None

Absent: None

16. Approve Pomona 2 Standalone Storage Energy Storage Services Agreement (ESSA)
Managing Director Power Services Vosburg provided a PowerPoint presentation on the Pomona 2 Standalone Storage Energy Storage Services Agreement (ESSA).

Board questions and comments ensued.

ACTION: Motioned by Director McCann (Chula Vista) and seconded by Director Parent (La Mesa) to approve the Pomona 2 Standalone Storage Energy Storage Services Agreement (ESSA). The motion carried by the following vote:

Vote: 6-0
Yes: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
No: None
Abstained: None

Absent: None
MINUTES – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 7 REPORTS BY CHIEF EXECUTIVE OFFICER AND GENERAL COUNSEL CEO Burns reported on SDCP’s ongoing efforts and recent activities and events.

DIRECTOR COMMENTS
There were no director comments.

PUBLIC COMMENTS ON CLOSED SESSION ITEMS
There were no public comments.

CLOSED SESSION

1. CONFERENCE WITH LABOR NEGOTIATORS
Agency designated representatives: Chair LaCava and SDCP CEO Karin Burns Unrepresented employee: General Counsel

2. PUBLIC EMPLOYEE APPOINTMENT (RECRUITMENT UPDATE)
Title: General Counsel

ROLL CALL
PRESENT: Chair LaCava (City of San Diego), Director McCann (Chula Vista), Director Hinze (Encinitas), Director Aguirre (Imperial Beach), Director Parent (La Mesa), and Director Yamane (National City)
ABSENT: Vice Chair Lawson-Remer (County of San Diego)
Also Present: General Counsel Baron

REPORT FROM CLOSED SESSION
General Counsel Ryan Baron reported there was no reportable actions from the closed session.

ADJOURNMENT
Chair LaCava (City of San Diego) adjourned the meeting at 6:15 p.m.

Prepared by:

Sandra Vences, Deputy Clerk

SAN DIEGO COMMUNITY POWER
Staff Report – Item 2
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Colin Santulli, Director of Programs
Via: Jack Clark, Chief Operating Officer
Subject: Update on Programs
Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATIONS
Receive and file update on customer energy programs.

BACKGROUND
Staff will provide regular updates to the Board of Directors (“Board”) regarding the following SDCP customer energy programs: Building Electrification, Energy Education, Energy Efficiency, Flexible Load, Grant Programs, and Solar and Energy Storage.

ANALYSIS AND DISCUSSION
Updates on customer energy programs are detailed below.

Building Electrification
California Energy Commission (“CEC”) Equitable Building Decarbonization Program
Please refer to Item 4 of the November 16, 2023 Board staff report for the most recent update on this program.

Energy Education
Energy Education Website
Status: Staff recently launched the Power Your Life and Electrify Your Life webpages that provide education on the benefits of electrification and the various advanced electrification technologies currently available. Staff anticipate launching a marketplace powered by Electrum in December 2023 that will allow customers to learn more about the costs to install solar and batteries and/or heat pump water heaters. Customers can then create an account and get actual bids on the work from an Electrum-vetted list of contractors and get connected to an energy advisor to receive support and assistance in completing a project. Criteria and a sign-up form will be provided on the marketplace landing page that will allow local contractors to join the network.

Next Steps: The “Power Your Life” and “Electrify Your Life” webpages will be updated in December 2023 with links to the marketplace and a marketing campaign for the marketplace will commence at the beginning of 2024.

Energy Efficiency
Regional Energy Network (“REN”) Formation
Status: Staff are requesting approval of the REN Business Plan Application and supporting documents at the December 14, 2023 Board meeting, prior to submittal to the California Public Utilities Commission (“CPUC”).

Next Steps: Staff expect to submit the completed Business Plan Application to the CPUC in January 2024.

Flexible Load
Flexible Load Strategy
Status: Staff have been developing a flexible load strategy that can be implemented across a range of programs. The strategy is being designed to optimize customer energy usage around time of use rate schedules and customer preferences, directly reducing participant bills, while decreasing major SDCP cost drivers, such as energy and resource adequacy procurement. The strategy will outline target end use technologies, key points of integration with existing/planned programs, a proposed software architecture to drive device dispatch and control, as well as a framework to guide dispatch and device operations.

Next Steps: Staff plan to bring an update on the flexible load strategy to the Community Advisory Committee (“CAC”) and Board in Q1 2024. Staff plan to begin the procurement process for the associated software architecture in late Q1 2024.

Grant Programs
Community Grant Program
Please refer to Item 4 of the November 16, 2023 Board staff report for the most recent update on this program.

Member Agency Grant Program
Please refer to Item 4 of the November 16, 2023 Board staff report for the most recent update on this program.

Solar and Energy Storage
Net Energy Metering (“NEM”) and Net Billing Tariff (“NBT”) Status: In November 2023, the CPUC approved new subtariffs for virtual and aggregation Net Billing Tariff. In these new subtariffs, the current Virtual Net Energy Metering and Net Energy Metering Aggregation are closed to new customers interconnecting after February 2024. The new net billing subtariffs mirror the Net Billing Tariff adopted by the CPUC in December 2022 meaning that electricity exports will continue to be compensated at the Avoided Cost Calculator (“ACC”) values, while imports (consumption) would be charged retail rates. The utilities have until March 31, 2025 to align their billing systems to support full implementation of the virtual and aggregation net billing subtariffs. The CPUC also extended the ACC “Plus” adders to these subtariffs.

Next Steps: Staff are evaluating the development of the subtariffs by the utilities. In Q1 2024, Staff expect to bring an updated Net Billing Tariff (approved by the Board in October 2023) to include provisions to allow for virtual and aggregation subtariffs.

Residential Solar + Storage Program
Status: Staff have been working on developing a solar plus battery storage program to continue to support the solar and storage industries and support the transition to NBT from NEM. The program will target residential customers throughout SDCP’s service territory who do not have solar and storage. Staff have been obtaining feedback from stakeholders on the program design, specifically local installers, original equipment manufacturers (“OEMs”), national solar and storage companies, and potential financing partners. Staff have developed an initial program design for a daily dispatch program and are drafting a Program Manual in addition to developing battery and installer requirements to ensure the highest quality for SDCP customers.

Next Steps: Staff plan to bring an update on the program design to the CAC and Board in Q1 2024. Staff plan for the program to officially launch in Q2-Q3 2024.

Solar for Our Communities
Please refer to Item 3 of the October 26, 2023 Board staff report for the most recent update on this program.

AD-HOC COMMITTEE AND/OR SUBCOMITTEE REVIEW
Staff meet monthly with the CAC Ad-Hoc Programs Committee to discuss ongoing Programs Department activities.

FISCAL IMPACT
N/A

ATTACHMENTS
N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 3
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Byron Vosburg, Managing Director of Power Services Via: Karin Burns, Chief Executive Officer
Subject: Update on Power Resources
Date: December 14, 2023
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Recommendation: Receive and file update on Power Resources

BACKGROUND
Staff provides the updates below to the Board of Directors regarding SDCP’s power energy procurement activities.

ANALYSIS AND DISCUSSION
Power Services Staffing
Building out a team of experienced, knowledgeable energy professionals has long been a top priority and allows SDCP not only to solicit, negotiate, and administer contracts for energy supply effectively, but also to monitor market activity, manage risk, bring in-house a number of activities that have historically been completed by consultants, and to dedicate additional resources to local and distributed energy procurement and development efforts. The SDCP Power Services team, having recently hired a Compliance Analyst and a Contract Management Associate, is now ten people strong.

Long-term Renewable Energy RFPs
As SDCP strives to meet its environmental, financial, and regulatory compliance goals and requirements, long-term power purchase agreements (PPAs) are becoming integral components of its energy supply portfolio. Long-term PPAs provide renewable generation facility developers with the certain revenue stream against which they can finance up-front capital requirements, so each long-term PPA that SDCP signs with a developing facility will underpin a new, incremental renewable energy project. In addition, long-term PPAs lock in renewable energy supply around which SDCP can build its power supply portfolio while also providing power supply cost certainty around which SDCP can develop its pro forma financial model. Moreover, the California Renewable Portfolio Standard (RPS), as modified in 2015 by Senate Bill 350, requires that SDCP provide 65% of its RPS-required renewable energy from contracts of at least ten years in length.

Finally, in D.21-06-025, the California Public Utilities Commission (CPUC) required each Load Serving Entity (LSE) in California to make significant long-term purchase commitments for resource adequacy from new, incremental generation facilities that will achieve commercial operation during 2023 through 2026 for purposes of “Mid Term Reliability” (MTR). These requirements have been augmented and extended into 2026 and 2027 via D.23-02-040.

In pursuit of long-term contracts for renewable energy, staff released two RFPs for eligible Renewable Energy resources in the past 12 months. Staff are deep in negotiations with several respondents for resources that are expected to be online between 2025 and 2028.

Staff and the Energy Contracts Working Group (ECWG) evaluate all RFP submissions prior to entering negotiations with selected participants. Assuming that Staff and shortlisted developer(s) are able to agree to mutually agreeable contracts consistent with terms authorized by the ECWG, Staff then review draft agreements with the SDCP Board for approval and authorization to execute the relevant documents.

In addition to RFPs issued by SDCP, the power service team also closely monitors market offers from the IOUs in California to secure contracts for short-term and long-term renewable projects.

Stand-Alone Energy Storage RFO
In addition to the two aforementioned Renewable Energy RFPs, staff also launched an RFO for stand-alone energy storage resources, which will allow SDCP to meet resource adequacy requirements and protect against market price volatility with clean, reliable storage capacity that can be contracted for 10-20 years. SDCP pursued stand-alone energy storage resources of at least 10 MW in capacity, at least 4-hours of duration, and which are expected to be online between 2024 and 2028. Staff shortlisted and waitlisted select projects after review with the ECWG. Staff negotiated with select respondents for resources that are expected to be online by 2028. Since the November 2023 Board meeting, SDCP has fully executed the Board-approved Pomona 2 energy storage service agreement and will be executing the Arevon Avocet energy storage service agreement soon.

Local Development
SDCP’s rolling Local RFI remains open and has already brought in multiple projects under negotiation and contract, including the 35 MW Arrowleaf Solar+Storage facility (Imperial County, executed June 2023) and 19.5MW of long-term agreements recently executed with EnerSmart for Local RA from battery storage facilities in San Diego County. SDCP also released an RFO for distributed renewable energy resources (DERs) on October 25th, which focuses on a broad range of distribution-level renewable projects within San Diego County - responses are due on December 22. SDCP expects to bring a handful of resulting PPAs to the Board in Q1 for consideration. Additional ongoing local initiatives include a Feed-in-Tariff Program revamp and expansion, expected in Q1, and continued collaboration with member agency staff to identify strategic opportunities to further infill development in 2024.

As Program Administrators of the CPUC’s Disadvantaged Communities Green Tariff (DAC-GT) and Community Solar Green Tariff (CSGT) programs, SDCP launched the RFP solicitation for respective program resources on August 26th, proposals for which will be due in late February 2024. SDCP has hosted three webinars to aid bidders with the solicitation process.

SDCP’s Local RFI and Feed-in Tariff remain open. More information is available about each at the links below.
x https://sdcommunitypower.org/resources/solicitations/ x https://sdcommunitypower.org/programs/feed-in-tariff/ RPS Procurement
SDCP staff continues to actively manage its environmental portfolios and to closely monitor the market for renewable and carbon-free energy sources, procuring RPS in the bi-lateral market, and continuing procurement efforts as market opportunities become available. These procurement efforts will serve to help meet SDCP’s near-term environmental goals as long-term projects in development come online.

Market Update
Due to lingering effects of the COVID-19 pandemic, namely inflation and heavily impacted commodity supply chains that have delayed development of new-build energy resources expected to be online over the last two years, the market for renewable energy and resource adequacy (RA) resources continues to be exceptionally tight and expensive.

Staff are working with developers, industry groups, the CPUC, and CA Governor’s Office and legislators to brainstorm near-term solutions while also actively procuring short-term energy and capacity products and long-term energy resources i) to meet SDCP's portfolio needs practically and cost-effectively and ii) to establish a portfolio of resources that will provide value to SDCP and California's clean, reliable energy needs into the future.

COMMITTEE REVIEW
N/A

FISCAL IMPACT
N/A

ATTACHMENTS
N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 4
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Chandra Pugh, Director of People Operations
Via: Karin Burns, Chief Executive Officer
Subject: Update on Human Resources
Date: December 14th, 2023
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and File the Update on Human Resources.

BACKGROUND
This month, SDCP welcomes several new employees:

Isabela Krall, Contracts Management Associate
Patrick Welch, Sr. Legislative Manager
Current open positions include:

Senior Executive Assistant
We are excited to close out the year with an employee appreciation All Staff Meeting where we will spend time thanking our incredible staff for their amazing milestones and contributions this year.

We are also excited to come together in celebration at our annual holiday party in support of a local business located in National City.

DISCUSSION AND ANALYSIS
N/A

COMMITTEE REVIEW
N/A

FISCAL IMPACT
N/A
ATTACHMENTS:

N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 5
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Lucas Utouh, Senior Director of Data Analytics and Customer Operations Via: Karin Burns, Chief Executive Officer
Subject: Update on Customer Operations
Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file an update on various customer operations.

BACKGROUND
Staff will provide regular updates to the Community Advisory Committee 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 customer operations.

ANALYSIS AND DISCUSSION
A) Mass Enrollment Update
Phase 4:

Mass enrollment for our Non-Net Energy Metering (NEM) customers in National City and Unincorporated County of San Diego is officially complete as of May 3, 2023. As of November 27, 2023, SDCP is serving a cumulative total count of 932,576 active accounts correlating to 1,107,719 meters. There are 155,938 active accounts already enrolled in Unincorporated County of San Diego and 18,603 in National City.

Accounts on Net Energy Metering (NEM) within Phase 4 in National City and County of San Diego began enrollment into SDCP service in April 2023 and will continue for the next twelve months, coinciding with their true up month through March 2024. Enrolled customers will receive 2 post enrollment notices through the mail at their mailing address on file within 60 days of their account switching over to SDCP service.

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 November 13th, 2023:
*Historical opt outs including inactive accounts as of 11/13/2023.

Phase 4 mass enrollment process in National City and Unincorporated County of San Diego for Non-Net Energy Metering (NEM) customers is officially completed as of May 2023. The participation rate for this new phase is fluid and will change as we continue with our enrollment of Net Energy Metering (NEM) customers from April 2023 through March 2024. In the interim, we are reporting on the opt outs and eligible accounts associated with the phase based on those accounts that we have noticed for enrollment on a rolling basis as of the reporting month.

C) Contact Center Metrics
Call volumes in September and October have remained relatively steady relative to August. With the transition to winter rates effective as of November 1st, call volumes are expected to go down.

The chart below summarizes contact made by customers into our Contact Center broken down by month through November 13th, 2023:

Similar to 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.

D) Customer Service Email Trends
As of this latest reporting month, we still have a total of 13 Dedicated Customer Service Representatives staffed at our Contact Center and 2 Supervisors. 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.

AD-HOC COMMITTEE AND/OR SUBCOMITTEE REVIEW
N/A

FISCAL IMPACT
N/A

ATTACHMENTS
N/A

SAN DIEGO COMMUNITY POWER
Staff Report – Item 6
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Jen Lebron, Director of Public Affairs
Via: Karin Burns, Chief Executive Officer
Subject: Marketing, Public Relations, and Government Affairs Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file update on marketing, public relations, and government affairs activities for San Diego Community Power.

BACKGROUND
San Diego Community Power (SDCP) has engaged in a variety of public relations, marketing, community outreach, and local government affairs activities to drive awareness, spark community engagement, and maintain high customer enrollment.

ANALYSIS AND DISCUSSION
SDCP’s Public Affairs Department has been participating in events across our member agencies as it aims to increase general awareness and answer questions in a friendly, helpful manner.

Recent and Upcoming Public Engagement Events
Nov. 3, 2023 – Lesley K. McAllister Symposium on Climate and Energy Law Nov. 3, 2023 – Chula Vista Chamber of Commerce First Friday Breakfast Nov. 4, 2023 – La Mesa Parks Appreciation Day
Nov. 7, 2023 – California Efficiency + Demand Management Council Nov. 8, 2023 – La Mesa Library
Nov. 8, 2023 – North San Diego Chamber Regional Connect Nov. 9, 2023 – Business For Good Summit
Nov. 9, 2023 – San Diego Regional Chamber of Commerce Legislative Lounge Nov. 14, 2023 – Encinitas Chamber of Commerce Moonlight Mixer Nov. 15, 2023 – Voltility Conference
Nov. 15, 2023 – Mission Valley Branch Library
Nov. 18, 2023 –Imperial Beach Sun Coast Farmers Market
Nov. 30, 2023 – Chula Vista Library
Dec. 1, 2023 – Chula Vista Chamber of Commerce
Dec. 6, 2023 – La Mesa Library
Dec. 6, 2023 – Business for Good
Dec. 9, 2023 – National City Community Breakfast
Dec. 12, 2023 – North Park Library
Dec. 13, 2023 – Imperial Beach Library
Dec. 14, 2023 – Mission Valley Library
Dec. 16, 2023 – Surfrider Imperial Beach Cleanup
Dec. 21, 2023 – Spring Valley Library
Marketing, Communications and Outreach
SDCP has sponsored a number of large events throughout the greater San Diego region to increase general brand awareness, even when we do not have the staff capacity to have an in-person booth.

SDCP is the mobility sponsor for December Nights in the City of San Diego and a bronze sponsor for the City of Chula Vista’s Starlight Parade and Festival. Between these two capstone events for the two largest cities in SDCP’s territory, SDCP anticipates more than 400,000 impressions in-person. As the December Nights mobility sponsor, SDCP is also being featured in radio advertisements and earned media spots on local news stations that will reach thousands of San Diegans across all member agencies.

The Public Affairs team has been working diligently behind the scenes to support programmatic efforts including the launch of “Solar for Our Communities” green tariff programs, a soon-to-be launched electrification education hub, and updating information around the recently-approved Net Billing Tariff. The Public Affairs team is working closely with internal and external stakeholders to encourage participation in programs and leveraging relationships with community partners to amplify our marketing and outreach efforts.

SDCP is in regular communication with regional media in the spirit of transparency and openness with the goal of providing factual, timely information to the public at large. Over the past several months, SDCP has engaged with reporters to provide information about the greater energy landscape in California and update them on our organization’s activities.

The Public Affairs team will continue to develop new strategies, processes and capacity over the next several months to conduct more community outreach, expand marketing and brand awareness efforts, and provide timely, accurate information across multiple channels.

SDCP has ramped up its efforts to connect with local leaders with the hiring of its Local Government Affairs Manager earlier this fall. Over the past month, SDCP has participated in the San Diego Regional Chamber’s Legislative Lounge, meeting with the leaders of sovereign tribal nations, enhancing coordination with member agency staff, and planning out opportunities to more regularly present at member agency public meetings. On Dec. 6, SDCP is slated to present an update on organizational activities at the Imperial Beach City Council meeting.

AD-HOC COMMITTEE AND/OR SUBCOMITTEE 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: Xiomalys Crespo, Community Engagement Manager
Via: Karin Burns, Chief Executive Officer
Subject: Receive and File Community Advisory Committee Monthly Report Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and file Community Advisory Committee (CAC) monthly report.

BACKGROUND
Per Section 5.10.3 of the San Diego Community Power (SDCP) Joint Powers Authority (JPA) Agreement:

The Board shall establish a Community Advisory Committee comprised of non-Board members. The primary purpose of the Community Advisory Committee shall be 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 the Authority.

At the direction of the Chief Executive Officer, the CAC provides quarterly presentations to the Board of Directors in the regular agenda, and monthly reports in the consent agenda.

ANALYSIS AND DISCUSSION
During the December 7, 2023 regular CAC meeting:
x Chair Vasilakis (City of San Diego) welcomed recently appointed member Sandoval (City of Imperial Beach) as the newest member of the CAC, as well as SDCP’s new Contract Management Associate Isabella Krall. x The CAC approved the consent agenda, which included the November meeting minutes, and updates on Marketing, Public Relations, and Government Affairs and Customer Operations. Members received staff reports and briefings for all items, which included a dedicated section on government affairs activities at the request of the Committee.
x The Regulatory and Legislative Affairs team provided a comprehensive update on legislative activity over the last year and CAC members commended the team for its efforts to provide ratepayers with savings and uphold the sovereignty and long-term sustainability of Community Choice Aggregators. x At the request of the Committee, members also received an update on the Local Distributed Infill Plan. The CAC encouraged the Power Services team to work with Public Affairs to increase outreach around active solicitation opportunities. x The Programs team provided an update on Energy Education and Online Marketplace, in which staff: guided members through currently active website content on electrification and the sustainability advantages of electrifying specific areas of customers’ homes; and provided visuals of the dashboard that will help customers connect with vetted vendors to facilitate the purchase of solar systems, battery storage, and heat pump water heaters once launched in 2024. Members encouraged staff to leverage this opportunity to connect customers to the services, products, and programs of local nonprofits and contractors whenever possible. x The CAC discussed and recommended that the Board of Directors approve SDCP’s Conflict of Interest and Ethical Conduct Policy by a unanimous vote. x The CAC heard updates on the October activity of its Ad-Hoc Committees. The Programs Ad-Hoc Committee learned about and provided feedback on SDCP’s Residential Solar & Battery Storage Program, and discussed the potential formation of program-specific ad-hoc committees to continue collaborating with staff in the development of offerings for SDCP customers. The Community & Equity Ad-Hoc Committee discussed the 2024 CAC Work Plan and provided feedback on proposed changes to the CAC Scope of Work.
x Lastly, the CAC received an update on the progress of updating the CAC Work Plan. Staff has leveraged the creation of the CAC Community & Equity Ad-Hoc Committee to solicit and receive feedback on proposed changes for 2024, and will present a draft for full CAC discussion during the January 11, 2024 regular meeting.
x The CAC voted to approve the 2024 CAC Meeting Calendar, which includes meetings taking place every second Wednesday of the month at the current meeting site, unless otherwise specified. The Committee will take a meeting recess in August 2024. Committee members had no announcements or further recommendations on potential agenda items for the Board of Directors.

As of December 8, 2023, the CAC has one vacancy representing the County of San Diego (unincorporated). Members of the public must be residents, community leaders, and/or business owners of the respective jurisdictions and may submit their applications electronically.

COMMITTEE REVIEW
N/A

FISCAL IMPACT
N/A

ATTACHMENTS
Attachment A: Community Advisory Committee December 7, 2023 Regular Meeting Agenda
AGENDA – COMMUNITY ADVISORY COMMITTEE – SAN DIEGO COMMUNITY POWER 1 AGENDA
Regular Meeting of Community Advisory Committee
San Diego Community Power (SDCP)
December 7, 2023
5:30 p.m.

City of San Diego Metropolitan Operations Complex (MOC II) Auditorium 9192 Topaz Way, San Diego, CA 92123
Alternate Location:
7354 Eads Avenue, San Diego, CA 92037
The meeting will be held in person at the above date, time and location. Community Advisory Committee (CAC) Members and members of the public may attend in person. Under certain circumstances, CAC Members may also attend and participate in the meeting virtually pursuant to the Brown Act (Gov. Code § 54953). As a convenience to the public, SDCP provides a call-in option and internet-based option for members of the public to virtually observe and provide public comments at its meetings. Additional details on in-person and virtual public participation are below. Please note that, in the event of a technical issue causing a disruption in the call-in option or internet-based option, the meeting will continue unless otherwise required by law, such as when a CAC Member is attending the meeting virtually pursuant to certain provisions of the Brown Act.

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

1. Providing Oral Comments During Meeting. Anyone attending in person desiring to address the CAC is asked to fill out a speaker’s slip and present it to the CAC Chair or the Secretary. To provide remote 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.

2. Written Comments. Written public comments must be submitted prior to the start of the meeting by using this (web comment form). Please indicate a specific agenda item when submitting your comment. All written comments received prior to the meeting will be provided to the CAC 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 AGENDA – COMMUNITY ADVISORY COMMITTEE – SAN DIEGO COMMUNITY POWER 2 meeting will be limited to the first 400 words. Comments received after the start of the meeting will be collected, sent to the CAC members in writing, and be part of the public record.

If you have anything that you wish to be distributed to the CAC, please provide it via [email protected], who will distribute the information to the Members.

The public may participate using the following remote options:

Teleconference Meeting Webinar
https://zoom.us/j/93647500600
Telephone (Audio Only)
(669) 900-6833 or (253) 215-8782 | Webinar ID: 936 4750 0600

WELCOME

ROLL CALL

PLEDGE OF ALLEGIANCE

LAND ACKNOWLEDGMENT

SPECIAL PRESENTATIONS AND INTRODUCTIONS

ITEMS TO BE WITHDRAWN OR REORDERED ON THE AGENDA

PUBLIC COMMENT FOR ITEMS NOT ON THE AGENDA
Opportunity for members of the public to address the CAC on any items not on the agenda but within the jurisdiction of the CAC. 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 CAC member 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 November 9, 2023 CAC Meeting Minutes

2. Update on Marketing, Public Relations, and Government Affairs

3. Update on Customer Operations
AGENDA – COMMUNITY ADVISORY COMMITTEE – SAN DIEGO COMMUNITY POWER 3 REGULAR AGENDA
The following items call for discussion or action by the CAC.

4. Update on Regulatory and Legislative Affairs
Recommendation: Receive and File the Update on Regulatory and Legislative Affairs

5. Update on Local Distributed Infill Plan
Recommendation: Receive and File the Update on Local Distributed Infill Plan

6. Update on Energy Education and Online Marketplace
Recommendation: Receive and File the Update on Energy Education and Online Marketplace

7. Review of SDCP’s Conflict of Interest and Ethical Conduct Policy Recommendation: Recommend Board Approval of SDCP’s Conflict of Interest and Ethical Conduct Policy

8. Update on 2024 Rate & Power Charge Indifference Adjustment (PCIA) Projected Changes
Recommendation: Receive and File the Update on 2024 Rate & Power Charge Indifference Adjustment (PCIA) Projected Changes

9. Updates from Programs and Community & Equity Ad-Hoc Committees Recommendation: Receive and File the Updates on the Programs and Community & Equity Ad-Hoc Committees

10. Update on CAC Work Plan Update Progress
Recommendation: Receive and File the Update on CAC Work Plan Update Progress

11. Approval of 2024 CAC Regular Meeting Calendar
Recommendation: Approve the 2024 CAC Regular Meeting Calendar

DISCUSSION OF POTENTIAL AGENDA ITEMS FOR BOARD OF DIRECTORS

MEETINGS
There are two ways that the CAC may bring items to the attention of the Board:

AGENDA – COMMUNITY ADVISORY COMMITTEE – SAN DIEGO COMMUNITY POWER 4 1. Standing Board Agenda Item: CAC Report. The CAC report may be a standing item on the Board agenda, in which the CAC Chair or CEO reports on updates related to a recent CAC meeting. Consistent with the Brown Act, items raised during the CAC report may not result in extended discussion or action by the Board unless agendized for a future meeting.

2. Suggesting Board Agenda Items: The CAC may suggest agenda items for a Board of Directors meeting agenda. Such agenda items would allow extended discussion or action by the Board. These must have prior approval of the SDCP Chief Executive Officer and the Chair of the Board of Directors to be added onto 4 the agenda. If approval is provided, staff must be given at least 5 days before the date of the Board meeting to work with the CAC to draft any memos and materials necessary.

COMMITTEE MEMBER ANNOUNCEMENTS
Committee Members may briefly provide information to other members and the public. There is to be no discussion or action taken on comments made by Committee Members unless authorized by law.

ADJOURNMENT
Availability of Committee Documents
Copies of the agenda and agenda packet are available at https://sdcommunitypower.org/resources/meeting-notes/. Late-arriving documents related to a CAC meeting item which are distributed to a majority of the Members prior to or during the CAC meeting are available for public review as required by law. Public records, including agenda-related documents, can instead be requested electronically at [email protected] or by mail to SDCP at 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, 2305 Historic Decatur Road, Suite 200, San Diego, CA 92106. Please contact [email protected] to arrange an appointment.

SAN DIEGO COMMUNITY POWER
Staff Report ,WHP
--------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Joe LaCava, Chair of the Board of SDCP
Ad Hoc Committee on General Counsel Recruitment
Subject: Appointment of General Counsel and Approval of Employment Agreement Date: December 14, 2023
---------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Recommendation: Appoint Veera Tyagi as General Counsel effective February 1, 2024, and approve execution of an Employment Agreement in substantially the form attached hereto, with non-substantive revisions approved by the Chair and reviewed and approved as to form by General Counsel, and subject to successful completion of the employee onboarding process.

BACKGROUND
During the Board’s Regular Meeting on September 28th, the CEO presented, and the Board discussed whether to hire an in-house General Counsel (GC). The September staff report outlined the rationale for considering an in-house GC as well as the potential costs and/or risks. The decision was made to proceed with hiring an In-House GC and establish an Ad Hoc Committee on GC Recruitment.

The Board engaged Futura, a professional executive search firm, to assist in recruitment for a new General Counsel. SDCP had already retained the Futura professional executive search firm under an existing agreement for a variety of searches and repurposed existing funding so Futura could assist with recruitment for a new General Counsel.

During the Board’s Closed Session Meeting on November 16th, the CEO provided the Board with an update on the recruiting process and sought delegation of authority for the CEO and the Board Chair to negotiate an Employment Agreement with the final selected candidate.

At the end of November, final round interviews were held and shortly thereafter the decision was made to offer the role to one of the final candidates, Veera Tyagi.

Ms. Tyagi has close to twenty years of experience as an environmental attorney, primarily as in-house counsel for air pollution control districts. She has significant experience with general governmental laws, an expertise in air quality laws and the California Environmental Quality Act (CEQA), and a strong understanding of the regulatory framework and energy policy needs of the SDCP. Ms. Tyagi’s experience as an environmental regulator has shaped her into a powerful advocate with a unique ability to build consensus amongst diverse groups of stakeholders. She has developed strong relationships with federal, state, and local agencies, businesses, and environmental and community groups, including the Environmental Protection Agency, California Air Resources Control Board, San Diego Gas & Electric Co., and the Environmental Health Coalition. She has also served as the Chair of the California Air Pollution Control Officers Association attorneys committee for three years and just recently spoke by invitation at the Environmental Law Conference in Yosemite. Her background combined with her commitment to pursuing forward-thinking, sustainable energy solutions make her make her uniquely qualified for this position.

Ms. Tyagi earned a Bachelor’s of Science in Environmental Science in Earth Systems from Queen’s University Kingston, Ontario, Canada, and Juris Doctorate, Cum Laude from the University of La Verne College of Law, Ontario, California.

Ms. Tyagi is a member of the State Bar of California.

ANALYSIS AND DISCUSSION
The proposed GC Employment Agreement was developed after evaluation of similar contracts and a review of compensation for municipal, CCA, and public power attorneys in the Southern California area and the state. Attached is the proposed employment agreement. Here are the key terms:

Base salary: $330,000/annually
Term: Effective February 1, 2024
Key Benefits: Retirement (employer contribution of approx. 10% annually) Vacation/Sick Time (160 hrs./year; 96 hrs./ea. banked)
Technology Allowance ($100/monthly)
Car allowance $500.00 / monthly
Health, dental, and other insurance/benefits provided to SDCP employees and their dependents
Severance: The contract includes the relatively standard severance benefit of an amount equal to six months base pay and
benefits, if terminated without cause.

FISCAL IMPACT
The cost of the contract $331,800 plus benefits. There is no impact to the current budget for Fiscal Year 23-24, as GC salary and benefits were anticipated to be incurred during this fiscal year.

ATTACHMENTS
Attachment A: Proposed General Counsel Employment Agreement 1 GENERAL COUNSEL EMPLOYMENT AGREEMENT
This GENERAL COUNSEL AGREEMENT ("Agreement") is made by and between SAN DIEGO COMMUNITY POWER, a California joint powers authority ("SDCP"), and VEERA TYAGI, an individual ("Executive") as of )HEUXDU\, 2023 (“Effective Date”).

RECITALS
A. Whereas, Section 5.5 of the San Diego Community Power Joint Powers Agreement, amended and restated on December 16, 2021 (“JPA”), requires the SDCP Board of Directors (“Board”) to appoint a General Counsel who shall be responsible for all legal matters of SDCP, and shall have other duties as may be assigned from time to time by the Chief Executive Officer.

B. Whereas, the Board desires to retain Executive to perform those duties and functions as may be specified by the JPA and to perform such other legally permissible and proper duties and functions as SDCP may from time-to-time assign; and
C. Whereas, Executive desires to accept employment by SDCP as its General Counsel.

NOW, THEREFORE, in consideration of the mutual covenants herein contained, the Parties agree as follows:

AGREEMENT
SECTION 1. DUTIES OF EXECUTIVE. Executive shall assume the powers of the General Counsel position and perform the functions and duties specified by SDCP’s Board and as provided by any such other resolutions of the Board, applicable laws, rules, regulations, orders, directives, policies, or procedures now in effect or hereafter adopted by SDCP. a. Legal Duties. The General Counsel is the responsible legal counsel for SDCP and shall act in that capacity to discharge, oversee, and coordinate SDCP’s legal activities and functions to ensure SDCP’ with and adherence to appliable law. More specific duties include, but are not limited to:
• Monitor and provide the requisite legal services and advice within SDCP and ensure that SDCP is fully represented in any judicial, administrative, regulatory, or similar action or proceedings;
• Assist SDCP to develop, maintain, or modify policies and procedures as to be in compliance with or in conformance with applicable law;
• Keep fully informed on all legislation and regulatory developments affecting SDCP’s operations and pertinent developments in corporate and regulatory legal matters, and where needed, inform, and advise affected SDCP management of changes in law that materially affect SDCP’s business or transactions.
2 b. Full Energy and Skill. Executive shall faithfully, diligently, and to the best of Executive's abilities, perform all duties that may be required under this Agreement. Executive agrees that Executive has a duty of loyalty and a general fiduciary duty to SDCP. Executive shall devote the whole of Executive's working time, skill, experience, knowledge, ability, labor, energy, attention, and best effort exclusively to SDCP's business and affairs. c. No Conflict. Executive shall not engage in any employment, activity, consulting service, or other enterprise, for compensation or otherwise, which is actually or potentially in conflict with, inimical to, or which interferes with the performance of Executive's duties. Nothing herein shall prevent Executive from participating in charitable, civic, educational, professional, or community affairs or from serving on the board of directors or advisory boards of private companies, subject to SDCP’s Board approval and provided such activities do not materially interfere with the performance of her duties hereunder or create a potential conflict with SDCP or the appearance thereof. If at any time service on any board of directors or advisory board would, in the good faith judgment of the Board, conflict with the Executive’s fiduciary duty to SDCP or create any appearance thereof, then Executive shall as soon as reasonably practicable considering any fiduciary duty to the other entity, resign from such other board of directors or advisory board after written notice of the conflict is receive from the Board. d. Hours of Work. Executive is an exempt employee but is expected to engage in those hours of work that are necessary to fulfill the obligations of the General Counsel position.

Executive does not have set hours of work as Executive is expected to be available at all times. It is recognized that Executive must devote a great deal of time to the business of SDCP outside of SDCP's customary office hours, and to that end Executive's schedule of work each day and week may vary in accordance with the work required to be performed and in accordance with any specific direction provided by the Board.

SECTION 2. EFFECTIVE PERIOD.

Executive is appointed as General Counsel beginning on the Effective Date through March 31, 2026, (the “Effective Period”) unless terminated earlier in accordance with Section 3, below. The Effective Period is not a term for employment and the end date set forth above does not create and is not intended to create a term for employment as that phrase is used and understood by California Labor Code section 2922.
a. At-Will Employment Status, Termination of Agreement.

The parties hereby expressly agree that the employment relationship created by the Agreement is “at will” and that Employee serves at the will and pleasure of SDCP. Nothing in this Agreement or any resolution, statute, ordinance, rule or policy shall prevent, limit or otherwise interfere with 3 the right of SDCP to terminate the services of Employee at any time without cause or right of notice, Skelly conference, hearing, appeal or grievance. Employee agrees that this Agreement sets forth the only terms and conditions applicable to the termination of Employee’s employment and that Employee hereby waives any rights Employee would otherwise have thereunder. At any time, and without prior notice, SDCP may terminate Employee’s employment for any reason, with or without cause. In the event SDCP exercises its right under this provision to terminate employment without cause, SDCP shall pay Employee all compensation due and owing through the last day actually worked. At any time, Employee may resign from employment for any reason, with or without cause, by providing the Board of Directors with fourteen (14) days’ advance written notice. The Board of Director shall have the option to make Employee’s termination effective at any time prior to the end of such notice period, provided that SDCP pays Employee all compensation due and owing through the last day actually worked.

No Property Interest. Executive understands and agrees that Executive has no constitutionally protected property or other interest in Executive's employment as General Counsel. Executive understands and agrees that Executive works at the will and pleasure of SDCP’s Board, and that Executive may be terminated, or asked to resign, at any time, with or without cause, by a majority vote of its members.

SECTION 3. TERMINATION.
a. By SDCP—Not “For Cause”.

At any time, SDCP may terminate Executive’s employment without Cause (as defined in Section 3(b) below) by providing Executive written notice of termination. In the event Executive is terminated without Cause, Executive shall be entitled to an amount equal to Executive’s base salary for six (6) months conditioned upon Executive execution of a settlement agreement (i) waiving any and all claims Executive may have against SDCP and/or its officers or directors; (ii) including a release of all known or unknown claims related to or arising out of Executive’s employment with SDCP, including the termination of said employment; (iii) a Civil Code section 1542 waiver; and (iv) any other provisions, clauses, terms and/or conditions, deemed appropriate by the Board at the time of the termination of Executive’s employment, under the facts and circumstances of such termination. In order for Executive to be eligible for the severance payment, the release agreement must be finalized no later than twenty-one (21) days after the effective date of Executive’s termination or the date upon which the release agreement is presented to Executive, whichever is later. Thereafter, all of SDCP’s obligations under this Agreement shall cease. SDCP may dismiss Executive as provided in this Section 3 notwithstanding anything to the contrary contained in or arising from any statements, policies, or practices of SDCP relating to the employment, discipline, or termination of its employees.

Notwithstanding any other provision herein, in accordance with Government Code section 53260, the cash payment that Executive may receive in the event of the termination of this Agreement, as set forth in this Section, shall not exceed an amount equal to the monthly base 4 salary of Executive multiplied by the number of months left on the unexpired term of this Agreement but in no event shall the amount exceed 18 months. b. By SDCP “For Cause”.

At any time, and without prior notice, SDCP may terminate Executive for Cause. SDCP shall pay Executive all compensation then due and owing; thereafter, all of SDCP’s obligations under this Agreement shall cease. Termination shall be "For Cause" if Executive: (i) acts in bad faith and to the detriment of SDCP; (ii) willfully and unequivocally refuses or fails to act in accordance with any specific direction or order of SDCP’s Board; (iii) exhibits in regard to his or her employment gross unfitness or chronic unavailability for service, unsatisfactory performance, misconduct, dishonesty, habitual neglect, or incompetence; (iv) is convicted of a crime involving dishonesty, breach of trust, or physical or emotional harm to any person resulting in incarceration; (v) commits or is accused of committing an act involving moral turpitude under federal, state, or local law (regardless of whether or not such act involving moral turpitude is a misdemeanor or felony); and/or (vi) breaches any material term of this Agreement. c. Statutory Requirements.

In compliance with Government Code section 53243, to the extent SDCP provides: (i) paid leave to Executive pending an investigation; (ii) funds for the legal criminal defense of the Executive; and/or (iii) a cash settlement to Executive related to the termination of Executive pursuant to Section 3(b) of this Agreement, Executive shall fully reimburse SDCP for any and all amounts paid by SDCP which fall within any such categories in the event that Executive is convicted of a crime involving the abuse of their office or position. d. By Executive.

In the event that Executive desires to terminate this Agreement during such time as SDCP desires for Executive to continue in the capacity of General Counsel, then Executive agrees to provide SDCP with at least forty-five (45) days’ written notice of said termination.

SECTION 4. COMPENSATION AND PERFORMANCE REVIEWS.
a. Executive shall receive the base annual salary of Three Hundred Thirty-Thousand Dollars and No Cents, ($330,000) payable on a pro-rata basis in accordance with SDCP’s payroll practices and less all applicable payroll taxes and withholdings. Executive may be eligible for an increase in salary on the anniversary of this Agreement, subject to approval by a majority of the members of the Board.
5 b. SDCP shall perform a performance review of Executive at least annually. The Board or a committee of the Board of Directors shall additionally review the base compensation, bonuses, and benefits provided to Executive under this Agreement and may, in their sole discretion, adjust the same.

SECTION 5. OTHER BENEFITS.

Executive shall be entitled to participate in SDCP’s benefits adopted by SDCP on the same basis as other executives of SDCP.

D Automobile. Executive shall receive a gross monthly vehicle allowance of Five Hundred Dollars and No Cents ($500.00) per month. The Parties intend for this taxable allowance to be in lieu of reimbursement on an itemized basis for mileage, gas, maintenance of a vehicle, etc.

Executive shall not be separately reimbursed for mileage incurred in connection with the execution of her duties.

E Technology Allowance. Executive shall receive either an SDCP-owned cell phone and (accompanying SDCP-paid plan) or a $100 monthly taxable technology allowance to use towards his or her personal discretionary technological purchases and expenses in furtherance of employment (e.g., cellular phone, tablet, data plan, laptop computer). The Parties intend this allowance to cover all technology-related costs that Executive incurs in the course and scope of his or her employment with SDCP.

F Other Benefits. Executive shall be entitled to participate in benefits, including health care coverage, retirement plans and/or 457(b) plans, and to receive sick leave, vacation accrual, and any and all other benefits to the same extent and as other executives of SDCP.

SECTION 6. INDEMNIFICATION.
6 SDCP shall indemnify and defend Executive in accordance with the California Government Claims Act. Unless otherwise specifically required by law, SDCP’s Board shall determine, in its sole discretion, whether to file an appeal if a final judgment is adverse to Executive or whether to compromise and settle any such claim or suit against Executive, as well as the amount of any settlement or judgment rendered thereon. SDCP shall also pay for the cost of any fidelity or other bonds required by law for the position of General Counsel.

SECTION 7. OTHER TERMS AND CONDITIONS OF EMPLOYMENT.

SDCP shall make any other terms and conditions of employment related to the performance of Executive, provided such terms and conditions are not inconsistent with the provisions of this Agreement or by law.

SECTION 8. NOTICES.

Notices given under this Agreement shall be in writing and shall be served personally or sent by Federal Express or some equivalent private overnight delivery service. Notices shall be deemed received at the earlier of actual receipt or two (2) days following transmission to an overnight carrier.

To SDCP: Attn: Chair of the Board of Directors
San Diego Community Power
655 W. Broadway, Suite 1500
San Diego, CA 92101
With a copy to:

B. Allison Borkenheim, Shareholder
Littler Mendelson, P.C.
501 W. Broadway, Suite 900
San Diego, CA 92101-3577
To Executive: Veera Tyagi
At the address on file with
SDCP’s Human Resources Department
SECTION 9. INTEGRATION.

This Agreement is intended to be the final, complete, and exclusive statement of the terms of Executive's employment by SDCP. This Agreement supersedes all other prior and contemporaneous agreements and statements, whether written or oral, express, or implied, pertaining in any manner to the employment of Executive, and it may not be contradicted by 7 evidence of any prior or contemporaneous statements or agreements. To the extent that the practices, policies, or procedures of SDCP, now or in the future, apply to Executive and are inconsistent with the terms of this Agreement, the provisions of this Agreement shall control.

SECTION 10. AMENDMENTS; WAIVERS.

This Agreement may not be amended except by an instrument in writing, signed by each of the Parties. No failure to exercise and no delay in exercising any right, remedy, or power under this Agreement shall operate as a waiver thereof, nor shall any single or partial exercise of any right, remedy, or power under this Agreement preclude any other or further exercise thereof, or the exercise of any other right, remedy, or power provided herein or by law or in equity.

SECTION 11. ASSIGNMENT; SUCCESSORS AND ASSIGNS.

Executive agrees that he or she will not assign, sell, transfer, delegate, or otherwise dispose of, whether voluntarily or involuntarily, or by operation of law, any rights, or obligations under this Agreement. Any such purported assignment, transfer, or delegation shall be null and void. Nothing in this Agreement shall prevent the consolidation of SDCP with, or its merger into, any other entity, or the sale by SDCP of all or substantially all of its assets, or the otherwise lawful assignment by SDCP of any rights or obligations under this Agreement. Subject to the foregoing, this Agreement shall be binding upon and shall inure to the benefit of the Parties and their respective heirs, legal representatives, successors, and permitted assigns, and shall not benefit any person or entity other than those specifically enumerated in this Agreement.

SECTION 12. SEVERABILITY.

If any provision of this Agreement, or its application to any person, place, or circumstance, is held by an arbitrator or a court of competent jurisdiction to be invalid, unenforceable, or void, such provision shall be enforced to the greatest extent permitted by law, and the remainder of this Agreement and such provision as applied to other persons, places, and circumstances shall remain in full force and effect.

SECTION 13. ATTORNEY’S FEES.

In any legal action, arbitration, or other proceeding brought to enforce or interpret the terms of this Agreement, the prevailing party shall be entitled to recover reasonable attorneys' fees and costs.
8 SECTION 14. GOVERNING LAW AND VENUE. This Agreement shall be governed by and construed in accordance with the laws of the State of California. The Parties agree that venue for any dispute shall be in San Diego County Superior Court.

SECTION 15. INTERPRETATION.

This Agreement shall be construed as a whole, according to its fair meaning, and not in favor of or against any party. By way of example and not in limitation, this Agreement shall not be construed in favor of the party receiving a benefit nor against the party responsible for any particular language in this Agreement. Captions are used for reference purposes only and should be ignored in the interpretation of the Agreement.

SECTION 16. REPRESENTATION BY COUNSEL.

The Parties acknowledge and agree that they were, or had the opportunity to be, represented individually by legal counsel with respect to the matters that are the subject of this Agreement and that they are fully advised with respect to their respective rights and obligations resulting from signing this Agreement.

SECTION 17. COUNTERPARTS AND ELECTRONIC SIGNATURES.

This Agreement may be executed in triplicate counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument. The Parties agree that this Agreement may be executed and delivered by electronic signatures and that the signatures appearing on this Agreement are the same as handwritten signatures for the purposes of validity, enforceability, and admissibility.

SIGNATURES ON FOLLOWING PAGE
9 IN WITNESS WHEREOF, SDCP and Executive have executed this Agreement on the date written below:

SAN DIEGO COMMUNITY POWER EXECUTIVE
By: _______________________________ By:______________________________ Joe LaCava Veera Tyagi
Chair, SDCP Board of Directors
APPROVED AS TO FORM:

By: _______________________________
B. Allison Borkenheim
Littler Mendelson, P.C.

SAN DIEGO COMMUNITY POWER
Staff Report – Item
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Eric W. Washington, Chief Financial Officer
Via: Karin Burns, Chief Executive Officer
Subject: Review of Treasurer’s Report for Period Ending 10/31/23 Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Receive and File Treasurer’s Report for Period Ending 10/31/23.

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 October 31, 2023, along with budgetary comparisons.

SDCP additionally reports monthly metrics during its Board meetings as part of its Update on Back-Office Operations. As part of the Treasurer’s Report, certain key metrics related to risk are to be presented during Financial and Risk Management Committee (FRMC) and Board of Director (Board) meetings.

ANALYSIS AND DISCUSSION
Actual financial results for the period ended 10/31/23: $657.18 million in net operating revenues were reported compared to $686.20 million budgeted for the period. $424.23 million in total expenses were reported (including $414.18 million in energy costs) compared to $393.44 million budgeted for the period (including $374.25 million budgeted for energy costs). After expenses, SDCP’s change in net position of $232.95 million was reported for Fiscal Year 2023-24. The following is a summary of the actual results compared to the Fiscal Year 2023-24 Budget.

Table 1: Budget Comparison Versus Actual Results
• Net operating revenues finished $29.02 million (or 4.0 percentage points) under the budget primarily due to lower-than-expected remittances given less demand year-to date attributed to lower customer load than expected related to mild weather during the summer period.
• Operating expenses finished $30.79 million (or 8.0 percentage points) over the budget primarily due to a larger-than expected energy expense recognized in October 2023 related to the SDCP Voluntary Allocation and Market Offer (VAMO) contract, and higher-than-expected energy costs related to resource adequacy and renewables.

As a result of lower customer demand and increasing energy costs, SDCP’s change in net position was 21% under the projection.

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

Table 2: Proforma Comparison Versus Actual Results
Budget Comparison
YTD FY24 as of
10/31/23 (4 mos) FY24 YTD Budget Budget Variance ($) Budget (%) Net Operating Revenues 657,179,799 $ 686,198,508 $ (29,018,709) $ 96% Total Expenses 424,234,991 $ 393,440,537 $ 30,794,454 $ 108% Change in Net Position 232,944,808 $ 292,757,971 $ (59,813,163) $ -20% Proforma Comparison
YTD FY24 as of
10/31/23 (4 mos)
FY24 YTD
ProForma
ProForma
Variance ($)
Proforma
(%)
Net Operating Revenues 657,179,799 $ 686,198,508 $ (29,018,709) $ -4% Total Expenses 424,234,991 $ 393,115,212 $ 31,119,779 $ 8% Change in Net Position 232,944,808 $ 293,083,296 $ (60,138,488) $ -21% Figure 1: Proforma versus Actual Results
For the period ending 10/31/23, SDCP contributed $232,944,808 to its reserves but was expected to gain $292,757,971 per the FY 2023-24 adopted budget. Total SDCP reserves at the end of the period were $416,426,199 and total available liquidity (including lines of credit) was $520,696,199. SDCP has a total FY 2023-24 year-end reserve target of $491,079,452, which is equivalent to 180-days of total operating expenses as set in SDCP’s Reserve Policy and Strategic Goals.

Figure 2: Participation Rates
Phase 4 mass enrollment process in National City and Unincorporated County of San Diego for Non-Net Energy Metering (NEM) customers is officially completed as of May, 2023. The participation rate for this new phase is fluid and will change as we continue with our enrollment of Net Energy Metering (NEM) customers from April 2023 through March 2024. In the interim, we are reporting on the opt outs and eligible accounts associated with the phase based on those accounts that we have noticed for enrollment on a rolling basis as of the reporting month.

Staff are also presenting State of SDCP Arrearages directly related to financial risk for FRMC and Board consideration and for regular review. Additional metrics can be added by request. The below arrearage data includes SDCP’s Receivables aged 120+ Days as of 12/01/2023.

Figure 3: State of SDCP Arrearages
Figure 4: State of SDCP Arrearages Residential vs Commercial

COMMITTEE REVIEW
N/A

FISCAL IMPACT
N/A

ATTACHMENTS
Attachment A: 2023 Year-to-Date Period Ended 10/31/23 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 October 31, 2023, 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
December 4, 2023
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com Current assets
Cash and cash equivalents - unrestricted 327,946,343 $
Cash and cash equivalents - restricted 500,000
Accounts receivable, net of allowance 153,806,030
Accrued revenue 88,904,888
Prepaid expenses 3,962,988
Other receivables 115,325
Deposits 32,493,075
Total current assets 607,728,649
Noncurrent assets
Lease asset, net of amortization 748,503
Capital assets, net of depreciation 147,317
Cash and cash equivalents - restricted 1,897,888
Total noncurrent assets 2,793,708
Total assets 610,522,357
Current liabilities
Accrued cost of electricity 173,333,093
Accounts payable 708,760
Other accrued liabilities 4,681,415
State surcharges payable 216,052
Deposits - energy suppliers 2,385,000
Interest payable 124,130
Lease liability 371,849
Total current liabilities 181,820,299
Noncurrent liabilities
Bank note payable 8,730,000
Supplier security deposits 624,000
Lease liability 395,383
Total noncurrent liabilities 9,749,383
Total liabilities 191,569,682
Net investment in capital assets 128,588
Restricted for collateral 2,397,888
Unrestricted 416,426,199
Total net position 418,952,675 $

NET POSITION

SAN DIEGO COMMUNITY POWER

STATEMENT OF NET POSITION
As of October 31, 2023
ASSETS

LIABILITIES
See accountants' compilation report. 2

OPERATING REVENUES
Electricity sales, net 656,548,799 $
Grant revenue 631,000
Total operating revenues 657,179,799

OPERATING EXPENSES
Cost of electricity 414,179,629
Contract services 6,293,979
Staff compensation 3,082,816
Other operating expenses 1,205,462
Depreciation and amortization 136,514
Total operating expenses 424,898,400
Operating income 232,281,399

NON-OPERATING REVENUES (EXPENSES)
Interest income 1,439,063
Interest and financing expense (780,118)
Nonoperating revenues (expenses), net 658,945
CHANGE IN NET POSITION 232,940,344
Net position at beginning of year 186,012,331
Net position at end of year $ 418,952,675

SAN DIEGO COMMUNITY POWER

STATEMENT OF REVENUES, EXPENSES

AND CHANGES IN NET POSITION
Four Months Ended October 31, 2023
See accountants' compilation report. 3

CASH FLOWS FROM OPERATING ACTIVITIES
Receipts from customers 604,017,504 $
Receipts of supplier security deposits 20,902,875
Other operating receipts 3,535,951
Payments to suppliers for electricity (325,715,382)
Payments for goods and services (6,467,670)
Payments of staff compensation and benefits (3,036,469) Payments for deposits and collateral (2,605,000)
Payments of state surcharges (1,157,645)
Net cash provided by operating activities 289,474,164

CASH FLOWS FROM NON-CAPITAL FINANCING ACTIVITIES
Principal payments - bank note (27,000,000)
Interest and related expense payments (1,198,394)
Net cash provided (used) by non-capital
financing activities (28,198,394)

CASH FLOWS FROM CAPITAL AND RELATED

FINANCING ACTIVITIES
Payments of lease liability (129,932)
Payments to acquire capital assets (71,550)
Net cash (used) by capital and related financing activities (201,482)

CASH FLOWS FROM INVESTING ACTIVITIES
Interest income received 1,439,063
Net change in cash and cash equivalents 262,513,351
Cash and cash equivalents at beginning of year 67,830,880 Cash and cash equivalents at end of year 330,344,231 $
Reconciliation to the Statement of Net Position
Cash and cash equivalents (unrestricted) 327,946,343 $
Restricted cash - current 500,000
Restricted cash - noncurrent 1,897,888
Cash and cash equivalents 330,344,231 $

SAN DIEGO COMMUNITY POWER

STATEMENT OF CASH FLOWS
Four Months Ended October 31, 2023
See accountants' compilation report. 4
Operating income 232,281,399 $
Adjustments to reconcile operating income to net
cash provided by operating activities
Depreciation and amortization expense 136,514
(Increase) decrease in:

Accounts receivable, net (43,292,299)
Accrued revenue (10,112,104)
Prepaid expenses 26,564,510
Other receivables 118,390
Deposits (14,836,725)
Increase (decrease) in:

Accrued cost of electricity 95,987,751
Accounts payable 269,497
Other accrued liabilities 886,768
State surcharges payable (284,537)
Supplier security deposits 1,755,000
Net cash provided by operating activities 289,474,164 $

SAN DIEGO COMMUNITY POWER
STATEMENT OF CASH FLOWS (continued)
Four Months Ended October 31, 2023

RECONCILIATION OF OPERATING INCOME TO NET

CASH PROVIDED 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 operating fund budgetary comparison schedule of San Diego Community Power (SDCP), a California Joint Powers Authority, for the period ended October 31, 2023, 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
December 4, 2023
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com 2023/24 YTD
Budget
2023/24 YTD
Actual
2023/24 YTD
Budget
Variance
(Under) Over
2023/24
YTD
Actual/
Budget %
2023/24 Annual
Budget
2023/24 Budget
Remaining
REVENUES AND OTHER SOURCES Gross Ratepayer Revenues 714,790,112 683,904,999 $ (30,885,113) 96% 1,346,325,552 $ 662,420,553 $ Less Uncollectible Customer Accounts (28,591,604) (27,356,200) 1,235,404 96% (53,853,022) (26,496,822) Grant revenue - 631,000 631,000 - (631,000)
Total Revenues and Other Sources 686,198,508 657,179,799 (29,018,709) 1,292,472,530 635,292,731 OPERATING EXPENSES Cost of Energy 374,248,739 414,179,629 39,930,890 111% 948,529,425 534,349,796 Professional Services and Consultants 8,366,108 6,000,904 (2,365,204) 72% 22,939,626 16,938,722 Personnel Costs 4,469,305 3,082,816 (1,386,489) 69% 13,178,031 10,095,215 Marketing and Outreach 1,085,684 835,812 (249,872) 77% 2,973,829 2,138,017 General and Administration 3,076,593 707,415 (2,369,178) 23% 7,861,973 7,154,558 Programs 101,583 100,000 (1,583) 98% 278,250 178,250
Total Operating Expenses 391,348,012 424,906,576 33,558,564 995,761,134 570,854,558 Operating Income (Loss) 294,850,496 232,273,223 (62,577,273) 296,711,396 64,438,173 NON-OPERATING REVENUES (EXPENSES) Investment income - 1,439,063 1,439,063 - (1,439,063) Interest and related expenses (812,525) (767,478) 45,047 94% (2,437,574) (1,670,096) Transfer to Capital Investment Program (1,280,000) - 1,280,000 0% (3,840,002) (3,840,002) Total Non-Operating Revenues (Expenses) (2,092,525) 671,585 2,764,110 (6,277,576) (6,949,161) NET INCREASE (DECREASE) 292,757,971 $ 232,944,808 $ (59,813,163) $ 290,433,820 $ 57,489,012 $

SAN DIEGO COMMUNITY POWER

BUDGETARY COMPARISON SCHEDULE
Four Months Ended October 31, 2023

OPERATING FUND
See accountants' compilation report.

SAN DIEGO COMMUNITY POWER
Staff Report – Item 10
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From: Jen Lebron, Director of Public Affairs
Via: Karin Burns, Chief Executive Officer
Subject: Approve San Diego Community Power’s Conflict of Interest Policy Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Approve San Diego Community Power’s Conflict of Interest Policy.

BACKGROUND
In the pursuit of fostering good governance, transparency, and fairness, San Diego Community Power (SDCP) seeks to implement a Conflict of Interest and Ethical Conduct Policy. This policy is designed to consolidate and articulate a code of ethics and acceptable conduct applicable to all SDCP Board of Directors members, Community Advisory Committee (CAC) members, and employees. The primary goals are to emphasize the public trust bestowed upon each individual, the necessary adherence to the highest moral and ethical standards, and the provision of efficient, high-quality services to the community in a fair and impartial manner.

This policy expands on existing Federal and State regulations.

ANALYSIS AND DISCUSSION
Policy Overview
The Conflict of Interest and Ethical Conduct Policy serves to summarize a code of ethics and standards that are applicable to all those who serve SDCP – the elected officials on the Board of Directors, the residents who are appointed to the CAC, and SDCP employees. The policy outlines the responsibilities of all who serve SDCP in accordance with the following sections.

Responsibility of Public Services:

All SDCP directors, committee members, and employees are obligated to uphold the Constitution of the United States and the Constitution of the State of California. Their conduct, both official and private, must align with the highest standards of integrity, prioritizing the well-being and welfare of the general public.

General Rules Regarding Conflict of Interest:

Directors, committee members, and employees are prohibited from engaging in any business or transaction that may conflict with their official duties or compromise their independence, judgment, or action. This prohibition aligns with the California Government Code, regulations of the Fair Political Practices Commission, and common law conflicts of interest under California law.

Acceptance of Favors, Gifts, and Gratuities:

The policy establishes the guidelines for accepting gifts, ensuring that such actions do not compromise the impartiality of directors, committee members, and employees.

Notably, gifts received in violation of this policy should be returned or donated to a public charity.

Collateral or Outside Employment by Employees:

Employees engaged in outside business activities are required to provide notice and obtain departmental approval to ensure compatibility with SDCP duties.

Use of SDCP Position or Resources for Personal or Outside Gain:

Directors, committee members, and employees are prohibited from using SDCP time, facilities, equipment, or supplies for private or outside gain. They shall not review or approve, or influence or attempt to influence in any manner, an SDCP contract, grant, or decision relating to their work done as a private individual, self-employed consultant or by their collateral employer, regardless of whether the work or proposal submitted was done by the Director, Committee Member, or Employee or other staff of their collateral employer or other financial interest.

Use of Confidential Information:

Directors, committee members, and employees are prohibited from using or disclosing confidential information acquired in the course of their position for personal gain.

Compliance with disclosure requirements and cooperation with investigations is mandated.

Responsibility and Penalties:

The policy establishes the responsibilities and penalties for SDCP directors, committee members, and employees. Violations may lead to censure, removal or other appropriate action by the Board of Directors or Chief Executive Office.

In summary, the Conflict of Interest and Ethical Conduct Policy is essential for upholding the values of good governance, transparency, and fairness within SDCP. The Advisory Committee is urged to recommend the approval of this policy to reinforce the commitment to ethical conduct and the highest standards of service to the community.

AD-HOC COMMITTEE AND/OR SUBCOMITTEE REVIEW
The Community Advisory Committee voted unanimously to recommend that the Board of Directors adopt the policy on December 7, 2023.

FISCAL IMPACT
N/A

ATTACHMENTS
Attachment A: Conflict of Interest Policy

CONFLICT OF INTEREST AND ETHICAL CONDUCT POLICY
Effective Date: ___________, 2023

PURPOSE
The purpose of this Conflict of Interest and Ethical Conduct Policy (“Policy”) is to:
ƒ Summarize in a single document a code of ethics and acceptable conduct which will apply equally to all SDCP Directors, Committee Members, and Employees, regardless of individual position or employment duties and responsibilities; ƒ Emphasize that each Director, Committee Member, and Employee occupies a position of public trust which demands the highest moral and ethical standard of conduct; and
ƒ Ensure that members of the public are provided with efficient, productive, and high-quality services in a courteous impartial manner. Such services should be equally available, with no special advantage given any member of the public beyond that available to all others.

Policies and regulations governing the conduct of SDCP Directors, Committee Members, and Employees appear in the California Government Code, regulations of the Fair Political Practices Commission, other SDCP policies, and the SDCP Employee Handbook, Committee Members, and Employees shall familiarize themselves with the pertinent sections of these documents and consult them as necessary for information and guidance. This Policy is not intended to supersede State law. If there is a conflict between the provisions of this Policy and controlling State law, Directors, Committee Members, and Employees must comply with the more stringent policy or law.

This Policy applies to SDCP Directors, Committee Members, and Employees, as defined below.

POLICY
Definitions

1. Director means a member of the SDCP Board of Directors.

2. Committee Member means a member of the Community Advisory Committee or member of any other committee, board, or commission appointed by the SDCP Board of Directors.

3. Employee means any employee of SDCP, whether exempt or non-exempt, full-time or part-time.

4. Gift, Gratuity, Favor, or Entertainment means any payment, loan, opportunity, service, accommodation, use of facility or any other benefit provided to a Director, Committee Member, or Employee that confers a personal benefit for which the Director, Committee Member, or Employee does not provide compensation or other consideration, of equal or greater value.

5. Immediate Family means a spouse or registered domestic partner, son, daughter (son and daughter include: step, foster or adopted), mother, father (mother and father include: step-father, step-mother, father-in-law, mother-in-law), brother, sister (brother and sister include: step, foster or adopted), aunt, uncle, niece, nephew, grandfather, grandmother, granddaughter and grandson.

6. Nominal Value means a monetary value of $50 or less.

Responsibility of Ethical Conduct

1. It is the responsibility of all Directors, Committee Members, and Employees to engage in ethical behavior and practices.

2. Every Director, Committee Member, and Employee is responsible for both the actual and perceived conflict of interest that may arise as a result of the Director’s, Committee Member’s, or Employee’s actions and it is the Director’s, Committee Member’s, or Employee’s responsibility to reduce or eliminate to the extent possible such actual and perceived conflicts of interest.

Responsibility of Public Services

1. All Directors, Committee Members, and Employees are bound to uphold the Constitution of the United States and the Constitution of the State of California, and to abide by the laws and regulations of the nation, State, and SDCP.

2. All Directors, Committee Members, and Employees are bound to observe in their official acts, the highest standards of integrity and to discharge faithfully the duties of their position, recognizing that the lives, safety, health and welfare of the general public must be their primary concern. Their conduct in both their official and private affairs should be above reproach to assure that their public position is not used nor perceived as being used for personal gain.

3. The conduct of all Directors, Committee Members, and Employees shall be such as to provide the best public service to each member of the public and the community as a whole. The conduct of all Directors, Committee Members, and Employees shall be consistent with the goals and values of SDCP.

General Rule Regarding Conflict of Interest
Directors, Committee Members, and Employees shall not engage in any business or transaction, and shall not have a financial or other personal interest, direct or indirect, which is incompatible with the proper discharge of their official duties or would tend to impair their independence, judgment, or action in the performance of such duties. This prohibition shall be interpreted in a manner consistent with the requirements of the California Government Code, regulations of the Fair Political Practices Commission, and common law conflicts of interest under California law.

Acceptance of Favors, Gifts, and Gratuities

1. All Directors, Committee Members, and Employees should be mindful as to not accept a Gift, Gratuity, Favor, or Entertainment from any person or business entity other than SDCP, which would create an appearance of influencing him or her in the discharge of his or her duties.

2. The following are not considered a Gift, Gratuity, Favor, or Entertainment solely for purposes of this Policy:
a. Personalized plaques, trophies, souvenirs or mementos of Nominal Value associated with a given event or given to an employee from a professional organization where the person holds or held a position in the organization; b. Edible or perishable items provided to an SDCP
department/division/program;
c. Discounts, rebates or concessions available to the public in general or to all SDCP employees;
d. Passes and tickets that provide admission to facilities, goods, services, or other benefits that are not used by the employee and are not given by the employee to another person;
e. Passes and tickets to attend fundraisers for campaign committees or other candidates or organizations exempt from taxation under section 501(c)(3) of the Internal Revenue Code;
f. Free admission and refreshments provided an employee at an event in which he/she gives a speech, participates in a panel or seminar or other similar service, as well as, travel payments (transportation, lodging (the day immediately preceding, day of, and day immediately following speech panel, seminar or similar service)) associated with such an event; and g. Passes, tickets or other items or activities provided to SDCP and used by SDCP for agency business and reported by SDCP on FPPC Forms 801 or 802.

3. A Gift, Gratuity, Favor, or Entertainment, the receipt of which is prohibited by this section, shall be returned to the donor when feasible. If no return is feasible, the gift or gratuity shall be donated to a public charity (non-profit, tax exempt 501(c)(3) organization), SDCP, or other governmental agency within 30 days of receipt.

4. If there is a conflict between the Gift, Gratuity, Favor, or Entertainment provisions of this Policy and those in controlling State law, Directors, Committee Members, and Employees subject to State law must comply with those rules.

5. Nothing in this Policy shall exempt any Director, Committee Member, or Employee from complying with applicable provisions of State law or other SDCP policies including, but not limited to, responsibility for completion and filing of a Statement of Economic Interests (Form 700).

6. In questionable situations, Directors should seek guidance from the General Counsel. Committee Members should seek guidance from the committee’s staff liaison, who will coordinate with the General Counsel. Employees should seek guidance from their supervisor or the Human Resources Department. In the instance where the supervisor or Human Resources Department is uncertain, the General Counsel may be contacted as well.

Collateral or Outside Employment by Employees

1. Notification and Departmental Approval
a. Employees who are engaged in any collateral or outside business activity or employment shall provide written notice to their Department Director or other appropriate appointing authority. Such notice may be in the form contained in Attachment 1 below, or in a separate writing containing the same information. Persons contemplating such business activity or employment shall obtain departmental approval before accepting such employment.

2. General Prohibition
a. Employees shall not engage in any collateral employment or business activity which is incompatible or in conflict with the duties, functions, or responsibilities of SDCP, their department, or their employment decision. b. Activities which may constitute a conflict include: use of SDCP time, facilities, equipment and supplies, or the use of a badge, uniform, prestige or influence of SDCP or employment for private gain or advantage. An Employee shall not engage in any collateral business activity or employment, which, by its nature, hours or physical demands, would impair the required quality or quantity of the Employee’s work with SDCP, impair the Employee’s independence of judgment or action in the performance of official duties, reduce the effectiveness or efficiency of the Employee’s department, reflect discredit on SDCP, or tend to increase the SDCP’s payments for sick leave, worker’s compensation benefits, long term disability, or other leave benefits.

Use of SDCP Position or Resources for Personal or Outside Gain

1. Directors, Committee Members, and Employees shall not use, for private gain or advantage, their SDCP time or SDCP’s facilities, equipment or supplies.

2. Directors, Committee Members, and Employees shall not use or attempt to use their positions to secure unwarranted privileges or exemptions for themselves or others.

3. Directors, Committee Members, and Employees shall not use their position, title or status to influence, or attempt to influence, SDCP’s review or approval of an SDCP contract, grant, or other decision for the Director, Committee Member, or Employee in his or her capacity as a private individual, self-employed cpoonsultant or to facilitate work, grant funds, or other benefits for a collateral employer or other financial interest.

4. Directors, Committee Members, and Employees shall not review or approve, or influence or attempt to influence in any manner, an SDCP contract, grant, or decision relating to their work done as a private individual, self-employed consultant or by their collateral employer, regardless of whether the work or proposal submitted was done by the Director, Committee Member, or Employee or other staff of their collateral employer or other financial interest.

5. Employees in supervisory positions shall not assign to a subordinate any work (1) resulting from the supervisor’s collateral employment or other financial interest; or (2) requiring SDCP’s review or approval or other SDCP-provided service.

Use of Confidential Information

1. Directors, Committee Members, and Employees shall not use confidential information acquired by, or available to, them in the course of their position or employment with SDCP for speculation or personal gain.

2. Directors, Committee Members, and Employees shall not disclose confidential information, which may include, but not be limited to, confidential market-sensitive energy information, personnel information, or customer information, acquired by or available to them in the course of their position or employment with SDCP except in the performance of their duties as required by law.

SDCP Contracts
Directors, Committee Members, and Employees shall not be financially interested in any contract made by them in their official capacity, or by any body or board of which they are members. This includes, but is not limited to, Directors, Committee Members, and Employees exercising or attempting to exercise any discretionary powers or participating in any way with respect to any contract or sale to which SDCP or any department thereof is a party and in which such Directors, Committee Members, and Employees are knowingly directly or indirectly financially interested.

Personal Investments
Directors, Committee Members, and Employees shall endeavor not to make personal investments in enterprises which they have reason to believe may be involved in decisions or recommendations to be made by them, or under their supervision, or which will otherwise create conflict between their private interests and the public interest. If, however, a Director, Committee Member, or Employee has a financial interest in matters or enterprises coming before them, or before the department in which they are employed, they shall disqualify themselves from any participation therein.

Discussion of Future Employment
Directors, Committee Members, and Employees shall not make, participate in making, or use their official position to influence any SDCP decision related to a prospective employer.

Communication Limitations with Former Employees
Employees shall not communicate with former SDCP Employees regarding any project, issue or matter in which that former Employee rendered a decision or gave approval or disapproval, made recommendations, gave advice, or had any other substantial involvement or participation for a period of one year from the former Employee’s final date of active employment.

Equal Employment
Directors, Committee Members, and Employees shall not, in the performance of their service responsibilities, discriminate against any person on the basis of race, religion, color, creed, age, marital status, national origin or ancestry, pregnancy, sex, sexual orientation, gender identity, gender expression, physical or mental disability, veteran status, genetic information, medical condition, and any other category protected by federal, state, or local laws, and they shall cooperate in achieving the equal employment opportunity and affirmative action goals and objectives of the SDCP.

Reporting of Fraud, Waste or Abuse

1. Directors, Committee Members, and Employees are strongly encouraged to disclose, to the extent not expressly prohibited by law, improper governmental activities within their knowledge. Directors, Committee Members, and departmental managers are encouraged to contact the Chief Executive Officer or, if appropriate, the General Counsel. Employees are encouraged to contact a departmental manager or Human Resources Department to report this information.

2. No Director, Committee Member, or Employee shall directly or indirectly use or attempt to use their authority or influence for the purpose of intimidating, threatening, coercing, commanding, or influencing any other Director, Committee Member, or Employee with the intent of interfering with that Director, Committee Member, or Employee’s duty to disclose such improper activity.

Favoritism / Nepotism

1. Directors, Committee Members, and supervisory or management Employees shall not participate in the appointment or recommend the appointment of any member of their Immediate Family, or any other person with whom the Director or Employee has a close personal or private business relationship, to a position of any department, office, bureau or division over which they have administrative control.

2. Directors, Committee Members, and supervisory or management Employees shall not participate in the appointment or recommend the appointment of a member of their Immediate Family, or any other person with whom the Director, Committee Member, or Employee has a close personal or business relationship, to another supervisory or management position of SDCP.

3. This Policy permits Immediate Family members and close personal friends of Directors, Committee Members, or supervisory or management Employees to be appointed as Employees in any department provided such Directors, Committee Members, and supervisory or management Employees make no recommendation nor otherwise attempt no recommendation nor otherwise attempt to influence such appointments.

4. No supervisory or management Employee shall:
a. directly supervise any Immediate Family member or person with whom the supervisor has a close personal relationship;
b. influence the approval of any Employee rewards for any Immediate Family member or person with whom the supervisor has a close personal or business relationship;
c. interfere with any performance evaluation or disciplinary proceeding for any Immediate Family member or person with whom the supervisor has a close personal or business relationship; or
d. recommend or attempt to influence any contractor or business which has a business relationship with SDCP to employ a member of his or her Immediate Family or any other person with whom the Employee has a close personal or business relationship.

Product Endorsement

1. Directors, Committee Members, and Employees, in their capacity as SDCP Directors, Committee Members, and Employees, shall not endorse a product or service or comment on that product or service if it is the intent of the solicitor of the endorsement, or of the vendor or manufacturer of that product or service, to use such comments for purposes of advertisement.

2. Directors, Committee Members, and Employees are not prohibited from responding to inquiries regarding the effectiveness of products or services used by SDCP unless the Director, Committee Member, or Employee is aware that it is the inquirer’s intention to use those comments for purpose of advertisement.

Solicitation of Campaign Contributions from Employees
Directors, Committee Members, and Employees shall not, directly or indirectly, solicit a political contribution from an Employee of SDCP, with knowledge that the person from whom the contribution is solicited is an Employee of SDCP. This provision shall not prohibit a Director, Committee Member, or Employee from requesting political contributions from Employees if the solicitation is part of a solicitation made to a significant segment of the public which may include Employees of SDCP. This provision shall not prohibit a Director, Committee Member, or Employee from making a contribution.

Duty to Disclose
Employees shall immediately disclose the nature and extent of any interest, direct or indirect, which may conflict with their responsibility or duty, or which, because of their position, may influence a decision to the benefit of the organization in which they have an interest. Such disclosure shall be in the form of a memorandum to the Chief Executive Officer, transmitted via the employee’s department head.

Duty to Cooperate
Employees shall cooperate fully with judicial bodies and courts, and with lawfully constituted investigative commissions, committees, bodies and juries; appear before them upon request; and answer all questions concerning their conduct in office or their performance of official duties or matters within their knowledge pertaining to the property, government or affairs of SDCP. Failure to do so shall be cause for appropriate disciplinary action, including possible dismissal from SDCP service.

RESPONSIBILITY AND PENALTIES
All SDCP Directors

1. Responsible for understanding and complying with this Policy at all times.

2. Any member of the Board of Directors found to be in violation of this Policy or who is found guilty or liable by any court of law, enforcement agency, administrative hearing officer, or public agency investigation, of violating California Government Code section 1090, the California Political Reform Act, or the regulations of the Fair Political Practices Commission, in relation to their service to SDCP, may be subject to censure by the Board of Directors, as well as removal from SDCP committees.

All SDCP Committee Members

1. Responsible for understanding and complying with this Policy at all times.

2. Any Committee Member found to be in violation of this Policy or who is found guilty or liable by any court of law, enforcement agency, administrative hearing officer, or public agency investigation, of violating California Government Code section 1090, the California Political Reform Act, or the regulations of the Fair Political Practices Commission, in relation to their service to SDCP, may be subject to censure, removal or other action deemed appropriate by the Board of Directors.

3. All SDCP Employees

1. Responsible for understanding and complying with this Policy at all times.

2. Employees engaging in outside employment or enterprise will provide written notice as required above and keep it up to date at all times. Such notice may be in the form contained in Attachment 1 below, or in a separate writing containing the same information. To the extent there is a change in the Employee’s outside employment or enterprise, the Employee will immediately update the notice and resubmit it to their department.

3. With regard to any Employee found to be in violation of this Policy or who is found guilty or liable by any court of law, enforcement agency, administrative hearing officer, or public agency investigation, of violating California Government Code section 1090, the California Political Reform Act, or the regulations of the Fair Political Practices Commission, in relation to their service to SDCP, such Employee may be subject to appropriate disciplinary action by the Chief Executive Officer or by an authorized designee; such disciplinary action may include, but not be limited to, termination of employment.

Supervisory or Management Employees

1. Monitor to ensure Employees’ compliance with this Policy.

2. Take immediate administrative action when made aware of a potential violation of this Policy.

Human Resources Department
Assist with addressing questions raised by departments and working closely with General Counsel to provide guidance in accordance with this Policy.

SAN DIEGO COMMUNITY POWER
Staff Report – Item 11
-------------------------------------------------------------------------------------------------------------------- To: San Diego Community Power Board of Directors
From͗ Colin Santulli, Director of Programs
Sheena Tran, Senior Program Manager
Via: Karin Burns, Chief Executive Officer
Subject: Request Approval of Regional Energy Network (REN) Application to California Public Utilities Commission (CPUC)
Date: December 14, 2023
--------------------------------------------------------------------------------------------------------------------

RECOMMENDATION
Approve the Regional Energy Network (REN) Application to the California Public Utilities Commission (CPUC).

BACKGROUND
One of the Programs Team’s FY 2023-24 annual priorities is to lead initial steps in a regional effort to develop a REN in San Diego. The approval of a REN in San Diego by the CPUC would allow access to funds to administer and implement energy efficiency (EE) programs focused on underserved and hard-to-reach residents, businesses, and public agencies in the region. Additionally, this effort achieves several intended goals for establishing SDCP, as stated in the Joint Powers Agreement (JPA), including ‘[pursuing] purposeful and focused investment in communities of concern, … workforce development, and policies and programs centered on economic, environmental, and social equity.’
The energy efficiency programs offered by the RENs vary and are designed to meet the needs of its region while filling gaps and focusing on hard-to-reach customers. REN programs are intended to be complementary to IOU administered programs (regional and statewide) and coordination is required among Program Administrators to avoid customer confusion. San Diego Gas & Electric currently offers a robust EE program portfolio, with a 4-year ~$330M EE portfolio approved by the CPUC in June 2023.

SDCP Staff presented and introduced the topic of a REN in San Diego at the May 26, 2022 Board of Directors meeting as an option to access CPUC funding for customer energy programs. SDCP Staff presented and identified forming a REN as one of the FY 22-23 Programs Department priorities during the New Board of Directors Orientation meeting on January 18, 2023. SDCP Staff presented an update on the progress of the Ϯ
REN formation at the February 2023 meetings of the Community Advisory Committee (CAC) and the Board of Directors. Finally, in October 2023, SDCP Staff presented a progress update to include a description of each of the draft programs, the governance structure and the draft budget to the Board of Directors.

ANALYSIS AND DISCUSSION
CPUC Application
The application submitted to the CPUC is primarily made up of two sections: Exhibit 1, the Strategic Business Plan, and Exhibit 2, the Portfolio Plan. Additional supporting information will be included with the final application such as the Statement of Qualifications, the Letter of Commitment to Cooperate Between SDCP, the County Of San Diego, and San Diego Gas & Electric (Attachment A) and letters of support (Attachment B).

Exhibit 1, the Strategic Business Plan, (Attachment C) is a comprehensive descriptive narrative for the proposed San Diego REN or SDREN. Core values, guiding principles, and desired outcomes are included. The Strategic Business Plan also includes a description of the proposed SDREN governance structure, collaborative framework and stakeholder engagement conducted. This Exhibit also includes the proposed approach to portfolio segmentation (i.e., Equity vs Market Support vs Resource Acquisition vs Codes & Standards (C&S) segments) and sectors the REN will target (i.e., Residential, Commercial, Public, Workforce, Education & Training (WE&T), and C&S). Lastly, the Strategic Business Plan includes a summary of annual portfolio budgets as well as a distribution of budgets across sectors and segments. The Strategic Business Plan includes additional pertinent information relating to the formation of SDREN, which can be found in Attachment A.

The largest section of the application is Exhibit 2, the Portfolio Plan, (Attachment D). The Portfolio Plan provides an in-depth review of the portfolio via each segment and sector of the proposed SDREN. The segmentation strategy provides a rationale for the 4-yr budget distribution, goals, desired outcomes, metrics and coordination tactics for each segment and its programs. The sector strategy provides a market characterization, goals, metrics, implementation strategies and coordination tactics for programs in each sector. The Portfolio Plan also includes detailed “program cards” that summarize detailed information and justification on each of the proposed ten SDREN programs. Additionally, the Portfolio Plan outlines expected portfolio-level cost effectiveness as well as proposed portfolio management strategies (i.e., procurement/contract management, risk distribution, continued stakeholder engagement, and portfolio coordination). Lastly, the Portfolio Plan outlines the planned Evaluation, Measurement & Verification (EM&V) activities for SDREN.
ϯ
Engagement
Extensive stakeholder outreach and engagement yielded unprecedented regional support for the formation of SDREN. Staff presented SDREN formation concepts and draft program ideas in over 25 presentations to various stakeholder groups throughout the region. Stakeholders from the business groups, community organizations, environmental not-for-profit organizations, the workforce development sector and public agencies participated in engagements varying from informational webinars to interactive workshops designed to gather feedback.

The following 39 organizations have provided letters of support for the formation of SDREN:

Public Agencies: Community Based
Organizations:

Civic & Trade
Associations:

City of
Encinitas
City of Solana
Beach
San Diego
Association of
Governments
GRID Alternatives CleanTech San
Diego
City of
National City
City of El
Cajon
SD Community
College District
San Diego Foundation SD Green Building
Council
City of La
Mesa
City of
Carlsbad
Clean Energy
Alliance
International Code
Council SD Chapter
SD Workforce
Partnership
City of
Chula Vista
City of
Oceanside
SD Air Pollution
Control District
MAAC SD Regional
Chamber of
Commerce
City of
Imperial
Beach
City of Vista Southwestern
College
Center for Community
Energy
SD Regional
Economic
Development
Corporation
City of San
Diego
SDSU, Smart
Grid Lab
Palomar College SD Urban
Sustainability
Coalition
Local Government
Sustainable
Energy Coalition
SD Green New Deal
Alliance
City Heights CDC
Urban Collaborative
Project
SD Building
Electrification
Council
SD Regional Climate
Collaborative
Asian Business
Association
Art Produce Small Business
Utility Advocates
Climate Action
Campaign
Staff expect to receive an additional five to ten letters of support before submitting the application, bringing the total letters of support expected to be more approximately 50. ϰ
Next Steps:

Pending Board of Directors approval, SDCP Staff will submit the complete application and supporting documents to the CPUC in January 2024. With the submittal, the CPUC will open a public evaluation process of the SDREN application including soliciting and considering public feedback on the application materials. Although no time table is currently available for the expected review time by the PUC, previous REN applications have been approved in 9-12 months.

COMITTEE REVIEW
Staff presented SDREN draft programs and governance at the September 14, 2023, meeting of the CAC. Staff discussed SDREN draft programs, governance and budget with the CAC Programs Ad-Hoc Committee on September 6, 2023, and October 5, 2023.

FISCAL IMPACT
Were it to be approved by the CPUC, all SDREN activities are cost recoverable. SDCP staff time contributing to SDREN management is reimbursable by the CPUC.

ATTACHMENTS
Attachment A: Letter of Commitment to Cooperate Between San Diego Community Power, County Of San Diego, and San Diego Gas & Electric Company Attachment B: Letters of Support
Attachment C: Exhibit 1, Strategic Business Plan
Attachment D: Exhibit 2, Portfolio Plan

5857 Owens Ave, 3rd Floor | Carlsbad, CA | 760-209-6177 TheCleanEnergyAlliance.org
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November 3, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of Climate Action Campaign, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

As a non-profit organization with a mission to create a zero carbon future through effective and equitable policy action, Climate Action Campaign has a history of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. Climate Action Campaign would be pleased to be a member of the inaugural SDREN Advisory Committee to provide advisement on program outreach and enrollment, feedback on program evaluation, and recommend program improvements. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. Working closely with both SDCP and the County since Climate Action Campaign was founded, we are confident SDREN will provide successful and equitable programming.

Climate Action Campaign recognizes there are significant gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address significant unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Nicole Capretz
Founder and Chief Executive Officer
Climate Action Campaign
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102

SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION

Dear CPUC President Reynolds:

On behalf of MAAC, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

MAAC is a leading provider of comprehensive social services in San Diego County and provides life-changing services to nearly 100,000 individuals every year. We create healthier and stronger communities by providing a space where individuals and families can find means to self-sufficiency, through advocacy and access to high-quality programs in five key areas of focus:

Housing, Economic Development, Education, Health & Well-being, and Advocacy & Leadership Development. Collaboration with community partners ensures MAAC remains on the forefront of the community’s ever-changing needs.

MAAC recently worked with SDCP on the development of its five-year strategic plan for customer programs, known as the Community Power Plan. Energy efficiency (EE) programs were identified as a priority in the plan to achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. We heard firsthand from our communities that there is a great need for program opportunities that focus on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. MAAC is pleased to be a member of the inaugural SDREN Advisory Committee to provide advisement on program outreach and enrollment, feedback on program evaluation, and recommend program improvements.

SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. MAAC recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the CPUC to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Arnulfo Manriquez
President & CEO
MAAC
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission Sincerely,
ArnulfoManriquez
President & CEO
November 21, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
Subject: Support for San Diego Regional Energy Network (SDREN) Application to California Public Utilities Commission (CPUC)
Dear CPUC President Reynolds:

The San Diego Association of Governments (SANDAG) is pleased to support the proposed San Diego Regional Energy Network (SDREN) and its 2024-2031 Strategic Business Plan.

SANDAG has a history of supporting Energy Efficiency (EE) programs that achieve energy savings, reduce greenhouse gas emissions, and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego Office of Sustainability and Environmental Justice (OSEJ), with SDCP as the program lead. SANDAG is pleased to be a member of the inaugural SDREN Advisory Committee to provide advisement on program outreach and enrollment, feedback on program evaluation, and recommend program improvements.

The SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. SANDAG recognizes that there are gaps in current regional EE programs and services. The SDREN will address unmet needs by expanding EE program participation and benefits in our communities. We are excited to continue our collaboration on this very important initiative and urge the CPUC to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Thank you for considering this request.

Sincerely,

COLEEN CLEMENTSON
Deputy Chief Executive Officer
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission November 7, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK
(SDREN) 2024-2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the San Diego Green Building Council (SDGBC), I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

San Diego Green Building Council is a community benefit nonprofit whose mission is to inspire, educate and collaborate within our community to transform our built environment toward true sustainability. We do this through our four focus areas, equity, decarbonization, health & wellness and water reuse. SDGBC has a history of supporting energy efficiency (EE) programs that achieve energy savings, and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDGBC is pleased to be a member of the inaugural SDREN Advisory Committee to provide advisement on program outreach and enrollment, feedback on program evaluation, and recommend program improvements.

Our Vision Our buildings and communities will regenerate and sustain the health and vitality of all life within a generation.

Our Mission Inspire, educate and collaborate within our community to transform our built environment toward true sustainability. -1-
SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. SDGBC recognizes there are significant gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address significant unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Colleen FitzSimons
Executive Director
San Diego Green Building Council
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission Our Vision Our buildings and communities will regenerate and sustain the health and vitality of all life within a generation.

Our Mission Inspire, educate and collaborate within our community to transform our built environment toward true sustainability. -2-
December 1st, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the San Diego Regional Climate Collaborative (SDRCC) I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

SDRCC has a history of supporting energy efficiency (EE) programs that achieve energy savings, and deliver other benefits that contribute to a more resilient economy for San Diego County for more than a decade. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability. Since its inception in 2011, SDRCC has worked to support our members to advance climate change solutions that mitigate greenhouse gas emissions and adapt to the effects of climate change – including both SDCP and the County of San Diego.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDRCC is pleased to be a member of the inaugural SDREN Advisory Committee to provide advisement on program outreach and enrollment, feedback on program evaluation, and recommend program improvements.

SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. The San Diego Regional Climate Collaborative recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities, and we look forward to supporting the implementation of these programs.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Darbi Berry
Director
The San Diego Regional Climate Collaborative
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission 10124 Old Grove Rd. San Diego California 92131-1649
(858) 586-2600 Fax (858) 586-2601
www.sdapcd.org
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the San Diego County Air Pollution Control District (SDAPCD), I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

Energy efficiency (EE) programs support SDAPCD’s mission to improve air quality to protect public health and the environment by ensuring that the region uses energy wisely, minimizing air pollution associated with energy generation. SDAPCD has a history of supporting equitable programs that achieve energy savings, reduce emissions, and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. SDAPCD recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Kathleen Keehan
Chief, Emission Reduction Strategies
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission Art Produce 3139 University Ave. San Diego, CA 92104 artproduce.org 501(c)3 non-profit organization Tax ID #47-4426624
October 25, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of Art Produce, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN). Art Produce is a community based non-profit cultural center located in the busy urban commercial district of North Park in San Diego.

We recently worked with SDCP on the development of its five-year strategic plan for customer programs, known as the Community Power Plan. Energy efficiency (EE) programs were identified as a priority in the plan to achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. We heard firsthand from our communities that there is a great need for program opportunities that focus on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. Art Produce recognizes there are gaps in the current EE programs and services that are offered in our region.

We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the CPUC to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,

Lynn Susholtz
Art Produce, Founder/Executive Director
Art Produce 3139 University Ave. San Diego, CA 92104 artproduce.org 501(c)3 non-profit organization Tax ID #47-4426624
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission

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City of Carlsbad City Council
City Hall 1200 Carlsbad Village Drive ° Carlsbad, CA 92008 ° 442-339-2820 t November 13, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031 STRATEGIC BUSINESS

PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the City of Carlsbad, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

The City of Carlsbad has a long history of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability. In 2019, the city adopted its first reach code which incorporated deep EE measures into new construction and major renovations. The city also continues to implement its Climate Action Plan, which is currently being updated, to promote EE programs that a REN would greatly support.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions.

The City of Carlsbad recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Keith Blackburn, Mayor
City of Carlsbad
City of Carlsbad City Council
City Hall 1200 Carlsbad Village Drive ° Carlsbad, CA 92008 ° 442-339-2820 t CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission The Center for Community Energy
A 501(c)3 non-profit
https://centerforcommunityenergy.org/
1470 Encinitas Blvd., #312
Encinitas, CA 92024
November 15, 2023
To: President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
Re: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the Center for Community Energy (CCE), I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

The Center for Community Energy was formed to promote energy efficiency (EE) and distributed energy resource programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

Last year the CCE conducted a study for San Diego County on promoting heat pump water heaters to the owners of multi-unit housing. One of the issues we identified was the lack of a local REN to provide the kind of support and guidance a REN can provide in this kind of task. Creating or joining a REN was one of the recommendations in our report: Eliminating Gas Hot Water Heaters From Multi-tenant Housing .

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions.

The Center for Community Energy recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Jose Torre-Bueno, PhD
Executive Director
Center for Community Energy
The Center for Community Energy
A 501(c)3 non-profit
https://centerforcommunityenergy.org/
249 So. Hwy. 101, Unit 564
Solana Beach, CA 92075
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission

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401 WEST A STREET
SUITE 200
SAN DIEGO, CA 92101
858-568-7777
cleantechsandiego.org
MISSION:

To accelerate
clean technology
innovation and
promote the
equitable
deployment
of sustainable
solutions across
the San Diego
region for the
benefit of the
economy, the
environment, and
all members of
the community.

October 25, 2023
Ms. Alice Reynolds
President, California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
Re: Support for the San Diego Regional Energy Network’s (SDREN) 2024-2031 Strategic Business Plan Application
Dear President Reynolds:

On behalf of Cleantech San Diego, I am pleased to provide this letter of support for the establishment of the San Diego Regional Energy Network (SDREN). The proposed SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator.

Cleantech San Diego is a member-based business organization founded in 2006 that positions the San Diego region as a leader in the cleantech economy by fostering collaborations across the private-public-academic landscape, engaging in advocacy efforts to promote cleantech priorities, supporting energy entrepreneurs through the Southern California Energy Innovation Network, and encouraging more equitable investment across the San Diego region.

As part of the SDREN, it is our hope that the program administrators will look to San Diego-based businesses to help meet its energy efficiency goals. In 2016, Cleantech San Diego launched the Southern California Energy Innovation Network with support from the California Energy Commission. The program provides free resources through a consortium of regional partner organizations to help energy entrepreneurs successfully bring their innovations to market. Many of the companies we work with offer energy efficiency solutions. By partnering with these companies and supporting their entry into the market, the SDREN will provide energy efficiency solutions that help customers reduce their energy consumption while supporting local companies.

Thank you in advance for your support.

Sincerely,
Jason Anderson
President and CEO
Cleantech San Diego

OFFICE OF SUSTAINABILITY AND ENVIRONMENTAL JUSTICE
5500 OVE RLA ND AVE N U E, SAN D I EGO, CA 92123
( 858) 694 – 3030
www.sandiegocounty.gov/osej

EDEN BRUKMAN

CHIEF SUSTAINABILITY OFFICER
(619) 782 – 8261
September 27, 2023
Karin Burns
Chief Executive Officer
San Diego Community Power
815 E Street Suite 12716
San Diego, CA 92112
SUBJECT: LETTER OF SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK To Karin Burns,
On behalf of the County of San Diego (County), I am pleased to commit our support for the motion that will be filed by San Diego Community Power (SDCP) with the California Public Utilities Commission (CPUC) to create a San Diego Regional Energy Network (SDREN) that will list SDCP as the lead applicant and administrator.

The County’s Office of Sustainability and Environmental Justice (OSEJ) serves as a central point for the County to shepherd collaborative sustainability solutions that are equitable, cost-effective, and feasible. We strive to reduce disparities and expand opportunities in traditionally underserved communities while working to achieve zero carbon emissions and safeguard the health of the San Diego region’s people and natural resources. We champion regional initiatives, such as the County’s Regional Decarbonization Framework (RDF)—a community-informed effort that is well-aligned with the goals of a Regional Energy Network in the San Diego region.

RENs require two public agencies as part of the governance structure. SDCP will serve as one agency; it will be the lead Program Administrator and manage all fiscal, regulatory, procurement, and administrative responsibilities; and serve on the Executive Committee. The County will serve as the second public agency; act as a thought partner for the ideation of program content; collaborate on initial development of the Business Plan; and serve on the Executive Committee.

Through the County’s role, we would also participate in an SDREN Advisory Committee which would be composed of local and regional government representatives, along with representatives from community-based organizations, who will provide feedback to guide and advise SDREN on Letter Of Support for San Diego Regional Energy Network Page 2 September 26, 2023
program outreach and enrollment, program evaluation reports, and program improvement recommendations.

We look forward to the partnership with SDCP and the opportunity to shape the development of energy efficiency programs for residents and business across the region. If you have any questions, please contact me or Brenda Garcia Millan, OSEJ’s Group Program Manager and primary point of contact for the SDREN process and program, at 619-753-2523 or via email at [email protected].

Sincerely,
Eden Brukman
Chief Sustainability Officer
[email protected] | 619-782-8261
CC: Colin Santulli, San Diego Community Power
Sheena Tran, San Diego Community Power
Community Development

City of El Cajon ● 200 Civic Center Way ● El Cajon, CA 92020 Building Safety 619-441-1726 ● Housing 619-441-1710 ● Planning 619-441-1742 www.elcajon.gov
November 22, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102

SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION

Dear CPUC President Reynolds:

On behalf of the City of El Cajon, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

The City of El Cajon supports energy efficiency (EE) programs that achieve energy and cost savings to businesses and households, especially those most impacted by the high cost of energy. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. The City of El Cajon understands there are gaps in the current EE programs and services that are offered in the San Diego region. We are confident that the proposed SDREN will fill these gaps and effectively address unmet EE program needs through significantly expanding participation and benefits in all of the region’s communities.

Therefore, the City of El Cajon believes that this is an important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Anthony Shute, AICP
Director of Community Development
City of El Cajon
A - 2
cc: Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission City of
Encinitas
Tel 760/633-2600 FAX 760/633-2627, 505 South Vulcan Avenue, Encinitas, CA 92024 TDD 760/633-2700 November 20, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the City of Encinitas, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

The City of Encinitas has a long history of supporting sustainability and energy efficiency (EE) programs and projects that achieve energy savings and deliver other benefits that contribute to a more resilient climate for San Diego County. However, there is a great need for new EE program opportunities in the region. The development of SDREN would foster broad participation in new EE programs, generate customer equity, and increase access to affordable energy.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions.

City of Encinitas recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet needs by significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Pamela Antil
City Manager
CC: Kellie Shay Hinze, Council Member, SDCP Board Member Kerry Kusiak, Development Services Director
Crystal Najera, Sustainability Manager

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SAN DIEGO URBAN SUSTAINABILITY COALITION
www.sdusc.org 342 Euclid Ave Ste 406 # 404 San Diego CA 92114 (619) 616-5890 November 30, 2003
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of San Diego Urban Sustainability Coalition, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

San Diego Community Power has a history of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. The San Diego Urban Sustainability Coalition recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,

SAN DIEGO URBAN SUSTAINABILITY COALITION
www.sdusc.org 342 Euclid Ave Ste 406 # 404 San Diego CA 92114 (619) 616-5890 Eddie Price
Executive Director
San Diego Urban Sustainability Coalition
November 07, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the San Diego Community College District (SDCCD), I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

The San Diego Community College District serves approximately 100,000 students annually in its four colleges: San Diego City, Mesa, Miramar, and Continuing Education. The SDCCD has a history of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego, with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance.

SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. The SDCCD recognizes that there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs by significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Joel Peterson
Chief Operations Officer
San Diego Community College District
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission Operations,Enterprise ServicesandFacilities
Sincerely,
J l P t
November 22, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of The San Diego Green New Deal Alliance, we would like to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

The San Diego Green New Deal Alliance supports programs that contribute to a more resilient and just economy for San Diego County, including energy efficiency (EE) programs that achieve energy savings. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. The San Diego Green New Deal Alliance recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Ali Mariko Dressel, Chair,
San Diego Green New Deal Alliance
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission November 28, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of San Diego Regional EDC (EDC), I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

EDC is an independently funded non-profit organization working to grow San Diego’s economy. With investment from nearly 200 companies, public agencies, and private organizations, we are able to provide direct services to help companies grow and lead initiatives to enhance the region’s competitiveness. EDC understands the importance of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. EDC recognizes there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

President Alice Busching Reynolds Page 2
We are excited to continue our collaboration on this important initiative and recommend that the California Public Utilities Commission authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Mark Cafferty
President & CEO

27 October 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of the San Diego Building Electrification Coalition (SDBEC) and the undersigned member organizations, we are pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

SDBEC is an alliance of nearly 40 community, business, faith, justice, and environmental organizations coming together to accelerate electrification in residential and commercial buildings.

Building electrification is essential to meeting California and San Diego’s ambitious climate goals by reducing greenhouse gas emissions, improving air quality in our homes and buildings, and protecting public health.

We support energy efficiency (EE) programs that achieve energy savings, and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability. We hope to see EE programs that also support building electrification.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions.

SDBEC recognizes there are significant gaps in the current EE programs and services that are offered in our region. We believe that the proposed SDREN will fill these gaps in current EE programs and effectively address significant unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Kelly Lyndon
Co-Chair
San Diego Building Electrification Coalition
Colleen FitzSimons
Executive Director
San Diego Green Building Council
Tanish-Jean Martin
Climate Community Director
San Diego Urban Sustainability Coalition
Jim Miller
Vice President
AFT 1931
Ann Feeney
Co-chair Building Electrification
San Diego 350 Serena Pelka
Policy Advocate
Climate Action Campaign
Susan Wayo
Board Member & Secretary
Center for Community Energy
Amy Steward
Executive Director
Emerald Keepers
Marian Sedio
Board Member
North County Climate Change Alliance
Sean Armstrong
Managing Principal
Redwood Energy Adria Fox
Managing Director
C4GS-ZEDlife
Leslie Gomez
San Diego
Climate Reality Project
American Institute of Architects
San Diego
Cooper Marcus
CEO and Chief Quitter
QuitCarbon
Lucero Sanchez
Community Policy Coordinator
San Diego Coastkeeper
Alicia Nichols Gonzalez
Mothers Out Front
Organizing Manager, California
Chef Christopher Galarza, Founder
Culinary Sustainability Consultant
Forward Dining Solutions LLC.

Joy Frew
Co-founder
Fallbrook Climate Action Team
Jean Huy
Managing Director
Viet Vote SD
Rhea and Armin Kuhlman
Co-Chair, Climate Justice Team
First Unitarian Universalist
Church of San Diego Sister Maria A. Muhammad
CEO
I Am Green, Inc.

Adam Aron
Green New Deal at UCSD
Adrienne Fusek
Executive Director
In Good Company
Marc Friedmann
Citizens’ Climate Lobby
San Diego Chapters
Suzanne Hume
Educational Director & Founder
CleanEarth4Kids.org
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission 3:

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October 26, 2023

OFFICE OF ASSISTANT SUPERINTENDENT/VICE PRESIDENT, ACADEMIC AFFAIRS Isabelle Saber, M.A.

Assistant Superintendent/
Vice President, Academic Affairs
Governing Board
Roberto Alcantar
Don Dumas
Kristine Galicia Brown
Robert Moreno
Corina Soto
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of Southwestern College, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

Southwestern College has a history of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions.

Southwestern College there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Isabelle Saber (Oct 27, 2023 10:11 PDT)
Isabelle Saber
Assistant Superintendent/Vice President, Academic Affairs Southwestern College
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission 900 Otay Lakes Road, Chula Vista, CA 91910-7299 • (619) 482-6338 • Fax (619) 482-6449 • TTY (619) 482-6470 • www.swccd.edu dŚĞhƌďĂŶŽůůĂďŽƌĂƚŝǀĞWƌŽũĞĐƚͮϲϳϴϱ/ŵƉĞƌŝĂůǀĞŶƵĞ͕^ĂŶŝĞŐŽ͕ϵϮϭϭϰͮǁǁǁ͘ƵĐƉƌŽũĞĐƚ͘ŽƌŐ November 21, 2023
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
RE: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024- 2031 STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of The Urban Collaborative Project CDC (UCP-CDC), I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

UCP-CDC is a BIPOC-led 501(c)3 non-profit organization based in and serving Southeast San Diego since 2013. We advocate for equity and resident capacity-building to overcome disparities in the areas of health, housing, art, transportation, and infrastructure. Our community healing process and collaborative social infrastructure is designed to build capacity by empowering, training, and supporting residents to identify and solve community issues together. UCP-CDC also works closely with the County of San Diego to provide outreach and community engagement for the Regional Decarbonization Framework, as well as with the City of San Diego to provide equitable engagement and seek resident feedback on the Environmental Justice Element for the city’s General Plan. Given this work and our overall mission to improve equity in our community, UCP-CDC is supportive of energy efficiency (EE) programs that achieve energy savings and contribute to a more resilient economy and sustainable future for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability in under-resourced communities like Southeast San Diego.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions. UCP-CDC recognizes there are gaps in the current EE programs and services that are offered in our region.

We are confident that the proposed SDREN will fill these gaps in current EE programs and dŚĞhƌďĂŶŽůůĂďŽƌĂƚŝǀĞWƌŽũĞĐƚͮϲϳϴϱ/ŵƉĞƌŝĂůǀĞŶƵĞ͕^ĂŶŝĞŐŽ͕ϵϮϭϭϰͮǁǁǁ͘ƵĐƉƌŽũĞĐƚ͘ŽƌŐ effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Brian Pollard
Founder and Executive Director
The Urban Collaborative Project CDC

CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission

October 26, 2023

OFFICE OF ASSISTANT SUPERINTENDENT/VICE PRESIDENT, ACADEMIC AFFAIRS Isabelle Saber, M.A.

Assistant Superintendent/
Vice President, Academic Affairs
Governing Board
Roberto Alcantar
Don Dumas
Kristine Galicia Brown
Robert Moreno
Corina Soto
President Alice Busching Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102
SUBJECT: SUPPORT FOR SAN DIEGO REGIONAL ENERGY NETWORK (SDREN) 2024-2031

STRATEGIC BUSINESS PLAN APPLICATION
Dear CPUC President Reynolds:

On behalf of Southwestern College, I am pleased to provide this letter of support for the creation of the proposed San Diego Regional Energy Network (SDREN).

Southwestern College has a history of supporting energy efficiency (EE) programs that achieve energy savings and deliver other benefits that contribute to a more resilient economy for San Diego County. There is a great need for the new EE program opportunities that SDREN proposes that are focused on the goals of broad participation, customer equity, and increased energy affordability.

The SDREN will be administered by San Diego Community Power (SDCP) and the County of San Diego with SDCP as the Lead Program Administrator. The Office of Sustainability and Environmental Justice (OSEJ) would represent the County and serve as the second public agency in SDREN’s governance. SDREN will provide an important venue to collect diverse County-wide perspectives that will catalyze and deliver impactful, community-led solutions.

Southwestern College there are gaps in the current EE programs and services that are offered in our region. We are confident that the proposed SDREN will fill these gaps in current EE programs and effectively address unmet EE program needs through significantly expanding EE program participation and benefits in our collective communities.

We are excited to continue our collaboration on this very important initiative and urge the California Public Utilities Commission to authorize the SDREN and their 2024-2031 Strategic Business Plan Application.

Sincerely,
Isabelle Saber (Oct 27, 2023 10:11 PDT)
Isabelle Saber
Assistant Superintendent/Vice President, Academic Affairs Southwestern College
CC:

Genevieve Shiroma, Commissioner, California Public Utilities Commission Darcie L. Houck, Commissioner, California Public Utilities Commission John Reynolds, Commissioner, California Public Utilities Commission Karen Douglas, Commissioner, California Public Utilities Commission 900 Otay Lakes Road, Chula Vista, CA 91910-7299 • (619) 482-6338 • Fax (619) 482-6449 • TTY (619) 482-6470 • www.swccd.edu

Table of Contents
Executive Summary................................................................................................................. 2 Exhibit One: Strategic Business Plan........................................................................................ 4 SDREN’s Vision for EE in CA: 2024 - 2031..................................................................................4 Core Values......................................................................................................................... 5 Guiding Principles...............................................................................................................6 Business Plan Strategies......................................................................................................8 Desired Portfolio Outcomes................................................................................................9 Governance Structure.......................................................................................................10 Regional Planning and Collaboration Framework............................................................. 14 Stakeholder Engagement............................................................................................ 18 Service Territory................................................................................................................20 Geography...................................................................................................................23 Tribal Context..............................................................................................................23 Demographics............................................................................................................. 24 Climate Impacts.......................................................................................................... 25 Regional Energy Profile............................................................................................... 27 Equity Considerations................................................................................................. 29 Workforce................................................................................................................... 33 Energy Efficiency Strategy................................................................................................. 34 Savings Forecasting and Quantification Methods.......................................................35 Strategies for Market Intervention and Energy Efficiency Adoption...........................36 New Strategies for Spurring Innovation...................................................................... 38 Strategy for Incorporating Low Global Warming Potential Refrigerants.....................39 IDSM Strategies...........................................................................................................40 Strategies for Tracking Outside Funding..................................................................... 42 Portfolio Management Strategies............................................................................... 42 Segmentation Strategy Summary......................................................................... 43 Sector Strategies................................................................................................... 44 Distribution of Budget Among Sectors and Segments.......................................... 46 Portfolio Coordination.......................................................................................... 46 Evaluation, Measurement, and Verification (EM&V).................................................. 47 Alignment with CPUC Requirements.......................................................................... 47 Portfolio Design and Alignment with Relevant Action Plans.......................................48 Annual Portfolio Budgets........................................................................................................ 54 Recommendations for New or Modified EE Policy................................................................. 54 1 Executive Summary
The projected impacts of climate change on the San Diego region are profound, driving the need for urgent collective actions to decarbonize. The creation of the San Diego Regional Energy Network (SDREN) represents an important step to support communities, particularly those who are underserved and hard-to-reach, to achieve a carbon free building sector in the San Diego region by 2050.

SDREN’s vision is to be a driving force for communities to adopt clean, reliable energy through community-driven solutions that contribute to local and state energy efficiency and climate goals. SDREN’s core values guide the design and execution of its program portfolio. These values are to integrate a collaborative and purposeful investment in the region’s underserved and hard-to-reach communities, grow a regional clean energy economy that creates opportunities for the local workforce, and be a trusted local resource to coordinate regional policy, partnerships, and programs.

The SDREN service territory is home to 3.3 million people, the second most populous of California’s 58 counties and the fifth largest county in the US. The Kumeyaay, referred to as Diegueno by the Spanish, were the original inhabitants of San Diego County. The territory includes the County of San Diego, 18 incorporated cities, 18 Tribal governments, 16 significant naval and military installations, 47 school districts, and 24 water districts.

SDREN aspires to be a regional leader focused on helping communities invest in strategies that hasten decarbonization. Through its portfolio of programs, guided by its core values, SDREN is committed to delivering programs that make inroads into communities to reduce greenhouse gas emissions, achieve equity, drive market transformation, and provide value to ratepayers.

Approval of the SDREN will complete the Regional Energy Network’s (REN) statewide coverage, bolstering the California Public Utilities Commission’s (CPUC) intention for RENs to fill gaps and complement investor-owned utility (IOU) services. Regional Energy Network (REN) programs have proven to be a critically important component of California energy efficiency and climate strategies, demonstrating the effectiveness of local governments to overcome barriers and motivate communities to take clean energy actions.

SDREN’s overall portfolio goals to advance decarbonization, provide comprehensive energy efficiency (EE) services that improve outcomes for underserved and hard-to-reach communities, and accelerate the clean energy economy through workforce opportunities, support attainment of California’s ambitious 2030 and 2045 climate goals. The proposed EE Portfolio is framed by three key principles—to advance environmental equity, catalyze collaboration, and support community-driven change.

SDREN is focused on working collaboratively with Environmental and Social Justice (ESJ) communities to provide needed programs and resources, aligned with the San Diego Regional 2 Decarbonization Framework, and informed by the CPUC’s ESJ Action Plan. SDREN’s long-term goal is to ensure an equitable transition to a carbon-free building sector in the San Diego region by 2050, seeking higher participation from hard-to-reach and underserved communities and reducing their energy burden.

SDREN’s portfolio and administration is led by San Diego Community Power (SDCP) and the County of San Diego. SDCP, the lead Portfolio Administrator (PA), will lead fiscal, regulatory, procurement, and program management. The SDREN Advisory Committee, composed of local and regional governments and community-based organizations (CBOs), will advise on and recommend program improvements. An SDREN programs operations team primarily of SDCP employees and third-party implementers will oversee day-to-day program operations and administration.

San Diego has a strong history of collaboration and engagement in EE programs. The SDREN joins a group of local, regional, and state agencies that have jurisdiction over climate change activities in the region, as well as CBOs, labor, business groups and other organizations that support climate efforts. SDREN’s proposed portfolio builds on the comprehensive regional sustainability and decarbonization planning in the region, and fills gaps and complements the programs provided by the region’s serving utility, San Diego Gas & Electric (SDG&E).

SDREN’s portfolio application includes ten programs, organized by segment, and sectors, as follows:
● Segments: Resource Acquisition, Market Support, Equity, and Codes & Standards ● Sectors: Commercial, Cross-cutting (Workforce, Education and Training and Codes and Standards), Public, and Residential
SDREN is requesting $124,274,206 over the four-year period from 2024 to 2027. This funding will enable SDREN to achieve its stated goals and outcomes and connect communities with available resources, which will accelerate decarbonization strategies in the region. All SDREN programs will target hard-to-reach and underserved communities, which comprise approximately 56% of the region’s population. SDREN is directing 46.1% of its portfolio to Equity programs, while Market Support programs comprise 34%, Resource Acquisition 13.8%, and Codes and Standards 6.1%.

SDREN’s portfolio includes two Equity Segment Residential Sector programs serving single-family and multifamily participants. Two Equity Segment programs are proposed for the Commercial Sector, targeting small and medium businesses, along with one Resource Acquisition program serving hard-to-reach and underserved commercial customers. SDREN is proposing one Market Support program within the Public Sector, supporting public agencies, and one Equity Segment Public Sector program supporting Tribes. Two Market Support Workforce, Education and Training (WE&T) programs will target high school students and adults supporting high road clean energy career pathways and skill development. A proposed Codes and Standards (C&S) program will assist public agency permitting authorities with compliance 3 and policy support. All of SDREN’s proposed programs support and complement the services of SDG&E and are designed to avoid duplication and customer confusion.

Collectively, SDREN’s portfolio-level strategies incorporate six delivery methods. Principles of environmental and social justice connect throughout these strategies and environmental justice considerations are incorporated across all programs, regardless of segmentation. First, the portfolio is designed to provide flexibility in program delivery so that services can adapt and change as new programs or resources become available and when programs close. Second, by integrating effective coordination and collaborations with partners and existing trusted organizations across program segments and sectors, SDREN can identify synergies, reduce costs and complexity, and deliver higher-value programs that reflect local priorities and needs. It can also mitigate customer confusion and grow impacts and success of all programs. Third, the SDREN portfolio reduces barriers to participation by offering customized support and connecting customers with available resources and programs. Fourth, SDREN will promote decarbonization through electrification measures and incentives to move away from methane-gas-burning technologies. Fifth, SDREN will monitor the market and coordinate with other programs to leverage complementary offerings and stack supplemental program services and external funding opportunities. Sixth, integration of IDSM offerings and support are considered as part of a holistic approach to deliver value to participants throughout the portfolio.

The creation of SDREN represents another milestone in California’s quest to reach its ambitious climate goals and ensure ESJ communities are at the forefront of these efforts. SDREN looks forward to joining the extensive statewide network of other RENs, IOUs, local agencies, CBOs, and others working collectively to achieve an urgently needed clean energy future.

Exhibit One: Strategic Business Plan
SDREN’s Vision for EE in CA: 2024 - 2031
The projected impacts of climate change on the future of San Diego become clearer every day, at a concerning pace. The San Diego region urgently needs to accelerate the transition to clean energy as failure to do so will have steep costs for the natural world and for the health and livelihoods of everyone. Additionally, a collaborative and purposeful investment is needed to ensure that San Diego’s most vulnerable are not left behind in the region’s efforts to decarbonize.
4 Figure 1. SDREN’s Vision
San Diego Regional Energy Network’s (SDREN)1 vision is to be a driving force for communities to adopt clean, reliable energy through community-driven solutions that contribute to local and state energy efficiency and climate goals.

SDREN aspires to be a leader supporting the 18 incorporated cities, 47 school districts, and 18 recognized Tribal governments across the San Diego region. In keeping with its core values, SDREN will integrate a collaborative and purposeful investment in the region's underserved and hard-to-reach communities2 to contribute to an equitable transition to a clean energy economy.

Approval of the SDREN will complete the statewide coverage of RENs and bolster the CPUC’s intended outcomes for RENs to fill gaps and complement IOU services. SDREN is committed to delivering programs that make further inroads into communities to reduce greenhouse gas emissions, achieve equity, drive market transformation, and provide value to ratepayers.

Core Values
SDREN’s EE portfolio is framed around three core values:
2 As defined in D.23-06-055.
1 All acronyms and abbreviations are listed in Exhibit 3 - Appendix X. 5 Figure 2. SDREN’s Core Values
Guiding Principles
SDREN’s portfolio of services is informed by its core values and framed by the following three principles:

1. Advance Environmental Equity. Through its proposed portfolio of services SDREN is committed to representing underserved communities and advancing environmental equity. SDREN fills a significant gap as there currently exists no central organization in the San Diego region that focuses on the energy needs and challenges of these populations who are more vulnerable to the effects of climate change and are more likely to be left behind in the transition to a clean energy future.

2. Catalyze Collaboration. A collaborative approach provides powerful leverage and access to clean energy solutions. SDREN will collaborate with and empower communities to design and deliver strategies that benefit them and advance decarbonization. As a regional energy leader and a trusted partner, SDREN will play a critical role in cultivating strong regional partnerships and robust stakeholder coordination. SDREN will focus on marshaling resources, providing access to financing, building local capacity, and supporting integrated and comprehensive strategies. A key role is to leverage resources that are increasingly available for energy programs, filling gaps to ensure resources are used efficiently, and integrating and stacking funding sources, where possible, for maximum advantage to local communities.

3. Support Community-Driven Change. Community-driven change is a key to the successful adoption of practices and policies that support the transformation to a clean energy economy. SDREN’s approach to program design and delivery will engage communities at early stages of planning to ensure the services that are developed reflect local needs and priorities.
6 Goals
SDREN’s portfolio complies with CPUC requirements and rulings and addresses the CPUC’s goals for RENs to deliver programs and activities that fill gaps and complement IOU offerings.3 SDREN has set the following overarching three goals for its portfolio:

1. Advance Decarbonization. Beyond reducing energy use and GHG emissions, decarbonization ushers in a host of benefits making communities and economies more resilient. Decarbonization lowers energy costs, increases access to clean energy, ensures safer and healthier homes and communities, reduces environmental burdens, and expands economic opportunity and high-quality jobs.

2. Provide Comprehensive EE Services that Improve Outcomes for Underserved and Hard-to-Reach Communities. SDREN’s portfolio of services will be centered around minimizing barriers to participation for underserved and HTR communities.

3. Accelerate the Clean Energy Economy through Workforce Opportunities. As a regional leader, SDREN will mobilize and leverage resources to support the local workforce and support the creation of energy related jobs and skills that benefit local communities. A goal is to support a high road4 approach to grow the regional clean energy economy and create new opportunities for the local workforce, with a focus on underserved communities.

These goals are intended to align with the Regional Decarbonization Framework (described further in the Regional Planning and Collaboration Framework section below) and were informed by the CPUC Environmental Social and Justice Action Plan (ESJAP)5 . They can be
further broken out into the following timeframes—short-term, mid-term and long-term. 5 https://www.cpuc.ca.gov/news-and-updates/newsroom/environmental-and-social-justice-action-plan. 4 An approach that integrates intentional policies and investments that center employee benefits and needs. 3 D.12-11-015, and reasserted in D.19-21-021.
7 Figure 3. SDREN’s Goals by Year
Business Plan Strategies
SDREN’s proposed EE strategy for the San Diego region builds off of the foundation established through long-standing local collaborations in the region (described below under Regional Planning and Collaboration Framework). The strategy is informed by SDRENs values and principles to deliver on the goals of decarbonization, comprehensive EE services, and building the local energy economy.

Collectively the portfolio-level strategies incorporate several key approaches as shown in Figure

4. First, the portfolio is designed to provide flexibility in program delivery so that services can adapt and change as new programs or resources become available and when programs close.

Second, by integrating effective coordination and collaborations with partners and existing trusted organizations across program segments and sectors, SDREN can identify synergies, reduce costs and complexity, and deliver higher-value programs that reflect local priorities and needs. It can also mitigate customer confusion and grow impacts and success of all programs.

Third, the SDREN portfolio reduces barriers to participation by offering customized support and connecting customers with available resources and programs. Fourth, SDREN will promote decarbonization through electrification measures and incentives to move away from methane-gas-burning technologies. Fifth, SDREN will monitor the market and coordinate with other programs to leverage complementary offerings and stack supplemental program services and external funding opportunities. Sixth, integration of IDSM offerings and support are considered as part of a holistic approach to deliver value to participants throughout the portfolio (described in more detail under IDSM Strategies). Finally, principles of environmental and social justice connect throughout each of these strategies and environmental justice considerations are incorporated across all programs, regardless of segmentation. 8 Figure 4. SDREN Key Strategies
These key strategies will be integral to the SDREN through the Business Plan period to deliver on the desired outcomes.

Desired Portfolio Outcomes
By bringing together regional perspectives, deepening partnerships, and cultivating community led strategies, SDREN will help realize meaningful multi-benefit solutions that result in long term positive change. Success relies on implementing community driven strategies to build climate resiliency and adopting energy efficiency and clean energy solutions that support the goals and policies of the CPUC.
● Portfolio Outcome 1. Reduce energy burden and improve energy affordability. ● Portfolio Outcome 2. Improve health and reduce energy consumption across the region. ● Portfolio Outcome 3. Improve access, increase participation by reducing the complexity of energy service programs, and achieve greater understanding of how to manage energy consumption, including peak demand reduction.
● Portfolio Outcome 4. Maximize benefits to customers by leveraging additional funding, such as IRA, to deliver on IDSM strategies.
● Portfolio Outcome 5. Create access to career pathways in clean energy.

An initial set of SDREN unique value metrics have been developed to track progress towards SDREN’s goals and outcomes that are described in Exhibit 2. Additionally, within the 2024-2027 portfolio plan period, SDREN will continue efforts with other stakeholders to refine relevant metrics, and to establish data methodologies, baselines and targets for tracking progress towards all portfolio goals.
9 Governance Structure
Led by San Diego Community Power (SDCP) and the County of San Diego, SDREN leverages the region’s capacity and experience to create a strong and collaborative governance structure. The region has a strong history of collaboration and engagement in EE programs. The following chart depicts the SDREN governance model.

Figure 5. SDREN Governance Model
The Oversight and Administration team of SDCP and the County of San Diego will provide portfolio-level vision and strategy, enact program changes during the portfolio cycle, and oversee future Business Plan development. Important decisions will be made using a consensus process. The goal is to reach a consensus for any significant portfolio-wide related issues.

However, if a consensus is not achieved in a timely fashion, a mediator will be used to make a final decision as a last resort. SDCP and the County of San Diego will proactively identify potential non-consensus issues early and work with impacted parties constructively.

San Diego Community Power is a Community Choice Aggregator (CCA) formed via a Joint Powers Authority by San Diego, Encinitas, La Mesa, Chula Vista, Imperial Beach, National City and the County of San Diego.

As a public not-for-profit entity, SDCP is focused on bringing cleaner power at competitive rates to its customers and investing excess revenue in the communities it serves.

SDCP provides affordable clean energy and invests in the community to create an equitable and sustainable future for the San Diego region. SDCP aims to be a global leader, inspiring innovative solutions to climate change by powering communities with 100% clean affordable energy while prioritizing equity, sustainability, and high-quality jobs. SDCP is a values-led, mission driven organization grounded in Justice/Equity/Diversity/Inclusion (JEDI), Impact, Integrity, Innovation, Servant Leadership, and Togetherness. SDCP’s mission is to bring 100% renewable power to its customers by 2035 or sooner. SDCP offers a 100% renewable product called Power100 which has helped many SDCP customers reach their respective ESG or GHG reduction goals. 10 In December of 2019, per the California Public Utilities Commission (CPUC) Resolution E-4907, the Cities of San Diego, Imperial Beach, Encinitas, La Mesa and Chula Vista, who had previously taken action to form a Joint Powers Authority, submitted to the CPUC an Implementation Plan and Statement of Intent for authority to provide service as a Community Choice Aggregator to eligible customers within the geographical boundaries of their service territory. Once approved by the CPUC, San Diego Community Power was eligible to begin enrollment of eligible accounts in 2021.

In March of 2021 SDCP launched its service and began enrolling customers through a multi-phased effort starting with municipal customer accounts (Phase 1). Commercial and Industrial accounts were enrolled in June 2021 (Phase 2), and residential accounts from February through May of 2021 (Phase 3). In December 2021, SDCP amended its JPA to expand its membership to include National City and the County of San Diego, and submitted an Implementation Plan to enroll eligible accounts of the new member agencies beginning in 2022.

The enrollment of accounts located in the unincorporated areas of the County and National City commenced on April 1st, 2023 (Phase 4).

SDCP is deeply committed to collaborating and leveraging regional resources and championing community needs to implement a comprehensive and adaptive portfolio. Throughout its growth, SDCP has demonstrated responsible fiscal management, and its structure provides regular public consultation with various public committees. 11 Figure 6. SDCP Community Leadership
As a not-for-profit public agency, SDCP is committed to developing a suite of customer energy programs that respond to community needs, with a focus on Communities of Concern6 . SDCP
has engaged these communities in the development of a Community Power Plan to support future development of programs (both described in more detail below). SDCP’s current customer program initiatives include:
● Residential Solar and Storage Program
● Solar for Our Communities green tariff program
● Commercial Peak Load Reduction Pilot
● Community Clean Energy Innovation Grant Program
● DAC-SASH Enabling Roof Repair Pilot
● Managed EV Charging Pilot
County of San Diego. The County of San Diego is a leader in sustainability. In pursuit of its vision for “a just, sustainable, and resilient future for all”, the County has undertaken ambitious sustainability and decarbonization efforts. One example is the creation of the Office of Sustainability and 6 Defined as the top 25% scoring areas from CalEnviroScreen, known as Disadvantaged Communities (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. 12 Environmental Justice (OSEJ), established in 2021, which strives to reduce disparities and expand opportunities in traditionally underserved communities as it works to achieve zero carbon emissions and safeguard the health of the region's people and natural resources, OSEJ focuses on both regional initiatives and County operations. OSEJ’s keystone effort is the Regional Decarbonization Framework (RDF) which is the County’s holistic approach to guide the region’s decarbonization efforts that promotes public and private interests working together to move the entire San Diego region toward zero carbon emissions in transportation, buildings, energy, food systems, and land use by mid-century (described further below). To lead by example, OSEJ works with the over 40 County departments and offices to implement sustainability plans to reduce the County’s carbon footprint in programs and operations. The County’s sustainability vision is to support all communities in the region by efficiently using and protecting its natural resources, balancing economic growth, and ensuring just and equitable provision of public services, without compromising the ability of future generations to also flourish and thrive. More information about the County's sustainable energy work is described in the next section, Regional Planning and Collaboration Framework.

The Lead Portfolio Administrator,
7 SDCP, will lead fiscal, regulatory, procurement, and program management.

The SDREN Advisory Committee will include local and regional governments and community-based organizations with the role to advise on outreach and enrollment, provide feedback on program evaluation reports, and recommend program improvements.

As the Oversight and Administration team optimistically plans for the launch of SDREN, it believes it’s important to have its governance in place and ready to execute on program delivery upon approval. As to not further delay providing REN benefits and services to communities, SDREN established its inaugural Advisory Committee. The inaugural Advisory Committee members represent entities and agencies with a regional or multi-jurisdictional footprint and it is anticipated that the full Advisory Committee will be formed upon SDREN approval.

Confirmed Inaugural Committee Members include:
● Clean Energy Alliance
● MAAC
● San Diego Regional Climate Collaborative
● San Diego Association of Governments (SANDAG)
● Climate Action Campaign
● San Diego Green Building Council
Expected Advisory Committee responsibilities would include:
● Post Submittal Phase: Receive monthly email updates and attend occasional meetings on the status of the CPUC review process.
7 D.23-05-066 makes the shift from “program administrator” to “portfolio administrator” or abbreviated as “PA”. Both terms may be found in this application.
13 ● Development phase (<6 months post-approval): Attend planning meetings approximately every other month to receive updates on SDREN launch (e.g., timing, marketing, regional coordination) and provide advice on development of Implementation Plans, RFP schedule, etc. and work closely with the Oversight and Administration team to develop process to expand the full Advisory Committee and develop Technical Ad-Hoc Sub-Committees.
● Implementation phase (>6 months post approval): Attend quarterly meetings to receive updates on program implementation and provide advice on program outreach, enrollment, adjustments to program elements.

The inaugural Advisory Committee member selection was guided by the desire to have comprehensive regional representation going into the initial phases of SDREN’s launch. SDREN will expand the bench of Advisory Committee members after the REN is authorized to include diverse organizations that can represent the variety of underserved and hard-to-reach communities in the San Diego region. SDREN places a high value on receiving input on program design and implementation directly from the communities who will benefit from its programs.

The SDREN Program Operations Teams, comprising SDCP employees and third-party implementers, will oversee day-to-day program operations and administration.

Additionally, SDG&E will act as the Fiscal Agent. SDG&E’s role as a fiscal agent for SDREN, as a REN operating within SDG&E’s territory, will be limited to collecting and disbursing funds under the direction of the Commission and does not include any compliance or monitoring functions or obligations.8
Regional Planning and Collaboration Framework
Comprehensive regional sustainability and decarbonization planning provides a solid foundation for the future success of SDREN. Several local, regional, and state agencies have jurisdiction over climate change activities in the San Diego region. Regional public agencies include SANDAG, San Diego County Air Pollution Control District, San Diego Community Power (SDCP), Clean Energy Alliance (CEA), the County, 18 local governments, 47 school districts, and 18 federally recognized Tribal governments.

Local Government Partnerships that formed in 2009 and were discontinued in 2020 not only expanded regional EE capacity but established an effective collaborative network among participating agencies. In 2023, the San Diego Regional Climate Collaborative (SDRCC) launched its Energy Resilience Working Group which consists of community and local government organizations committed to contributing to local, regional, and statewide decarbonization efforts. Over the last several years, the region launched two CCAs, San Diego Community Power and Clean Energy Alliance.

In addition, several cities in San Diego County have signed the US Mayors Climate Protection Agreement, others have joined the California Climate Action Registry, and most of the 18 cities 8 D.23-06-055, Conclusion of Law 13.
14 in the region now have a Climate Action Plan (CAP). The University of San Diego Energy Policy Initiatives Center (EPIC) conducted a first of its kind analysis for the San Diego region in comprehensively assessing the impact of adopted CAPs. The study found that CAPs alone will not be enough to reach aggressive decarbonization goals, underscoring the need and importance of regional collaborative initiatives that span jurisdictional boundaries to tackle the region's climate issues.9
Additionally, EPIC’s analysis found that most adopted CAPs do not include building electrification (BE) strategies, concluding that the impact of local CAPs in BE is limited. The report also highlighted that CAPs are only plans, and the measures included may not represent what is implemented over time. Therefore, regional initiatives such as a REN that span across jurisdictions are needed to help decarbonize buildings, reduce GHG emissions, and help tackle local climate issues.

Figure 7. Comprehensive Regional Planning
Regional Decarbonization Framework. In 2021, working with several regional stakeholders and technical experts, the County began working on the Regional Decarbonization Framework (RDF), a visionary framework that identifies community-driven partnerships, programs, and policies to support decarbonization.

In 2022, the County released the first foundation element, the RDF - Technical Report, a scientific analysis of decarbonization pathways for the San Diego region to reach net zero emissions by mid-century. The RDF includes two other foundational elements, a workforce development study and the Let’s Get There Playbook, a resource guide for local governments, organizations, and individuals to consult as they move toward zero carbon emissions. The RDF promotes public and private interests working together to move the entire San Diego region toward zero carbon emissions in transportation, buildings, energy, food systems, and land use. The RDF is intended to help policymakers work in harmony with community, industry, environmental, business, and labor groups to realize distinct and tangible actions that respond to the specific needs of cities and the unincorporated areas of the county. 9 Regional Decarbonization Framework Technical Report.
https://www.sandiegocounty.gov/content/dam/sdc/lueg/regional-decarb-frameworkfiles/RDF_Summary_for_Policy_Makers_FI NAL_2022.pdf.
15 County’s Climate Action Plan Update. The County is
currently developing a Climate Action Plan Update
to implement bold climate actions that reduce GHG
emissions. The CAP outlines actions, also referred to
as measures, to meet State targets and achieve a
goal of net zero carbon emissions by 2035-2045. The
CAP and associated goals apply to the unincorporated areas of the County and County operations.

Zero Carbon Portfolio Plan. This plan applies to all facilities occupied by the County and presents a strategy and specific measures that will result in a reduction in operational carbon emissions of 90% by 2030, relative to its 2008 baseline.

Additionally, all 40+ County of San Diego departments and offices have developed and operationalized Sustainability Plans to reduce carbon footprints from County operations and
facilities.

Community Power Plan. SDCP’s Community Power Plan (CPP)10 was an intensive effort from its program team to integrate community goals, needs, and priorities into a 5-year strategic plan for energy programs. The community needs assessment was a fundamental piece of the Community Power Plan.

Between May and November 2022, SDCP heard from more than 3,450 community members through listening sessions,
workshops, pop-up events in hard-to-reach communities, and a customer-wide survey. This helped SDCP understand the challenges, needs, goals, and priorities that could be addressed through customer energy programs. Throughout the community engagement process, SDCP prioritized equity and Communities of Concern.

SDCP prioritized partnering with local community-based organizations that work directly with community members in Communities of Concern to co-host listening sessions to minimize obstacles for program participation. SDCP provided compensation to the CBOs and participants were offered interpretation services, children’s activities, food and drinks, and gift cards for compensating their time and shared lived experience.

SDCP considered accessibility for the broadest range of community characteristics, including language, internet access, physical disability, time limitations, and subject matter understanding. A mix of virtual and in-person outreach events were offered and events were held at varying times, including outside of normal work hours. SDCP sought to develop outreach materials and presentations for broad understanding using non-technical, simplified terms. In addition, outreach materials, including the survey and plan itself, were offered in English, Spanish, and Filipino.
10 https://sdcommunitypower.org/community-power-plan-cpp/. 16 The team identified nine key community priorities based on feedback from initial community engagement. The priorities were included in the survey and respondents were asked to rank which were most important to them. Residential and commercial respondents ranked their top five priorities in the following order (Table 1). This feedback was considered in the development of SDREN’s program portfolio.

Table 1. Energy issues most important to SDCP residential and commercial respondents from the CPP community engagement process.

Order Residential Priorities Commercial Priorities
1 Reducing my energy bill Creating good, well-paying jobs in the energy sector
2 Addressing climate change by reducing
greenhouse gas emissions
Reducing my businesses’ energy cost
3 Getting rewarded to adjust when I use
energy
Getting compensated for when my
business uses energy
4 Creating good, well-paying jobs in the
energy sector
Addressing climate change by reducing
greenhouse gas emissions
5 Breathing cleaner air in my home Breathing cleaner air in my building Figure 8. Community Engagement Key Insights
Building and Housing Stock Analysis (BHSA) and Funding Gap Analysis. SDCP is developing a Building Housing Stock Analysis (BHSA) and Funding Gap Analysis that will be published in 2024.

The BHSA will provide data that will help SDREN identify broad opportunities for electrification and decarbonization across its member agencies. With the Funding Gap Analysis, SDCP will be able to determine existing gaps in current electrification, decarbonization, and energy efficiency 17 funding (including funding from the Infrastructure Investment and Jobs Act and Inflation Reduction Act that flows directly to customers and those distributed to States and agencies).

This will allow SDCP to make strategic decisions about how electrification programs are designed and identify investments needed to achieve our goals.

Stakeholder Engagement
In alignment with SDREN’s guiding principles, comprehensive engagement with key stakeholders was conducted during the preparation of this Business Plan. Key stakeholders include regional and community organizations as well as energy efficiency stakeholders across the state as detailed below. A majority of feedback was overwhelmingly positive with support for the formation of an SDREN, along with the proposed structure, values, strategies, and programs. A summary of this feedback and responses can be found in Exhibit 3 - Appendix X. ● SDG&E: SDCP met with SDG&E representatives on numerous occasions to discuss proposed programs and understand how services would be designed to avoid overlap and duplication. This included sector-level meetings with the appropriate SDG&E EE team members to walk through each program and discuss any comparable offerings and initial coordination strategies. The resulting SDCP work product that was reviewed with SDG&E during sector-specific coordination meetings can be found in Exhibit 3 - Appendix X. These conversations, alongside research into SDG&E portfolio, informed the sector specific coordination detailed within the Portfolio Plan. It also set a strong foundation for continued collaboration moving forward.
● San Diego Regional Climate Collaborative (SDRCC): SDRCC was formed in 2011 as a network for public agencies to advance climate change solutions that mitigate greenhouse gas emissions and adapt to the effects of climate change. Partnering with academia, non-profit organizations, and business and community leaders, the Collaborative raises the profile of regional leadership, shares expertise and leverages resources.11 ○ SDREN was presented to members on multiple occasions through the Regional Energy Resilience Working Group, which was launched in March 2023. Made up of approximately 30 members municipalities, educational entities, SDG&E, environmental NGOs, and consultants, this group was prioritized for early engagement and feedback. This included presenting both the draft governance structure and SDREN draft programs for feedback.
● Local governments and public agencies: Individual meetings were held with fourteen of the eighteen cities within the county and three key regional public agencies to collect feedback on SDREN programs and strategies. These agencies are listed below and individual letters of support from eleven of these agencies can be found in Exhibit 3 - Appendix X.
11 https://www.sandiego.edu/soles/centers-and-institutes/nonprofit-institute/signature-programs/climate-collaborative. 18 ○ Chula Vista, City of San Diego, Encinitas, Imperial Beach, La Mesa, National City, El Cajon, Lemon Grove, Poway, San Marcos, Solana Beach, Carlsbad, Oceanside, Vista, San Diego Association of Governments (SANDAG), Port of San Diego, and the San Diego Air Pollution Control Board, Clean Energy Alliance. ● CPUC Energy Division: Monthly meetings were held from August 2023 through December 2023 to provide updates on Business Plan development and collect feedback on various elements of the SDREN formation and strategy.
● Existing RENs: SDCP met with existing RENs across the state individually for general guidance and best practices during the planning process and Business Plan
development. They also engaged with the newly formed
CalREN, composed of all RENs, for feedback on draft
programs, stakeholder engagement, and Business Plan
strategies.
● SDCP Board of Directors Meetings: SDCP staff secured Board support early in the process to lead efforts in forming a new REN and briefed them on progress throughout the Business Plan development. These meetings are outlined below:
○ May 2022 - SDCP staff presented an update on customer energy programs and outlined CPUC funding opportunities including REN formation as an option and discussed next steps to hire staff to lead development of application and program management.
○ January 2023 - SDCP staff discussed leading initial steps in regional effort to form a REN as priority for 2023.
○ February 2023 - SDCP staff presented an update on REN formation progress to include mention of open request for proposal for professional services to support Business Plan Application development and development of the SDREN governance structure.
○ April 2023 - SDCP staff presented an update on REN formation at 2023 Strategic Planning Session and reported addition of 1 full time employee dedicated to REN formation; obtained approval of Professional Services Agreement for consulting services to support REN formation.
○ October 2023 - SDCP staff presented an update on REN formation and proposed programs, and budget range to the Board for feedback.
19 ● SDCP Community Advisory Committee (CAC) and CAC Programs Ad-Hoc Committee:

SDCP staff received feedback and support on SDREN proposed governance, programs, and budget and briefed them on progress. These meetings are outlined below:
○ September 6, 2023 (CAC Programs Ad-Hoc) - SDCP staff presented an update on REN formation progress, draft programs and governance.
○ September 14, 2023 (CAC) - SDCP staff presented an update on REN formation progress, draft programs and governance.
○ October 4, 2023 (CAC Programs Ad-Hoc) - SDCP staff presented an update on REN formation progress and proposed budget.
● Regional Stakeholders: SDCP met with several regional stakeholders, including Community Based Organizations (CBOs), labor groups, and organizations that could support SDREN efforts, if authorized. During these discussions, SDCP presented formation concepts and draft program ideas:
○ Art Produce, BID Alliance Building Trades, Business for Good, Casa Familiar, Center for Community Energy, Chicano Federation, City Heights Community Development Corporation, Climate Action Campaign, Community College Foundation, Environmental Health Coalition, ICC, Labor Group IBEW 569, Local Government Sustainable Energy Coalition, MAAC, North County Chamber of Commerce, Palomar College, Project New Village, San Diego Community College District, San Diego Foundation, San Diego Green New Deal Alliance, San Diego Workforce Partnership, San Diego Building Electrification Coalition, San Diego Cleantech, San Diego Green Building Council, San Diego Regional Chamber of Commerce, San Diego Regional Climate Collaborative, San Diego State University, Small Business Utility Advocates, South County Economic Development Council, Southwestern College, Urban Collaborative Project, USD Sustainability, YouthWill. ● California Energy Efficiency Coordinating Committee (CAEECC): On November 29, 2023, representatives from SDCP and the County of San Diego attended the regularly scheduled CAEECC meeting to present to CAEECC in accordance with CPUC Decision 19-12-021.12 Staff were able to respond to all questions following the presentation and overall the overview was positively received. The CAEECC presentation and resulting summary report of feedback and responses is included in Exhibit 3 - Appendix X.

Service Territory
The SDREN service territory is home to 3.3 million people and includes the County of San Diego, 18 incorporated cities, 18 Tribal governments, 16 significant naval and military installations, 47 school districts, and 24 water districts. Public agencies or districts own over 60% of the land in the County13. The SDREN territory includes San Diego County, 70-miles of coastline, and shares an international border with Mexico. While the region’s coastline is highly developed and populated, there are a significant number of rural and semi-rural communities in the southern and eastern portions of the county.14 The territory is a microcosm of the state and includes 14https://www.sandiegocounty.gov/content/dam/sdc/pds/ProjectPlanning/NS/Newland%20DEIR/County%20Land%20Use%20El ement%20Figure%20LU-1%20(Regional%20Cat.%20Map)%20EXISTING%20AND%20PROPOSED.pdf. 13 SanGIS.
12 D.19-12-021, pg. 21 and OP2.
20 farming and non-farming workforces, with over 100 languages spoken,15 a large tourism economy accompanied by the highest cost of living in the United States, and the highest energy rates in California.

Figure 9. SDREN will serve San Diego County, which is bordered by the Pacific Ocean, Orange County, Riverside County, Imperial County, and Mexico.

RENs currently cover all densely (or highly) populated electric IOU-serviced counties within California, except for the San Diego region (see Figure 10 below). Approval of the SDREN will close this gap and enable RENs to fulfill the CPUC’s vision for RENs statewide to complement and supplement services not provided by IOUs. Existing collaborations established within the region make it well-suited to be designated as a single-county REN. 15 https://www.sandiego.gov/economic-development/sandiego/facts. 21 Figure 10. Authorized REN Territories
The following table showcases statewide RENs and their comparative size and demographic metrics.

Table 2. Statewide RENs: Size and Demographics
REN Countie
s
Cities Population Area (Sq
Miles)
Population/Sq
Miles
IOU Territory
SDREN 1 18 3.3 million 4,210 784 SDG&E
RuralREN 31 115 7 million 78,249 89 PG&E, SCE, SCG
I-REN 2 52 4.5 million 27,263 170 SCE, SCG
BayREN 9 101 7.8 million 6,907 1,123 PG&E
SoCalREN 12 226 20 million 50,000 400 SCE, SCG
3C-REN 3 25 1.6 million 7,877 211 PG&E, SCE, SCG
22 Geography
San Diego County covers approximately 4,210 square miles, including 70 miles of coastline, bordered on the south by Mexico. The region is highly diverse in its geography and biology, situated in the rolling hills and mesas that rise from the Pacific shore to join with the Laguna Mountains to the east. San Diego Bay is one of the country's finest natural harbors, hosting tremendous biodiversity. The region covers a large area of vastly different terrain, from miles of ocean and bay shoreline, densely forested hills, and fertile valleys to mountains, canyons, and deserts.16 This is reflected in the region’s diverse range of climate zones: the coastal climate zone 7, inland climate zone 10, mountain climate zone 14 and desert climate zone 15.

Figure 11. Division of Climate Zones in SDG&E territory17 Tribal Context
The Kumeyaay, referred to as Diegueno by the Spanish, were the original inhabitants of San Diego County. The San Diego region is built on Kumeyaay and Luiseno land, with the unincorporated area of San Diego County being home to 18 Tribal governments represented by 17 federally recognized Tribal Governments, more than any other county in the United States.18 The County of San Diego and SDCP acknowledge the harmony that existed among the land, nature and its original peoples, who have since endured displacement, persecution, and systemic oppression. The County and SDCP pay respect to the unceded territory and homelands of the eighteen federally recognized Tribes in our region, from four cultural groups, the Kumeyaay/Diegueño, the Luiseño, the Cupeño, and the Cahuilla. As climate change increasingly threatens the region, its peoples, and its cultural identities, the County and SDCP aspire to learn from Traditional Ecological Knowledge to create greater harmony with our natural environment and preserve the health of our planet. SDREN’s program portfolio will work to find opportunities to provide custom services to San Diego’s Tribal communities to bolster their access to resources that support their commitment to environmental stewardship. 18 https://www.sandiego.edu/native-american/reservations.php. 17 Image Credit: SDG&E (https://webarchive.sdge.com/baseline-allowance-calculator). 16 Regional Focus 2050 Study, San Diego Foundation 2008. 23 Figure 12. Federally Recognized Tribal Lands within San Diego County Demographics
San Diego County is the second most populous of California's 58 counties, and the fifth largest county in the United States, with a population of 3.3 million.

The San Diego region’s population is not anticipated to grow significantly by 2050. Between 2016 and 2050, the San Diego region was expected to grow by nearly 700,000, however San Diego's population is expected to peak in 2042, and then decline by about 100,000 by 2060, according to the latest regional forecast by the San Diego Association of
Governments (SANDAG).19 Estimates are that by 2060,
the region is only expected to have 40,000 more people
than it does today, though forecasts still expect the
region to add more jobs and housing.

The region’s population is aging. The senior and disabled populations are growing disproportionately compared to
the rest of the population. By 2050, almost ¼ of the
region’s residents will be 65 or older. However, the
19https://www.sandag.org/regional-plan/sustainable-growth-and-development. 24 current largest age demographic is age 25-34, which represents a large number of renters and the need to serve a population with marginal disposable income, especially in disadvantaged communities.20
The San Diego region is ethnically diverse and will be increasingly so by 2050. Of residents under 18, 46% are Latino/a, and this population is expected to continue to grow at a rapid rate.

Approximately 22% of the county's population are immigrants, including refugees who come from other countries, speak 100 different languages, and have various needs as they assimilate into their new environment.21
Table 3. Demographic Data for San Diego County
Category Regional Average Stats
Land Mass (sq mi) 4,210
Population 3,298,634
Population within “underserved communities” 1,855,064
Median Household Income $91,003
Percent of Residents in Rentals 47%
Unemployment Rate 5.4%
Under 5 6.0%
Under 18 20.7%
Above 18 78.3%
65 or Above 14.1%
Median Age 36.9
Language Other Than English Spoken at Home 36.30%
Percentage of Veterans 7.4 %
Percentage in Poverty 10.60%
Climate Impacts
The San Diego region is a popular place to live, known for its enviable lifestyle, beaches and amenities. The region is uniquely vulnerable to the impacts of climate change, with significant implications for its future success absent urgent collective action.22 All climate simulations indicate that heat waves will increase in frequency, magnitude, and duration. Data released by The National Oceanic and Atmospheric Administration (NOAA) 22 Ibid.
21 San Diego Economic Equity Report 2023.
20 https://www.sandiego.gov/economic-development/sandiego/population. 25 confirms the predicted trend of the San Diego
region growing increasingly warm and dry.23 Over
the next half-century, the warming in the San
Diego region will likely equal or exceed the
warming experienced over the last 100 years.

Summers will be hotter, particularly in the inland
areas, and on average, San Diego's daytime
temperature will be 1.5 to 4.5 degrees higher than
today.24 Analysis has shown a 10-degree increase
in temperature leads to a 3% increase in deaths on
any given day. Heat waves have claimed more lives
in California in the past 15 years than any other
disaster events. In San Diego, heat-related health
impacts occur at a higher rate in the inland regions than near the coast, though coastal San Diegans are less likely to have air conditioning.25
Climate change will negatively impact the availability of both imported and local water supplies, while population and economic growth will drive up water demand. If current trends continue, by 2050 regional water demand is projected to increase 37 percent above recent levels.

Regional water demands will continue to be met primarily by importing water, with imports from the Sacramento Delta and the Colorado River comprising about 80 percent of total supplies in 2050. Climate change threatens the reliability of both sources, however. Climate change could yield more instances of drought and reduce the chances that existing water sources will be able to meet projected demands. Despite plans for water conservation, desalinization, and recycling, demand for fresh water will outstrip supply by 2050, with growing potential for conflicts due to resource scarcity26.

Increased air pollution will take a toll on public health, particularly for the elderly, who will comprise almost ¼ of the population by 2050. San Diego ozone levels, already above federal standards, are in nonattainment, persistently exceeding the federally designated 8-hour ozone standard.27
Wildfires will become more frequent and more intense. San Diego County already has among the worst fire conditions in the country, and the situation is likely to worsen with climate change. San Diego has experienced some of the State's most devastating fires in the last two decades. Moreover, the SB535 disadvantaged communities map overlays the fire threat, warranting the need for resilience and energy efficiency in the region. Wildfire frequency has increased in direct proportion to population growth, portending a hazardous trajectory for the future. Different climate change models yield somewhat different predictions about the 27 San Diego Climate Action plan, https://www.sandiego.gov/sustainability-mobility/climate-action/cap. 26 Ibid.
25 Kalansky, Julie, Dan Cayan, Kate Barba, Laura Walsh, Kimberly Brouwer, Dani Boudreau. (University of California, San Diego). 2018. San Diego Summary Report. California’s Fourth Climate Change Assessment. Publication number: SUM-CCCA4-2018-009. 24 Regional Focus 2050 Study, San Diego Foundation 2008. 23 U.S. Climate Normals 2020, NOAA.
26 frequency, timing, and severity of future Santa Ana wind conditions, leading to uncertainty regarding how San Diego regional fire regimes may differ in the future due to climate change.

The CPUC High Fire Threat District Map entirely encompasses the service area aside from the most coastal communities in the region.28
The seasonal precipitation for San Diego is roughly ten and a half inches depending on which series of seasons is used for the average. The impact of climate change on precipitation is not entirely clear at this time. Analysis indicates that while San Diego will retain its strong Mediterranean climate with relatively wetter winters and dry summers, projections of future precipitation suggest the region will continue to be highly vulnerable to drought.

Over the next five decades, sea level rise will increase substantially—from threefold to almost sixfold—over its historical rate. By 2050, sea levels will increase relative to the 2000 level by 12-18 inches. As sea levels rise, there will be an increased incidence of extreme high sea level events (which occur during high tides, often when accompanied by winter storms and sometimes exacerbated by El Niño occurrences). Low-lying coastal areas of San Diego are at risk due to the combination of waves, tides, regional wind and barometric effects, El Niño effects and sea level rise. Sandy beach areas, wetlands, commercial, municipal, and residential properties will be lost or harmed, with implications for ecosystems, the economy, recreation, and public health.

Regional Energy Profile
The region’s energy, electricity and methane-based natural gas, has historically been served by SDG&E. In 2019, two CCAs, SDCP and Clean Energy Alliance (CEA) formed. CEA began offering services to the cities of Carlsbad, Del Mar, Solana Beach, Escondido, San Marcos, Oceanside, and Vista in 2021. CEA is a member of the SDREN inaugural Advisory Committee and has been an active participant in ongoing and standing collaboration discussions with SDCP and SDG&E on customer energy programs.
28 https://www.cpuc.ca.gov/industries-and-topics/wildfires/fire-threat-maps-and-fire-safety-rulemaking. 27 Figure 13. Map of SDCP and CEA Service Area
SDG&E has been the primary provider of energy programs in the region. SDG&E is the only IOU service territory without a REN, providing ample opportunity to bring additional resources to the region’s communities. SDG&E's rates are expected to increase significantly between now and 2027.29
IOUs have inherent constraints within their EE portfolio, including cost-effectiveness requirements that limit the breadth of program offerings. SDREN will work to fill demonstrated gaps in the region in program participation. For example, historical claims filed by SDG&E in Climate Zone 7, which covers the coastal region of its territory and includes underserved communities, houses 69% of the population but only 49% of the claims. Market characterizations performed by SDCP and its partners reveal opportunities for SDREN to make significant programmatic contributions to the region.

In addition to existing programmatic gaps, the demand for electricity in San Diego County is projected to increase significantly by 2050, largely driven by population increases, greater frequency of heat waves, and peak demand for cooling. Annual electricity consumption is expected to increase by more than 60% and peak loads by 70%. That will push consumption from the current level of approximately 20,000 gigawatt hours (GWh) to more than 32,000 GWH in 2050. Climate change accounts for approximately 2 percent of the expected rise in electricity consumption by 2050, and up to 7 percent of the increase in peak demand.30 30 Regional Foundation 2050 Study, San Diego Foundation. 29 Energy Toolbase. Electric Bill Inflation in California. 2023" (for electric rates; Environmental Defense Fund. A.22-05-015 Opening Brief. Aug 14, 2023.
28 Climate change will also have an impact on system reliability unless adequate planning and investments are made and consumers modify their consumption patterns. Peak demand will increase due to higher frequency of heat waves. Summertime, when demand is highest, is also the time when electric utility operating efficiency is lower and line losses increase—both due to temperature effects.31 These impacts will conspire to make managing regional demand even more challenging.

Equity Considerations
A goal of SDREN is to ensure that no communities are left behind in the transformation to a clean energy economy. In alignment with the CPUC’s equity segment, SDREN is using “underserved communities” and “hard-to-reach customers” to describe the target populations in their portfolio.

Figure 14. Defining Underserved32 Customers in SDREN’s Service Territory Figure 15. Defining Hard-to-reach Customers in SDREN’s Service Territory 32 Any residential or public customers living within an underserved community are considered an underserved customer. Other customers must also be an “underserved business group” as defined within Gov. Code Section 12100.63(h)(2) within an underserved community.
31 Ibid.
29 In reviewing this criteria, SDREN has determined that approximately 56% of the region’s population lives in an underserved community. Given this, along with the demographic trends of a growing non-English speaking population, a geography with the highest cost of living in the US, and the highest electric and gas rates in California, SDREN will devote the majority of its portfolio to programs designed to target hard-to-reach and underserved communities. SDREN acknowledges the region’s substantial disparities in poverty. Compared to their White counterparts, Latino/a San Diegans under the age of 18 were twice as likely to live in poverty, while young Black San Diegans were 2.5 more likely.33
33 San Diego Economic Equity Report 2023.
30 Figure 16. A map of the region with multiple indicators for underserved communities including CalEnviroScreen DACs, Tribal lands, low-income communities, and FRPM.

SDREN has undertaken stakeholder engagement initiatives and will continue to gather input from stakeholders and member agencies to inform the design and execution of programs that address long-standing barriers and that are accessible to communities who have experienced structural exclusion.34
SDCP, the City of San Diego, and the City of Chula Vista have committed ongoing investments to “communities of concern”, which are defined as the top 25% scoring areas from CalEnviroScreen, known as Disadvantaged Communities (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.
34 Stakeholder engagement further described in Section vii. Alignment with Legislative and CPUC Requirements and Relevant Action Plans. Also see Appendix X showcasing letters of support from stakeholders engaged in the process. 31 SDCP is committed to supporting populations historically underrepresented in energy program participation and receiving associated benefits. As such, SDCP has committed at least 50% of a program’s non-administrative budget, to the extent allowed by funding sources, to participation from Communities of Concern. SDCP will center Communities of Concern in program design to enable participation by all customers. It is important to note that while SDCP will follow the commitment with internal funds, it may not be possible with external funds due to specific rules and regulations.

In 2019, the City of San Diego developed the first-of-its-kind Climate Equity Index (CEI), in partnership with several community-based organizations representing communities of concern or advocating for environmental justice policy development. Specifically, the City of San Diego identified communities of concern 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 analysis35. In an ongoing attempt to elevate community-based language and needs, SDREN will continue to consider any indicators or definitions proposed by member agencies.

The goal of the CEI is to measure the level of access to opportunity residents have within a census tract and assess the degree of potential impact from climate change to these areas. The CEI is the first tool in the country that considers the effects of climate change, environmental pollution, and vulnerable populations. With the CEI, the City has better identified communities of concern to include census tracts with very low, low, and moderate access to opportunity.

These include Oceanside, Escondido, El Cajon, and National City. These regions are also considered underserved according to the CPUC’s definition.

Energy costs and the energy burden for San Diego County residents disproportionately impact underserved communities. In 2021, an estimated 335,000 San Diegans were living below the poverty line36. With about one in ten San Diegans not having enough income to pay for basic expenses, this demonstrates a significant need to reduce energy burden. According to the DOE's Low-Income Energy Affordability Data (LEAD) tool, the national average energy burden for low-income households is 8.6%, three times higher than the estimated 3% for non-low-income households. In San Diego, low-income households paid an average of 3.9% of their income for energy, while all households paid an average of 2.3%. SDREN’s proposed portfolio brings additional customized resources that are best equipped to penetrate these more vulnerable populations and overcome typical barriers to program participation. 36 San Diego Economic Equity Report 2023.
35 City of San Diego Climate Equity Index, https://www.sandiego.gov/sites/default/files/prbr210715a-item201b.pdf. 32 Figure 17. A map demonstrating the region’s energy burden37 Workforce
Over the last 50 years, the San Diego region’s
economy has changed from one reliant on
military, naval shipping, agriculture, and fisheries
to a more diversified economy including
manufacturing, scientific research,
communications technology, and tourism. The
San Diego region’s economy relies heavily on the
service sector for the majority (72.2%) of its
output. Major service-sector industries include
financial, trade, professional and technical
services, communications, high-technology, and
hospitality. With respect to the production of
goods in San Diego County, manufacturing,
37 Public data collection effort of customers reporting their annual energy cost and income. 33 construction, and agriculture are the largest industries, accounting for 7.3 percent, 5.3 percent and 1 percent of total output respectively.

San Diego’s unemployment rate is currently 5.4%. Employment declined less and recovered more quickly than in most other regions in California after the COVID-19 pandemic. The San Diego region has seen above-average employment growth, sitting at 2.9% relative to pre-pandemic levels (1.3 percentage points higher than statewide). Jobs in professional, scientific and technical services, health care, and transportation and warehousing are driving growth in the San Diego region. Expansions in administrative and support services have also contributed to job growth in the region.

The RDF-Technical Report estimates that no jobs in the region’s fossil fuel-based industries will be displaced by 2030, even with contractions in the fossil fuel demand.38 However, job displacements will occur between 2031 – 2050, as oil consumption in the region falls by 95 percent relative to the present level and natural gas consumption falls by 75 percent. The modeling used in the RFD-Technical Report indicates that decarbonization will result in net job creation overall. Therefore, advancing the transition to a zero emissions economy is a critical part of regional decarbonization, and developing a viable set of just transition policies for the workers in the community who will experience job displacement between 2031 – 2050 will be essential.

There is an opportunity to meet demand for energy jobs that support statewide goals as the younger population (28% under 18) grows. The regional decarbonization framework projects overall net job creation due to decarbonization initiatives.39 However, creating jobs is not enough to prevent negative impacts on workers. Ensuring the creation of high-road jobs is key.

High-road jobs are defined by both job quality (i.e., family-supporting wages and benefits, long-term career pathways, and worker protections) and job access (i.e., access and entry-points to good jobs for local workers, and training to support advancement). High-road jobs are a win-win approach for employers and communities as employers gain access to skilled and committed workers, and community members gain access to good careers. Investments in growing, diversifying, and upskilling the workforce can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to delivering emissions reductions and achieving climate targets.

Energy Efficiency Strategy
As described previously, SDREN’s proposed EE strategy for the San Diego region builds off of the foundation established through long-standing local collaborations in the region and are informed by SDREN’s values and principles to deliver on the goals of decarbonization, comprehensive EE services, and building the local energy economy. 39 Eric Larson et al., “Net-Zero America: Potential Pathways, Infrastructure, and Impacts - Final Report Summary” (Princeton University, October 29, 2021),
https://netzeroamerica.princeton.edu/img/Princeton%20NZA%20FINAL%20REPORT%20SUMMARY%20(29Oct202).pdf. 38 Carol Zabin, Maggie Jones, and Betony Jones, June 13, 2022, “Putting San Diego County on the High Road: Climate Workforce Recommendations for 2030 and 2050,” Inclusive Economics, Oakland, CA. 34 Collectively, the portfolio-level strategies incorporate several key approaches as shown in Figure 18 below.

Figure 18. SDREN Key Strategies
These key strategies will be integral to the SDREN through the Business Plan period and beyond.

The below strategies touch on strategies that were central to the first four-year Portfolio Plan and will continue to be refined over the Business Plan period.

Savings Forecasting and Quantification Methods
SDREN’s savings forecast methods vary by the type of program being delivered. SDREN’s savings projections were developed using only the approved savings assumptions and/or methodologies, as follows:
● SDREN is proposing a single resource acquisition program that will comply with D.23-06-055 by using a meter-based method for savings measurement. Savings forecasts were developed taking into account program ramp-up and available incentive budgets, including incentive rate estimates in line with other similar programs. Savings claimed will be based on actual savings realized and will apply a population-level NMEC approach in alignment with the most current version of the CPUC’s NMEC Rulebook. ● All equity and market support programs utilize Deemed Measures that are currently approved and active in the eTRM (California Electronic Technical Reference Manual) database and follow the Statewide Deemed Workpaper Rulebook. 35 SDREN is not using the current custom process and meter-based approaches to savings measurement as they will not be cost effective with the target customers in equity and market support segmented programs.

While SDREN recognizes the benefits of meter-based savings approaches, there are currently limitations to its effectiveness for certain customers. SDREN will actively engage in statewide working groups to overcome barriers and explore more cost effective solutions for smaller customers. SDREN third-party implementers will also be encouraged to explore opportunities to incorporate meter-based savings approaches into the programs. SDREN will also explore through the JCM process how to support SDG&E third-party program providers with the delivery of meter-based savings projects, as appropriate.

Strategies for Market Intervention and Energy Efficiency Adoption SDREN will incorporate the following strategies for market intervention and EE adoption.

Table 4. Strategies for Market Intervention Based on Target Audience Target Audience Strategy
Non-English speaking
resident or business owner
● In-person equitable and inclusive education and
outreach (i.e. in-language materials with cultural
understanding, vision and hearing impaired customers,
etc. taken into consideration) conducted by trusted
local individuals when possible.

Homeowner, business owner,
public agency
● Offer comprehensive concierge services and speak to
holistic benefits to simplify adoption by customer and
present a single point of entry to access programs,
including SDG&E offerings.
● Provide customized technical assistance paired with
advisory services to identify and install comprehensive EE and IDSM opportunities at homes/facilities.
● Offer funding, financing assistance, and guidance to
customers on how to qualify, utilize, and stack funding sources, such as IRA, OBF, TECH, and SGIP.
● Provide direct installation of no to low cost energy
efficiency measures.
● Deliver outreach, education and training to improve
access, increase participation, increase awareness and
knowledge of how to manage and reduce energy
consumption.
● Partner with CBOs to deliver messaging and services
through local, trusted community members.
36 Tribes
● Offer direct funding to Tribal nations to propose,
design, and deliver tailored programming and initiatives to meet their unique community needs to increase
access to EE programs, reduce energy burdens and
decarbonize assets.
● Provide ongoing access to technical advisors with EE
expertise to support successful implementation of
programming and initiatives.
● Also, refer to all strategies noted above for other
public agencies.

Disadvantaged workers40 ● Build and leverage external partnerships to enhance DAC worker outcomes such as:
○ Employers to provide training to staff and boost
opportunities for growth, and
○ Local community college partnerships to provide
college level courses and skill development
opportunities.
● Provide education through the provision of training,
certifications, networking, and apprenticeship
opportunities to build skills to enter the green
workforce.
● Offer wraparound services such as career coaching to
match participants with employers to secure clean
energy jobs.

Employers connected to EE
deployment
● Support and work alongside employers to understand
and overcome barriers to offer targeted EE training for staff.
● Deploy a targeted survey to local employers to
determine emerging clean energy industry careers and
required skills and qualifications for incoming
professionals to be successful.
● Stack opportunities available to employers by
connecting them to other workforce development
programs.
40 Disadvantaged worker definition from D.19-08-006, Attachment B, p.6: “Disadvantaged Worker” means a worker that meets at least one of the following criteria: lives in a household where total income is below 50 percent of Area Median Income; is a recipient of public assistance; lacks a high school diploma or GED; has previous history of incarceration lasting one year or more following a conviction under the criminal justice system; is a custodial single parent; is chronically unemployed; has been aged out or emancipated from the foster care system; has limited English proficiency; or lives in a high unemployment ZIP code that is in the top 25 percent of only the unemployment indicator of the CalEnviroScreen Tool. 37 Code enforcement officials
and stakeholders
● Leverage data driven insights to develop tools,
technical resources, and templates for permitting
electrification and other energy efficiency measures.
● Educate officials and authorities having jurisdiction (AHJ) about permitting and codes.
● Provide person-to-person support through an Energy
Code Coach to provide comprehensive compliance and
enforcement strategy support services.

New Strategies for Spurring Innovation
With a focus on SDREN’s principles of environmental equity, collaboration, and community-driven SDREN will incorporate the following strategies to spur innovation throughout the portfolio:

Table 5. Strategies for Innovations Based on SDREN Principles SDREN Principle SDREN Strategies for Innovation
Environmental Equity ● Focus on methods that maximize non-energy benefits for equity customers such as:
○ Engage multiple markets to identify best
strategies to reach equity customers, and
○ Build environmental justice priorities and
opportunities to suggest innovations into all
program solicitations.
● Compensation for CBOs that engage and support SDREN.

SDREN would also provide any needed energy education
and training to these groups, in order to build staff
capacity and more effectively contribute to SDREN goals.

Collaboration ● Prioritize collaboration, coordination and flexibility in program design in order to fill gaps and develop future innovations through the following strategies:
○ Work with local energy program administrators
and implementers to optimize coordinated
service delivery and ensure resources are used
efficiently, and
○ Work with SDREN Advisory Committee members
and other regional partners, such as CBOs and
local governments, to design approaches that
reflect local needs and priorities, and maximize
advantages for local communities.
38 ● Leverage and marshal financial resources, provide access to financing, integrate and stack funding sources.
○ This includes state and federal funding
opportunities, such as IRA and the CEC Equitable
Building Decarbonization DI Program, as well as
regional offerings, such as SDG&E programs,
where feasible.

Community-Driven ● Engage communities at early stages of planning to ensure the services that are developed and delivered not only reflect local needs and priorities but invest in
community based program delivery.
● Identify success measures reflective of desired
community outcomes, informed by SDCP’s Community
Power Plan and the County of San Diego’s Regional
Decarbonization Framework.
● SDREN Advisory Committee to include CBOs with the
role to advise on outreach and enrollment, provide
feedback on program evaluation reports, and
recommend program improvements.
● Ongoing engagement will focus on collecting feedback to inform 2028-2031 Portfolio Plan.
○ This will also be informed by the
Community-based pilot led by SoCalREN.41
● Tribal program designed to ensure community driven
and culturally-centered design and service delivery.

Strategy for Incorporating Low Global Warming Potential Refrigerants Hydrofluorocarbon refrigerants (HFCs) are “super” GHGs that are currently being phased out but significant support is needed to accelerate the San Diego region to a safe transition to Low Global Warming Potential (low-GWP) refrigerants. Low-GWP refrigerants will be incorporated into the portfolio using the following strategies.

Table 6. Strategies for Incorporating Low-GWP Refrigerants Based on Sector Portfolio Sector/Program SDREN Supporting Strategy
Residential, Commercial and
Public
● Offer education about low-GWP refrigerants with
customers receiving relevant measures or
recommendations within technical assistance offered.
41 D.23-06-055, OP 30.
39 ● Requirements for installers to use low GWP
refrigerants in newly installed equipment.
● Support proper reclamation of HFC refrigerants in
addition to providing measures with low-GWP
refrigerants.

Codes & Standards ● Provide information to all local permitting agencies and other market actors about the HFC phase out and
low-GWP refrigerants along with code requirements.

Workforce Education &
Training
● Incorporate training to participants on proper
installation and management of low-GWP Refrigerants
and proper reclamation of HFC-based refrigerants,
along with education about phase out and benefits of
low-GWP.

Additionally, SDREN will cooperate with the Market Transformation administrator should new HVAC and refrigeration initiatives be introduced to handle new low-GWP changes and regulations.42
IDSM Strategies
CPUC ruling D.23-06-055 authorizes PAs to propose IDSM programs through the submission of a Tier 3 Advice Letter no later than March 15, 2024, for programs to be launched during the 2024-2027 portfolio period. Guidance for what is to be included in the Advice Letter is anticipated to be issued by the Energy Division no later than January 1, 2024.43 Given that SDREN is not anticipated to be authorized as a PA before March 15, 2024, SDREN is proposing that the CPUC authorize SDREN’s IDSM strategy outlined below and described in further detail in Exhibit 2. If necessary, SDREN will file additional details as directed by the Energy Division or the Commission.

SDREN anticipates allocating the full cap of $4 million towards IDSM activities.44 The integration of other IDSM activities and services alongside EE is a cost effective use of resources to drive deeper decarbonization strategies across the region. In line with SDREN’s goals of decarbonization and the portfolio strategy of customized support, SDREN will comprehensively consider IDSM opportunities across all programs to be integrated throughout the portfolio. 44 Per CPUC ruling A.22-02.005, a PA may, but is not required to, expand up to 2.5 percent, or $4 million, whichever is greater, of its energy efficiency budget for the portfolio period, up to a maximum of $15 million, on a pilot basis for ongoing load shifting that reduces peak consumption.
43 The CPUC will allow IDSM programs to be proposed through the submission of Tier 3 advice letters no later than March 15, 2024, for programs to be launched during the portfolio period (2024-2027). 42 D.21-05-031 at 60.
40 SDREN’s proposed potential IDSM strategies across the portfolio include:
● Regional IDSM Working Group
a. Convene regional LSEs (CEA, SDCP, and SDG&E) to discuss IDSM programs, including building electrification, transportation electrification, demand response, distributed generation, storage, in order to optimize SDREN program design and delivery.
b. Discuss regional grid needs (e.g., hosting capacity, distribution congestion, etc.) to inform program design, electrification priorities, and operational strategies. c. As appropriate, update SDREN IDSM activities to incorporate feedback from Regional IDSM Working Group.
● Equipment specification
a. Document eligibility requirements of IDSM program, including equipment features and functionality, OEM eligibility, DERMS integration, and compatibility with relevant codes, industry standards and workforce needs. b. Work with SDREN implementers to align, to the extent possible, program QPLs with regional IDSM program requirements.
● Identification, Installation and Commissioning
a. Identification of IDSM opportunities based on customer preferences b. Incorporate enrollment (e.g., device enrollment) support and process (e.g., T&Cs acceptance) into SDREN programs, including marketplace offers, contractor partnerships, and ED guidance on incentive stacking and IRA reporting. c. Integrate device commissioning requirements for IDSM programs (e.g., digital connectivity commissioning, DERMS integration) into contractor driven SDREN program delivery.
d. Ensure customer preferences, awareness, and education activities are integrated throughout the program delivery lifecycle.
● Codes and Standards
a. Provide education and technical support to code officials on implementation of new requirements related to flexible load technologies (e.g., Title 24 Compliance Credits for Storage and HPWHs, Flexible Demand Appliance Standards) ● Workforce education and training
a. Incorporate flexible load program requirements, incentives, commissioning processes and other IDSM program material, into energy efficiency training modules for participating contractors.
b. Educate and collaborate with participating contractors on inclusive outreach, customer acquisition, and sustained customer satisfaction with technology and behavioral interventions contributing to IDSM program goals. ● Education and customer support
a. Assist customers in applying for additional IDSM funding and incentives b. Incorporate information on the opportunities and benefits of IDSM program participation into customer education and outreach materials and workshops. 41 Customers will be funneled into appropriate programs and decarbonization strategies that will result in event-based or permanent load shifting or load reduction. As part of its development of IDSM strategies, SDREN will closely coordinate with other IDSM programs and administrators.

Strategies for Tracking Outside Funding
The CPUC is correctly focused on leveraging non-ratepayer funds to increase EE project implementation opportunities for customers. Substantial new funding for EE and IDSM projects is being made available through federal and state agencies. Many of these federal and state programs have not yet been launched, and the final program designs and eligibility criteria have not yet been finalized. It is, therefore, not possible at present to know when and how these outside funds will be applied within SDREN territory to support specific customer EE activities.

SDREN is committed to the leveraging and stacking of non-ratepayer funding whenever possible, and supports the dissemination of information to customers, as a component of SDREN program’s ME&O, on the applicable state and federal funding that is available to support their EE and IDSM projects. Additionally, to reduce customer confusion and complexity, SDREN anticipates supporting customers through the process of securing these additional funds when appropriate.

A majority, if not all, of the state and federal funding that will be available will flow directly to customers and not through SDREN. In these cases, it may not be possible for SDREN to accurately track the use of these funds separately. SDREN can work through the program “energy coaches” to collect this information through customer consultations. Customers can also be requested to self-report through a program survey but this may be prone to data gaps when done voluntarily. SDREN is, however, supportive of future CPUC direction related to collecting information on customer use of non-ratepayer project funding that is feasible and practicable for SDREN to collect and track.

Portfolio Management Strategies
SDREN’s portfolio management approach is focused on helping underserved and hard-to-reach communities invest in and accelerate decarbonization strategies and actions that benefit them and hasten the transformation to a clean energy future. SDREN’s management strategies that help drive the distribution of budget across segments and sectors are described below in descending order based on priority for investment.
42 Segmentation Strategy Summary
Figure 18. Defining Equity
All programs within the SDREN portfolio have been designed with equity objectives in mind, regardless of segmentation. For example, a key strategy of SDREN’s portfolio is to involve communities, grassroots organizations, and CBOs early in program development to assess needs, design strategies, and deliver the programs that meet local needs. SDREN’s alignment with the CPUC’s ESJAP is described later under the section Portfolio Design and Alignment with Legislation and Relevant Action Plans.

Nearly half (46%) of SDREN’s portfolio is directed to Equity programs that support underserved communities. These programs will be key in driving progress towards SDREN’s long-term goal of equitable decarbonation of the San Diego region. To support this goal, SDREN has integrated the following strategies into its equity programs:
● Focus outreach on and target underserved and HTR customers. ● Provide in-person, equitable, and inclusive outreach and support services. ● Customized energy programs and strategies shaped by community input. ● 1:1 support to connect customers to all other available programs, services, and funding opportunities.
● Offer direct installation of energy efficiency measures.

Additionally, SDREN will market and support customers in leveraging other resources and programs to maximize the benefits to these communities.

Figure 19. Defining Market Support
43 A portfolio goal is to advance greater understanding and increase awareness and participation in energy programs, reduce the energy burden for communities, and lessen market confusion.

SDREN’s Market Support strategy, comprising over one third (34%) of its portfolio, seeks to bolster the green energy workforce in underserved communities by providing green career pathways for K-12 students, training adults who are incumbent or new to the green job market, developing skills, and supporting employers to increase green career opportunities.

A centerpiece of SDREN’s Market Support strategy is to engage public sector agencies to adopt decarbonization measures. SDREN will support the County, 18 incorporated cities, 47 school districts and 31 water agencies to implement energy efficiency and decarbonization strategies, including agency wide benchmarking and strategic energy resilience planning. Start to finish customized, unbiased, hands-on, expert guidance and support will enable public agencies to accelerate adoption of urgently needed clean energy actions.

Figure 20. Defining Resource Acquisition
Fourteen percent of the portfolio budget is directed to Resource Acquisition through a program supporting commercial property owners. This program will help SDREN advance decarbonization, reduce energy burdens, reduce energy consumption, and increase participation in and access to EE programs. The program will focus outreach efforts on small to medium HTR and underserved commercial customers that may be missed or passed over by other programs. A key strategy will be to provide performance based incentives designed to cause project developers (aggregators) to deliver projects that reduce peak demand usage and verifiable savings. It is intended to deliver a majority of the TSB savings for the portfolio.

Sector Strategies
Following is an overview of SDREN’s strategies for each portfolio sector in descending order based on priority for investment.

Residential
SDREN proposes two Residential programs, both of which address equity. Both fill gaps in current SDG&E offerings to multifamily and single-family customers by providing customized support and education. Because residential customers are typically confused by the number of program offerings and entry points, pairing behavioral engagement is a key strategy to 44 demystify funding opportunities for residents. Programs highlight non-energy benefits and incorporate a pathway to electrification through education about "healthy homes." The total eight-year budget for Residential programs is $84 million, representing 29% of the overall portfolio.

Commercial
SDREN proposes three Commercial sector programs that fill gaps and coordinate closely with SDG&E programs. Two are equity programs supporting small-medium businesses by raising awareness and increasing adoption of EE and other IDSM practices and measures. These programs will deploy a direct install approach to alleviate the cost barrier to participation and allow store owners to participate in energy efficiency program offerings as store owners have limited staff capacity and capital to invest in energy efficient equipment. The third program is a resource program providing incentives to commercial customers that realize peak demand reduction and verifiable energy savings. The total eight-year budget for the Commercial sector is $83.8 million, representing 29% of the SDREN portfolio.

Public Sector
The Public Sector segment offers two programs that fill gaps in SDG&E services. One is a market support program that offers customized and unbiased end to end EE project services to public agencies within San Diego County. The second is an equity program that will collaborate with Tribal communities to determine program design and delivery. There are no current Tribal specific strategies or programs offered by SDG&E. The total eight-year budget for the Public Sector is $56 million, representing 20% of the SDREN portfolio.

Cross-Cutting – Workforce, Education and Training (WE&T) SDREN proposes three Market Support WE&T programs that fill gaps and support development of a green workforce representative of vulnerable populations, with opportunities to build more resilient communities. These programs support green career development for K-12 students, provide clean energy jobs training for new market entrants, and green workforce training through employers. The total eight-year budget for the Cross-Cutting WE&T sector is $46.3 million, representing 16% of the SDREN portfolio.

Cross-Cutting – Codes & Standards (C&S)
SDREN’s proposed C&S program will supplement and complement both the SDG&E C&S programs and all statewide C&S programs. SDREN’s program will provide local agencies with policy and compliance support and enhance communication and experience among permitting authorities and permit applicants.

SDREN’s C&S program works with public agencies to provide policy and compliance support.

The program fills gaps in the current SDG&E program which primarily focuses on advocacy at the CEC and DOE related to appliance and building standards. Programs designed for permitting agencies and local governments focus on Title 24 compliance education and adopting Title 24 45 reach codes. These programs are offered statewide by PG&E, SCE and SDG&E with limited local customization. All RENs in the state will have a C&S offering starting in 2024 highlighting a clear gap in San Diego for this enhanced support. The total eight-year budget for the Cross-Cutting C&S sector is $17.6 million, representing 6% of the SDREN portfolio.

Distribution of Budget Among Sectors and Segments
The below tables provide a summary of the budget allocations based on the strategies described above.

Table 7. Budget Overview by Segment (excluding EM&V)
Segment # of Programs 8-year Budget % of Portfolio
Equity 5 $132,578,532 46%
Market Support 3 $97,891,627 34%
Resource Acquisition 1 $39,690,430 14%
Codes & Standards45 1 $17,640,065 6%
Table 8. Budget Overview by Sector (excluding EM&V)
Sector # of programs 8-year budget % of Portfolio
Residential 2 $84,067,503 29%
Commercial 3 $83,791,159 29%
Public 2 $55,997,047 20%
CC-WE&T 2 $46,304,880 16%
CC-C&S 1 $17,640,065 6%
Portfolio Coordination
A key for success in achieving SDREN’s energy goals and outcomes is the effective collaboration and coordination among the numerous entities providing energy services to constituents.

SDREN will actively coordinate with the following organizations and programs:
● RENs statewide. SDREN will join and engage in ongoing participation in the newly formed CalREN46 organization.
● SDG&E. SDREN will coordinate with SDG&E in several ways, including (1) through the annual Joint Cooperation Memo (JCM), (2) ongoing regular coordination at the portfolio level, and (3) additional coordination at the program level with SDG&E and associated third party implementers where complementary services are offered by SDREN. 46 https://californiaregionalenergynetworks.org.
45 Codes & Standards is classified as both a segment and as part of the Cross-Cutting sector. 46 ● Statewide programs. SDREN will coordinate with the new BayREN Statewide offering and will coordinate with all applicable statewide programs, including:
○ Statewide Reach Codes Program
○ Energy is Everything
○ Energize Careers
○ Golden State Rebates
○ Quality Residential HVAC Services Program
○ Comfortably California
○ CA Food Service Instant Rebate Program
○ Higher Education Energy Efficiency Program (HEEP)
○ California Energy Design Assistance Program (CEDA)
● Other regional partners. SDREN will coordinate with SDCP and CEA programs, as well as other regional partners delivering energy and workforce programs. ● Other DSM programs. SDREN will coordinate with other DSM programs, including:
○ CPUC DSM funding: TECH, BUILD, DR, SGIP, EV Charging
○ CPUC low-income programs: ESA
■ Single-family coordination
■ Multi-family coordination
○ Market Transformation
■ Emerging technologies, workforce initiatives, and strategies related to building performance and grid interactive buildings and grid impacts. ○ IRA, other federal funding
■ Education and guidance for customers on how to take advantage of offerings.
○ CA Equitable Building Decarb DI program and other state funding ■ Coordination with the SoCal Administrator for marketing and outreach to customers.

Evaluation, Measurement, and Verification (EM&V)
SDREN will coordinate with the CPUC, other PAs, and appropriate stakeholders to define data collection requirements and processes. SDREN will ensure data collection procedures capture relevant information that informs CPUC evaluation activities, program performance, and continuous improvement.

Table 9. EM&V Budget
Sector 8-year budget % of Portfolio
EM&V $11,512,026 4%
Alignment with CPUC Requirements
The development of SDREN’s business plan follows all CPUC guidance and requirements as described below. Additionally, SDREN will comply with all applicable Commission policies and directives following authorization.
47 SDREN’s business plan aligns with the CPUC’s Guidance Decision (D.12-11-015 and updated in D.19-12-021) for Regional Energy Networks which calls for RENs to conduct activities that utilities or CCA Program Administrators cannot or do not intend to undertake. RENs may pilot activities where there is no current utility or CCA PA program offering, and where there is potential for scalability to a broader geographic reach, if successful. In addition, RENs may also pilot activities in hard-to-reach markets, whether or not there is a current utility or CCA PA program that may overlap.

All programs described in the 2024-2027 portfolio plan meet at least one of the existing REN criteria as listed above. SDREN also proposes that “underserved” be incorporated into the third criteria as detailed in the section Recommendation for New or Modified EE Policy.

SDREN’s proposal conforms with other CPUC directives, as follows:
● SDREN will coordinate with SDG&E on a Joint Cooperation Memo (JCM) to avoid overlap and duplication of programs and services.
● Programs are properly segmented, as follows:
○ Resource Acquisition
○ Market Support
○ Equity
○ Codes and Standards.
● SDREN’s business plan provides information on SDG&E programs and how proposed program designs mitigate or minimize ratepayer risk of program overlap or duplication. ● Programs that only meet the criterion of serving hard-to-reach customers (and not the gap filling or pilot criteria confirmed by D.19-12-021) are/will be designed to target, and will be marketed exclusively to, hard-to-reach customers or specific hard-to-reach customer segments.
● SDREN’s proposal is a result of coordination with overlapping PAs in the course of preparing the filings.

The CPUC ruled in D.19-12-021 (pg 21) that a new REN proposal may be brought forward to the Commission by filing a motion in the Energy Efficiency Rolling Portfolio proceeding or its successor (in whichever proceeding is the open energy efficiency rulemaking at the time of the REN proposals), imposing certain requirements. A table outlining SDREN Business Plan compliance is included Exhibit 3 - Appendix X.

Portfolio Design and Alignment with Relevant Action Plans At its foundation, SDREN’s eight-year Business Plan is guided by the state’s goals of doubling EE in existing buildings by 2030, reducing emissions from existing buildings by at least 40 percent below 1990 levels by 2030, achieving 100 percent renewable and zero-carbon retail electricity by 2045, and becoming entirely carbon neutral by 2045. SDREN’s Plan is also guided by the state’s focus on identifying and addressing barriers to advancing EE and decarbonization in low-income and disadvantaged communities, as well as the CPUC’s most recent ESJAP 2.0 Update. Across all SDREN programs, the intent is to support and advance both State legislative 48 mandates as well as deliver programs that meet CPUC regulatory requirements, while simultaneously providing unique value to our local constituents.

The SDREN portfolio design and budget are aligned with the following policy and legislative mandates:
● CPUC Environmental & Social Justice Action Plan 2.0
○ To demonstrate its commitment to advancing the state’s equity goals by serving ESJ communities, the SDREN is deeply aligned with the CPUC’s Environmental and Social Justice Action Plan (ESJAP) goals as described below.

Table 10. SDREN Business Plan Alignment with ESJAP
ESJAP Goals SDREN Alignment
Goal 1: Consistently integrate equity and
access considerations throughout CPUC
regulatory activities.

Equity and ESJ considerations are integrated
throughout the SDREN Business Plan, and will
be included in all future regulatory filings if
authorized.

The SDREN governance structure considers
ESJ priorities within its Advisory Committee.

There will be an effort to include ESJ
representation on the committee and
members will be provided educational
opportunities to better understand the
regulatory and decision making process.

Goal 2: Increase investment in clean energy
resources to benefit ESJ communities,
especially to improve local air quality and
public health.

Authorization of the SDREN advances this
goal given that the goals of the SDREN drive
for equitable decarbonization. Many of the
decarbonization strategies of transitioning
from methane gas to electrification within
programs will lead to improved air quality
and health benefits for ESJ community
members.

All SDREN programs will engage with ESJ
communities and SDREN will pursue
opportunities to better understand and
analyze impacts of programs on ESJ
communities.

SDREN will work across all eligible funding
sources and support IDSM efforts to
maximize impacts to these communities.
49 Goal 3: Strive to improve access to
high-quality water, communications, and
transportation services for ESJ communities.

SDREN will collaborate with regional partners
to support improved access to additional high
quality services, such as clean transportation.

Goal 4: Increase climate resiliency in ESJ
communities.

Climate resiliency is a key design
consideration around programs that are
focused on ESJ communities. Customized
IDSM services will be integrated to support
resilient ESJ communities.

Goal 5: Enhance outreach and public
participation opportunities for ESJ
communities to meaningfully participate in
the CPUC’s decision-making process and
benefit from CPUC programs.

SDREN Advisory Committee will include CBO
representatives and will consider ESJ
representation in membership. Members will
be given opportunities to participate and
learn about the CPUC regulatory process.

The SDREN public sector Tribal program is
intended to build pathways to involve these
communities in the planning process to
develop program strategies.

Goal 6: Enhance enforcement to ensure
safety and consumer protection for all,
especially for ESJ communities.

Trusted local partners will be used for
engagement and program outreach. SDREN
will manage all program implementation
contracts with protections built in to protect
against fraud and unfair business practices.

SDREN’s C&S program will support enhancing
the enforcement of codes to ensure safety
and consumer protection for ESJ
communities.

Goal 7: Promote high road career paths and
economic opportunity for residents of ESJ
communities.

SDREN’s WE&T programs are focused on
promoting high road clean energy career
paths in close partnership with other
agencies. These programs will engage and
support ESJ communities.

Goal 8: Improve training and staff
development related to environmental and
social justice issues within the CPUC’s
jurisdiction.

All SDREN staff will be trained on ESJ issues
and will work to support continued training
on ESJ-aligned plans.
50 Goal 9: Monitor the CPUC’s environmental
and social justice efforts to evaluate how they
are achieving their objectives.

SDREN will continue to monitor progress of
CPUC ESJ efforts and will actively engage in
the feedback loop, including supporting
methodologies and metrics to track progress.
● California Long-term Energy Efficiency Strategic Plan ○ The SDREN portfolio contains multiple strategies that are tied to the California Long-term Energy Efficiency Strategic Plan goals:
■ Local governments (LGs) lead by example in their facilities. ■ LGs lead their communities with innovative energy efficiency programs. ■ LGs lead adoption of advanced energy efficiency standards and reach codes.
■ LGs lead energy code compliance and enforcement.
● AB 758, Existing Buildings Energy Efficiency Action Plan ○ The SDREN portfolio contains multiple strategies that are tied to the Existing Buildings Energy Efficiency Action Plan:
■ Lays out a ten-year roadmap to mobilize market forces and transform California’s existing building stock into high performing and energy-efficient buildings.
■ Establishes requirements for providing energy assessments, benchmarking, energy ratings, cost effective energy improvements, financing options, public outreach and education and workforce training. ● AB 802, Building Energy Benchmarking Program
○ The SDREN portfolio contains multiple strategies that are tied to the Building Energy Benchmarking Program:
■ Mandates use of metered data for measurement of impacts from energy efficiency program interventions.
■ Program Administrators can receive credit for energy savings and provide incentives and support for EE projects that help customers meet current energy code requirements, in contrast to previous rules where Program Administrators could only count energy savings for projects where the improvements exceeded code requirements.
■ SDREN has incorporated a commercial program that uses a meter-based approach to measuring savings.
■ Provides a relevant framework to implement building benchmarking and labeling ordinances that accurately reflect what building operators and tenants see on their energy bills.
■ SDREN’s commercial programs will improve compliance with AB 802, the Building Energy Benchmarking Program, by helping businesses understand their energy consumption and comply with reporting requirements using Energy Star Portfolio Manager.®
● SB 350, Clean Energy and Pollution Reduction Act
51 ○ The SDREN portfolio contains multiple strategies that are tied to the Clean Energy and Pollution Reduction Act:
■ Mandates 50% renewable energy content in the state’s overall electricity mix and a doubling of energy efficiency goals for existing buildings by 2030.
■ SDREN’s commercial programs will help deliver deep and persistent energy savings for SMBs and large commercial customers. ■ Address barriers for low-income customers to EE and weatherization, especially in disadvantaged communities.
■ Require local governments to participate in efficiency program implementation.
● SB 375, Sustainable Communities and Climate Protection Act ○ The SDREN portfolio contains multiple strategies that are tied to the Sustainable Communities and Climate Protection Act:
■ Requires local governments to implement long-term integrated planning of land use and transportation.
■ Drives critical public agency initiatives to reduce per capita GHG emissions in the San Diego County region.
● SB 32, California Global Warming Solutions Act
○ The SDREN portfolio ties to the Sustainable Communities and Climate Protection Act through requiring the state to cut greenhouse gas (GHG) emissions to 40 percent below 1990 levels by 2030.
● SB 100, The 100 Percent Clean Energy Act of 2018
○ The SDREN portfolio contains multiple strategies that are tied to the 100 Percent Clean Energy Act:
■ Sets a 2045 goal of powering all retail electricity sold in California and state agency electricity needs with renewable and zero-carbon resources—those such as solar and wind energy that do not emit climate-altering greenhouse gasses.
■ Requires the Energy Commission, Public Utilities Commission and Air Resources Board to use programs under existing laws to achieve 100 percent clean electricity.
■ Updates the state’s Renewables Portfolio Standard to ensure that by 2030, at least 60 percent of California’s electricity is renewable. ● Governor’s Emergency Proclamation (July 30, 2021)
○ The SDREN portfolio contains multiple strategies that are tied to the Governor’s Emergency Proclamation:
■ Ensure that California has a safe and reliable electricity supply to reduce strain on the energy infrastructure, and to ensure increased clean energy capacity by adding new energy efficiency programs or measures that target peak and net peak hours and integrating demand response or conservation actions with energy efficiency program actions or investments.
52 ■ CPUC to exercise its powers to expedite Commission actions, to the maximum extent necessary, to meet the purposes and directives of this proclamation, including by expanding and expediting approval of demand response programs and storage and clean energy projects. ● SB 48 Building Energy Savings Act
○ The SDREN portfolio contains multiple strategies that are tied to the newly enacted Senate Bill 48:
■ While this bill has not yet entered the rulemaking phase, it is anticipated that during the first and second EE portfolio cycles, opportunities will exist to engage with the CEC in the alignment of statewide and local equitable building performance standards.
■ Equitable Building Performance Standards offer opportunities to combine cross cutting strategies to engage communities, accelerate regional decarbonization, and pilot new support programs that focus on IDSM strategies to improve the way buildings, people, and the grid operate. ● CARB Scoping Plan
○ The SDREN portfolio contains multiple strategies that are tied to the 2022 Scoping Plan for Achieving Carbon Neutrality:
■ The plan lays out a path to achieve targets for carbon neutrality and reduce anthropogenic greenhouse gas (GHG) emissions by 85 percent below 1990 levels no later than 2045, as directed by Assembly Bill 1279. ■ The strategies within the Scoping Plan include dedicated guidance for local actions, sustainable and equitable communities, building decarbonization, and non-energy benefits such as public health. ■ As the CARB continues to update the plan and local air quality management districts consider new policy related to buildings and transportation, pilots and gap filling activities in the SDREN portfolio to promote viable electric alternatives, electrification, and community engagement will be leveraged to support CARB policy.
● Flexible Demand Appliance Standards
○ The SDREN portfolio contains IDSM strategies that are tied to the State’s Flexible Demand Appliance Standards:
■ Senate Bill 49 authorizes the California Energy Commission to adopt standards for appliances to facilitate the deployment of flexible demand technologies. The standards shall reduce greenhouse gas emissions by scheduling, shifting or curtailing appliance operations with consumer consent. The standards shall be feasible and cost-effective. ■ Title 20 and 24 are evolving to include controllable grid-enabled appliances, which aligns with SDREN efforts to target customers and measures that advance decarbonization.
■ The CPUC and CEC are actively engaged in developing data standards and infrastructure to enable dynamic price signals and tariffs, which will require localized efforts to address technology and behavioral energy adoption in disadvantaged communities via SDREN programs. 53 ■ These standards are reflected in CPUC rulemakings, including demand response requirements in the SGIP proceeding, the Distributed Energy Resource Program Cost-Effectiveness Issues, Data Access and Use, and Equipment Performance Standards proceeding, as well as the High DER proceeding.
■ The latest EPIC 2021-2025 IOU program authorization includes strategies to “Increase the Value Proposition of DERs to Customers on the Grid.” This decision offers opportunities for collaboration to further align ESJ Action Plan goals though SDREN programs supporting DACs and communities to participate in complementary demand flexibility interventions.

Annual Portfolio Budgets
SDREN’s annual projected portfolio budget summary table adding up to the 8-year authorized budget cap including Savings, Cost Effectiveness & TSB forecasts is below and additional details can be found in Exhibit 3 - Appendix X.

Table 11. SDREN Annual Projected Portfolio Budget Summary Year Requested
Budget
TSB TRC PAC Net Annual
kWh
Net
Annual
kW
Net
Annual
Therms
2024 $15,852,720 0 0 0 0 0 0
2025 $32,755,736 $4,865,784 0.18 0.17 3,864,663 203 200,788 2026 $36,031,310 $6,168,332 0.20 0.20 4,990,604 228 235,749 2027 $39,634,441 $7,160,300 0.21 0.21 5,391,513 254 274,631 2028 $41,219,818 $7,370,804 0.21 0.21 5,300,382 249 269,989 2029 $42,868,611 $7,479,904 0.21 0.20 5,212,917 245 265,534 2030 $44,583,355 $7,620,565 0.20 0.20 5,128,856 241 261,252 2031 $46,366,690 $7,852,868 0.20 0.19 5,047,966 237 257,131 Total $299,312,680 $48,518,557 0.18 0.17 34,936,901 1,657 1,765,074 Recommendations for New or Modified EE Policy
Decision 19-12-021, approved on December 5, 2019, adopts three revised criteria which will be considered by the Commission in approving new or renewed REN Business Plans. The third REN criterion that was designated is: “Activities serving hard-to-reach markets, whether or not there 54 is another utility or CCA program that may overlap.” In its discussion, the Decision notes that “With respect to the third criterion, numerous commenters suggested broadening it beyond “hard-to-reach” which is now specifically defined in D.18-05-041, and to include a new category called “underserved.”47 The Decision further states that “While we appreciate the motivation behind this suggestion, which is to serve more customers, no party provided a suggested definition of “underserved” that we can readily adopt here. Without a specific definition, we fear we would be opening up the REN portfolios too broadly and creating more potential for overlap in customer segments that are being served, but meet a particular proponents’ unique definition of underserved. As such, we will not adopt a broadening of the third criterion here.”48 The Decision then concludes that “If a consensus among parties is reached in the future about an appropriate definition of “underserved,” we would consider broadening this criterion in the future.”49
In the Decision authorizing the 2024-2031 Energy Efficiency Portfolios and Business Plans, D.23-06-055 approved on June 9, 2023 (Sec. 7.2, pages 45-48), a very detailed and comprehensive definition for underserved customers was adopted by the Commission. As a logical next step to ensure the full incorporation of this newly adopted underserved customer definition into soon to be launched energy efficiency program portfolios, it is respectfully recommended that the Commission revise REN criterion number three as follows: “Activities serving hard-to-reach markets and underserved customers, whether or not there is another utility or CCA program that may overlap.”
49 Ibid.
48 Ibid.
47 D.19-12-021, pg. 31.
55 Table of Contents
Table of Contents 2
Portfolio Summary 5
Core Values 5
Guiding Principles 6
Goals 6
Key Metrics and Outcomes 8
Portfolio Outcomes 8
Energy Efficiency Strategy 12
Savings Forecasting and Quantification Methods 12
Strategies for Market Intervention and Energy Efficiency Adoption 13 New Strategies for Spurring Innovation 15
Strategy for Incorporating Low Global Warming Potential Refrigerants 17 IDSM Strategies 17
Application Summary Tables Covering the 4-year Budget Request 19 Distribution of Budget Among Sectors and Segments 20
Projected Sector-Level and Portfolio-Level Cost Effectiveness 21 Resource Acquisition Segment 22
All Segments 22
Forecast Methodology 23
Portfolio Administration vs. Program Implementation Costs 23 Segmentation Strategy 24
Strategies Driving Distribution of Budget Among Segments 24 Resource Acquisition 26
Preliminary Resource Acquisition Budget for 2024-2027 and Rationale for Distribution 26 Resource Acquisition Goals, Strategies, and Outcomes 26 Projected Portfolio and Sector-level Metrics 27
Resource Acquisition Segment-Specific Coordination 28
Codes & Standards 28
Preliminary Codes & Standards Budget for 2024-2027 and Rationale for Distribution 28 Codes & Standards Goals, Strategies, and Outcomes 28
Projected Annual Portfolio and Sector-Level Metrics 30
C&S Segment-Specific Coordination 30
Market Support 31
Preliminary Market Support Budget for 2024-2027 and Rationale for Distribution 32 2 Market Support Goals, Strategies, and Outcomes 32
Projected Annual Portfolio and Sector-Level Metrics 34
Market Support Segment-Specific Coordination 36
Equity 36
Preliminary Equity Budget for 2023-2027 and Rationale for Distribution 36 Equity Specific Strategies, Goals, and Outcomes 37
Projected Annual Portfolio and Sector-Level Metrics 39
Equity Segment Coordination 40
Sector Strategy 41
Strategies Driving Distribution of Budget Among Sectors and Alignment with Broader Portfolio Objectives 41
Description of Sectors SDREN Proposes to Serve 42
Preliminary Distribution of Budget Among Sectors for 2024-2027 and Rationale for Distribution 43
Commercial Sector 45
Market Characterization 45
Commercial Sector Goals, Objectives and Strategies 46
Commercial Sector Coordination 47
Categorization by Segment 49
Commercial Sector Program Details 49
Cross-Cutting Sector – Codes & Standards 60
Market Characterization 60
C&S Sector Goals, Objectives and Strategies 61
C&S Sector Coordination 63
Categorization by Segment 64
C&S Sector Program Details 64
Cross-Cutting Sector – Workforce, Education & Training 70 Market Characterization 70
WE&T Sector Goals, Objectives and Strategies 72
WE&T Sector Coordination 74
Categorization by Segment 75
WE&T Sector Program Details 76
Public Sector 85
Market Characterization 85
Public Sector Goals, Objectives and Strategies 86
Public Sector Coordination 89
3 Categorization by Segment 90
Public Sector Program Details 91
Residential Sector 100
Market Characterization 100
Residential Sector Goals, Objectives and Strategies 102 Residential Sector Coordination 104
Categorization by Segment 105
Residential Sector Program Details 106
Portfolio Management 114
Strategies to Optimize Portfolio and Manage Risk 114
How SDREN Will Stay On-Target 115
Approach to Risk Management 116
Approach to Flexible Portfolio Management 117
Planned Procedures and Course Correction if Off-Track 118 Third-Party Programs 119
Solicitation Strategy 119
Third-Party 2024-2027 Solicitation Schedule 119
Risk Distribution 119
Incorporation of Input on Current Solicitation Practices 120 Supplier Diversity 120
Continued Stakeholder Engagement on Solicitation Process 121 Statewide Programs 121
Assessment and Mitigation of Risk from Portfolio Diversity 121 Contract Management 122
Portfolio Coordination 122
Coordination with Other PAs 122
How SDREN’s Portfolio is Complementary With Other PAs in Service Territory 124 How SDREN’s Portfolio Mitigates Duplication of Efforts 126 How SDREN Will Coordinate Efforts With Other Demand-Side Programs 127 Stakeholder Engagement in the Development of This Application 129 Evaluation, Measurement & Verification 130
Summary of Planned EM&V Studies and Activities 130
SDREN’s Budget Allocation and Justification 131
Cost and Cost Recovery 131
Summary of Costs at Portfolio-level 131
SDREN’s Approach to Classification of Unspent Funds 132 4 Portfolio Summary
The projected impacts of climate change on the San Diego region are profound, driving the need for urgent collective action to decarbonize. The San Diego Regional Energy Network (SDREN) represents an important step to support communities, particularly those who are underserved and hard-to-reach, to achieve a carbon free building sector in the San Diego region by 2050.

Figure 1. SDREN’s Vision
SDREN aspires to be a regional leader supporting San Diego County, 18 incorporated cities, 47 school districts, and 18 federally recognized Tribal governments. Approval of the SDREN will complete the RENs’ statewide coverage, bolstering the California Public Utilities Commission’s (CPUC) intention for RENs to fill gaps and complement investor-owned utility (IOU) services.

SDREN is focused on helping communities invest in and accelerate decarbonization to hasten the transformation to clean energy. SDREN is committed to delivering programs that make inroads into communities to reduce greenhouse gas emissions, achieve equity, drive market transformation, and provide value to ratepayers.

Core Values
SDREN is guided by its core values.
5 Figure 2. SDREN’s Core Values
Guiding Principles
SDREN’s portfolio of services is informed by its core values and framed by the following principles:
● Advance Environmental Equity. Through its proposed portfolio of services, SDREN is committed to representing underserved communities and advancing environmental equity.
● Catalyze Collaboration. SDREN will collaborate with stakeholders to develop and strengthen regional partnerships to accelerate decarbonization and maximize community benefits.
● Support Community-Driven Change. SDREN’s approach to program design and delivery will engage communities at early stages of planning to ensure the services that are developed reflect local needs and priorities.

Goals
SDREN has the following goals for its overall portfolio:
● Advance decarbonization. Decarbonization lowers energy costs, increases access to clean energy, ensures safer and healthier homes and communities, reduces environmental burdens, and expands economic opportunity and high-quality jobs. ● Provide comprehensive energy efficiency (EE) services that improve outcomes for underserved and hard-to-reach communities.1 SDREN’s portfolio of services will be centered around minimizing barriers to participation for underserved and hard-to-reach (HTR) communities.
1 As defined in D.23-06-055.
6 ● Accelerate the clean energy economy through workforce opportunities. As a regional leader, SDREN will mobilize and leverage resources to support the local workforce and create energy-related jobs and skills that benefit local communities. SDREN’s goal is to support a high road approach to grow the regional clean energy economy and create new opportunities for the local workforce, with a focus on underserved communities.

In line with the San Diego Regional Decarbonization Framework - Technical Report2 and informed by the CPUC Environmental and Social Justice (ESJ) Action Plan, the long term goal for the SDREN is to ensure an equitable transition to a carbon-free building sector in the San Diego region by 2050.

SDREN will prioritize equity so that building decarbonization includes underserved and HTR communities and relieves the burden of increasing gas rates. SDREN has the opportunity to meet the need for incorporating social equity considerations into building decarbonization policies. SDREN is focused on working with these communities and providing programs and resources that meet their needs.

The short and mid-term goals will support progress in reaching the region’s long-term goal of full decarbonization, as follows:
● Short-term goal by 2027: by the end of the four-year SDREN Portfolio Plan period ○ Normalize replacing end-of-life methane gas space and water heating systems with highly efficient electric versions with load flexibility for hard-to-reach and underserved customers.
○ Support “electrification ready” or “all-electric” standards for new construction and major renovations through building energy codes.
○ Support and utilize workforce assessments and set foundations for prioritization of workforce development for electrification.
● Mid-term goal by 2031: by the end of the eight-year period of the SDREN Strategic Business Plan
○ Full or whole building electrification/decarbonization programs are successfully reaching equity communities.
○ Workforce supply for decarbonization jobs meets regional demand.

As emphasis on electrification grows at the state and federal level, SDREN will focus on regional coordination, tools, capacity building alongside targeted investments for appliance replacements that address equity concerns.
2 McCord, Gordon C., Elise Hanson, Murtaza H. Baxamusa, Emily Leslie, Joseph Bettles, Ryan A. Jones, Katy Cole, Chelsea Richer, Eleanor Hunts, Philip Eash-Gates, Jason Frost, Shelley Kwok, Jackie Litynski, Kenji Takahashi, Asa Hopkins, Robert Pollin, Jeannette Wicks-Lim, Shouvik Chakraborty, Gregor Semieniuk, David G. Victor, Emily Carlton, Scott Anders, Nilmini Silva Send, Joe Kaatz, Yichao Gu, Marc Steele, Elena Crete, and Julie Topf. San Diego Regional Decarbonization Framework: Technical Report.

County of San Diego, California. 2022.
7 Figure 3. Regional Decarbonization Framework on Replacing Appliances Key Metrics and Outcomes
Portfolio Outcomes
SDREN’s portfolio complies with CPUC requirements and rulings and addresses the CPUC’s goals for RENs to deliver local programs and activities that fill gaps and complement IOU offerings with a focus on hard-to-reach markets.3 By bringing together regional perspectives, deepening partnerships, and cultivating community-led strategies, SDREN will realize meaningful multi-benefit solutions and equitably transition to a carbon-free building sector in the San Diego region by 2050. If executed successfully, SDREN’s mid-term goals of (1) full electrification/decarbonization programs successfully reaching equity communities4 and (2) a balanced supply and demand for jobs supporting decarbonization will deliver the following outcomes by 2031:
● Portfolio Outcome 1. Reduce energy burden and improve energy affordability. As customers move from methane gas to electric appliances, they should not see increased costs.
● Portfolio Outcome 2. Improve health and reduce energy consumption across the region.

When done effectively, building electrification leads to both health benefits and a reduction of energy use.
● Portfolio Outcome 3. Improve access and increase program participation by reducing programs’ complexity, helping program participants to understand how best to manage their own energy consumption. Education is at the foundation of an equitable transition and ease of access to all resources.
● Portfolio Outcome 4. Maximize benefits to customers by leveraging additional funding, such as Inflation Reduction Act (IRA) funds, to deliver IDSM strategies. Coordination of these resources will maximize benefits to the customer. ● Portfolio Outcome 5. Create access to career pathways in clean energy, supporting a trained clean energy regional workforce with “high quality jobs”. 4 As defined in D.23-06-055.
3 D.12-11-015, and reasserted in D.19-21-021.
8 SDREN’s portfolio application includes ten programs, organized by segment and sectors, as follows:
● Segments: Resource Acquisition, Market Support, Equity, and Codes & Standards ● Sectors: Commercial, Cross-cutting (Workforce, Education & Training and Codes & Standards5
), Public, Residential.

SDREN will measure progress toward achieving goals and delivering outcomes for each program, segment and sector through progress trackers that include various targets, indicators and metrics, which will be reported on either quarterly or annually. In addition to tracking progress at the program, segment and sector-level, SDREN will also track and report on progress at the portfolio level.

All indicators and metrics are detailed in the SDREN 2024-2031 EE Application Excel Sheets.

They include indicators for equity and market support segments from D.23-06-055, the “common metrics and indicators” from D.18-05-041, and SDREN’s unique value metrics (UVMs).

The common metrics include both portfolio and sector-level metrics.

For the 2024-2027 portfolio period, SDREN has established an initial set of UVMs and identified additional key metrics/indicators at the portfolio, sector, and segment level that will measure progress towards eight-year business plan outcomes (see Table 1 below). Data methodologies, baselines and targets for tracking progress have been established for these UVMs and are outlined in the SDREN 2024-2031 EE Application Excel Sheets. 5 Codes & Standards is categorized as both a distinct segment and a cross-cutting sub-sector. 9 Figure 4. Indicator, Metric, Target, and Progress Tracker Definitions Table 1. Mapping of Portfolio Plan key indicators and metrics with Business Plan strategic outcomes
Type of
progress
tracker
Progress Tracker Tie-in with Portfolio Plan Outcomes
Unique
Value
Metric
% of customers anticipated to
experience lower energy costs as a
result of program participation, by
sector
Outcome 1: Reduce energy burden and
improve energy affordability.

Equity
Segment
Indicator
Median of equity target participants’
expected first-year bill savings in
equity segment, by sector
Portfolio
Metric
Total system benefit (TSB) achieved Outcome 2: Improve health and reduce energy consumption across the region.
10 Unique
Value
Indicator
EE savings funneled to non SDREN
programs
Unique
Value
Metric
% of customers funneled to non
SDREN programs
Outcome 3: Improve access and
increase program participation.

Unique
Value
Metric
External funding leveraged to support
SDREN programs/ communities as a
% of total budget spend
Outcome 4: Maximize benefits to
customers by leveraging additional
funding.

Unique
Value
Indicator
Count of newly educated or
credentialed individuals
Outcome 5: Create access to career
pathways in clean energy.

Ahead of authorization, SDREN will engage with the joint Portfolio Administrators (PAs)6 as part of the joint Tier 2 Advice Letter (AL) to be filed by May 1, 20247 . This action is intended to
address any modifications of the common metrics and indicators and to clarify and modify the adopted equity and market support indicators. This coordination will help to define the process for proposing and adopting long-term market support and equity goals, and will help to establish the metrics for success for the next portfolio period.

SDREN will conduct an evaluation, measurement, and verification (EM&V) study before filing the 2028-2031 Portfolio Plan to refine goals and UVMs. The study will support development of the appropriate methodologies, baselines and targets to align with SDREN’s goals for the portfolio. The EM&V study will set the foundation for developing an effective 2028-2031 Portfolio Application that will deliver on SDREN’s mid and long term goals. This study will be coordinated with other RENs’ efforts to develop a total community benefit or alternative REN metric. Since a majority of the SDREN portfolio supports the market support and equity segments,8 SDREN will also coordinate with the joint PAs’ work to establish equity and market support metrics and goals.
8 From D.23-06-055 "because the majority of the REN portfolios is dedicated to equity and market support offerings, new goals covering these primary purposes should be important accountability mechanisms for RENs...It is our intention that a goals development process for the market support and equity segments will follow a timeline that aligns goals adoption to the next portfolio cycle beginning in 2028. ...Market support and equity goals are ultimately expected to be long-term, broken into four-year increments, and will begin in 2028. This approach is also intended to allow the RENs to continue to work on their proposed Total Community Benefit metric, included in rebuttal testimony, if they so choose." 7 D.23-06-055 Ordering Paragraph (OP) 11: “The portfolio administrators shall jointly submit a Tier 2 advice letter by no later than May 1, 2024 clarifying all of the Indicators adopted in this decision, including any modifications from metrics and Indicators adopted in Decision 18-05-041, and identifying information that could be used as baselines for future targets or methodologies for how the indicator information can be used as baselines.” 6 D.23-05-066 makes the shift from “program administrator” to “portfolio administrator” or abbreviated as “PA”. Both terms may be found in this application.
11 Before filing for the 2028-2031 portfolio period, SDREN’s goals will conform to the guidance of D.23-06-055, and will have all of the following characteristics:
● A medium to long term (i.e., 12-24 years) timeframe, divided by four year increments. ● Established from known baselines.
● Be high priority metric(s), a score or ratio, or single monetary value (or equivalent). ● Count total progress toward market support and equity goals from all programs in the portfolio, regardless of segmentation.
● Set targets and measures demonstrating incremental progress toward meeting goals.

Energy Efficiency Strategy
SDREN’s proposed EE strategy builds off of the foundation established through long-standing regional collaborations. The strategy is informed by SDREN’s desire to deliver decarbonization, comprehensive EE services, and workforce opportunities.

Our portfolio-level strategies incorporate several key approaches, as listed below.

1. The portfolio is designed to provide flexibility in program delivery so that services can adapt and change as new programs or resources become available and when programs close.

2. By integrating effective coordination and collaboration with partners and trusted organizations across program segments and sectors, SDREN can identify synergies, reduce costs and complexity, and deliver high-value programs that reflect local priorities and needs. With effective coordination and collaboration, SDREN will also mitigate customer confusion and maximize the success of all programs.

3. The SDREN portfolio reduces barriers to participation by offering customized support and connecting customers with available resources and programs.

4. SDREN will promote decarbonization through electrification measures and incentives to move away from technologies that burn methane gas.

5. SDREN will monitor the market and coordinate with other programs to leverage complementary offerings and stack supplemental program services and external funding opportunities.

6. SREN will take a holistic approach, integrating IDSM offerings to deliver value to participants throughout the portfolio (described in more detail under IDSM Strategies).

Principles of environmental and social justice connect throughout each of these strategies.

SDREN will consider and incorporate environmental justice across all programs, regardless of segmentation.

Savings Forecasting and Quantification Methods
SDREN’s savings forecast methods vary by program type. SDREN’s savings projections were developed using only approved savings assumptions and/or methodologies, as described below. 12 SDREN is proposing a single resource acquisition program that will comply with D.23-06-055 by using a meter-based method for savings measurement. SDREN developed high-level savings forecasts taking into account program ramp-up and available incentive budgets, including incentive rate estimates in line with other similar programs. Savings claimed will be based on actual savings realized and will apply a population-level NMEC approach in alignment with the most current version of the CPUC’s NMEC Rulebook.

All equity and market support programs utilize deemed measures that are currently approved in the eTRM (California Electronic Technical Reference Manual) database and follow the Statewide Deemed Workpaper Rulebook. SDREN will explore the benefits of establishing a deemed measure working group modeled after SoCalREN’s efforts. This group would monitor the effectiveness of measures most relevant to its target customers and portfolio goals, recommend new measure additions, and make recommendations for phasing out deemed measures.

SDREN will not use the current custom process and meter-based approaches to savings measurement because they will not be cost effective with the target customers in equity and market support segment programs.

While SDREN recognizes the benefits of meter-based savings approaches, there are currently limitations to its effectiveness for certain customers. SDREN will engage in statewide working groups to overcome barriers and explore cost effective solutions for smaller customers. SDREN’s third party implementers will be encouraged to explore opportunities to incorporate meter-based savings approaches into the programs. SDREN will also use the joint cooperation memo (JCM) process to identify the best strategies to support San Diego Gas and Electric (SDG&E) third party program providers with the delivery of meter-based savings projects, as appropriate.

Strategies for Market Intervention and Energy Efficiency Adoption SDREN will incorporate the following strategies for market intervention and EE adoption.

Table 2. Strategies for market intervention and EE adoption by target audience Target Audience Strategy
Non-English speaking
resident or business
owner
● In-person equitable and inclusive education and outreach (i.e. in-language materials with cultural understanding, and with vision and hearing impaired customers taken into
consideration) conducted by trusted local representatives when possible.

Homeowner,
business owner,
public agency
● Offer comprehensive services to simplify participation and present a single point of entry to access programs, including SDG&E offerings.
● Speak to holistic benefits available through offerings. 13 ● Provide customized technical assistance paired with advisory services to identify and install comprehensive EE and IDSM opportunities at homes/facilities.
● Offer funding, financing assistance, and guidance to
customers on how to qualify, utilize, and stack funding sources such as IRA, OBF, TECH, and SGIP.
● Direct installation of no to low cost energy efficiency measures.
● Deliver outreach, education, and training to improve access, increase program participation, and increase knowledge of energy management best practices.
● Partner with community-based organizations (CBOs) to
deliver messaging and services through local, trusted
community members.

Tribes ● Offer direct funding to Tribal nations to propose, design, and deliver programming and initiatives to meet their unique needs, increase access to EE programs, reduce energy burdens, and decarbonize assets.
● Provide access to a technical advisor with EE expertise to support program and initiative implementation.
● Also, refer to all strategies noted above for other public agencies.

Disadvantaged
workers9
● Build and leverage external partnerships to enhance
disadvantaged community (DAC) worker outcomes such as:
○ Partnering with employers to provide training to staff and boost opportunities for growth.
○ Partnering with local community colleges to provide
college level courses and skill development
opportunities.
● Provide education through training, certifications, networking, and apprenticeship opportunities to build skills for the green workforce.
● Offer wraparound services such as career coaching or other support services to remove barriers to successful program participation.
9 Disadvantaged worker definition from D.19-08-006, Attachment B, p.6: “Disadvantaged Worker” means a worker that meets at least one of the following criteria: lives in a household where total income is below 50 percent of Area Median Income; is a recipient of public assistance; lacks a high school diploma or GED; has previous history of incarceration lasting one year or more following a conviction under the criminal justice system; is a custodial single parent; is chronically unemployed; has been aged out or emancipated from the foster care system; has limited English proficiency; or lives in a high unemployment ZIP code that is in the top 25 percent of only the unemployment indicator of the CalEnviroScreen Tool. 14 ● Match participants with employers to secure clean energy jobs.

Employers connected
to EE deployment
● Support employers to help them overcome barriers to offering EE training for staff.
● Deploy a survey to local employers to identify emerging clean energy industry careers and determine the required skills and qualifications for incoming professionals to succeed.
● Stack opportunities available to employers by connecting them with other workforce development programs.

Code enforcement
officials and
stakeholders
● Leverage data-driven insights to develop tools, technical resources, and templates for permitting electrification and other energy efficiency measures.
● Educate officials and authorities having jurisdiction (AHJ) about permitting and codes.
● Provide person-to-person support through an energy code coach who can provide comprehensive compliance and
enforcement strategy support.

New Strategies for Spurring Innovation
With a focus on SDREN’s environmental equity, collaboration, and community-driven principles, SDREN will incorporate the strategies outlined in the table below to spur innovation throughout the portfolio.

Table 3. Strategies for Innovations Based on SDREN Principles SDREN Principle SDREN Strategies for Innovation
Environmental Equity ● Focus on methods that maximize non-energy benefits for equity customers such as:
○ Engage multiple markets to identify the best strategies to reach equity customers including collaborations
with community-based organizations that may overlap
with but not be directly tied to energy (e.g. health
work, local and sustainable food systems).
○ Build environmental and social justice priorities and opportunities to incorporate innovations into all
program solicitations. Examples could include
strategies for culturally sensitive outreach, customer
protections, and emphasis on non-energy benefits
that benefit underrepresented communities.
● Compensation for CBOs that engage and support SDREN,
15 such as through program engagement.
● SDREN will provide energy education and training to these groups as needed to build staff capacity and enable them to more effectively contribute to SDREN goals.

Collaboration ● Prioritize collaboration, coordination and flexibility in program design in order to fill gaps and develop future innovations through the following strategies:
○ Work with local energy program administrators and
implementers to optimize coordinated service delivery
and ensure resources are used efficiently.
○ Work with SDREN Advisory Committee members and
other regional partners, such as CBOs and local
governments, to design approaches that reflect local
needs and priorities and maximize advantages for
local communities.
● Leverage and marshal financial resources, provide access to financing, and integrate and stack funding sources.
○ This includes state and federal funding opportunities, such as IRA and the California Energy Commission
(CEC) Equitable Building Decarbonization DI
Program10, and regional offerings, such as SDG&E
programs, where feasible.

Community-Driven ● Engage communities at early stages of planning to ensure the services that are developed and delivered reflect local needs and priorities and invest in community-based program
delivery.
● Identify success measures reflective of desired community outcomes, informed by SDCP’s Community Power Plan and
the County of San Diego’s Regional Decarbonization
Framework.
● SDREN Advisory Committee to include CBOs with the role to advise on outreach and enrollment, provide feedback on
program evaluation reports, and recommend program
improvements.
● Ongoing engagement will focus on collecting feedback to inform 2028-2031 Portfolio Plan.
○ This will also be informed by the Community-based
10 https://www.energy.ca.gov/programs-and-topics/programs/equitable-building-decarbonization-program 16 pilot led by SoCalREN.11
● Tribal program designed to ensure community driven design and service delivery.

Strategy for Incorporating Low Global Warming Potential Refrigerants Hydrofluorocarbon refrigerants (HFCs) are “super” greenhouse gasses (GHGs) that are being phased out due to their negative environmental impact. However, the San Diego region needs significant support to transition safely to low-GWP refrigerants. Low-GWP refrigerants will be incorporated into the portfolio using the strategies outlined in the table below.

Table 4. Strategies for Incorporating Low-GWP Refrigerants Portfolio Sector/Program SDREN Supporting Strategy
Residential, Commercial
and Public
● When providing technical assistance to customers, pair it with education about and recommendations for relevant
low-GWP refrigerants.
● Require installers to use low-GWP refrigerants in newly installed equipment.
● Support proper reclamation of HFC refrigerants.

Codes & Standards Provide information to all local permitting agencies and other market actors about the HFC phase out, low-GWP refrigerants, and code requirements.

Workforce, Education &
Training
Incorporate training for program participants on proper installation and management of low-GWP refrigerants, proper reclamation of HFC-based refrigerants, and the phase out and benefits of low-GWP refrigerants.

SDREN will cooperate with the Market Transformation administrator should new HVAC and refrigeration initiatives be introduced to handle low-GWP changes and regulations.12 SDREN will closely monitor programs with low-GWP strategies, such as TECH and the BayREN Refrigerant Replacement Program, to drive the market toward low-GWP refrigerants and identify best practices to integrate into program designs before launching programs.

IDSM Strategies
CPUC ruling D.23-06-055 authorizes PAs to propose IDSM programs by submitting a Tier 3 Advice Letter (AL) no later than March 15, 2024 for programs to be launched during the 12 D.21-05-031 at 60.
11 D.23-06-055, OP 30.
17 2024-2027 portfolio period. Guidance for what is to be included in the AL is anticipated to be issued by the Energy Division no later than January 1, 2024.13 Given that SDREN is not anticipated to be authorized as a PA before March 15th, 2024, SDREN is proposing that the CPUC authorize SDREN’s IDSM strategy outlined below. If necessary, SDREN will file additional details as directed by the Energy Division or the Commission.

SDREN anticipates allocating the full cap of $4 million towards IDSM activities14 because integrating IDSM activities and services alongside EE is a cost effective use of resources to drive deep decarbonization across the region. In line with SDREN’s decarbonization goal and the portfolio strategy of customized support, SDREN will comprehensively consider IDSM opportunities across all programs to be integrated throughout the portfolio.

SDREN’s proposed potential IDSM strategies across the portfolio include:
● Regional IDSM Working Group
a. Convene regional Load Serving Entities (Clean Energy Alliance, SDCP, and SDG&E) to discuss IDSM programs, including building electrification, transportation electrification, demand response, distributed generation, and storage, in order to optimize SDREN program design and delivery.
b. Discuss regional grid needs (e.g., hosting capacity, distribution congestion) to inform program design, electrification priorities, and operational strategies. c. As appropriate, update SDREN IDSM activities to incorporate feedback from the Regional IDSM Working Group.
● Equipment Specification
a. Document IDSM program eligibility requirements, including equipment features and functionality, original equipment manufacturers (OEM) eligibility, Distributed Energy Resource Management System (DERMS) integration, and compatibility with relevant codes, industry standards, and workforce needs. b. Work with SDREN implementers to align, to the extent possible, program Qualified Product Lists (QPLs) with regional IDSM program requirements. ● Identification, Installation and Commissioning
a. Identify IDSM opportunities based on customer preferences. b. Incorporate enrollment (e.g., device enrollment) support and process (e.g., T&Cs acceptance) into SDREN programs, including marketplace offers, contractor partnerships, and Energy Division (ED) guidance on incentive stacking and IRA reporting.
c. Integrate device commissioning requirements for IDSM programs (e.g., digital connectivity commissioning, DERMS integration) into contractor-driven SDREN program delivery.
14 Per CPUC ruling A.22-02.005, a PA may, but is not required to, expand up to 2.5 percent, or $4 million, whichever is greater, of its energy efficiency budget for the portfolio period, up to a maximum of $15 million, on a pilot basis for ongoing load shifting that reduces peak consumption
13 The CPUC will allow IDSM programs to be proposed through the submission of Tier 3 advice letters no later than March 15, 2024, for programs to be launched during the portfolio period (2024-2027). 18 d. Ensure customer preferences, awareness, and education activities are integrated throughout the program delivery lifecycle.
● Codes and Standards
d. Provide education and technical support to code officials on implementation of new requirements related to flexible load technologies (e.g., Title 24 compliance credits for storage and HPWHs, flexible demand appliance standards). ● Workforce Education and Training
a. Incorporate flexible load program requirements, incentives, commissioning processes and other IDSM program material into energy efficiency training modules for participating contractors.
b. Educate and collaborate with participating contractors on inclusive outreach, customer acquisition, and sustained customer satisfaction with technology and behavioral interventions contributing to IDSM program goals. ● Education and Customer Support
c. Help customers apply for additional IDSM funding and incentives. d. Incorporate information on the opportunities and benefits of IDSM program participation into customer education and outreach materials and workshops.

Customers will be funneled into appropriate programs and decarbonization strategies that will result in event-based or permanent load shifting or load reduction. As part of its development of IDSM strategies, SDREN will closely coordinate with other IDSM programs and administrators.

Application Summary Tables Covering the 4-year Budget
Request
SDREN’s annual budget request for 2024-2027 is outlined in the table below. The 2024 budget request is lower than subsequent years to account for a partial year and ramp up activities, in anticipation of the application not being authorized until mid-2024. For example, contracting and coordination with SDG&E, program solicitations, development of Implementation Plans, SDREN branding/website, and regulatory activities are anticipated to begin in mid-2024.

Table 5. Annual Budget Request Breakdown by Budget Category Budget Category 2024 2025 2026 2027 Total
Administration $1,524,300 $3,149,590 $3,464,549 $3,811,004 $11,949,443 Marketing and
Outreach
$914,580 $1,889,754 $2,078,729 $2,286,602 $7,169,666
Direct
Implementation -
Non-incentive
$12,804,120 $15,687,391 $17,256,130 $18,981,743 $59,517,456 19 Direct
Implementation -
Incentive
$0 $10,769,165 $11,846,082 $13,030,690 $40,857,865
EM&V $609,720 $1,259,836 $1,385,820 $1,524,402 $4,779,777 Total $15,852,720 $32,755,736 $36,031,310 $39,634,441 $124,274,206 Distribution of Budget Among Sectors and Segments
Table 6. Distribution of 2024-2027 budget by sector and segment (does not include EM&V) Sector Resource
Acquisition
Market
Support
Equity C&S Total
Commercial $16,479,316 - $18,310,722 - $34,790,038
Cross-Cutting C&S - - - $7,323,955 $7,323,955
Cross-Cutting WE&T - $19,225,425 - - $19,225,425
Public - $21,418,605 $1,831,406 - $23,250,011
Residential - - $34,905,000 - $34,905,000
Total $16,479,316 $40,644,030 $55,047,128 $7,323,955 $119,494,429 Figure 5. Budget Breakdown by Segment
20 Figure 6. Budget Breakdown by Sector
Projected Sector-Level and Portfolio-Level Cost Effectiveness Table 7. Forecasted cost effectiveness for portfolio and by sector and segment TRC, No Admin TRC, W/ Admin PAC, No Admin PAC, W/ Admin Portfolio 0.51 0.17 0.48 0.17
Resource
Acquisition

0.64 0.39 0.87 0.46
Market Support 0.16 0.03 0.16 0.03
Equity 0.08 0.03 0.06 0.03
Codes &
Standards

0.00 0.00 0.00 0.00
Commercial 0.51 0.27 0.62 0.29
WE&T 0.00 0.00 0.00 0.00
Public 0.16 0.06 0.16 0.06
Residential 0.26 0.14 0.19 0.12
21 Resource Acquisition Segment
The below table details the forecasted cost effectiveness for the Resource Acquisition segment.

There is one Commercial Sector program segmented as Resource Acquisition in the portfolio.

For this reason, only the Commercial Sector is listed below.

Table 8. Forecasted cost effectiveness of resource acquisition segment at portfolio, sector, and program level
TRC, no Admin TRC, w/Admin PAC no Admin PAC w/Admin
Resource
Acquisition
Segment

0.64 0.39 0.87 0.41
Commercial
Sector

0.51 0.27 0.62 0.29
SDREN Flex
Market Program

0.64 0.43 0.87 0.52
All Segments
SDREN is proposing one Resource Acquisition program, five Equity programs, three Market Support programs, and one Codes and Standards program. Several of these programs will contribute to SDREN’s total system benefit (TSB) forecasts by offering measures and services not covered by other programs. Most, if not all, of SDREN programs will drive participation in SDG&E programs through referrals. This will, in turn, contribute to the region's TSB goals.

The biannual Potential and Goals (P&G) Study that develops savings goals to inform EE program planning for PAs does not currently set goals for RENs. The CPUC Decision Adopting Energy Efficiency Goals for 2024-2032 established the TSB goal for 2024-2027 in SDG&E territory at $184,147,673, based on the 2023 P&G Study.15 Based on their most recently filed true up advice letter (TUAL), SDG&E’s total TSB forecast is $395,517,890 for program years 2024-2027, equating to 215% of their goal.16
SDREN recognizes the importance of delivering on the TSB goals set through the authorization of this portfolio. The table below outlines the forecasted four-year TSB, net first year kWh, kW, therms, and CO2 emissions avoided at the portfolio level, by segment and by sector.

Table 9. Forecasted 2024-2027 cumulative TSB, net first year savings, and GHG emissions avoided
16 SDG&E True Up Advice Letter 4302-E.
15 D. 23-08-005, pg. 18
22 TSB ($) Net kWh Net kW Net Therms Tons CO2e
Portfolio $18,194,415 14,246,780 684 711,168 8,561
Resource
Acquisition
$7,428,942 12,615,801 0 0 4,278
Market
Support
$6,826,309 364,996 313 456,727 2,533
Equity $3,939,164 1,265,984 372 254,442 1,750
Codes &
Standards
$0 0 0 0 0
Commercial $9,021,653 15,493,358 372 (445) 5,215
WE&T $0 0000
Public $1,753,895 364,996 313 456,727 2,533
Residential $637,360 (1,611,573) 0 254,887 813
Forecast Methodology
Portfolio Administration vs. Program Implementation Costs SDCP started its portfolio planning process by focusing on the REN directives and designing an energy efficiency program portfolio appropriate to meet the unique unmet needs within San Diego County. A reasonable budget range was then designated for the portfolio by looking at the budgets of other RENs and PAs. The program-level budgets were developed using a zero-based budget approach and followed guidance from the CPUC and EE Policy Manual.

SDCP has tried its best to assess the EE program gaps and EE service needs within San Diego County, focusing particularly on HTR and underserved customer segments, to design and propose programs that will fill gaps and meet communities’ needs. The proposed budgets are calibrated to allow a sufficient scale for program delivery to the targeted customer segments in the SDREN service territory and to confidently expect significant positive customer impacts. The requested budgets are commensurate with the program and portfolio budgets that have previously been approved by the CPUC for RENs in other IOU territories.

SDREN developed a budget conforming to CPUC guidance (referencing D.21-05-031 pp 32-33 for program administration versus program implementation) and the Energy Efficiency Policy Manual. The budget breakdown in the SDREN 2024-2031 EE Application Excel Sheets and SDREN 23 Attachment B Supplemental Budget Information Narrative includes the following categories and costs:
● Administration: The budget forecast includes 10% administrative costs allocated within each program to be apportioned at the portfolio-level for all activities that are not associated with program implementation. As a new REN, SDCP is allocating the full 10% cap, but anticipates developing administrative efficiencies to reduce administrative costs during operation. SDREN will meet regularly with other PAs, such as the other RENs, to understand best practices for decreasing the overall portfolio allocation to administration.
● Marketing, education, and outreach (ME&O): 6% ME&O has been allocated within each program to be apportioned for activities both at the program level and the portfolio level.
● Direct implementation - incentives: This has been allocated at the program level for any program that offers incentives for measures that deliver TSB. The allocation by program has been determined based on estimated incentive value disbursed through the program and energy savings targets achieved for measures installed or delivered. ● Direct implementation - non-incentives: This has been allocated at the program-level and is based on the services and resources the programs will deliver. It has been developed to align with the incentive program forecast when applicable. ● EM&V: 4% has been allocated at the portfolio-level in accordance with D.21-05-031 and in alignment with the 2024-2031 EE Application Attachment Tables.

Segmentation Strategy
SDREN’s overarching segmentation strategy is described below. Additional details on SDREN’s segmentation justification at the program level can be found in Exhibit 3 - Program Segmentation Justification Template Attachment A from D.23.06.055.

Strategies Driving Distribution of Budget Among Segments SDREN’s portfolio includes programs in all segments, with the majority of its budget allocated to the market support and equity segments. The strategies driving its segmentation approach and budget distribution are in alignment with broader portfolio objectives to complement existing and emerging offerings to accelerate equitable decarbonization throughout San Diego County.

SDREN’s segmentation strategy, as described below, is informed by its core values and guiding principles.

The budget allocation by segment is illustrated in the graphic below. 24 Figure 7. SDREN 2024-2027 Budget Allocation by Segment Resource Acquisition: SDREN has allocated nearly 14% of its budget toward the resource acquisition segment. SDREN recognizes that SDG&E is investing heavily in this segment and is projected to significantly exceed TSB goals established from the P&G study.17 Given SDG&E’s investment in resource programs, SDREN is proposing only one resource acquisition program. It is targeted to HTR customers that are not anticipated to be served by SDG&E programs. This market access program (MAP) expands an existing SDCP program that has been launched in their territory. The SDREN proposed program will expand this existing program to the entire SDREN territory using lessons learned from SDCP’s program.

Codes & Standards: Approximately 6% of SDREN’s portfolio budget is allocated toward codes and standards activities for a program focused on decarbonization-related code enforcement, compliance, and adoption of reach codes. SDREN identified that C&S activities are a demonstrated strength of RENs. As such, SDREN’s budget allocation is commensurate with spending by other RENs within this segment.

Market Support: 34% of SDREN’s budget is allocated to the market support segment. SDREN is proposing three market support programs, primarily focused on workforce, education, and training. All programs are based on successful models to build local capacity and strengthen the energy market’s long-term success.

Equity: The highest proportion of SDREN’s budget, at just over 46%, is allocated to equity programs. SDG&E has a limited investment in the equity segment, with just 7%18 of their portfolio directed to equity programs.19 SDREN’s portfolio includes five equity programs designed to fill this gap in funding for equity customers. These programs are key to meeting SDREN’s long-term goal of equitable decarbonization of the San Diego region. They will help 19 CPUC Budget Filing Metrics 2024-2027
https://public.tableau.com/app/profile/capublicutilities/viz/CPUC24-27BudgetFilingData/BudgetPlanDashboard. 18 SDG&E True Up Advice Letter 4302-E.
17 SDG&E True Up Advice Letter 4302-E.
25 equity customers to leverage other resources and programs and maximize the benefits to their communities.

Resource Acquisition
Resource acquisition programs have the primary purpose of and a short-term ability to deliver cost-effective avoided cost benefits to the electricity and natural gas systems. For SDREN, this segment is forecasted to deliver the bulk of savings to achieve TSB goals.20 Preliminary Resource Acquisition Budget for 2024-2027 and Rationale for Distribution
SDREN’s resource acquisition segment budget is $16,479,316, representing 13.8% of SDREN’s proposed 2024-2027 budget. There is one commercial sector program within the resource acquisition segment, which will focus on projects that reduce peak demand usage and deliver verifiable energy savings. This program will help SDREN advance decarbonization, reduce energy burdens, reduce energy consumption, and increase participation in and access to EE programs.

The program will focus outreach efforts on small to medium HTR and underserved commercial customers that may be missed or passed over by other programs. It is intended to deliver a majority of the TSB savings for the portfolio.

Table 10. Resource Acquisition Four-Year Budget Breakdown by Sector Sector 2024 2025 2026 2027 Total
Commercial $2,102,000 $4,343,600 $4,777,960 $5,255,756 $16,479,316 Resource Acquisition Goals, Strategies, and Outcomes
For the 2024-2027 portfolio period, SDREN will follow the goals, strategies, and outcomes in the table below for the market support sector. The strategies included will help the state achieve Environmental and Social Justice Action Plan (ESJAP) goals 2 and 4 by investing in clean energy resources and improving climate resilience, while benefiting ESJ businesses.

Table 11. Resource Acquisition Goals, Strategies and Outcomes Goals Strategies Outcomes
● Accelerate
implementation of EE
measures.
● Accelerate load
modification program
participation.
● Scale an existing
program that
incentivizes long-life
measures that also
reduce peak demand.
● Leverage incentives and
commissioning process
● Establish emerging EE
technologies such as heat
pump water heaters with
DR integration capabilities
as the standard practice.
● Normalize device
commissioning and
20 Decision 21-05-031, pg 14.
26 ● Provide short-term
benefits to electricity
and natural gas systems,
as measured by TSB.
● Achieve verifiable energy
savings and peak
demand reductions.
● Increase HTR and
underserved businesses’
participation in EE
programs.
for load modification
programs alongside EE
measure purchase and
installation.
● Focus on commercial
customers that are
underserved by other
regional market access
programs.
● Work with trusted local
advisors to support
access to programs.
enrollment in load
modification programs as a
standard business practice
by contractors.
● Fully realize the potential of
EE through comprehensive
whole building retrofits
that capture ‘stranded’
to-code energy savings at
the meter.
● Small and medium
businesses that have
previously not participated
in EE experience multiple
benefits through
participation.

Projected Portfolio and Sector-level Metrics
The following resource acquisition metrics will also be reported at the portfolio and commercial sector levels. Additional metrics and/or indicators may be identified by the implementer once under contract or through Commission direction. SDREN will report on relevant common metrics and others that roll up into the unique value metrics.

Table 12. Resource Acquisition Metrics
Description 2024 2025 2026 2027 Total
Total system
benefit
(TSB; $)
$0 $4,865,784 $6,168,332 $7,160,300 $18,194,416
Net GHG
reduction
0 2,368 2,977 3,216 8,561
Net kWh
savings
0 3,864,663 4,990,604 5,391,513 14,246,780
Net kW
savings
0 203 228 254 685
Net therms
savings
0 200,788 235,749 274,631 711,168
27 Resource Acquisition Segment-Specific Coordination
SDG&E is growing the number of resource acquisition commercial sector programs it offers through several current and upcoming third party solicitations. SDREN will coordinate closely with SDG&E ahead of program launch to prevent any market confusion. To ensure commercial customers are served effectively, SDREN will train local trusted entities as customer engagement representatives to direct customers to programs that fit their needs. Customer engagement representatives will target and market programs to HTR and underserved commercial customers that would benefit from customized engagement approaches.

Codes & Standards
The codes and standards segment has the following primary purposes:
● Influencing standards and code-setting bodies (such as the CEC) to strengthen energy efficiency and load management regulations.
● Improving compliance with existing codes and standards. ● Helping local governments develop ordinances that exceed statewide minimum requirements.
● Coordinating with the other programs and entities to support the state’s policy goals.21 Preliminary Codes & Standards Budget for 2024-2027 and Rationale for Distribution
The Codes & Standards segment budget is $12,791,171, representing 6.1% of the SDREN proposed four year budget. The segment mirrors the cross-cutting C&S sector, which includes just one program. SDREN’s C&S segment is intended to complement existing efforts at the state and regional level by improving compliance at the local level. The C&S landscape requires a localized approach due to the current gaps, barriers, and challenges permitting agencies face and the urgency needed to rapidly scale up compliance to meet ambitious decarbonization goals. SDREN’s program will provide tailored support to help agencies navigate the intricate energy code compliance landscape effectively. Given agencies’ needs and successes noted in other regions, the budget was developed to be commensurate with budget allocations for other REN C&S programs.

Table 13. C&S Four-Year Budget Breakdown
Sector 2024 2025 2026 2027 Total
C&S $934,000 $1,930,500 $2,123,550 $2,335,905 $7,323,955 Codes & Standards Goals, Strategies, and Outcomes
For the 2024-2027 portfolio period, SDREN will follow the goals, strategies, and outcomes for the C&S sector outlined in the table below. The strategies below will support the state in meeting ESJAP goal 6: enhancing the enforcement of codes to ensure safety and consumer 21 D.23-06-055, pg.13-14.
28 protection for ESJ communities. Reference the C&S Sector Goals, Objectives, Strategies section for a full description of goals, strategies, and outcomes.

Table 14. Codes & Standards Goals, Strategies and Outcomes Goals Strategies Outcomes
● Empower permitting
agencies and the C&S
community to
improve energy code
compliance, reduce
energy consumption,
and reduce GHG
emissions while
supporting the state’s
EE and GHG goals.
● Help public agencies
compile and use data
to enhance energy
code compliance and
facilitate adoption of
advanced energy
codes and policies.
● Promote the
adoption,
implementation, and
enforcement of
advanced energy
codes, standards, and
policies that improve
building energy
performance and
accelerate
decarbonization.
● Streamline permitting
processes.
● Provide comprehensive
support for implementation
of advanced energy codes.
● Develop compliance and
enforcement strategies and
effective tracking
mechanisms.
● Create a suite of tools,
technical resources, and
templates, including an
energy code coach.
● Build participant staff
capacity and their ability to
use building stock,
benchmarking and C&S
data.
● Create feedback loops from
C&S activities that inform
comprehensive strategies
across SDREN offerings.
● Provide educational
information to the C&S
community about the
phase out of HFCs and
low-GWP refrigerant
alternatives.
● The C&S community
achieves
high-performance and
resilient buildings.
● Streamlined permit
approvals that include
energy resiliency and
climate adaptation
design elements.
● Public agency energy
resilience action plans,
energy/GHG reduction
targets, and other
strategies are informed
by digitized data
collected from
permitting.
● Reduced energy costs,
improved indoor air
quality, and enhanced
building functionality.
● State and federal
technical expertise and
funds are leveraged to
develop and deploy new
policies.
● Local building
performance standards
(BPS) and building
benchmarking
requirements that
improve building
efficiency, comfort,
economics, and health
become common
practice.
29 Projected Annual Portfolio and Sector-Level Metrics
The following C&S metrics/indicators will be reported at the Portfolio and Cross-Cutting C&S Sector levels. Additional metrics/indicators may be identified by the implementer once under contract or through Commission direction.

Table 15. Codes & Standards Metrics
Metric or
Indicator
Metric/Indicator Description 2024-2027
Metric Number and percent of local government permitting agencies receiving C&S program services and assistance.

To be confirmed after
SDREN awards
contract to
Metric Number and percent of local governments who adopt implementer. model energy codes and advanced energy
policies/standards.

Indicator Magnitude of improved code compliance and closed permit outcomes by participating local governments.

Indicator Number and percent of local governments who
implement improved permit data collection, tracking, and analysis to enhance energy code compliance outcomes.

Metric Number of training activities (classes, webinars, workshops, etc.) held and number of participants by
category.

Metric Number and percent of permitting agencies who receive assistance from an SDREN energy code coach.

SDREN will also report on segment- and sector-specific common metrics and other metrics and indicators that roll up into the portfolio’s unique value metrics.

C&S Segment-Specific Coordination
SDREN will coordinate its C&S segment strategies with SDG&E’s C&S programs and with statewide C&S programs administered by the IOUs and the CEC. Coordination with other C&S programs will avoid potential overlap and duplication and ensure that the SDREN C&S programs and initiatives provide substantial new value to the San Diego County C&S community. SDREN will leverage best practices, coordination strategies, program design innovations, and tools and resources from other RENs and IOUs, such as Energy Code Ace and the Energy Hub developed with the San Diego Regional Climate Collaborative (SDRCC), to develop consistent and comprehensive C&S solutions.
30 SDREN and SDG&E staff will convene regular meetings and communication to ensure a well-coordinated set of codes and standards program offerings and a comprehensive set of C&S policy strategies and compliance solutions. SDREN and SDG&E will also work together on marketing and outreach efforts. Both the proposed SDREN C&S program and the SDG&E Local Codes and Standards program will strive to offer a comprehensive set of strategies to effectively address current and anticipated C&S policy drivers and increase compliance support for permitting agencies and permit applicants. Areas of anticipated SDREN and SDG&E collaboration and coordination include:
● Working together on C&S needs assessments.
● Developing customized education and technical assistance for city and county building departments.
● Developing complementary C&S education tools, resources, workshops, training, and forums.
● Developing complementary approaches to educating and advocating for improved existing building performance, such as benchmarking, building performance standards, rating systems, energy auditing, etc.
● Working together to create innovative C&S solutions that assist in meeting state climate and energy goals.

Market Support
Market Support programs have a primary objective of supporting the long-term success of the energy efficiency market by educating customers, training contractors, building partnerships, or moving beneficial technologies towards greater cost-effectiveness.22 Multiple sub-objectives for the segment have also been identified and are listed below:23

1. Demand: Build, enable, and maintain demand for energy efficient products and services in all sectors and industries to ensure interest in, knowledge of, and awareness of how to obtain energy efficient products and/or services.

2. Supply: Build, enable, and maintain supply chains to increase the capability of market actors to supply energy efficient products and/or services, and to increase the ability, capability, and motivation of market actors to perform/ensure quality installations that optimize energy efficiency savings.

3. Partnerships: Build, enable, and maintain partnerships with consumers, governments, advocates, contractors, suppliers, manufacturers, community-based organizations and other entities to obtain delivery and/or funding efficiencies for energy efficiency products and/or services and create added value for partners.

4. Innovation and Accessibility: Build, enable, and maintain innovation and accessibility in technologies, approaches, and services to increase value, decrease costs, increase 23 Ibid.
22 D.21-05-031, pg 14.
31 energy efficiency, and/or increase scale of and access to energy efficient products and services.

5. Access to Capital: Build, enable, and maintain increased and equitable access to capital and program coordination to increase affordability of and investment in energy efficient projects, products, or services.

SDREN will also consider integration of flexible load products and projects alongside energy efficiency for these sub-objectives.

Preliminary Market Support Budget for 2024-2027 and Rationale for Distribution SDREN’s Market Support segment budget is $40,644,030, representing 34.0% of SDREN’s proposed 2024-2027 budget. There are a total of three market support programs in the portfolio, one in the Public sector and two in the Cross-Cutting WE&T sector. SDREN’s investment in the Market Support sector will support the long-term success of the EE market in the San Diego region by investing in a strong workforce and the public agencies that represent and lead the region. The allocation of budget to this segment is imperative for SDREN to deliver on all three of its portfolio goals: advancing decarbonization, providing comprehensive services that improve outcomes for underserved and HTR communities, and accelerating the clean energy economy through workforce opportunities. The overall budget commensurate with the investments of other RENs within the market support segment.

Table 16. Market Support Four-Year Budget Breakdown by Sector Sector 2024 2025 2026 2027 Total
Public $2,732,000 $5,645,500 $6,210,050 $6,831,055 $21,418,605 WE&T $2,452,000 $5,067,500 $5,574,250 $6,131,675 $19,225,425 Total $5,184,000 $10,713,000 $11,784,300 $12,962,730 $40,644,030 Market Support Goals, Strategies, and Outcomes
For the 2024-2027 portfolio period, SDREN will follow the goals, strategies, and outcomes listed in the table below for the market support sector. The strategies related to public agencies will support the state in meeting ESJAP goals 2 and 4 by increasing climate resiliency and investment in clean energy resources to benefit ESJ communities. Strategies related to workforce development will address the ESJAP goal 7 to promote high road career paths and economic opportunity for residents of ESJ communities.

Table 17. Market Support Goals, Strategies and Outcomes Sector Goals Strategies Outcomes
WE&T ● Build participant
workforce
capacity.
● Provide comprehensive
workforce educational
and wraparound services
● Increase the supply of
skilled employees
32 ● Enhance
workforce
training
pathways.
● Strengthen
employee skills
and support
professional
growth focused
on green careers.
to build skills and match
participants with
employers.
● Coordinate with job
placement programs to
support workforce
development.
● Partner with local
community college
districts to provide
college-level courses and
skill development
opportunities.
entering into the energy
and green workforce.
● Increase opportunities for
job training and
certifications.
● Connect participants to
high road jobs.
● Increase participating
organizations’ staff
retention and internal
promotional
opportunities.

Public ● Increase
capacity,
awareness, and
understanding of
the benefits of
decarbonization
and IDSM
strategies.
● Help public
agencies address
and adapt to
climate change
by reducing GHG
emissions and
increasing
energy
resilience.
● Offer comprehensive
project management and
technical assistance
services to identify and
install projects.
● Deliver education and
training to public
agencies.
● Deliver customized
decarbonization and
resilience roadmaps.
● Provide energy analysis
reports at the portfolio
and project level.
● Directly install EE and
flexible load measures.
● Channel project
opportunities to other
applicable EE and IDSM
programs.
● Help agencies secure
internal and external
funding for
decarbonization projects.
● Agencies improve their
energy resilience,
increase preparedness for
climate-related
emergencies, and
decarbonize their
facilities and assets.
● Public agencies
demonstrate awareness
of benefits of DERs and
integrate policies and
actions as standard
practice.
● Agency awareness of
energy consumption and
costs.
● Integration of EE and
IDSM recommendations
into existing or new
Climate Action Plans.
● Agencies receive capital
to fund their
decarbonization and
energy resilience projects.
● Energy bill reductions are
achieved.
33 Projected Annual Portfolio and Sector-Level Metrics
The 2023 decision authorizing EE Portfolios and Business Plans adopted a set of Market Support segment objectives and indicators. SDREN will engage with the joint PAs as part of the joint Tier 2 Advice Letter to be filed by May 1, 202424 to modify the common metrics, clarify and modify the adopted indicators, and define the process for proposing and adopting long-term market support and equity goals and metrics for success.

SDREN will track and report on the adopted and finalized Market Support indicators (by sector where applicable). These will be reported annually or quarterly and either at the segment or portfolio level, as outlined in the table below.

Table 18. Adopted Market Support Indicators
Market Support Indicators
Reported
Annually or
Quarterly?
Reported at
Segment or
Portfolio Level
Number of partners by type and purpose(s) Q P
Dollar value of non-ratepayer in-kind funds/contributions provided via partnerships A P
Participation rate relative to eligible target population for curriculum Q S
Percent of total WE&T program participants that meet the CPUC’s definition of disadvantaged worker Q S
Number of career and workforce readiness participants who have been employed for 12 months after receiving training A S Prior year percentage of new measures added to the portfolio that were previously emerging technology program (ETP)
technologies A P
Prior year percentage of new codes or standards that were previously ETP technologies A P
Savings (lifecycle net kWh, kWh, and therms) of measures currently in the portfolio that were supported by ETP, added since 2009. Ex ante with gross and net for all measures, with ex post where available A P
Number of new, validated technologies recommended to the California Technical Forum A P
Cost-effectiveness of a technology before and after intervention by the market support program (percentage change in
cost-effectiveness) A S
24 D.23-06-055 Ordering Paragraph (OP) 11.
34 Number of collaborations, with a contextual descriptions, by business plan sector to jointly develop or share training materials or resources A P
Number of participants by sector that complete training Q S Number of projects (outside of ETP) that validate the technical performance, market barrier knowledge, and/or effective program interventions of an emerging/under-utilized or existing energy efficient technology A P
Total projects completed/measures installed and dollar value of consolidated programs by sector Q P
Ratio of ratepayer funds expended to private capital leveraged by sector Q P
Percentage of partners that have taken action supporting energy efficiency by type Q P
Number of contractors (that serve in the portfolio administrator service areas) trained by relevant market support programs to provide quality installations that optimize energy efficiency Q S Assessed value of the partnership by partners A P
Percent of market penetration of emerging/under-utilized or existing energy efficiency products or services A P
Percent of market participant awareness of
emerging/under-utilized or existing energy efficiency products or services A P
Aggregated confidence level in performance verification by production, project, and service (for relevant programs) A P Cost differential between comparable market rate products and program products A P
Comparisons between market-rate capital vs. capital accessed via energy efficiency programs (e.g., interest rate, monthly payment) A P
Other progress trackers SDREN will report on include:
● The additional seventeen indicators focused on awareness, knowledge, attitude, and behavior (AKAB) outlined in D.23-06-055, once additional guidance is available.25 ● Program-level progress trackers, which are outlined in the program cards and will be finalized after award of contract to implementation consultant. ● Portfolio- and sector-specific common metrics and indicators. 25 D.23.06.055, pg 63.
35 ● Metrics and indicators that roll up into the portfolio’s unique value metrics.

Market Support Segment-Specific Coordination
To meet the objectives of the market support segment, SDREN will thoughtfully and consistently coordinate with SDG&E and their third party program implementers. SDREN will engage with SDG&E ahead of soliciting any of the market support programs to third party implementers in order to clearly outline service gaps and opportunities for integrating coordination into the solicitations. Additionally, SDREN will coordinate with other workforce development actors in the region and across the state, such as other RENs and EE third party implementers, to share best practices and resources.

As part of SDREN’s unique value and to meet market support objectives, they will coordinate with the following regional entities: San Diego Regional Climate Collaborative, SDCP, CEA, SDG&E, San Diego Workforce Partnership, San Diego Association of Governments (SANDAG), San Diego Green Building Council, and International Code Council (ICC) SD Chapter.

SDREN will also closely monitor market transformation initiatives and activities from CalMTA26 for opportunities to incorporate them into the Market Support segment of the SDREN portfolio.

Equity
The purpose of Equity segment programs is to provide energy efficiency resources to hard-to-reach or underserved customers and disadvantaged communities and to advance the ESJ Action Plan.27
Multiple sub-objectives for the segment have also been identified as listed below:28

1. Address disparities in access to energy efficiency programs.

2. Promote resilience, health, comfort, safety, energy affordability, and/or energy savings.

3. Reduce energy-related greenhouse gas and criteria pollutant emissions.

4. Provide workforce opportunities.

Preliminary Equity Budget for 2023-2027 and Rationale for Distribution SDREN’s Equity segment budget is $55,047,128, representing 46.1% of SDREN’s proposed 2024-2027 budget. Consistent with SDREN’s Guiding Principle 1 (to advance environmental equity) and Portfolio Goal 2 (to improve outcomes for underserved and hard-to-reach communities), SDREN has allocated the most significant portion of its budget to Equity segment activities. This focus area fills a gap in the region, since SDG&E’s portfolio focuses only a small fraction of its budget on Equity segment activities.

As part of the market assessment when developing this application, SDREN developed a map to visualize the geographic regions considered hard-to-reach and underserved based on definitions 28 Ibid.
27 D.21-05-031, pg 14.
26 https://calmta.org/
36 adopted in D.23-06-055. Based on this map, it was determined that 56% of the SDREN population lives in an underserved community.

Figure 8. Underserved communities within SDREN territory, where 56% of population resides SDREN proposes a total of five Equity programs in the Commercial, Public, and Residential sectors. The total budget allocated to each sector within the Equity segment is outlined in the table below. It is notable that nearly half (46%) of the total segment budget is allocated to direct install measures. This strategy, in alignment with SDREN’s portfolio vision, enhances SDREN’s ability to ensure underserved, hard-to-reach, and disadvantaged communities are not left behind in the clean energy transition.

Table 19. Equity Four-Year Budget Breakdown by Sector
Sector 2024 2025 2026 2027 Total
Commercial $2,336,000 $4,826,200 $5,308,820 $5,839,702 $18,310,722 Public $234,000 $482,600 $530,860 $583,946 $1,831,406
Residential $4,453,000 $9,200,000 $10,120,000 $11,132,000 $34,905,000 Total $7,023,000 $14,508,800 $15,959,680 $17,555,648 $55,047,128 Equity Specific Strategies, Goals, and Outcomes
For the 2024-2027 portfolio period, SDREN will pursue the goals, strategies, and outcomes listed in the table below for the Equity sector. All of the below strategies will support the state’s ESJAP goals. The strategies related to Tribes will support the state in meeting ESJAP goal 5 by involving Tribal communities in the process of developing program strategies. All other strategies support 37 ESJAP goals 2 and 4 by increasing climate resiliency and investment in clean energy resources to benefit ESJ communities.

Table 20. Equity Segment Strategies, Goals, and Outcomes Goals Strategies Outcomes
● Deliver equitable
services to
traditionally
underserved and
HTR customers
to ensure they
are included in
the clean energy
transition.
● Reduce barriers
to EE and flex
load program
participation
among HTR and
underserved
customers.
● Focus outreach on and target
underserved and HTR
customers.
● Provide in-person, equitable,
and inclusive outreach and
support services (i.e.
in-language materials with
cultural understanding, taking
into consideration vision and
hearing impaired customers,
and customers without
internet access etc.).
● Customized energy programs
and strategies shaped by
community input.
● Increased incentive
opportunities for HTR and
underserved communities.
● One-on-one support to
connect customers to other
available programs, services,
and funding opportunities.
● Direct installation of energy
efficiency measures.
● Framework in which Tribal
governments propose and
design customized energy
programs and strategies to
meet their unique community
needs.
● Funding and financing
support, connecting
participants to other
incentive programs, financing
offerings, tax credits etc.
● Increased access to and
awareness of energy efficiency,
DER technologies, and funding
and financing programs.
● Increased participation in
ratepayer-funded EE programs
by HTR customers and
underserved communities.
● Reduced energy burden for
HTR and underserved
participants.
● Energy co-benefits (e.g. health,
comfort) realized by HTR and
underserved participants.
● A clean energy transition
inclusive of customers
historically left out of energy
programs.
● Energy justice for HTR
customers and underserved
communities.
● Increased adoption of EE and
IDSM measures and strategies.
38 Projected Annual Portfolio and Sector-Level Metrics
The Equity segment objectives and indicators were adopted in D.23-06-055. SDREN will engage with the joint PAs as part of the Tier 2 Advice Letter to be filed by May 1, 202429 to modify the common metrics, clarify and modify the adopted indicators, and define the process for proposing and adopting long-term market support and equity goals and metrics for success.

SDREN will track and report on the adopted and finalized Equity segment indicators (by sector where applicable). These will be reported annually or quarterly and either at the segment or portfolio level as outlined in the table below.

Table 21. Adopted Equity Indicators
Equity Sector Indicators
Reported
Quarterly or
Annually?
Reported by
Segment or
Portfolio?
Count of equity target participants in each segment and sector Q S
Sum of equity target participants’ expected first-year bill savings in Equity segment by sector Q S
Sum of all Equity segment participants’ greenhouse gas
reductions (in tons of carbon dioxide equivalent) Q S
Sum of all equity segment participants’ kilowatt hour (kWh) savings Q S
Sum of all equity segment participants’ kW savings
Sum of all equity segment participants’ therm savings Q S Sum of all equity segment participants’ TSB Q S
Median of equity target participants’ expected first-year bill savings by sector Q S
Percent of hard-to-reach customer participants in portfolio by residential single family/multi-family and commercial sector A P Percent of disadvantaged community customer participants in portfolio by residential single-family/multifamily and commercial sector A P
Percent of equity target participants in equity segment by sector Q S
Other equity segment metrics SDREN will report on include:
29 D.23-06-055 Ordering Paragraph (OP) 11
39 ● Program-level progress trackers for the adopted Equity segment indicators. These trackers are outlined in the program cards and will be finalized after a contract is awarded to an implementation consultant.
● Portfolio- and sector-specific common metrics.
● Metrics and indicators that roll up into the portfolio’s unique value metrics. ● Pursuant to D.23-06-055, SDREN will also develop indicators for the equity segment to measure community engagement. These will be included in the mid-cycle advice letter in 2025 and in subsequent annual reports.30
SDREN will engage in efforts outlined in D.23-06-055 to quantify non-energy benefits (NEBs) and report demographic EE program participation.

SDREN will participate in the newly formed working group intended to inform goals, priorities and scope of a study that responds to questions regarding NEBs31. Achievement of NEBs directly ties to equity objectives and SDREN anticipates that it will serve as a key metric for future portfolios focused on serving equity customers.

In D.23-06-055, the Commission directed PAs to work with the Reporting Policy Coordination Group to jointly submit a report addressing demographic questions by no later than September 1, 2025. SDREN will participate in this process and, based on that analysis, will include preferred approaches to reporting demographic energy efficiency program participation information in its 2026 proposal.32
Equity Segment Coordination
Similar to the other segments, SDREN will coordinate closely with SDG&E’s team managing Equity programs. In addition to EE market rate program coordination, SDREN will look to engage with low-income programs for ongoing coordination strategies33. Before releasing solicitations for the Equity programs, SDREN and SDG&E will work together to clearly outline service gaps and opportunities for integrating coordination into the solicitations. SDREN will promote and support access to SDG&E programs for equity customers whenever possible.

To advance the ESJ Action Plan Goal 5 to “enhance outreach and public participation opportunities for ESJ communities to meaningfully participate in the CPUC’s decision-making process and benefit from CPUC programs,”34 SDCP will look for ways to engage with communities to collect ongoing feedback to inform program design and delivery. 34 Environmental & Social Justice Action Plan Version 2.0. 33 Page 15 of D.21-05-031 states, “the ‘equity’ category is distinct from our separate low-income energy efficiency Energy Savings Assistance (ESA) programs, which have separate goals and regulatory treatment. While there is some overlap in customers within the target segments, the ‘equity’ category is intended to be defined within the energy efficiency programs covered in this rulemaking that are not specifically targeting low-income populations with program offerings that low-income populations could receive at no cost from the ESA program.” 32 D.23-06-055 OP 23.
31 D.23-06-055 pg. 34.
30 D.23-06-055 OP 24.
40 Sector Strategy
Strategies Driving Distribution of Budget Among Sectors and Alignment with Broader Portfolio Objectives
SDREN’s portfolio includes the Commercial, Public, Residential, and Cross-Cutting C&S and WE&T sectors. The portfolio’s focus and budget allocation across the targeted sectors of Commercial, Residential, and Public is in close alignment with the distribution of electricity consumption of these sectors across SDG&E’s territory.

Figure 9. SDG&E 2018-2020 Average Electric Consumption by Sector35 The Commercial, Residential, and Public sectors’ budget allocations also reflect the portfolio objectives related to decarbonization and providing comprehensive services. SDREN’s investment in the Cross-Cutting sector supports the portfolio objectives related to accelerating the clean energy economy through workforce, education and training and codes and standards offerings.

The budget allocation by sector is illustrated in the graphic below. 35 SDG&E EE Business Plan Testimony (2024-2031) - Exhibit 1, pg.9. 41 Figure 10. SDREN 2024-2027 Budget Allocation by Sector Description of Sectors SDREN Proposes to Serve
Through a market assessment, SDREN evaluated energy data (including the number of customers by type), energy efficiency program availability, and participation across sectors in San Diego County. This analysis informed SDREN’s sector focus and resources for its portfolio.

To address gaps and adequately serve HTR communities, SDREN has identified programs that will serve the Commercial, Residential and Public sectors as well as the Cross-Cutting sectors of WE&T and C&S.

Commercial Sector: SDREN proposes three Commercial Sector programs that fill gaps and will be closely coordinated with SDG&E programs. Two are equity programs, targeting HTR small-to-medium sized businesses. The goal of these programs is to deliver equitable services to HTR customers to ensure they are not left behind in the clean energy transition. The programs will achieve this goal by reducing barriers to participation, increasing awareness, and increasing adoption of EE practices and measures. Store owners, particularly HTR owners, have limited staff capacity and capital to invest in energy efficient equipment. Two of SDREN’s three commercial sector programs will deploy a direct install approach to alleviate the cost barrier to participation and enable store owners to participate in energy efficiency program offerings.

SDREN’s third commercial sector program is a resource program that will provide incentives to commercial customers for peak demand reduction and verifiable energy savings. 42 Public Sector: The public sector will offer two programs that fill gaps in SDG&E services and will guide participants to SDG&E programs where applicable. One is a market support program that offers comprehensive, customized and unbiased end to end EE project services to public agencies within San Diego County. The second is an equity program that will collaborate with Tribal communities to design and deliver community-specific programs. There are no current Tribal-specific EE strategies or programs offered by SDG&E or any other PA.

Residential Sector: SDREN proposes two residential programs, both of which address equity.

Both fill gaps in current SDG&E offerings to multifamily and single-family customers by providing customized support and education to HTR renters and homeowners. Because residential customers are typically overwhelmed by complex program offerings and multiple entry points, SDREN will provide behavioral engagement and an unbiased “energy advisor” to demystify funding opportunities. Programs will conduct education and outreach to highlight non-energy benefits and a pathway to electrification. Understanding that the multifamily sub-sector has experienced EE program challenges across the state, SDREN will coordinate directly with PAs and implementers to apply the latest lessons learned from other multifamily programs prior to implementation.

Cross-Cutting Sector: SDREN’s portfolio supports the Cross-Cutting sector through C&S and WE&T programs.
● Codes & Standards: SDREN‘s proposed codes and standards program will supplement and complement SDG&E’s C&S programs and all statewide C&S programs. SDREN’s program will provide local agencies with policy and compliance support, increase permitting authorities’ expertise, and enhance communication between permitting authorities and permit applicants. SDREN’s C&S program works with public agencies to provide policy and compliance support. Similar to other RENs, the program will coordinate closely with the current local SDG&E program and statewide programs, which primarily focus on advocacy to the CEC and Department of Energy (DOE) related to appliance and building standards.
● Workforce, Education & Training: SDREN proposes two market support WE&T programs that fill gaps, support development of a green workforce that includes vulnerable populations, and build resilient communities. These programs offer wraparound services targeting individuals in HTR, DAC, and historically underserved communities. They will provide equitable access to education and skill-building pathways that will increase clean energy career opportunities for new market entrants and increase green workforce training through employers.

Preliminary Distribution of Budget Among Sectors for
2024-2027 and Rationale for Distribution
Table 22. Distribution of programs and budgets among sectors for 2024-2027 (not including EM&V)
Sector Number of 2024-2027 Budget % of Portfolio
43 Programs
Residential 2 $34,905,000 29%
Commercial 3 $34,790,038 29%
Public 2 $23,250,011 19%
Cross-Cutting: WE&T 2 $19,225,425 16%
Cross-Cutting: C&S 1 $7,323,955 6%
Total 10 $119,494,429 100%
Commercial Sector: SDREN proposes three Commercial sector programs with a total four-year budget of $34.8 million, representing 29% of the SDREN portfolio. The Commercial sector accounts for the largest share of electricity consumption within SDG&E's service territory, comprising 40% of the total usage.36 Approximately 77% of SDG&E commercial sector customers fall into the small commercial category and nearly two-thirds of all commercial customers have fewer than five employees.37 This market context, coupled with the fact that all but one of the planned EE programs within the commercial sector will be focused on resource equity goals, justify SDREN’s focus on this sector.

Cross-Cutting Sector: Approximately 22% of SDREN’s portfolio is allocated to the Cross-Cutting sector, which includes both C&S and WE&T programs.
● C&S: SDREN is proposing a single codes and standards program with a total four-year budget of $7.3 million, representing 6% of the total portfolio budget. The budget is based on SDREN’s evaluation of C&S market needs within San Diego County and is commensurate with total budget allocations of other REN C&S budgets that support IOU and statewide efforts. The C&S sector program fills gaps and is critical to accelerating a decarbonized energy future in San Diego County. The SDREN program will support permitting agencies on Title 24 compliance and adopting Title 24 reach codes, and will offer customized support. All other RENs in the state will have a C&S offering starting in 2024, highlighting a clear gap in San Diego for this support. ● WE&T: SDREN‘s portfolio includes two WE&T programs with a total four-year budget of $19.2 million, representing 16% of the total portfolio. The percent allocation of other REN WE&T budgets range from 4% (SoCalREN) to 25% (RuralREN). The transition toward decarbonized buildings, coupled with substantial investments in a clean energy economy (e.g. IRA and the Equitable Building Decarbonization Program), creates a heightened need for a skilled workforce to deliver on local, state, and federal climate and energy goals. SDREN is dedicated to addressing the shortage of workers with essential skills to support the transition to clean energy.

Public Sector: The Public sector segment will offer two programs with a total four-year budget of $23.3 million, representing 19% of the SDREN portfolio. SDREN has allocated a significant 37 SDG&E Business Plan, Exhibit 1, pg. 9.
36 SDG&E EE Portfolio Testimony (2024-2027), Exhibit 2, pg. 57. 44 budget to this sector because it has historically been underserved. Existing programs in the sector are resource segment programs, which tend to leave small customers behind due to strict cost-effectiveness requirements. Furthermore, during coordination discussions with SDG&E, SDREN identified a programmatic gap that formed when SDG&E’s third party implemented k-12 schools program closed. SDREN’s programs fill this gap and ensure public agencies are served equitably and comprehensively.

Residential Sector: SDREN proposes two residential equity programs with a total four-year budget of $34.9 million, representing 29% of the overall portfolio. SDREN has allocated a significant portion of its budget to this sector since the Residential sector is the largest customer group in SDG&E territory and it is currently challenging for HTR customers to participate in and fully benefit from the clean energy program landscape. Additionally, the EE P&G study found opportunity for significant savings in the region based on incremental market potential.

Commercial Sector
Market Characterization
The small-medium business (SMB) community is composed of diverse business owners, with approximately 77% falling into the small commercial category (energy demand of <20 kW).

Nearly two-thirds of all commercial customers are micro businesses with fewer than five employees.38 Additionally, it is estimated that 38% of San Diego County residents speak a language other than English at home.39 SDREN's proposed Commercial sector programs open the door to a substantial market opportunity in the Commercial sector. The Commercial sector accounts for the largest share of electricity consumption within SDG&E's service territory, comprising 40% of the total usage.40
There are currently two SDG&E EE third party Commercial sector programs available for commercial customers, but SDG&E is actively soliciting several Commercial sector offers as outlined in the table below. These additional commercial programs are anticipated to be contracted and launched over the next eighteen months and are anticipated to target several market sub-sectors. Five of SDG&E’s EE Commercial programs are segmented as resource acquisition programs, and there is one equity and one market support program anticipated to launch in early 2024.

Table 23. Current and upcoming SDG&E EE third party commercial programs Program Type or Name and Segmentation Status
Comprehensive Energy Management Solutions (CEMS)
for customers >20kW - Resource Acquisition Currently active Business Energy Solutions (BES) for customers <20kW -
Resource Acquisition
Will ramp down for new equity
program
Small Business Outreach - Equity Anticipated launch Q1 2024 40 SDG&E EE Portfolio Plan Testimony (2024-2027), Exhibit 2, p.57. 39 US Census Data for San Diego County. https://www.census.gov/quickfacts/fact/table/sandiegocitycalifornia/PST045222 38 SDG&E Business Plan, Exhibit 1, pg. 9.
45 Groceries, Restaurants, Food Storage - Resource
Acquisition Anticipated launch Q4 2024
Private Institutions, Healthcare - Resource Acquisition Anticipated launch Q2 2025 Lodging - Resource Acquisition Anticipated launch Q1 2025 Cross-cutting Non-Residential Behavior - Market Support Advice letter pending / anticipated launch Q1 2024
Commercial Sector Goals, Objectives and Strategies
SDREN’s commercial portfolio has been crafted to meet the diverse energy efficiency needs of various business types, with a focus on hard-to-reach and underserved commercial customers.

SDREN’s services aim to bridge gaps by referring customers to appropriate programs and services.

The overarching objective for this sector is to deliver equity-driven and high-impact EE programs. These programs are designed to expand market reach, particularly among HTR and underserved businesses. Furthermore, they seek to accelerate the implementation of deep EE retrofits and deliver quantifiable EE benefits that reduce greenhouse gas emissions and increase grid reliability.

Table 24. Commercial Sector Goals, Objectives, and Strategies Goals Strategies Objectives
Deliver equitable
services to the
traditionally
underserved micro and
small business sector.
● Focus on disadvantaged,
underserved, and hard-to-reach
communities within San Diego
County.
● Provide in-person, in-language and
culturally sensitive outreach and
support services through trusted
representatives.
● Increase participation
of HTR customers in
ratepayer-funded EE
programs.
● Create equity
co-benefits such as
healthy, fresh food
offerings in local
grocery stores.

Reduce barriers to EE
program participation
among commercial
customers.
● Provide each participant with a
single implementer point of contact
(energy coach) as a connection
point to programs and services.
● Offer direct installation of energy
efficiency measures for SMBs.
● Build program participants’ EE
expertise and train them to identify
energy-saving potential at their
businesses.
● Increase commercial
sector adoption of EE
equipment.
● Increase awareness of
EE technologies and
funding/financing
programs.
● Reduce lifecycle costs
of installing EE
measures.
46 ● Connect businesses to and provide
information on EE
funding/financing, including IRA tax
credits, in alignment with the 2023
Potential and Goals Study.
● Provide in-language and culturally
sensitive outreach materials and
program documents.
● Help customers save
on energy bills and
reduce GHG
emissions.
● Realize TSB.

Accelerate
implementation of EE
measures and
long-term EE market
transformation through
program interventions.
● Provide pathways through the SMB
Energy Coach program for
decarbonization, such as through
heat pump water heaters.
● Flex Market program will incentivize
long-life measures that provide high
TSB via multi-year energy savings.
● Facilitate access to programs that
encourage long-term sustainable
energy actions, such as the
California Green Business Network.
● Emerging EE
technologies like heat
pump water heaters
have become
standard practice.
● Realize full potential
of EE through
comprehensive whole
building retrofits that
capture ‘stranded’
to-code energy
savings at the meter.
● Avoid peaker plant
emissions through
deep peak demand
reduction.
● Increase participation
in locally recognized
programs that offer
green business
certifications.

Commercial Sector Coordination
SDG&E and statewide programs overlapping in this sector include:
● Comfortably California, a statewide upstream and midstream heating, ventilation and air conditioning (HVAC) program that offers deemed HVAC measures. SDREN’s SMB Energy Coach program may refer program participants to this program as applicable. ● The Smart Thermostat Program for Businesses, where customers receive a $50 incentive for installing and registering an approved thermostat that activates during DR events. SDREN’s SMB Energy Coach program will highlight this opportunity to eligible participants.
47 ● SDG&E’s commercial portfolio includes a Small Business Outreach equity program called Small Business Saver targeting EE interventions with small business customers (under 20 kW). As of the filing of this Business Plan, this program has not yet launched with a new third party implementer. SDREN will coordinate closely with this program to fill gaps and avoid duplication.
● SDG&E offers a market access program and the Comprehensive Energy Management Solutions (CEMS41) program for large commercial customers (over 20 kW). While the CEMs and Market Access Program (MAP) will be available to customers also eligible for the SDREN Flex Market program, the programs have notable differences, including:

1. SDG&E CEMS offers direct install, deemed, custom, and site-NMEC incentives.

2. SDG&E MAP offers a population-NMEC approach for a subset of measures that are unable to participate in SDG&E’s other downstream EE programs with performance-based incentives paid to the aggregator.

3. SDREN Flex Market offers a measure-flexible population-NMEC approach with performance-based incentives paid to the aggregator targeted to underserved and HTR businesses.

To avoid overlap among SDG&E and statewide programs in the region, SDREN will coordinate closely with SDG&E and the statewide program administrators and their implementers to offer complimentary and gap-filling services to program participants. Upon Business Plan approval, SDREN will file a joint cooperation memo with SDG&E and any other program administrators operating in shared service territory to outline coordination protocols that ensure services fill gaps, meet regional needs, and avoid duplication. Some initial strategies discussed with SDG&E during the portfolio application development include:
● Mapping of full commercial portfolios, including eligibility criteria, customer targeting, and services ahead of SDREN solicitations.
● Coordinating closely with the new SDG&E Commercial Equity program to fill gaps in service and prevent market confusion.
● Developing a joint customer messaging strategy.
● Promoting complementary programs such as Comfortably California and the Smart Thermostat Program to eligible customers.

While SDG&E’s Small Business Outreach program may offer similar services to SDREN’s SMB Energy Coach program, SMB Energy Coach pairs technical assistance and advisory services with turnkey direct install measure delivery for a seamless, integrated program experience. SDREN’s direct install model alleviates the out-of-pocket cost barrier to EE measure adoption.

Importantly, the SMB Energy Coach will identify all opportunities available to participants including SDG&E, statewide, and federal programs and funding opportunities. As with all of SDREN’s offerings, the program will also integrate IDSM support. SDREN’s Efficient Refrigeration program will target small local grocery stores, corner stores, and local small businesses that sell 41 https://cedars.sound-data.com/documents/download/2889/main/ 48 food products. The equity efficient refrigeration program will offer DI measures not offered by other programs. Both the SMB Energy Coach and equity Efficient Refrigeration programs will target hard-to-reach customers.

SDREN will monitor the market and coordinate with other programs to leverage complementary offerings and combine incentives, including:
● Leveraging GoGreen Financing to develop projects with favorable financing terms through California Alternative Energy and Advanced Transportation Financing Authority (CAEATFA) and IDSM incentive programs.
● Stacking IRA tax credits, 179D Commercial Building EE tax deductions, and TECH incentives to reduce equipment costs.

Categorization by Segment
Additional details on SDREN’s segmentation justification at the program level can be found in Exhibit 3 - Attachment X: Program Segmentation Justification template Attachment A from D.23.06.055.

Table 25. Commercial Sector Program Categorization by Segment Program Segment Justification/Goal
SMB Energy Coach Equity Provide energy efficiency services to hard-to-reach and/or underserved communities in alignment with
the Commission’s Environmental and Social Justice
Action Plan.

Efficient Refrigeration
Flex Market Resource
Acquisition
Deliver cost-effective avoided cost benefits to the
state’s energy systems. SDREN will rely on this program to deliver the bulk of the commercial portfolio’s TSB
target, in alignment with the CPUC’s directive to
expand NMEC programs statewide.

Commercial Sector Program Details
Table 26. Program Card for SMB Energy Coach
Program Name: SMB Energy Coach
Program ID: SDREN-01-COM-SMB
New/Existing: New
Link to implementation plan if existing (see D.21-05-031): N/A Portfolio Segment: Equity Implementation Party: Third-Party Implementer
49 Applicable Sector: Commercial Market Sub-Sector: Small-Medium businesses
Sector Challenge:
● SMBs may be unaware of EE
technologies and value, and lack
bandwidth to research and access
resources.
● SMBs lack education on how to
develop and pursue EE projects while
meeting the varying requirements to
access incentives, tax credits, and
financing.
● SMBs need technical expertise to
identify EE opportunities and to
develop the scope of work and
technical specifications for EE
projects.
● Many small businesses lease their
space and do not control
investing/implementing EE
opportunities.
○ Coordination with both
tenants and landlords is
required.
● Without energy program support,
up-front capital costs prevent EE
measure implementation.

Sector Opportunity:
● Small businesses (<20 kW) make up
the majority (77%) of commercial
SDG&E customers.
● Assist SMBs to work with local CA
Green Business Network to receive
recognition for EE program
participation.
● Provide EE education and advisory
services to landlords/property
management companies and tenants
to address split incentive challenges.
● Educate SMBs on behavioral,
retro-commissioning, and operational
(BRO) measures applicable to their
facilities.
● In alignment with AB 793, educate
SMBs on energy management
technologies.

Known Equity Concerns in the Selected
Markets: There are multiple equity concerns
related to SMBs in San Diego County. Many
SMBs lack the knowledge and/or experience
to pursue incentive opportunities and
financing programs for EE projects, which
may deter them from considering energy
upgrades. SMBs commonly perceive EE
measures as expensive investments, and they
may lack the capital to pursue EE measures in
their budget. Given the diversity of business
owners in San Diego county, there are often
language barriers for SMBs in HTR
neighborhoods; current programs might not
Proposed Solutions to Equity Concerns:

This program will provide a dedicated energy
coach as a single point of contact and entry
point to commercial sector opportunities.

This energy coach will serve as an extension
of participants’ staff, offering education,
technical assistance, and project
management support. The program will also
provide direct installation options for energy
efficiency measures to avoid out of pocket
costs to participating businesses. The
program will provide various in-language and
culturally sensitive outreach materials and
program documents with messaging that
resonates with diverse SMBs and their staff.
50 provide effective in-language outreach or
materials to accommodate this need.

Program Description: The SMB Energy Coach Program will raise awareness and increase adoption of energy efficiency practices and measures. The program will connect a dedicated energy coach to each participating SMB to educate them on the value of EE and IDSM, provide facility benchmarking and EE opportunity assessments, support access to funding and financing, offer technical assistance, and install EE measures at no cost to program participants. The program will coordinate with SDG&E EE programs, statewide EE programs, and the San Diego Green Business Council, the local partner of the Green Business Network, to combine service offerings and compound the programs’ value. Through coordination with the Green Business Network, program participants may receive public recognition via Green Business Certification for their EE upgrades, encouraging continued investment in EE. The program may leverage partnerships with community-based organizations to provide resources for returning program participants, to encourage continuous pursuit of clean energy measures, and to provide ongoing education and training for SMB staff.

Intervention Strategy: Downstream - direct
install and technical assistance.
● Facility energy report and opportunity
assessments: the program will provide
on-site and virtual assessments to
identify EE measures at each business
and provide an in-language energy
report. The report will incorporate:
○ No and low-cost EE measures
available through EE programs.
○ Incentive and funding
opportunities through external
mechanisms such as SDG&E,
statewide, and federal
programs.
○ Green Business Certification.
○ IDSM program opportunities,
including demand response.
○ Education on reducing energy
costs.
○ If applicable, the program will
assist with benchmarking in
Energy Star Portfolio Manager
(ESPM) to help businesses
understand their facility’s
energy performance and
comply with AB802 for
facilities over 50,000 sq. ft.

Program Metrics:
● kWh
● kW
● Therms
● TSB
● Annual GHG reductions
● Number of SMBs enrolled
● Number of SMBs served
● Number of facility benchmarking and
EE opportunity assessments
performed
● Number of direct install projects
completed
● Number of funding and financing
presentations performed
● Number of projects where technical
assistance was provided
51 ● Technical assistance: the program will
provide technical specifications for
identified projects to ensure
implemented measures realize
anticipated energy savings.
● Direct installation: the program will
offer a menu of direct install measures
available at low-to-no-cost for
program participants. Sample EE
measures include smart thermostats,
LED lighting, controls, economizer
controls/repair, duct sealing,
appliances, faucet aerators, auto door
closers, ice makers, and smart plugs.
● Funding and financing support: the
program will connect SMBs to other
incentive programs, SDG&E on-bill
financing, GoGreen Financing, IRA tax
credits, and other local/state/federal
funding and financing programs.

High-level description of delivery workforce including necessary scale and its risks:

SDREN’s local trusted partners will engage with businesses to determine eligibility and interest in program offerings. The program implementer staff and energy coaches will guide program participants through the SDREN commercial and other applicable program offerings and services. Licensed local contractors, electricians, and equipment manufacturers will support the direct installation of energy efficiency measures. Engineering consultants will provide technical assistance as needed. The program implementer(s) will work with community partners, including CBOs, to ensure SMB participants are aware of local resources and opportunities. There are workers in place to support these programs, but an increase in demand may require additional training and recruitment of specialized support. A delay in manufacturing and delivery of equipment (or high demand) can pose a risk to project completion timelines.

Market actors necessary for success:
● Third-party implementer(s).
● Trade professionals.
● Local contractors.
● Equipment manufacturers.
● Community outreach staff.
● Property management/landlords, if applicable.

Solicitation Strategy: Third-party solicited Transition Plan: Not applicable 52 Expected Program Life: 2024 - ongoing Short Term Plan: Launch program in 2024 and ramp up implementation through 2027
to serve SMB customers.

Cost Effectiveness: 4 Year TRC: 0.14 Long Term Outlook:
● Increased interest in EE and IDSM.
● Adoption of EE measures among
SMBs as a result of program
intervention.
● Continuous engagement with
returning and new program
participants to achieve program
objectives in alignment with state
goals.

Proposed Annual Budgets for 2024-2027:
2024: $1,402,000
2025: $2,895,700
2026: $3,185,270
2027: $3,503,797
2024-2027 Total: $10,986,767
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
maintain program steady-state beyond 2027.

For years 2028-2031, budgets will increase at
a moderate 4% to address inflation and to
meet increasing customer demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Table 27. Program Card for Efficient Refrigeration
Program Name: Efficient Refrigeration
Program ID: SDREN-02-COM-ERF
New/Existing: New
Link to implementation plan if existing: N/A
Portfolio Segment: Equity Implementation Party: Third-party Implementer
Applicable Sector: Commercial Market Sub-Sector: Micro, small, and medium businesses, focusing on small local
grocery stores, corner stores, and local small
businesses that sell food products.

Sector Challenge:
● Store owners have limited staff
capacity and capital to learn about
high efficiency equipment options and
to invest in energy efficient
equipment.

Sector Opportunity:
● A direct install approach alleviates the
cost barrier to participation and
allows store owners to participate in
energy efficiency program offerings.
53 ● Business priorities and day-to-day
operations take precedence over
energy efficiency.
● Leverage other programs, such as the
CDFA Healthy Refrigeration Grant
Program to create co-benefits, such as
educating store owners about health
benefits to providing local access to
fresh, perishable food options (fruits,
vegetables, nuts).
● Installation of high efficiency
refrigeration equipment with
low-GWP refrigerants will realize
utility bill savings for participants,
encouraging future investment in
energy efficiency.
54 Known Equity Concerns in the Selected
Markets: Past programs offering support with
refrigeration equipment have focused on
larger customers, leaving smaller customers
without any offerings focused on
refrigeration. Based on the recent EM&V
study conducted by SoCalREN, energy burden
is a concern for this sub-market. Corner
stores in particular feel burdened by high
electricity bills associated with refrigeration.42
Recent inflation and supply chain issues have
also impacted small business owners, with
85% of small business owners indicating they
are concerned about inflation.43
Additionally, when considering this
sub-market, it is beneficial to consider the
health-energy nexus related to food access.

Several communities within San Diego County
face poverty and food insecurity.44 In 2019, 77
census tracts had a poverty rate of 50% or
more. Across San Diego County, the
percentage of the population experiencing
food insecurity by region is: central: 26.9%,
east: 46.6%, north central: 38.5%, north
coastal: 39.8%, north inland: 30.9%, and
south: 27.7%. These communities lack regular
access to fresh, healthy foods. They need
personalized in-person, in-language and
culturally sensitive outreach and program
services.

Proposed Solutions to Equity Concerns: This
program will encourage stores to sell fresh,
healthy, and affordable food products by
providing high efficiency refrigerators and
freezers. This program will also develop
in-language outreach materials to improve
the education and communication to staff at
participating businesses and the local
community. The program will deploy
in-person program outreach staff to reach
businesses and tell them about program
opportunities and objectives. This program
will leverage local contractors to stimulate
the local economy and support local
workforce development.

Program Description: The Efficient Refrigeration program will provide energy efficiency education and no-cost, direct install efficient refrigeration equipment to small corner stores/grocers/small businesses to support energy cost savings and the stocking of healthy, fresh, and affordable food products. This program will provide technical assistance to identify refrigerators that are eligible for replacement with high efficiency units. This program will also leverage other programs and resources to provide one-on-one education on sourcing California-grown produce and product placement/promotion to encourage shopper purchases. Additionally, it will deliver community outreach events to promote program 44 https://www.sandiegocounty.gov/content/dam/sdc/hhsa/programs/phs/CHS/ Poverty%201%20 Areas%20of%20 Concentrated%20 Poverty%20and%20Food%20 Insecurity%20Brief.pdf. 43 “Special Report on Inflation and Supply Chain Shocks on Small Business,” U.S. Chamber of Commerce, March 3, 2022, https://www.uschamber.com/small-business/special-report-on-inflation-and-supply-chain-shocks-on-small-business. 42 SoCalREN Food Desert Energy Efficiency Equity Program Market Study, pg. 14. 55 services, provide education on the benefits of energy efficiency, and encourage the public to shop at participating business locations by highlighting the availability of fresh, healthy foods.

This program’s target measures include glass and solid door refrigerator and freezer units.

This program will also look for opportunities to integrate strategies from the new BayREN Refrigerant Replacement Program to encourage low-GWP refrigerants.

Intervention Strategy: Downstream - direct
install, education and outreach.
● In-person and in-language culturally
sensitive outreach: given the staff
capacity barrier to EE program
participation and that 36% of County
residents speak a language other than
English at home, the program will
provide in-person and in-language
outreach to target businesses that are
underserved by existing programs.
● Direct installation of high efficiency
refrigeration equipment: the program
will provide no-cost installation of
refrigeration equipment, generating
utility bill savings for program
participants at no cost.
● Community-level and one-on-one
education on EE and healthy food
options: the program will educate
program participants on the benefits
of EE, low-GWP refrigerant, EE
programs, and best practices for
stocking healthy, fresh, perishable
foods.
● IDSM program participation
education: share informational
materials and resources to
participants on the benefits of
participating in DR and other IDSM
programs.

Program Metrics:
● kWh
● Therms
● TSB
● Number of small corner
stores/grocers/small businesses
enrolled
● Number of small corner
stores/grocers/small businesses
served
● Number of in-person outreach events
● Number of in-language outreach
activities (events and/or marketing
materials)
● Number of direct-installations of high
efficiency refrigeration equipment
completed
High-level description of delivery workforce including necessary scale and its risks: This program is reliant on partnership with owners and staff of small grocery and corner stores across San Diego County. The program also requires installer partner(s) to facilitate the purchase and installation of efficient refrigerators and freezers. Implementer staff and outreach partners will perform program education and outreach. No risks were identified regarding the delivery of workforce for this program.
56 Market actors necessary for success:
● Third-party implementer(s).
● Multi-lingual local outreach staff.
● Grocery and corner store owners.
● Local refrigerator/freezer installers.
● Refrigerator/freezer manufacturers and distributors.

Solicitation Strategy: Third-party solicited Transition Plan: Not applicable Expected Program Life: 2024 - ongoing Short Term Plan: Ramp up third-party program to full implementation to deliver
year-round peak demand reduction.

Cost Effectiveness: 4 year TRC: 0.02 Long Term Outlook:
● Small corner stores/grocers/small
businesses realize utility bill savings by
installing high efficiency refrigeration
equipment.
● Local communities have increased
access to fresh, healthy food.
● Small corner stores/grocers/small
businesses understand the benefits of
EE and pursue opportunities beyond
refrigeration upgrades.

Proposed Annual Budgets for 2024-2027:
2024: $934,000
2025: $1,930,500
2026: $2,123,550
2027: $2,335,905
2024-2027 Total: $7,323,955
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Table 28. Program Card for SDREN FLEX Market
Program Name: SDREN FLEX Market
Program ID: SDREN-03-COM-FXM
New/Existing: New
Link to implementation plan if existing: N/A
Portfolio Segment: Resource Acquisition Implementation Party: Third-party Implementer
57 Applicable Sector: Commercial Property
Owners
Market Sub-Sector: Small/Medium
Businesses (SMBs)
Sector Challenge:
● Delivering scalable programs with
costs less than delivered TSB.
● High administrative and capital cost
barriers to business participation in EE
programs.
● Limited customized solutions have to
serve a wide range of customer types,
including HTR and underserved
businesses.
● Risk of large program investment
without the delivery of anticipated
TSB.
● Customer engagement through a
trusted entity.

Sector Opportunity:
● Capture significant energy savings and
peak demand reduction through
tailored services offered via
aggregators.
● Bundle program services with federal
IRA funding to improve project
cost-effectiveness.
● Leverage performance-based
aggregator incentive approach to
minimize program investment without
the delivery of TSB and demand
reduction.
● Work with local trusted partners, such
as chambers of commerce, to reach
hard-to-reach and underserved
businesses.

Known Equity Concerns in the Selected
Markets: Barriers to EE implementation vary
from business to business. However,
small-to-medium businesses typically have
limited staff capacity and resources to pursue
EE projects. High capital costs are also a
common barrier. There is often a lack of
programs or incentives designed to serve HTR
and underserved businesses.

Proposed Solutions to Equity Concerns: To
reduce customer administrative burden, the
aggregator will manage a program
compliance process and provide flexible
benefits to each customer. Benefits may
include price concessions or technical
services to motivate the customer to pursue
the project. Higher investment and targeted
approaches will help engage and serve HTR
and underserved businesses.

Program Description: SDREN’s Flex Market Program will provide performance-based incentives to project developers (aggregators) who deliver projects that realize peak demand reductions and verified energy savings. The program will utilize a population NMEC methodology to verify savings while paying incentives based on TSB achieved, encouraging long-life measures that deliver maximum grid benefit. The program will develop a suite of tools for aggregators to use to identify high opportunity projects at facilities with significant summer and year-round peak demand reduction potential, estimate energy savings, and secure incentives. Local trusted entities will lead customer engagement to high opportunity businesses, with a focus on HTR and underserved businesses. Aggregators will develop project opportunities and offer customizable services and financial benefits to participating businesses. This will influence businesses to implement identified energy measures. Since incentives will be delivered to aggregators based on NMEC-verified benefits to the grid, aggregators are encouraged to ensure projects realize or exceed anticipated energy savings. 58 Sample EE measures include HVAC replacement, HVAC controls, VFDs, lighting replacement, lighting controls, building envelope, and refrigeration.

Intervention Strategy: Downstream –
population-level normalized metered energy
consumption (NMEC).
● Aggregator network: the program will
maintain a network of qualified
aggregators that operate in the
marketplace to identify and install EE
projects in exchange for
performance-based incentives.
● Performance-based incentives: the
program will provide
performance-based incentives to
aggregators based on achieved TSB for
their portfolio of projects.
● Tax provision education: The program
will educate aggregators on available
EE tax provisions, including the 179D
Energy Efficient Commercial Buildings
tax deduction, which was recently
enhanced by IRA, in order for
aggregators to bundle
ratepayer-funded incentives with tax
deductions to improve project
cost-effectiveness.
● Targeted outreach: the program will
partner with trusted local entities to
develop materials and outreach
strategies for HTR and underserved
businesses.

Program Metrics:
● kWh
● kW demand savings
● Therms
● TSB
● Annual GHG savings
● Number of participating businesses
● Number of projects installed
● Number of aggregators enrolled
● Dollar amount of incentives disbursed
to aggregators
● Number of local entity partnerships
High-level description of delivery workforce including necessary scale and its risks: Program success will rely on the availability of qualified aggregators. The delivery workforce will include implementer staff, equipment vendors, and local trusted entities for outreach. There are no known workforce risks for successful implementation of the program.

Market actors necessary for success:
● Third-party implementer(s).
● Aggregators and contractors.
● EE equipment vendors.
● Local trusted organizations for outreach.
59 Solicitation Strategy: Third-party solicited Transition Plan: Not applicable Expected Program Life: 2024 - ongoing Short Term Plan: Ramp up third-party program to full implementation to deliver
year-round peak demand reduction.

Cost Effectiveness: 4 year TRC: 0.43 Long Term Outlook:
● Year-round peak demand reductions
are delivered.
● Delivered TSB exceeds program costs.

Proposed Annual Budgets for 2024-2027:
2024: $2,102,000
2025: $4,343,600
2026: $4,777,960
2027: $5,255,756
2024-2027 Total: $16,479,316
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Cross-Cutting Sector – Codes & Standards
Market Characterization
The Codes and Standards (C&S) community is multi-faceted and involves a diverse array of stakeholders including local agency building department staff (who play a pivotal role in the energy code enforcement), building owners, contractors, developers, architects, mechanical engineers, and energy code consultants. The interactions among the various players are integral to achieving energy code compliance and enforcement.

Energy codes and energy technologies in new and existing buildings are growing more complex.

This complexity is closely tied to the growing trend toward hyper-efficiency and the trend toward the “electrification of everything” as we modernize the electrical grid and strive to meet air quality standards. Permit agency staff and the broader C&S community need new knowledge, training, and experience to keep up. They must become well-versed in the selection, installation, and operation of heat pump water and space heating equipment, distributed renewable generation, battery storage, EV charging, real-time energy management systems, low-carbon construction materials, passive construction practices, and many other emerging building technologies.

Local governments are increasingly asserting their leadership in the realms of energy efficiency and decarbonization practices. Their authority over construction, land use, and the implementation of model codes, standards, and policies position them as catalysts for 60 enhancing building energy performance. Their regulatory leadership will propel communities toward more sustainable construction and contribute to state and local policies accelerating cleaner, more energy efficient practices within their jurisdictions.

C&S Sector Goals, Objectives and Strategies
SDREN's Codes and Standards (C&S) interventions are designed to work in harmony with SDG&E's C&S programs, statewide IOU programs, the CEC’s building and appliance standards, CARB’s evolving scoping plan, and regional climate policy. By complementing and supplementing existing initiatives, SDREN aims to strengthen collective impact on the C&S landscape.

The C&S landscape needs a localized program approach, particularly in light of current gaps, barriers, and challenges for permitting agencies. These agencies require tailored support to navigate the intricate energy code compliance landscape effectively.

To address these needs, SDREN’s proposed energy code coach services will be a focal point of the sector. These services will target gaps and overcome barriers that previous C&S programs have insufficiently addressed. The program will emphasize smaller and rural permitting agencies that face more capacity and resource constraints than their larger counterparts to ensure they can access tools and knowledge to overcome these constraints. By promoting local activities and addressing agency-specific limitations, SDREN's program will create a more equitable and comprehensive C&S landscape in support of energy code compliance and a decarbonized energy future.

Table 29. C&S Goals, Objectives, and Strategies
Goals Strategies Objectives
Provide permitting
agencies and the C&S
community with
actionable resources to
improve energy code
systems and compliance,
reducing energy
consumption and GHG
emissions in buildings and
supporting the state’s
energy efficiency and GHG
goals.
● Coordinate with the C&S
community to simplify and
streamline permitting
processes while
demonstrating the
economic benefits of
enhanced energy code
compliance.
● Create a suite of tools,
technical resources, and
templates, including an
energy code coach, to
support the C&S
community, industry
groups, trade allies, and
their supply chains to
accelerate building and
● Provide the C&S community
with actionable resources
that enable them to achieve
high-performing and
resilient buildings by
improving permitting,
inspection, and enforcement
compliance outcomes.
● Streamline the permit
review and approval
processes to facilitate the
inclusion of energy
resiliency and climate
adaptation design elements,
including DERs, in new and
existing buildings.
61 transportation systems
electrification and the
adoption of emerging
clean energy technologies.
● Coordinate with the C&S
community to enhance
consumer protections,
increase affordability of
high-performance buildings,
and prevent unjust or
inequitable implementation
of energy codes and
policies.

Assist public agencies in
compiling and utilizing
building stock and C&S
data to enhance energy
code compliance and
facilitate adoption and
implementation of
advanced energy codes
and policies.
● Implement data-driven
training strategies to build
the staff capacity,
competency, and permit
agencies’ efficiency,
making use of building
stock and C&S data.
● Provide access to
residential and
commercial energy
benchmarking and energy
performance standards
tools and software to
increase energy
performance outcomes in
new and existing buildings.
● Create feedback loops
from C&S activities that
lead to comprehensive
strategies across SDREN
offerings.
● Enable public agencies to
leverage digitized data
collected from their
permitting activities to
inform their energy
resiliency action plans and
energy/GHG reduction
targets and strategies.
● Enable C&S community to
reduce energy costs while
improving building health
and functionality through
assistance with EE, load
reduction strategies, and
beneficial electrification
approaches, which help
mitigate costs from time-and location-dependent
electricity pricing.

Promote the adoption,
implementation, and
enforcement of advanced
energy codes, standards,
and policies that lead the
way for improved building
energy performance and
accelerate the
decarbonization of
building construction
practices.
● Assist with and advocate
for the development and
adoption of reach codes,
model codes, and
advanced energy
regulations/policies.
● Provide comprehensive
support to local permit
agencies for the
implementation of
advanced energy codes.
● Coordinate and promote the
adoption of advanced
energy codes that pave the
way for improved building
performance and increased
prevalence of decarbonized
and zero net energy (ZNE)
buildings.
● Facilitate and advocate for
local building performance
standards (BPS) and building
62 ● Assist in the development
of compliance strategies,
enforcement strategies,
and effective tracking
mechanisms for advanced
energy codes.
● Leverage state and federal
funding and technical
analysis to develop
equitable policies aligned
with Justice 40, the ESJ
Action Plan 2.0, and the
DOE Affordable Home
Energy Shot.™
● Provide educational
information to the C&S
community about the
phase out of HFCs and
low-GWP refrigerant
alternatives.
benchmarking requirements
that will improve the
efficiency, comfort,
economics, and health of
buildings.
● Lead regional efforts to
attract funding and technical
expertise for policy
development and
deployment.
● Promote and facilitate
regional policies that
support adoption of efficient
heat pump-based space and
water heating systems to
replace methane-gas-based
systems in both new and
existing buildings.

C&S Sector Coordination
SDREN acknowledges that cross-sector coordination is essential to empowering local governments and their constituents to lead the way towards a clean energy transformation within their communities.

Local governments have significant legal purview through their permitting authority to improve the way energy is generated and used within their communities. Land-use policies, building codes, and other regulations can improve the performance of new and existing buildings.

SDREN’s C&S program will harness strong relationships with local governments to support portfolio success across sectors and segments. SDREN will create a resource hub for referring C&S program participants to other program opportunities.

SDREN is committed to harmonizing its efforts with all statewide codes and standards programs, including any San Diego County-specific programs implemented by SDG&E or local government permit agencies. SDREN will collaborate with SDG&E to ensure that SDREN’s C&S services will augment and not duplicate the C&S programs and services already available in the County of San Diego. SDREN will also coordinate with statewide residential and commercial new construction programs and C&S programs administered by other RENs, particularly with BayREN, to build on their C&S experience and lessons learned. SDREN will collaborate with professional associations for building officials and building departments, statewide professional groups, and associations that focus on education and cooperation between permitting agencies 63 and building permit/code compliance professionals. (See the C&S Segment-specific coordination discussion in the Codes & Standards program section above).

SDREN will forge partnerships with the administrators of energy benchmarking and energy performance standards tools and software. These partnerships will empower local permitting agencies to improve energy performance in new and existing buildings, align with the clean energy objectives in their communities, and create tailored solutions for underserved and HTR communities. Through this comprehensive approach, SDREN will foster a unified, cohesive, impactful, and just transformation toward cleaner and more efficient energy practices.

Categorization by Segment
Additional details on SDREN’s segmentation justification at the program-level can be found in Exhibit 3 - Program Segmentation Justification template Attachment A from D.23.06.055.

Table 30. C&S Sector Program Categorization by Segment
Program Segment Justification
Codes and
Standards
Codes and
Standards
SDREN, as a local government-led network, is poised to play a pivotal role in assisting local government agencies with energy code compliance. SDREN’s support will include collecting and evaluating building stock characteristics, energy use patterns, and building permit data. SDREN will champion advanced
energy codes and requirements, setting the stage for a
decarbonized energy future.

Energy use in California is shifting toward full electrification of buildings and transportation. The recent influx of federal and state funding is hastening this transformation, which will hinge on the adoption of advanced, efficient, and integrated energy technologies. To meet the state's climate goals and support the transition to a clean energy future, permitting processes must not prohibit large-scale adoption of these technologies.

C&S Sector Program Details
Table 31. Program Card for C&S
Program Name: Codes & Standards
Program ID: SDREN-01-CS-CSS
New/Existing: New
Link to implementation plan if existing (see D.21-05-031): N/A Portfolio Segment: Codes and Standards Implementation Party: Third-party Implementer
Applicable Sector: Cross-Cutting Market Sub-Sector: Cross-Cutting 64 Sector Challenge:
● Energy codes are complex and local
government staff lack sufficient
capacity and time to understand the
codes and implement effective review
and enforcement mechanisms.
● Energy efficiency is typically not a high
priority for building departments,
permit applicants, or within the C&S
community. This results in missed
opportunities for significant energy
savings.
● There is a lack of resources for
training, capacity, and technical
support to build local government
staff expertise, impeding their
capacity to meet evolving energy code
requirements.
● Increasingly stringent energy codes
create compliance gaps, hindering the
state from reaching decarbonization
and greenhouse gas reduction goals.
● Future code cycles will incorporate
requirements for building and
transportation electrification, demand
flexibility, indoor air quality, and grid
interactive buildings, which will
necessitate education for permitting
agencies and their staff.
● Many types of projects (HVAC, water
heating, etc.) have low permitting
rates. This not only diminishes
potential energy savings but also
complicates code enforcement efforts,
which play a vital role in energy
efficiency.
● Most local governments lack the
capacity and confidence to lead by
example in advanced energy codes
and standards for new and existing
buildings, which is important for
broader compliance.

Sector Opportunity:
● Conducting a needs assessment to
identify C&S compliance gaps and
barriers among local permitting
agencies.
● Ongoing technical assistance, training,
tools, case studies, peer-to-peer
learning, and online resources can
help local building department staff
and permit applicants understand and
comply with current and future
energy codes and standards.
● An energy code coach can fill gaps in
building department code
comprehension and capacity. This
resource can serve as a dedicated
expert to assist local agencies with
effectively implementing energy
codes.
● Leverage SDCP’s Building Housing
Stock Analysis currently underway to
inform strategies.
● Data-driven assistance with advanced
energy codes, building performance
requirements, and benchmarking
requirements will encourage local
leadership in energy efficiency,
passive design, and ZNE construction.
● Energy code comprehension and
compliance within the C&S
community (developers, contractors,
architects, engineers, property
owners, etc.) can be enhanced
through technical information, online
and in-person education and training,
and more effective code compliance
assistance. This approach will create a
more informed and compliant
industry.
● The compilation and evaluation of
accurate, digitized, and standardized
permitting and compliance data will
drive better local decision-making and
65 ● There is frequently a disconnect
between new energy code
development, adoption, and
enforcement. The disconnect can lead
to confusion and delays in code
implementation.
● Energy code requirements vary by
permit scope, climate zone, and
building or site attributes. Moreover,
energy code interpretation and
enforcement varies by jurisdiction.

These nuances and variability can lead
to confusion and inconsistencies.
● There is no transparent data available
on local building stock. Better data
could inform permitting and code
compliance actions and reduce energy
use and GHGs in the building sector.
● Over the next several years, billions of
dollars in new federal and state
funding are earmarked for
electrification and efficiency retrofits
to existing buildings (with a major
emphasis on income-qualified
households), which will create
significant new workload for
permitting agencies.
better energy performance in new
and existing buildings.
● Given the expected influx of federal
and state funding for electrification
and efficiency retrofits in the coming
years, permitting agencies must
prepare in advance. This will ensure
they can efficiently review and
approve the significant number of
new projects that are coming soon.

Preparation will mitigate workload
impacts and result in more efficient
and well-managed building projects.

Known Equity Concerns in the Selected
Markets: One pressing equity concern in the
market is the issue of low compliance with
energy code performance requirements,
which leads to increased energy consumption
and less healthy, safe, and comfortable living
and working environments. This
disproportionately affects vulnerable
communities, further exacerbating existing
disparities in access to energy efficient and
comfortable spaces.

Low-income building owners and occupants
are often confronted with significant financial
constraints. As a result, they may be more
likely to perform unpermitted work within
Proposed Solutions to Equity Concerns: The
program recognizes the potential for
substantial improvements in code compliance
and building performance through improved,
more efficient, and more effective practices
by permitting agencies. Permitting agencies
can ensure codes are followed by improving
their processes, resulting in
higher-performing buildings that are more
energy efficient and provide healthier, safer,
and more comfortable environments for
occupants.

To address equity concerns, the program
places a strong emphasis on implementing
building permit services and offering
technical assistance designed for
66 their buildings to reduce immediate costs and
skirt code compliance requirements.
underserved, hard-to-reach, and
disadvantaged communities. This approach
will help alleviate customer trepidation often
associated with the permit process, which
can disproportionately affect these
communities. In collaboration with the
statewide Codes and Standards Enhancement
(CASE) team and research institutions, the
program will develop grid-friendly
electrification opportunities that provide
building owners and residents with shared
economic benefits. In doing so, SDREN
expects to significantly reduce the prevalence
of unpermitted work in underserved, HTR,
and DAC communities. Increased compliance
will ultimately enhance energy efficiency,
health, and safety. By directly engaging with
communities and providing tailored support,
the program seeks to bridge gaps in access to
energy efficient and quality building
practices, promoting a more equitable and
sustainable future for all of San Diego County.

Program Description: The Codes and Standards (C&S) program will complement existing statewide and regional investor-owned utility programs and fill gaps in services for local governments and the C&S community. This program will engage and support local government permitting agencies to help them enhance energy code compliance and embrace advanced energy codes, standards, and policies. By doing so, the program seeks to significantly reduce energy consumption and GHG emissions, accelerating local government leadership in energy efficiency.

This program is committed to providing local agencies and the C&S community with data-driven and actionable resources. These resources will bolster understanding of energy codes, increase compliance, decrease energy consumption within buildings, and support the state’s energy efficiency and GHG reduction goals. The C&S program will help public agencies collect and use data on the age and condition of building stock, comparative energy usage within building sectors, and permit issuance and enforcement processes. This data will inform energy code compliance efforts and help identify the most promising opportunities for reach codes and policies.
67 Intervention Strategy: Downstream –
technical assistance, education, training, and
outreach.
● Design and deliver a comprehensive
needs assessment that will serve as
the foundation of the intervention
strategy. It will analyze permitting
trends, identify gaps in current local
government permit processes, and
flag barriers to improved energy code
compliance.
● Provide targeted education, tools,
training and resources to local
governments and C&S community
stakeholders, including access to an
energy code coach, to improve energy
code compliance and effectiveness.
● Leverage existing data resources and
existing tracking mechanisms to
measure and analyze code compliance
and code development interventions
that are supported by the program.

This data-driven approach will provide
insights and feedback for continuous
improvement.
● Provide information, analysis, and
technical assistance to design, adopt,
and implement advanced energy
codes, benchmarking and energy
audit requirements, buildings
emissions performance standards,
and other model approaches to
lowering energy usage and GHGs
(including low GWP refrigerants) in
new and existing buildings.
● Activate and engage key stakeholder
representatives in disadvantaged and
hard-to-reach communities to aid in
the development and delivery of
programs. This approach will foster a
sense of community ownership and
will ensure interventions are tailored
Program Metrics:
● Number and percent of local
government permitting agencies
receiving C&S program services.
● Number and percent of local
governments who adopt model
energy codes and advanced energy
policies/standards.
● Magnitude of improved code
compliance and closed permit
outcomes by participating local
governments.
● Number and percent of local
governments who implement
improved permit data collection,
tracking, and analysis to enhance
energy code compliance outcomes.
● Number of training activities (classes,
webinars, workshops, etc.) held and
number of participants by category.
● Number and percent of permitting
agencies who receive assistance from
an energy code coach.
68 to the specific needs and concerns of
participating communities.

High-level description of delivery workforce including necessary scale and its risks: The program implementer staff will play a crucial role in leading participants through the program’s offerings and services, acting as guides and facilitators. The program will leverage specialized subject-matter practitioners who are engaged by the implementer to provide comprehensive training and energy code coaching. The program will also leverage specialists to support data compilation, data analysis, and education and training.

Market actors necessary for success: The primary actors for the C&S program are local government departments/divisions that are responsible for building permit issuance and enforcement. Within most agencies this would include building and safety, community development, planning, and any other departments responsible for developing, overseeing, and enforcing statewide and local building standards and ordinances. Practitioners (developers, contractors, architects, engineers, etc.) who apply for permits that trigger energy code requirements are also market actors necessary for the program’s success, as well as third-party implementer(s).

Solicitation Strategy: Third-party solicited Transition Plan: Not applicable Expected Program Life: 2024 - Ongoing Short Term Plan: The program will launch in 2024 and ramp up implementation through
2027 to reach and serve the entire service
area.

Cost Effectiveness: TRC: N/A Long Term Outlook:
● Capacity and competence of local
permitting agencies to review, inspect,
and enforce energy code compliance
will increase. As a result, local
communities will experience
improved energy efficiency, leading to
more sustainable and comfortable
buildings.
● As new and more stringent energy
code requirements spread throughout
the state, local permitting agencies
will be capable of achieving broad
compliance with the new standards,
while contributing benefits to the
entirety of the energy system. This will
result in adherence to energy codes
69 and contribute to the state’s energy
and climate goals.
● The C&S community will increase
understanding of and adherence to
energy code requirements. They will
actively support more energy efficient
and lower GHG construction practices.

Proposed Annual Budgets for 2024-2027:
2024: $934,000
2025: $1,930,500
2026: $2,123,550
2027: $2,335,905
2024-2027 Total: $7,323,955
Anticipated directional and scale changes in
budget for years 2028-2031: Continue to
maintain program steady-state beyond 2027.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Cross-Cutting Sector – Workforce, Education & Training
Market Characterization
SDREN recognizes that the building sector is undergoing a fundamental transformation towards electrification and decarbonization. These changes will have a profound impact on the job market, influencing both workforce requirements and workforce development.

The move towards electrification brings with it a growing demand for a workforce with specialties such as HVAC technicians, certified electricians, building automation and controls specialists, and plumbers as outlined in the table below. At the same time, existing jobs in legacy industries, such as oil and gas, may be affected. One study cited that reducing commercial and residential gas usage by 30% could result in 6,200 fewer gas extraction jobs in California.45 California’s move toward clean energy introduces both opportunities and challenges for the workforce.

Studies have forecasted a significant shortage of workers with essential skills needed to support the transition to a clean energy future. The UCLA Luskin Center for Innovation completed a study in 2019 detailing employment impacts of building decarbonization, which requires both energy efficiency improvements and reducing the use of fossil fuels, including methane gas.

Their analysis concluded that electrifying 100% of California’s existing and new buildings by 2045 would require over 100,000 additional full time workers in the construction industry and up to 4,900 additional full-time manufacturing workers.46 This shortage underscores the urgency of developing a skilled workforce across the County of San Diego, where over 8% of Californians reside.
46 Ibid.
45 California Building Decarbonization Workforce Needs and Recommendations, UCLA Luskin Center for Innovation, Executive Summary pg. 4.
70 Table 32. Average number of jobs created in the San Diego region annually through energy demand expenditures from 2021-2030, by subsectors and technology. Figures assume 1 percent average annual productivity growth.47
Investment
Area
Average
Annual
Expenditure
Direct
Jobs
Indirect
Jobs
Direct and
Indirect
Jobs
Induced
Jobs
Direct,
Indirect, and
Induced Jobs
Vehicles $7.7 billion 3,427 1,427 4,854 1,508 6,362
HVAC $897.0
million
1,345 699 2,044 764 2,808
Refrigeration $761.9
million
1,315 491 1,806 711 2,517
Appliances $188.6
million
143 77 220 78 298
Construction $113.4
million
263 149 412 146 558
Lighting $106.6
million
177 95 272 100 372
Manufacturing $45.7
million
40 32 72 27 99
Other
commercial and
residential
$38.9
million
59 30 89 33 122
Agriculture $17.2
million
144 21 165 45 210
Mining $2.4 million 1 1 2 1 3
Total $9.9 billion 6,914 3,022 9,936 3,413 13,349
As we seek to electrify and decarbonize our buildings, SDREN will provide comprehensive training for the existing workforce and will prepare new workers to enter the industry, ensuring a pipeline of skilled professionals for the clean energy sector.

The transition toward decarbonized buildings, coupled with substantial investments in a clean energy economy (e.g. IRA and the Equitable Building Decarbonization Program), will require a 47 IMPLAN 3.1
71 skilled workforce. In response to these needs, SDREN is committed to investing in workforce development through its programs, ensuring that all San Diegans have the opportunity to participate in the industry or acquire the new skills needed to support the transition to a clean energy economy.

WE&T Sector Goals, Objectives and Strategies
SDREN will deliver impactful workforce, education, and training programs focused on individuals in hard-to-reach, disadvantaged, and historically underserved communities. These programs will teach the necessary skills through comprehensive training and development opportunities to meet the future regional needs of the energy, electrification, and decarbonization career sectors, resulting in increased career opportunities.

SDREN’s programs will train workers to identify, develop, fund, and implement energy savings across buildings and facilities.

The proposed programs focus on ensuring workers from hard-to-reach and underserved communities have access to certification, apprenticeship, education, and skill development opportunities to set them up to access high-quality jobs and ensure the San Diego region has skilled workers to meet future needs.

Table 33. Cross-Cutting WE&T Goals, Objectives, and Strategies Goals Strategies Objectives
● Expose high school
students to
energy/green career
pathways.
● Encourage students to
enroll in Science,
Technology,
Engineering, Arts, and
Mathematics (STEAM)
college courses.
● Build students’
connections with
employers to boost
their interest in a
career within the
green workforce.
● Target high school students
in disadvantaged and hard-to-reach communities to
promote program equity
and skill development
opportunities in areas with
fewer resources and historic
underinvestment.
● Partner with local
community college districts
to provide college-level
courses and skill
development opportunities
to enhance employment
opportunities.
● Partner with local employers
to connect high school
students with employers for
coaching and mentorship
opportunities.
● Build pathways for high
school students to enter
the green workforce with
knowledge of industry
practices and network
connections.
● Prepare students with
on-the-job energy and
green workforce skills for
a smoother entry into the
green workforce.
● Increase the number of
students interested in
pursuing energy and
green careers.
● Build career pathways and
a network of high schools
and colleges as feeders to
employment
opportunities.
72 ● Build participant
workforce
development capacity
in the region.
● Enhance workforce
training pathways
through existing
employers.
● Strengthen employee
skill sets by focusing
on entry-level energy
and green job skill
development for
workforce
participants.
● Support participating
employers’ internal
professional growth
focused on green
careers.
● Provide training,
certifications, networking,
and apprenticeship
opportunities to build skills
for participants to enter the
clean energy workforce.
● Provide wraparound services
such as career coaching and
mentorship to match
participants with employers
to secure jobs.
● Survey local employers to
determine emerging
industry careers and
necessary skills for incoming
professionals to succeed.
● Work with employers to
design and deliver employee
training to boost internal
growth opportunities and
employee retention.
● Guide employers to develop
new policies to encourage
employee training
opportunities, funding for
external training (e.g., the
IRA-funded Home Energy
Efficiency Contractor
Training Grants), and time
allocation for skill
development.
● Target employees at CBOs,
public agencies, contractors,
and labor unions for
workforce training
pathways.
● Explore worker placement
programs to build capacity
and support workforce
development.
● Increase the supply of
skilled employees
entering into the energy
and green workforce.
● Increase access to
opportunities for job
training, certifications,
and apprenticeships.
● Provide one-on-one
career pathway assistance
to support entry into the
workforce.
● Benefit future generations
and build career
opportunities within the
green workforce.
● Work with employers to
develop customized
internal training to boost
employee skills.
● Coordinate with
certification and
apprenticeship
opportunities to boost
internal employee skill
development.
● Increase participating
employers’ staff retention
and internal promotional
opportunities.
73 WE&T Sector Coordination
SDREN anticipates coordination efforts with the following approved SDG&E, statewide, and regional programs:

Career Connections - Energy is Everything, a statewide program administered by PG&E, provides standards-aligned, K-12 STEM, energy and environmental-focused curriculum and lesson supplies to educators statewide at no cost. The program also offers high school internships focused on energy and water audits to help students gain relevant industry skills. SDREN will coordinate on services, shared partnerships, internships, and/or job opportunities for program participants.

SDG&E Career & Workforce Readiness provides no-cost online energy classes that are readily available for skill development.

Construction Career Jumpstart Program, a regional program administered by San Diego Workforce Partnership, provides a four-week paid, hands-on program covering the fundamentals of a construction skilled trade position, including safety, trenching, jackhammering, proper usage of power tools, and other essential skills. Trainees are certified in several skills upon graduation.

Apprenticeship Readiness Program, a regional program administered by San Diego Workforce Partnership, provides the opportunity to explore various career/trade options while providing participants with the skills needed to get started in a construction career. The program utilizes the Multi-Craft Core Curriculum (MC3), which provides an overview of what each trade does and the qualifications and skills needed. This program offers an introduction to the tools of the trades, builds math skills, teaches workplace safety, and more.

California Climate Action Corps, a statewide program administered through California’s Office of the Governor, places fellows across California to work with public agencies, non-profits, CBOs, universities, colleges, school districts, and Tribes. The fellows gain training and work experience while supporting state climate action goals focused on wildfire resiliency, urban greening, organic waste diversion, and edible food recovery.

Sustainability Service Corps, a statewide program administered by Bay Area Community Resources, places fellows across California to work with public agencies, non-profits, CBOs, universities, colleges, school districts, 74 and Tribes. The fellows gain training and work experience in energy and environmental capacity building.

Energize Careers, a statewide program administered by SDG&E, provides holistic services to support disadvantaged workers through technical training, job placement, and wrap-around support. Energize Careers partners with regional contractors, pre-apprenticeship programs, apprenticeship programs, community-based training organizations, and community colleges.

Upon Business Plan approval, SDREN will file a Joint Cooperation Memo with SDG&E in conjunction with other program administrators operating in shared service territory to outline coordination protocols between programs and ensure services fill gaps, meet regional needs, and avoid duplication. Additional stakeholders SDREN will coordinate with that do not fall under the Joint Cooperation Memo include regional employers, college districts, and high schools.

SDREN will also monitor the market and coordinate with other programs to leverage complementary offerings and supplement program services. This includes:
● Leverage:
○ Career Connections - Energy is Everything to align on shared partnerships and services provided.
○ SDG&E to highlight potential internship or job opportunities for SDREN program participants.
○ Statewide Career & Workforce Readiness and other WE&T programs to share strategies and expand resources across the entire region. Partnership with Energize Careers will foster self-sustaining collaborations to train partners and industry partners.
● Stack:
○ Opportunities available to high schools and students served through Career Connections - Energy is Everything program to offer community college courses (CTE).
○ Opportunities available to employers by connecting them with programs such as Energize Careers for placement opportunities. Coordinate training resources, including custom training offerings offered directly through employers. ○ Sectorwide WE&T offerings through coordination on program-specific curriculum development and collaboratively filling gaps.

Categorization by Segment
Additional details on SDREN’s segmentation justification at the program level can be found in Exhibit 3 - Program Segmentation Justification template Attachment A from D.23.06.055. 75 Table 34. Cross-Cutting WE&T Programs Categorization by Segment Program Segment Justification/Primary Goal
Energy Pathways
Program
Market Support Increase awareness and build accessible pathways for youth to enter the green workforce, build
long-lasting careers, and form a robust
professional network.

Workforce Training &
Capacity Building
Market Support Build capacity in the region by working directly with employers to increase opportunities for
education, training, certifications, mentorship,
and job connections for energy job acquisition.

WE&T Sector Program Details
Table 35. Program Card for Energy Pathways Program
Program Name: Energy Pathways Program
Program ID: SDREN-01-WET-EPP
New/Existing: New
Link to implementation plan if existing (see D.21-05-031): N/A Portfolio Segment: Market Support Implementation Party: Third-Party Implementer
Applicable Sector: Cross-Cutting: Workforce,
Education, & Training
Market Sub-Sector: Workforce, Education, &
Training
Sector Challenge:
● High school students often need
academic prerequisites or specific
skills to pursue energy-related careers.
● Costs and the competitive nature of
higher education and energy-related
training programs that many energy
careers require can be a significant
barrier to entering the sector.
● High school students may not be
aware of energy career opportunities
and the pathway to an energy career.
● The energy industry can be highly
competitive with limited job openings.

High school students often need extra
skills to distinguish themselves and
secure job opportunities.

Sector Opportunity:
● Services that inform high school
students of energy career pathways
and skills to support their interest in
entering the energy sector.
● Incorporating a standards-aligned
curriculum and career technical
education (CTE) with employment
opportunities and postsecondary
training.
● Programs that connect high school
students to college courses and other
academic offerings to provide industry
knowledge and the technical skills
(including IDSM education/training
opportunities) required to enter the
workforce.
76 ● The perceived value of working in
construction and other skilled trades
is low, reducing the number of
individuals interested in entering this
field. For those interested,
understanding how to access these
trades is limited and pathways for
entry can be complicated.
● Connect high school students directly
to employers in their area to provide
mentorship, coaching, and career
guidance focused on industry skills,
terminology, and career pathways.
● Provide or connect high school
students with paid internship
opportunities to build skills, create
network connections, and increase
industry knowledge.
● Inform high school students of
industry trends and the value and
earning potential of energy careers
through networking with
professionals to support them in
navigating their career paths.
● Create or connect high school
students to scholarship opportunities
to pursue higher education, industry
technical skills certification, or
apprenticeships in STEAM or IDSM
fields.
● Access to resources such as financial
aid through college partners, private
scholarships, stipends for opportunity
youth, and paid internships.
● Leverage supplemental funding
opportunities to enhance or expand
STEAM or IDSM program services (as
available).

Known Equity Concerns in the Selected
Markets: There is a lack of access to Science,
Technology, Engineering, Arts, and
Mathematics (STEAM) programs for high
school students, especially in disadvantaged
and hard-to-reach communities. Because
access to these skill-building pathways is
limited, marginalized communities in the
energy and STEAM industries are affected.

Representation in the field matters, and high
school students may be discouraged from
pursuing careers in energy if they do not
identify with the current industry makeup.

Proposed Solutions to Equity Concerns: This
program will focus on disadvantaged
hard-to-reach communities and Title I high
school students to provide access to STEAM
educational opportunities. By connecting
high schools to no-cost educational
resources, paid internship opportunities, and
professional networks, eligible high school
students will access a network of diverse
(gender and ethnicity) energy/green
professionals to act as coaches and mentors,
provide guidance, and encourage them to
pursue careers in energy.
77 The program will provide one-on-one support
to help identify career pathways, navigate
course selection and enrollment, and secure
paid internships that will reduce equity
concerns and barriers to participation.

Multilingual educational outreach materials
and program documents will meet
hard-to-reach high school students where
they are and build the skilled worker pipeline
for local employers.

Program Description: SDREN’s proposed Energy Pathways program will increase access to education and training resources to develop students' awareness of energy/green career pathways, help them learn the skills to enter the workforce, and provide sector-specific information. The Energy Pathways program will provide high school students in the San Diego region with a standards-aligned curriculum focused on career technical education. Successful program implementation will build a bridge connecting participants to local employers within the energy, electrification, and decarbonization sectors.

Participants will have access to a diverse network of mentors and coaches to provide one-on-one guidance and educate them on the value of energy/STEAM career pathways. This personalized mentorship will focus on navigating the job market, building a network, resume development, interviewing skills, financial education, and industry-specific knowledge based on their desired field of employment. Partnerships with local higher education institutions will enable eligible students to enroll in college-level courses that boost their industry knowledge and technical skills to prepare them for the workforce at no cost. Students facing monetary barriers will be connected to additional resources such as financial aid through college partners, private scholarships, stipends for opportunity youth, and paid internships.

Intervention Strategy: Downstream –
Technical assistance, education, training, and
outreach.
● Deploy a needs assessment to inform
content development and identify job
trends, skills gaps, and barriers to
accessing entry-level positions in
STEAM careers, including IDSM
pathways.
● Deliver no-cost standards-aligned
curriculum and career technical
education in partnership with local
education agencies.
● Create placement opportunities for
program graduates within full-time
high-quality jobs (e.g., fellow to
Program Metrics:
● Number of high schoolers enrolled in
programming.
● Number of training hours provided.
● Number of DACs/HTR or Title I schools
participating.
● Number of mentors/coaches matched
with high school students.
● Number of college courses completed.
● Number of internships, certifications,
or apprenticeship opportunities
provided.
● Percentage of knowledge and skills
gained from program participants.
● Dollar amount of supplemental
funding leveraged.
78 full-time work placement, an
electrician at the local utility, etc.).
● Leverage existing data resources and
tracking to measure and analyze
energy career trends and future
industry needs.
● Engage key stakeholders (employers,
high schools, and colleges) in local
communities to support program
development and delivery.
● Develop a one-on-one
coaching/mentorship network with
local employers.
● Build articulation agreements
between participating high schools
and local colleges to support dual
enrollment in STEAM college courses
at no cost.
● Develop certification opportunities
for high school students to boost their
employability and match students to
paid internships, trade, school, or
apprenticeship opportunities.
● Build a network and career pipeline
between high schools, colleges, trade
schools, and local employers and offer
networking events to make direct
connections.
● Long term: Percentage of participants
entering into the
energy/STEAM/IDSM career sector, if
the program is able to track.

High-level description of delivery workforce, including necessary scale and its risks: The delivery workforce will include SDREN’s program implementation staff to lead program participants through offerings and services. Other workforce members include high school educators facilitating program delivery after participating in train-the-trainer exercises, faculty/staff within partner organizations (local colleges, trade schools, and apprenticeships), and local employers in our network of mentors/coaches. No risks were identified regarding the delivery of workforce for this program.

Market actors necessary for success: Third-party implementer(s), high school administrators, high school teachers, high school career counselors, high school students, local college district partners, and local energy employers/employees as mentors and coaches.

Solicitation Strategy: Third-party solicited Transition Plan: Not applicable 79 Expected Program Life: 2024 - ongoing Short Term Plan: Launch the program in 2024 and ramp up implementation through 2027
to reach and serve the entire service area.

Cost Effectiveness: TRC: N/A Long Term Outlook:
● Increase the pipeline of skilled local
workers in clean energy jobs (e.g.

STEAM, ISDM).
● Increase the opportunity for youth in
hard-to-reach and underserved
communities to build skills, overcome
barriers to high-quality jobs, and
create a representative workforce.

Proposed Annual Budgets for 2024-2027:
2024: $934,000
2025: $1,930,500
2026: $2,123,550
2027: $2,335,905
2024-2027 Total: $7,323,955
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Table 36. Program Card for Workforce Training and Capacity Building Program Name: Workforce Training and Capacity Building
Program ID: SDREN-02-WET-BRC
New/Existing: New
Link to implementation plan if existing (see D.21-05-031): N/A Portfolio Segment: Market Support Implementation Party: Third-party implementer
Applicable Sector: Cross-Cutting - Workforce,
Education, & Training
Market Sub-Sector: Workforce, Education, &
Training
Sector Challenge:
● Most clean energy careers require
specialized education or training.

Adult workers new to energy and
incumbents may need new skills or
certifications, which can be
time-consuming and costly.

Sector Opportunity:
● Provide workers with no or low-cost
specialized skill training, certifications,
networking, and apprenticeship
opportunities to build skills to enter
the clean energy workforce.
80 ● Specialized skills and certifications are
expensive for employees, and they
may be unable to invest their own
money into training due to other
pressing financial considerations.
● Inexperienced workers may struggle
to find entry-level positions in the
energy industry if they lack the
required experience or education.

They may need to start at a lower
level than their previous careers,
which can be financially challenging.
● Workers may not have emerging
industry-specific knowledge, training,
experience, or the technical skills
required to maintain employment.
● Lack of disadvantaged and
hard-to-reach workers with
knowledge of energy efficiency,
electrification, decarbonization, or
green building skills makes it difficult
to find local candidates for
employment. Lack of access to
external training resources, such as
training centers or facilities, can be
particularly challenging for employees
in remote or less developed areas.
● High regional demand for energy
efficiency, electrification,
decarbonization, or green building
workers in the face of an insufficient
supply of skilled workers.
● Employees may struggle to find time
for training within regular job duties
and personal responsibilities or may
not know what training will benefit
career growth.
● Workplace culture may not support
training and skill development, which
can discourage employees from
seeking opportunities on their own,
especially if they do not see a direct
● Create no-cost employer-led EE and
IDSM training programs for essential
and emerging industry skills. Connect
employees to external certifications
and skill-building opportunities.
● Provide entry-level on-the-job training
and wraparound services such as
career coaching and mentor/mentee
support by matching participants with
employers to support securing jobs.
● Survey local employers to determine
the emerging industry careers and
necessary skills for incoming
professionals to be successful in the
industry.
● Increase network connections
through industry events, professional
organizations, networking, or
shadowing professionals to build
connections and gain insights.
● Directly support career preparedness
training focused on resume
development, interviewing skills,
transferable skills, financial literacy,
and networking skills.
● Support and incentivize high-quality
career pathways, labor standards, and
job quality within clean economy
careers, particularly in the residential
sector.
● Develop or change employer policies
on training to allocate dedicated time
and funds to pursue education and
training opportunities that will benefit
the employees and employers.
● Increase on-the-job training and
skill-building opportunities through
pre-professional shadowing, expert
guest speakers, and industry leaders.
● More accredited training or
certification opportunities in
accessible locations or online.
81 pathway for career advancement or
pay increases.
● Improve employer outcomes and
revenues through a workforce capable
of installing measures in alignment
with local, state, and federal policies
and funding streams (e.g. IRA-funded
Home Energy Efficiency Contractor
Training Grants).

Known Equity Concerns in the Selected
Markets: A major known equity concern and
barrier to entry is the cost associated with
education opportunities, certification, or
retraining programs. These costs can be
prohibitive, particularly for those from
low-income backgrounds.

Workers from minority groups face challenges
accessing information, training materials, or
job opportunities, which reduces access to
quality education and training opportunities
in hard-to-reach and underserved
communities. Additionally, members of
marginalized communities disproportionately
hold low-wage positions, perpetuating the
cycle of poverty. Employer policies regarding
training, hiring, promotions, and general
career advancement may have biases that
prevent minority employees from advancing
in their positions. Further, a lack of training
opportunities or knowledge of where to
access training prevents career growth.

Proposed Solutions to Equity Concerns:

SDREN seeks to bolster internal employee
training and skill-building programs within
energy-efficiency or IDSM-deploying
employers to upskill the existing workforce
and enable hard-to-reach and underserved
participants to access high-quality jobs in the
clean energy economy. The program will use
a network of clean energy and green
professionals from diverse and representative
backgrounds as coaches and mentors to
improve equitable access to industry-specific
guidance and knowledge and support
participants’ long-term career success.

Identifying or creating additional EE and
IDSM accredited training or certification
opportunities in accessible formats will
ensure all program participants will benefit.

SDREN will help workers in hard-to-reach and
underserved communities access no-cost
education and certifications. By doing so, we
will also support businesses by providing
on-the-job training and skill development for
underserved, entry-level workers. Working
directly with the workforce and employers
places SDREN in a position to address equity
concerns with multiple stakeholders. SDREN
will encourage employers to change training
policies to dedicate time and funds to
education and training that will benefit the
employee and employer. By creating no-cost
employer-led training programs for essential
and emerging industry skills, SDREN will give
employees access to external certifications
and skill-building opportunities directly.
82 SDREN will provide multilingual educational
outreach materials and on-the-job training
opportunities through pre-professional
shadowing, expert guest speakers, and
industry leaders. These training opportunities
will meet participants where they are and
expand the skilled worker pipeline for local
employers.

Program Description: SDREN’s Workforce Training & Capacity Building program will enhance the clean energy workforce in our region, focusing on skill development for adult and incumbent workers. The program will target employees and employers, boosting employee skills and employer capacity to work on electrification and decarbonization projects.

By developing and delivering no-cost EE and IDSM training and certifications, SDREN will bolster employability, fill gaps for in-demand technical skills, and provide pathways for individuals to enter the clean energy workforce. This program will increase skills within the existing workforce, improve employee retention rates, foster participant career advancement, and provide opportunities for networking through industry events, professional organizations, and shadowing with seasoned professionals in the field. Participants will receive career coaching and mentorship focused on resume development, interviewing skills, transferable skills, financial literacy, and networking.

The program will collaborate with stakeholders within clean energy, electrification, and decarbonization workforce sectors, including CBOs, public agencies, contractors, and labor unions. Partnerships will boost growth opportunities for incumbent workers, increase retention rates for employers, and enhance employer workforce training. SDREN will guide participating employers to develop policies to promote employee training, allocate funding for external training, and set aside time for skill development.

Intervention Strategy: Downstream –
technical assistance, education, training, and
outreach.
● Develop and deploy a survey for local
employers to determine the emerging
clean energy industry careers and
required skills and qualifications for
professionals to be successful.
● Provide relevant training and ongoing
workforce support aligned with
industry needs to build capacity in the
region, supporting employers along
the way.
● Partner with local agencies to create
a network of connection resources,
Program Metrics:
● Number of participants trained.
● Number of jobs secured after program
participation.
● Number of training hours completed.
● Number of certifications provided.
● Number of employee program
participants.
● Percentage of HTR and underserved
participants.
● Number of mentors/mentees.
● Percentage of knowledge gained after
training participation.
● Number of career and workforce
readiness participants who have been
83 standardize content, and offer EE and
IDSM-focused training.
● Create opportunities for program
graduates to seamlessly transition
into employment with local
employers. Establish partnerships
with employers to facilitate job
placements.
● Foster connections between the
workforce and SDREN’s residential
programs.
● Create opportunities for participants
to connect with SDREN, IOU, and
statewide programs to gain additional
skills at no cost.
● Explore worker placement programs
that can build workforce capacity
while supporting participants skill
development.
employed for 12 months after
receiving training.
● Number of employers participating.
● Number of internal employer trainings
delivered.
● Number of employer policies
updated.
● Number of external training
opportunities offered.

High-level description of delivery workforce, including necessary scale and its risks: The delivery workforce will include SDREN’s program implementation staff to lead participants through program services. Other workforce members include local employers in the network of mentors and coaches for new and incumbent workers.

Market actors necessary for success: Third-party implementer(s), adult workers interested in entering the energy sector, incumbent workers, local energy employers within the clean energy, electrification, and decarbonization workforce sectors, and training providers.

Solicitation Strategy: Third-party solicited Transition Plan: Not applicable Expected Program Life: 2024 - Ongoing Short Term Plan: Launch the program in 2024 and ramp up implementation through 2027
to reach and serve the entire service area.

Cost Effectiveness: TRC: N/A Long Term Outlook:
● Increase the skills of the local
workforce and provide pathways for
employment in the energy workforce
within local communities.
● Substantially increase workforce skills
and provide pathways for industry
advancement.
84 ● Increase employers’ capacity to take
on new work within the clean energy,
electrification, and decarbonization
workforce sectors.

Proposed Annual Budgets for 2024-2027:
2024: $1,518,000
2025: $3,137,000
2026: $3,450,700
2027: $3,795,770
2024-2027 Total: $11,901,470
Anticipated directional and scale changes in
the budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Public Sector
Market Characterization
The public sector market is the group of customers that are taxpayer funded, have political mandates, and that must go through a public budgeting and decision-making process.48 They are a distinct and unique segment of non-residential customers with a set of exceptional challenges and characteristics that set them apart from other customer groups.

Public agencies encounter unique challenges based on common characteristics including multiple and competing goals, lengthy procurement processes, risk aversion, and funding constraints, among many others. Given these challenges, there is significant opportunity for SDREN to help agencies overcome barriers to participating in energy efficiency programs.

Historically, SDG&E has made efforts to engage with the public sector. However, previous efforts spanning 2018-2020 only yielded 4% of SDG&Es overall portfolio energy savings, though the public sector accounts for 15% of overall system electric consumption.49 Within SDG&E’s jurisdiction there are over 14,000 public sector accounts, with a significant 77% made up of small accounts with a peak demand of 20 kW or less.50 These small accounts often face difficulties qualifying for existing IOU resource programs, generally due to those programs’ cost effectiveness requirements.

SDG&E recently closed their K-12 Energy Efficiency program, so this customer group is being served by their Commercial BES program until another offering is available. This was out of SDG&E’s control and was unplanned since the implementer suspended business operations.51 Through coordination conversations with SDG&E leading up to this Business Plan submission, 51 SDG&E AL 4302-E, pg. 29.
50 Ibid.
49 SDG&E Business Plan Exhibit 2 p. 163.
48 Decision Authorizing Energy Efficiency Portfolios for 2024-2027 and Business Plans for 2024-2031. Conclusions of Law #33. 85 SDREN identified school districts in the territory as a service gap it could fill. Given this history and the persisting challenges in engaging public sector participants, SDREN identified a substantial opportunity to introduce impactful localized programs and services in this customer segment. As a result, SDG&E is not planning a new solicitation for this program, anticipating that SDREN will fill this gap if authorized.

Public Sector Goals, Objectives and Strategies
San Diego County hosts a diverse range of public agencies which SDREN aims to support through its offerings, including:52
● 24 San Diego Water Authority members.
● 19 local governments.
● 42 K-12 school districts and other public educational agencies. ● 13 community service districts.
● 18 Tribal nations.

These public agencies manage a wide range of infrastructure and facilities, from police stations and schools to wastewater treatment plants and streetlights. As public assets, these facilities are essential for community well-being and highly visible and accessible to the public. This unique positioning empowers public agencies to lead by example, setting the stage for community resilience.

By completing energy upgrades, public agencies can improve reliability, support cleaner energy systems, generate cost savings, inspire local action, and boost the local economy. This vital role of public agencies within their communities underscores the importance of addressing their unique needs and challenges.

SDREN will deliver programs and services that enable public agencies to lead their communities by example to a more decarbonized, affordable, and resilient energy future. The proposed public sector programs offer a comprehensive suite of services to public agencies throughout San Diego County. These services will overcome common barriers by helping agencies identify, develop, fund, and implement energy savings opportunities across buildings and facilities, ultimately contributing to local and regional decarbonization goals.

Public agencies are instrumental in setting the example for their communities. Therefore, our programs will go beyond conventional energy efficiency and will provide agencies with valuable educational information and technical support services for IDSM strategies. These offerings empower public agencies to establish or reinforce community resilience hubs, which play a crucial role as safe havens during climate-related emergencies. SDREN is well positioned to design and implement these programs successfully as its inaugural Advisory Committee consists of representatives from public agencies that are multi-jurisdictional.

SDREN’s public sector programs are designed to ensure underserved and hard-to-reach communities are not left behind in the clean energy transition. We will prioritize outreach and 52 Federal and state are currently served by existing programs and SDREN will not focus on these agencies unless there is a request from these agencies or SDG&E to coordinate and support offerings. 86 offer specialized services to HTR or underserved public agencies and K-12 schools to ensure that all communities in San Diego County can access the benefits of a cleaner, more resilient energy future.

Table 37. Public Sector Goals, Objectives and Strategies Goals (Informed by
SDCP Plan Community
Priorities)
Strategy Objectives
Help public agencies
address and adapt to
climate change by
reducing GHG emissions
and increasing energy
resilience.
● Technical assistance through
energy efficiency audits,
project management
services, and incentive and
financing application support
to identify and fund DER
projects.
● Direct EE measure
installations with a special
focus on K-12 schools.
● Portfolio analyses and
benchmarking paired with
community indicators to
identify facilities that are
good candidates for resilience
hubs.
● Identify and apply for outside
funding sources of DER
implementation including EE,
renewables, etc.
● Prioritize Tribal outreach to
improve and increase access
to programs that will provide
technical assistance and
support implementation of
shovel-ready EE projects.
● Support transition away from
HFC refrigerants by providing
education about low-GWP
alternatives. Customers will
receive relevant measures or
recommendations with
technical assistance.
● Coordinate with the C&S
community to simplify and
● Agencies improve their
energy resilience and
preparedness for
climate-related
emergencies.
● Decarbonization of agency
facilities and assets by
implementing DER projects
including EE, solar, battery
storage, EV charging, DR
program enrollment, etc.
● Agencies lead their
communities by example.
● Agencies receive capital to
fund their decarbonization
and energy resilience
projects.
● Energy bill reductions are
achieved.
● Serve diverse and
hard-to-reach communities.
87 streamline permitting
processes for IDSM and DERs.

Increase energy
capacity, awareness, and
competency.
● Agencies receive education
and training through
webinars, workshops, and
program deliverables on the
benefits of decarbonization,
energy resilience, and DR
program participation.
● Build capacity and awareness
through ongoing
engagement, sharing of case
studies, and educational
resources.
● Provide energy analysis
reports at the portfolio and
project level.
● Develop customized
decarbonization and
resilience roadmaps that
align with established agency
goals and priorities.
● Agencies demonstrate
awareness of DER benefits
by integrating related
policies and actions as a
standard practice.
● Agencies are aware of
energy consumption and
costs across their assets.
● Agencies incorporate
recommendations from the
program's decarbonization
and resilience roadmaps into
their CAPs to increase the
energy resilience of their
critical infrastructure,
increasing public buy-in.
● Agencies are more actively
engaged in supporting
decarbonization and
resilience activities in their
communities.

Ensure underserved
public agencies are not
left behind in the clean
energy transition.
● Develop a new framework in
which Tribal governments
propose and design
customized energy programs
and strategies to meet their
unique community and
cultural needs.
● Specialize services developed
to target K-12 schools that
would otherwise not be
served.
● Track all supplemental
funding sources, including
state and federal funding
sources such as IRA’s Indian
Affairs' Tribal Electrification
Program, that can be
leveraged for projects and
● Tribal communities benefit
from increased access to EE
resources through tailored
programming.
● Energy justice for DAC and
HTR communities through
reduced energy burden.
88 offer application assistance
for program participants.

Public Sector Coordination
Our primary goal for coordination efforts is to eliminate customer confusion about EE programs and encourage seamless participation. We will work closely with SDG&E and other stakeholders, and there are several key programs we aim to coordinate with:
● The SDG&E Local Government Third Party Program, Climate Action Plan for Zero Net Energy (CAP4ZNE) offers a concierge approach tailored to local governments for energy efficiency and greenhouse gas reductions. SDREN’s Public Sector programs will closely collaborate with this program to ensure SDREN’s program is complementary and fills gaps. SDREN will also channel project opportunities to this program, wherever possible. ● The Statewide Water Infrastructure and System Efficiency™ program (SW WISE™) provides solutions related to water production, distribution, and water/wastewater treatment systems. SDREN’s Climate Resilience Leadership program will introduce agencies with eligible project types to the WISE program and fill gaps in their services. ● The Business Energy Solutions (BES) program, which offers no-to-low cost direct install measures paired with audits and recommendations. SDG&E had intended to close the BES Program at the end of 2023 due to the launch of its new Small Business Outreach Program at the start of 2024. However, due to the early termination of the K-12 Energy Efficiency Program (KEEP), SDG&E now plans to keep the program active to serve the K-12 customer base.53 Instead of issuing a new solicitation for their K-12 EE program, SDG&E will continue to offer the BES program until the launch of the SDREN Climate Resilience Leadership program, which will serve K-12 school districts. ● The SDG&E On-Bill Financing (OBF) program offers 0% financing for energy upgrades; SDREN will facilitate access to SDG&E OBF for projects eligible for SDG&E incentive programs. SDREN will help public agencies apply for and access SDG&E OBF for projects pursuing an SDG&E program.
● The Higher Education Energy Efficiency Program (HEEP) serves existing higher education facilities owned or operated by University of California, California State University, or California Community College. SDREN will coordinate as applicable. ● The California Energy Design Assistance (CEDA) program offers EE incentives for new construction projects. SDREN will refer program participants to this program where applicable, as SDREN services do not address new construction. 53 SDG&E AL 4302-E, pg. 17.
89 ● San Diego (SD) EnergyLink provides energy services to federal buildings, military bases, and Tribal nations. SDREN will coordinate with the program to ensure participants receive comprehensive services.

SDREN will also collaborate with the San Diego Regional Climate Collaborative (SDRCC) and the San Diego Association of Governments (SANDAG) to build on successes from previous LGP programs. These organizations are established regional networks for public agencies to develop and advance climate change and decarbonization solutions.

Effective coordination is paramount to deliver comprehensive and efficient services to the public sector. To avoid overlap with SDG&E and statewide programs in the region, SDREN will coordinate closely with SDG&E and the statewide program administrators and their implementers to offer services that fill gaps for program participants. Upon Business Plan approval, SDREN will file a Joint Cooperation Memo with SDG&E and any other program administrators operating in shared service territory to outline coordination protocols that ensure services fill gaps, meet regional needs, and avoid duplication. Initial strategies discussed with SDG&E during the portfolio application development include:
● Close coordination with existing programs to fill gaps in service and prevent market confusion.
● Mapping of full public sector portfolios including eligibility criteria, customer targeting, and services ahead of SDREN solicitations.
● Develop joint strategy around messaging to customers. ● Promote complementary programs such as SDG&E’s CAP4ZNE and statewide WISE.

SDREN will also monitor the market and coordinate with other programs to leverage complementary offerings and stack supplemental program services, including:
● Leverage the CAP4ZNE program incentives and other unique offerings to bring incentive opportunities and services to public agency participants. ● Stack IRA tax incentives, 179D Commercial Building EE tax deductions, and TECH incentives to reduce equipment costs.
● Leverage previously drafted climate action plans to guide and inform opportunities with participants.

Categorization by Segment
Additional details on SDREN’s segmentation justification at the program-level can be found in Exhibit 3 - Program Segmentation Justification template Attachment A from D.23.06.055.

Table 38. Public Sector Program Categorization by Segment Program Sector Justification/Primary Goal
Climate Resilience
Leadership
Market
Support
Build capacity for public agency participants through
education, training, and technical services and instill EE as a best practice. These goals are in alignment with the 90 Commission MS objective to support long term success of the EE market.

Tribal Engagement Equity Provide energy efficiency services to Tribes, a hard-to-reach community that has been historically
underserved. This goal is in alignment with the primary purpose of Equity segment programs, i.e. to provide EE
services to HTR customers in DACs in advancement of the Commission’s Environmental and Social Justice Action
Plan.

Public Sector Program Details
Table 39. Program Card for Climate Resilience Leadership Program Name: Climate Resilience Leadership
Program ID: SDREN-01-PUB-CRL
New/Existing: New
Link to implementation plan if existing: N/A
Portfolio Segment: Market Support Implementation Party: Third-party Implementer
Applicable Sector: Public Market Sub-Sector: Eligible public agency types.
● Cities
● County
● Public education agencies
● Special districts
● Tribes
Sector Challenge:
● Limited staff capacity, understanding,
and expertise to address EE and
decarbonization opportunities to
improve energy resilience.
● Lengthy and cumbersome public
procurement processes.
● Limited access to data for informed
decision making.
● Limited capital and/or competing
priorities for EE projects.
● Risk aversion.
● Resource constraints as staff and
budgets have many competing
Sector Opportunity:
● Comprehensive yet tailored services
to meet public agencies’ unique
needs, with a focus on agencies
serving underserved and
hard-to-reach communities.
● Provision of technical assistance and
resources to help public agencies
identify and implement clean energy
projects and meet regional
decarbonization goals.
● Increase staff capacity through
education, outreach, project
management, and technical assistance
91 priorities and energy management is
just one of many.
● Complex decision making and political
dynamics.
● Long-term planning challenges.
● Gaps in IOU third party offerings,
including school district programming.
● Aging infrastructure, including
buildings and utility systems that may
require substantial energy efficiency
upgrades.
to integrate EE as standard practice
across operations.
● Reduced energy burden by reducing
energy costs and reinvesting energy
bill savings into communities.
● Provide no to low-cost EE measure
installations through a direct install
offering.
● Offer portfolio energy analyses to help
inform decision making, targeting of
clean energy opportunities, and
creation of resilience hubs across
agency owned assets.
● Support updating or creating short
and long-term energy resilience plans.

Known Equity Concerns in the Selected
Markets: Public agencies, especially smaller
ones, often have constrained budgets and
staff resources, making it difficult to allocate
funding and staff for clean energy projects or
take advantage of available services and
funding. Additionally, a large proportion of
public agency accounts are small (<20kW)
and may not qualify for many IOU resource
programs due to potential projects not
meeting programs’ cost effectiveness
requirements. This in turn leads to even
greater inequity in the long run, as energy
and operational costs continue to rise while
projects are delayed. These smaller agencies
may not have resources to develop climate
action or resilience plans and build internal
capacity around DERs. Public agencies are
expected to lead their communities by
example, but there is limited funding and
services to support them in achieving their
goals.

Proposed Solutions to Equity Concerns: The
program proposes to address equity concerns
by prioritizing outreach to agencies that have
historically been overlooked by EE programs.

The program will provide technical assistance,
end-to-end project management services,
and educational resources to public
agencies/facilities of all sizes, acting as an
extension of agency staff. Financial assistance
services will help agencies identify, apply for,
and secure funding for EE and IDSM projects.

The program will also offer:
● Increased incentives and no-cost
direct install support of EE measures
for HTR and underserved agencies.
● Education and training resources to
help agency staff grow their capacity
and awareness of the benefits of EE,
DER technologies, and DR program
participation to drive decarbonization
efforts.
● Assistance for underserved agencies
to develop actionable resilience
roadmaps.
92 Program Description: The Climate Resilience Leadership program is designed to overcome barriers hindering public agencies from implementing EE projects. It also promotes IDSM technologies and programs, facilitating deeper decarbonization to help agencies meet their climate goals. Dedicated project managers will act as an extension of agency staff to provide customized and unbiased start-to-finish guidance and to coordinate delivery of technical services to identify and implement EE projects.

The program operates through dedicated project managers who offer tailored guidance throughout the project cycle and coordinate technical service delivery to identify and implement EE and DER projects. This personalized approach ensures unbiased support and successful project execution.

To address common challenges related to funding and procurement and to fill IOU program gaps, the program provides incentives for direct installation of EE measures. This will include providing targeted and specialized direct install services to K-12 schools, recognizing that there is a gap in services available to this market sub-sector. Project managers will also coordinate and facilitate access to third-party incentive programs. Moreover, the program will monitor emerging funding opportunities for public agencies (such as IRA) and provide support for all relevant incentive and financing applications, relieving them of major administrative burdens.

In addition to the suite of project delivery services, the program tackles knowledge and capacity barriers by offering educational resources on DERs and DR programs through webinars, peer to peer learning opportunities, and case studies. Mini grants will also be available to fund public agency staff attendance at decarbonization or DER-related conferences and events. These resources empower agency staff to become champions for decarbonization internally while showcasing climate leadership to the broader community through successful project delivery.

Intervention Strategy: Downstream –
technical assistance, incentives via direct
install, outreach and education, funding and
financing support.

EE and DER project identification and
delivery interventions.
● Agency portfolio energy analysis and
resilience roadmap: provides
participants with overview of energy
consumption and costs and facilitates
project opportunities by identifying
energy-intensive infrastructure. Sets
foundation for development and
delivery of energy resilience roadmap,
which identifies DER opportunities to
improve community energy resilience
Program Metrics:
● kWh
● Therms
● TSB
● Number of public agencies engaged
and receiving services (including
project management and education
and outreach activities)
● Dollar amount of energy bill savings
● Audits completed
● Financial analyses delivered
● Projects managed
● Number of educational activities
delivered (webinars/workshops)
● Number of unique outreach materials
created
● Number of buildings benchmarked
93 and recommends sites to serve as
resilience hubs.
● Comprehensive energy audits:
identify energy savings, EE and
decarbonization opportunities.
● Financial analysis: utilizes outputs
from audit reports to provide business
case summary to invest in clean
energy projects.
● Project financing and funding
assistance: facilitate access to various
financing options including cash
incentives, low to no interest loans,
tax credits, and grants to help
agencies overcome financial barriers
to projects.
● Procurement assistance: provides
agencies with documentation to
procure installation contractors and
receive applicable internal approvals.
● Construction support: review scope
and contractor equipment submittals
to ensure alignment with anticipated
energy savings outcomes and funding
eligibility requirements.

Engagement, education and outreach
interventions.
● Workshops/webinars/training and
educational resources to build public
agency staff’s capacity and awareness
of EE, sustainability, and
decarbonization measures, including
DR program participation.
● Micro grants to fund public agency
participation in educational events,
e.g. conferences.

Direct installation of EE measures that help
agencies overcome funding, financing, and
procurement hurdles and achieve
decarbonization and resilience goals.
● Number of energy resilience
roadmaps delivered
● Number of energy savings measures
identified and installed
● Number of funding and financing
applications supported
● Dollar amount of non-ratepayer
funding leveraged
94 ● Sample direct install measures
include: economizer controls/repair,
heat pump water heaters, occupancy
sensors, outdoor LED lighting, and
pipe insulation.

High-level description of delivery workforce including necessary scale and its risks: The program delivery workforce will include SDREN staff and third party implementation partners, including subcontracted engineering consultants and other industry experts to provide as needed services to program participants. There are no known related workforce risks for successful implementation of the program.

Market actors necessary for success:
● Third-party implementer(s).
● Local entity or entities familiar with public agency barriers and solutions to installing EE and DERs.
● Local engineering firms and contractors.

Solicitation Strategy: Third-party Solicited Transition Plan: Not applicable Expected Program Life: 2024 - Ongoing Short Term Plan: Ramp up third-party program to full implementation to serve at
least 50% of all eligible customers in service
territory.

Cost Effectiveness: TRC 2024-2027: 0.41 Long Term Outlook ● Public agencies look to SDREN as a
trusted advisor to help them improve
energy resiliency and address energy
needs.
● Energy and cost savings realized.
● Broader reach and support across
underserved communities.
● Agencies demonstrate increased
awareness of EE and IDSM best
practices and integrate into operating
practices and procedures.
● Enhanced resilience to climate
challenges and emergencies, including
more resilient energy infrastructure
and practices.
● Disparities in energy access and
program participation are reduced.

Proposed Annual Budgets for 2024-2027:
2024: $2,732,000
2025: $5,645,500
2026: $6,210,050
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
95 2027: $6,831,055
Total 2024-2027: $21,418,605
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Table 40. Program Card for Tribal Engagement
Program Name: Tribal Engagement
Program ID: SDREN-02-PUB-TRE
New/Existing: New
Link to implementation plan if existing: N/A
Portfolio Segment: Equity Implementation Party: Third-Party Implementer
Applicable Sector: Public Market Sub-Sector: Tribes
Sector Challenge:
● Tribal cultural sensitivities, distrust in
government programs.
● Some Tribal governments may lack
in-house technical expertise,
resources, and staff capacity to plan,
implement, and manage energy
efficiency initiatives, making it
challenging to take advantage of
available programs.
● Lack of capital to invest in EE and
decarbonization strategies.
● Most public sector accounts in SDG&E
territory are small (<20kW) and may
be passed over by IOU resource
programs with cost effectiveness
requirements.
● Aging infrastructure, including
buildings and utility systems that may
require substantial energy efficiency
upgrades.
● Navigating the complex regulatory
environment, including compliance
with federal and Tribal regulations,
can be challenging for Tribal
governments.

Sector Opportunity:
● Tribal community-led design of
initiatives to facilitate energy
planning, increase access to EE
programs, reduce energy burdens,
and decarbonize assets.
● Ongoing access to technical advisor
with EE expertise to support
successful programming and
initiatives; access to industry experts
including engineering firms.
● Advance climate resiliency on Tribal
lands and in Tribal communities.
● Tribes demonstrate leadership in EE
and share best practices and lessons
learned.
96 Known Equity Concerns in the Selected
Markets: Tribal participants have long been
underserved and underrepresented in energy
efficiency programs. This historical
underinvestment in outreach to Tribal
participants is one of many factors that have
significantly eroded Tribal governments’ trust
in public sector programs. This has led to
missed opportunities for Tribal governments
to secure vital funding and resources.

One of the key equity concerns in Tribal
communities is limited access to information
about available programs, incentives, and
resources. This limited access not only
hinders the development of sustainable
energy practices within Tribal lands but also
compromises the resilience of Tribal
communities in the face of energy-related
emergencies and challenges.

Proposed Solutions to Equity Concerns: The
Tribal Engagement program recognizes that
addressing equity concerns within Tribal
communities is a multifaceted endeavor that
requires a tailored, culturally sensitive and
empathetic approach. To overcome historical
underinvestment in Tribal communities, the
program proposes to provide grant funding
and no-cost technical assistance to Tribal
participants for community-driven
interventions. This support will empower
Tribal governments to design and offer EE
programs to their Tribal government and
community members. By providing financial
resources and technical expertise, we aim to
break down the barriers that have historically
hindered Tribal participation in energy
initiatives.

Building trust within Tribal communities is a
fundamental component of our approach.

We understand that trust is built through
meaningful relationships, respect for cultural
sensitivities, and a genuine understanding of
Tribal needs. To achieve this, we plan to
establish partnerships with trusted leaders in
Tribal communities. These partners will play a
pivotal role in ensuring program design and
delivery is culturally sensitive and responsive
to the unique needs of each Tribal
community. This includes acknowledging and
addressing historical disparities in energy
access, infrastructure investment, and
environmental impacts that may have
disproportionately affected Tribal
governments. Building trust and engaging
Tribal communities takes time; we are
prepared to listen, learn, and adapt our
approach to the unique cultural and historical
context of each Tribal community.
97 Program Description: The Tribal Engagement program will create a pathway for Tribes and Tribal organizations in the San Diego region to develop, propose, and implement energy-related initiatives to address their unique needs and contribute to sustainability, resilience, and economic development within Tribal communities. Through our community-driven program, we will empower Tribes to take ownership of initiatives and exercise self-determination in pursuing decarbonization and sustainable energy practices.

Program resources will include tailored no-cost technical assistance, including a dedicated technical advisor to support initiative applications and champion their success from idea inception to successful execution.

All initiative applications will be required to promote sustainable energy practices within Tribal lands and enhance the resilience of Tribal communities by increasing their capacity to withstand energy-related emergencies and challenges. The third party program implementer will develop high-level blueprints of program design options for Tribes to follow and secure funding to implement. Moreover, we welcome and encourage innovative ideas outside of these blueprints, granting Tribes the freedom to propose unique solutions that align with their goals.

Initiative applications will be evaluated based on their alignment with Tribal needs, sustainability, resilience, and economic development goals. Approved initiatives will receive customized services and resources to support implementation. These services may include technical expertise, project funding, and partnerships.

The Tribal Engagement program is a catalyst for Tribal communities in the San Diego region to shape their energy destinies. By nurturing local talent, inspiring innovation, and providing the necessary support, we aim to create a vibrant and resilient energy landscape that Tribal communities can proudly call their own.

This program will coordinate with SDREN’s Climate Resilience Leadership program to ensure that there is no duplication of efforts. Tribes will be able to access all the technical services available from both programs, including direct install measure installations.

Intervention Strategy: Downstream –
technical assistance, outreach and education.
● Initiative ideation and application
technical services support: technical
assistance is provided to help Tribes
develop ideas and draft applications.
● Direct funding grants provided to
Tribes to implement initiatives.
● Initiative application evaluation:
includes approval by program
implementer.
● Technical assistance: Approved
initiatives receive customized services
and resources to support delivery,
Program Metrics:
● Number of initiative applications
submitted
● Number of initiative applications
approved
● Number of implementation plans
prepared
● Number of Tribes served
● Dollar amount of grant funds awarded
Additional metrics to be determined as Tribal
initiatives are approved.
98 including support to develop
implementation plans.
● Access to energy experts (e.g.
engineering firms, financial advisors,
local agencies, and relevant
stakeholders) to leverage expertise
and resources.

High-level description of delivery workforce including necessary scale and its risks: The delivery workforce will include third party implementation partners, including on-call subcontracted engineering consultants, and energy leaders from Tribal communities and organizations. Time and resource availability for Tribal energy leaders may be a risk factor.

Market Actors necessary for success:
● Third-party implementer(s).
● Tribal nations and Tribal organizations.
● Others to be determined based on proposed and approved grant initiatives.

Solicitation Strategy: Third-party Solicited Transition Plan: Not applicable Expected Program Life: 2024 - Ongoing Short Term Plan: Ramp up third-party programs to full implementation to offer
grants to at least 8 Tribes.

Cost Effectiveness: TRC: N/A Long Term Outlook:
● Tribes become more empowered as
they gain experience proposing,
implementing, and managing
initiatives, and they become more
sustainable as a result.
● A large portfolio of initiatives are
serving diverse Tribal needs.
● Reduced energy burden and increased
revenue generation through clean
energy projects.
● Enhanced resilience to climate
challenges and emergencies including
more resilient energy infrastructure
and practices.
● Disparities in energy access and
participation are reduced.
● Supplemental funding sources can be
leveraged, including IRA funding
earmarked for Tribal governments to
administer residential electrification
and DER programs.
99 ● Successful initiatives serve as models
for other Tribal communities within
and beyond San Diego. Scalability may
lead to expansion in other regions,
increasing impacts.
● Over time, Tribal communities that
have successfully implemented
initiatives may become sources of
knowledge and best practices for
other communities, fostering a culture
of shared learning.

Proposed Annual Budgets for 2024-2027:
2024: $234,000
2025: $482,600
2026: $530,860
2027: $583,946
2024-2027 Total: $1,831,406
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Residential Sector
Market Characterization
The residential sector is the largest customer group in SDG&E territory, making up 1.49 million accounts and consuming over a third of all electricity and more than half of all natural gas in San Diego County.54 The importance of serving this sector in the realm of energy efficiency is clear, as it represents a substantial opportunity for significant savings in the region based on incremental market potential identified in the 2023 Energy Efficiency Potential and Goals Study findings.55 These findings unequivocally illustrate the immense potential within the SDG&E territory's residential sector when compared to other sectors like agricultural, commercial, and industrial, as depicted in the figure below.
55 2023 P&G Study Results Viewer V1.0; filtered for SDG&E, Residential, Cumulative Market Potential for all measures. 54 SDG&E Business Plan Exhibit 2. P. 189.
100
Figure 11. SDG&E Residential Sector Energy Efficiency Savings Potential Moreover, the study categorizes a significant majority of this potential as behavioral, retro-commissioning, and operational (BRO), accounting for 94% of potential savings, with fuel substitution and water heating making up the majority of the remaining potential.56 These statistics emphasize the need for programs and services that can equitably serve the residential sector and instigate behavioral change and home electrification.

The residential sector has a diverse landscape of customer types, including single-family homes and multi-family dwellings, each with a distinct set of challenges and opportunities. The complexities vary from program accessibility and entry barriers to concerns surrounding equity and inclusion. For instance, programs targeting multi-family homes can have higher barriers, often necessitating approvals by property managers and owners, larger capital expenditures, and the potential for uneven distribution of program benefits, particularly among renters and property owners.

Furthermore, there is often a shortfall in ensuring equitable access to these programs, especially among HTR and underserved customers, due to insufficient consideration of equity and inclusion in program outreach and educational materials. This lack of accessibility is further compounded by the fact that affordable housing is often located in multi-family buildings, which can exacerbate gaps in program access and equity.
56 Ibid.
101
Residential Sector Goals, Objectives and Strategies
To help bridge existing program gaps and create a more equitable landscape, SDREN will implement two residential sector programs designed to deliver equitable services to underserved and hard-to-reach community members for single-family and multi-family homes.

These programs will work in harmony with all relevant existing third-party programs offered by SDG&E, state, and federal agencies. A key focus of the programs will be on stacking incentives wherever feasible, maximizing the benefits for customers while efficiently utilizing available resources.57 Understanding that the multifamily sub-sector has experienced EE program challenges across the state, SDREN will coordinate directly with PAs and implementers to apply the latest lessons learned from other multifamily programs prior to implementation.

Both of SDREN’s residential sector programs are strongly rooted in the principle of equity. They prioritize delivery to hard-to-reach customers by offering in-language outreach and anti-displacement policies. These programs will provide EE measures and serve buildings not covered (or only partially covered) through existing programs. Furthermore, they will fill gaps by addressing the specific needs of renters, including direct install upgrades and educational initiatives that emphasize non-energy benefits. Complementing these services, SDREN will help customers to leverage external funding and financing opportunities, including the stacking of incentives.

SDREN’s residential sector programs aim to promote equity and inclusivity, recognizing the diversity of challenges that both single-family and multi-family homes face within the realm of clean energy initiatives. We believe that through these programs, SDREN can create meaningful change, ensuring that every member of the community benefits from the clean energy future.

Table 41. Residential Sector Goals, Objectives, and Strategies Goals Strategy Objectives
Deliver equitable services to
traditionally underserved
and HTR residential
customers to ensure they
are included in the clean
energy transition.
● Focus on underserved and
HTR residential customers
within San Diego County.
● Provide in-person,
equitable, and inclusive
outreach and support
services (i.e. in-language
materials with cultural
understanding, taking into
account vision and
hearing impaired
customers, etc.).
● Customized energy
programs and strategies
shaped by community
● Increased access to and
participation in
ratepayer-funded EE
programs by HTR
customers and
underserved communities.
● Reduced energy burden
plus energy co-benefits
(e.g. health, comfort)
realized by HTR and
underserved residents.
● A clean energy transition
inclusive of customers
historically left out of
energy programs.
57 SDREN will ensure that there is no “double dipping” of ratepayer funding. 102
input and tailored to meet
unique community needs.
● Increased incentive
opportunities offered to
HTR and underserved
communities.
● Energy justice for HTR
customers and
underserved communities.

Reduce barriers to EE
program participation
among residential
customers.
● Provide one-on-one and
in-language support to
residents via an energy
advisor who can connect
customers to all other
available programs,
services, and funding
opportunities (e.g. IOU
third party, state, federal
programs, etc.).
● Offer direct installation of
energy efficiency
measures to lower
residents’ energy bills and
help secure rebates for
other identified measures,
ensuring various funding
sources are identified and
stacked wherever feasible.
● Provide guidance and
support to customers
seeking federal tax credits
and other available
incentives for clean
energy projects.
● Educate residents and
provide them with
resources to understand
energy-saving and
co-energy benefits (e.g.
health and comfort).
● Equitable and inclusive,
culturally sensitive
in-language outreach
materials and program
documents.
● Increased residential
sector adoption of EE and
energy upgrades/retrofits.
● Improved comfort and
health despite climate
threats like extreme heat.
● Increased access to and
awareness of EE
technologies and available
funding and financing
programs.
● Customer energy bill
savings and GHG
reductions realized.
103
Accelerate implementation
of EE and decarbonization
measures and long-term
market transformation
through program
interventions.
● The energy advisor works
to overcome barriers to
program adoption.
● Adapt and evolve program
services to best meet
customer needs.
● Programs foster
community and industry
partnerships to develop
holistic solutions to
address resident needs.
● Support deeper and
expanded electrification
of space and water
heating systems and other
methane gas-based
systems like ovens and
dryers with efficient
electric versions in order
to accelerate building
decarbonization.
● Assist resident enrollment
in demand response (DR)
programs and install
DR-ready measures.
● Emerging EE technologies
(e.g. heat pump water
heaters) move toward
standard practice.
● Full potential of EE for the
residential sector is
realized.
● Residents have a plan and
the resources for
future/capital intensive
clean energy upgrades.
● Avoided peaker plant
emissions through peak
demand reductions.

Residential Sector Coordination
During the development of SDREN’s Business Plan, SDREN held discussions with SDG&E to address potential overlap in ratepayer-funded programs and to avoid duplicating efforts.

Notable existing programs discussed during these meetings include:
● Residential Zero Net Energy Transformation (RZNET) program: a regional third-party program that serves multifamily and manufactured homes. ● Quality Residential HVAC Services: a statewide program that provides extra incentives, training, and tools to HVAC contractors who provide enhanced services including maintenance plans, maintenance calls, and quality installations. ● Golden State Rebates: a midstream statewide plug load and appliance program that offers incentivized EE measures to participating retailers and distributors. 104
Other SDG&E-specific programs for collaboration may include the Energy Savings Assistance (ESA) program,58 Residential Energy Solutions (RES)59 program, and the future residential equity program (anticipated to launch mid-2024) and residential fuel-substitution market support program (anticipated to launch in 2025).

Upon approval of the Business Plan, SDREN will file a Joint Cooperation Memo (JCM) with SDG&E and any other applicable program administrators (PAs) with programs operating in shared service territory. The JCM will outline coordination protocols to ensure that SDREN services fill gaps, meet regional needs, and avoid duplication. SDREN will collaborate with SDG&E, PAs, program implementers, and any applicable initiatives or campaigns to offer complementary services that fill gaps for residential program participants. An example initiative is the Switch Is On, which inspires consumers to “equitably electrify communities.”60 SDREN will monitor the market and coordinate with other programs to leverage complementary offerings and stack incentives, including:
● Self Generation Incentive Program (SGIP).
● Equitable Building Decarbonization Program (EBDB).
● California Electric Homes Program (CalEHP).
● California's Homeowner Managing Energy Savings Program (HOMES). ● High-Efficiency Electric Home Rebate Program (HEEHRA). ● TECH Clean California (TECH).
● Energy Savings Assistance (ESA) Multifamily Energy Savings program. ● GoGreen financing.
● IRA tax credits (e.g., Energy Efficient Home Improvement Credit and Clean Energy Tax Credit).

Categorization by Segment
Additional details on SDREN’s segmentation justification at the program-level can be found in Exhibit 3 - Program Segmentation Justification template Attachment A from D.23.06.055.

Table 42. Residential Sector Program Categorization by Segment Program Segment Justification
Residential Equity Program
(single-family)
Equity The primary goal of these programs is to provide energy efficiency services to hard-to-reach
customers and/or disadvantaged communities in
alignment with the Commission’s Environment and
Social Justice Action Plan.

Multi-Family Residential
(two or more units)
60 https://switchison.org/.
59 https://www.sdge.com/residential/savings-center/energy-saving-programs/res-program. 58 https://www.sdge.com/residential/pay-bill/get-payment-bill-assistance/. assistance-programs/no-cost-energy-efficient-home-improvements. 105
Residential Sector Program Details
Table 43. Program Card for Single Family
Program Name: Single Family
Program ID: SDREN-02-RES-SFM
New/Existing: New
Link to implementation plan if existing: N/A
Portfolio Segment: Equity Implementation Party: Third-party Implementer
Applicable Sector: Residential Market Sub-Sector: Detached, renter or owner-occupied single family residences
Sector Challenge:
● Residents often have limited
familiarity with and/or are confused
by existing EE and IDSM technologies,
programs, and service offerings.
● Capital intensive upgrades resulting
from deferred maintenance hinders
holistic projects and streamlined
program implementation.
● Difficulty establishing trust with HTR
customers and within underserved
communities.
● HTR and underserved communities
have historically faced disparities in
access to clean energy programs and
resources.
● Split incentives between renters and
property owners limit the
opportunities to reach
renter-occupied homes.
● Many single family homes have aging
infrastructure, which can be a barrier
to implementing energy efficient
technologies.
● Local regulations and permitting
requirements can be a major hurdle
for homeowners looking to make
energy-efficient improvements.

Navigating the bureaucracy and
securing the necessary approvals can
be time-consuming and frustrating.

Sector Opportunity:
● Partner with trusted CBOs and
community partners for customer
outreach to explain program
opportunities. These organizations
often have deep community
connections and can reach
underserved and hard-to-reach
populations.
● Focus on EE and IDSM offerings and
educational opportunities that result
in reduced energy costs and
non-energy benefits for residents.
● Support HTR and underserved
communities with early
decarbonization efforts. These
communities often bear a
disproportionate burden of
environmental and energy-related
challenges. Targeted support can
improve living conditions and energy
resilience of these customers.
● Pair program opportunities with
external programs for deeper savings
and incentive stacking.
● Provide no-cost installations through a
direct install offering.
106
● Homeowners may be resistant to
change, especially if they are
unfamiliar with or skeptical of new
energy efficient and IDSM
technologies.

Known Equity Concerns in the Selected
Markets: Single-family residents in HTR and
underserved communities often receive
limited outreach from EE programs. Shortfalls
in outreach can impede access to vital
resources and accessible funding, limiting
program participation. Programs often
remain inaccessible to community members
due to insufficient consideration of equity
and inclusion in outreach and educational
materials. The absence of culturally sensitive,
linguistically appropriate, and inclusive
materials exacerbates barriers to
participation, especially for non-English
speaking residents.

Additionally, residents’ busy schedules and
their need for personalized outreach and
program services through multiple mediums
further hinders HTR and underserved
community participation in EE programs.

Proposed Solutions to Equity Concerns: To
address equity concerns within the
residential sector, the program will
implement a multi-faceted approach that
includes an energy advisor service. Advisors
will be tasked with ensuring expanded access
to program services. Their role will
encompass technical guidance, community
outreach, and engagement.

To make information more accessible to all
community members, the program will
prioritize marketing materials that are
in-person, equitable, and inclusive. These
materials will be thoughtfully designed,
taking into consideration diverse needs such
as in-language content, cultural
understanding, accommodations for vision
and hearing impaired customers, etc.

Recognizing the importance of community
trust and engagement, the program will
partner with trusted CBOs and community
partners for outreach. By working alongside
organizations deeply rooted in the
community, the program can leverage
partners’ existing networks and credibility to
foster community trust and engagement.

Program Description: SDREN’S Single Family equity program will create a home energy advisor for residents that will serve as a personal concierge-style service to connect them to program information and funding and financing opportunities. The energy advisor will refer and connect residents to all eligible program resources and will act as a closed loop between participants and program service providers by coordinating with SDREN-supported contractors and contractors supporting other external programs. The program will offer a growing and evolving knowledge base to support participants.

This approach aims to increase program participation for HTR and underserved residents who would otherwise have limited access to these resources. To maximize accessibility for the community, the program will provide services through multiple mediums, including an online 107
platform with chat features, direct email correspondence to respond to participant questions and requests for information, and call centers.

The program’s support services will meet homeowner and renter needs. The program seeks to meaningfully engage with the renter community, a group historically left out of traditional energy programs, by offering a package of free energy efficiency upgrades (direct-install measures) for their homes. These upgrades will reduce residents’ energy consumption and lower their energy bills, and can complement other existing state programs aimed at reducing income-qualified resident utility bills, such as the Energy Assistance Savings program.

The energy advisor can support renters by working directly with property owners to advocate for upgrades at their properties. Rebates for additional energy efficiency measures will also be available. Targeted efficiency measures may include attic and wall insulation, LED lighting, duct testing and sealing, low-flow shower heads, and faucet aerators. The program will also focus on improving indoor air quality for residents through electrification by targeting heat pump water heaters, HVAC heat pumps, induction stoves, and heat pump clothes dryers. To support residents’ demand flexibility, the program will include smart thermostats to support demand response. The program will leverage local contractors for installations to stimulate the local economy and support local workforce development.

The program will provide energy efficiency kits and educational opportunities for renters and homeowners to create awareness of the benefits of energy conservation, energy efficiency, electrification, clean and renewable energy, DR program participation, and low-GWP refrigerants. Educational topics may include energy efficiency technologies and why they are eligible for incentives; topics may span a sample project scenario with stacked incentives and explanations of energy, financing, and policy-related terms (e.g. kilowatt hour, power purchase agreement, and governmental reach codes).

The program will provide equitable and inclusive marketing and outreach strategies to promote the energy advisor services to both renters and homeowners. It will partner with trusted CBOs and community partners for strategic outreach to explain available program opportunities to customers. The program will share specific information and materials for renters to help renters advocate for upgrades in their homes. The energy advisor can work with property owners directly to educate and advocate for upgrades on behalf of renters.

Intervention Strategy: Downstream –
Technical assistance, incentives (both rebates
and direct install), education, training, and
outreach.
● Personal support and coaching for
customers through an energy advisor
service that is accessible through
multiple mediums.
● Closed loop design for the customer
with a single source to provide
guidance and referrals to connect
Program Metrics:
● kWh
● Therms
● TSB
● GHG
● Number of outreach strategies
conducted
● Number of equity target participants
expressing interest via one or more
engagement channels
● Percent of disadvantaged community
and HTR customer participants
108
participants with relevant program
contractors.
● Equitable and inclusive outreach and
marketing materials.
● Educational materials including an EE
starter kit for customers.
● Direct install of selected EE measures.
● Rebates for selected EE measures that
can stack with, or meet gaps of, other
program rebate offerings.
● Number of and type of program
referrals provided by energy advisor
● Sum of equity target and non-equity
participants’ expected first-year bill
savings
● Sum of all participants’ greenhouse
gas reductions (in tons of carbon
dioxide equivalent; channeled)
● kWh channeled
● kW channeled
● Therms channeled
High-level description of delivery workforce including necessary scale and its risks:

SDREN staff, the program implementer staff, and the energy advisors will guide program participants through the SDREN residential program offerings and services, in partnership with subcontracted engineering consultants, CBOs, and community partners. Licensed local contractors, electricians, and equipment manufacturers will support the direct installation of energy efficiency measures. There are no known workforce related risks for successful implementation of the program, though a delay in manufacturing and delivery (or high demand) of equipment could pose a risk to project completion timelines.

Market actors necessary for success:
● Third party implementer(s).
● Trade professionals.
● Local contractors.
● Equipment manufacturers.
● Homeowners.
● Renters.
● Community based organizations and community outreach partners.

Solicitation Strategy: Third-party Solicited Transition Plan: Not applicable Expected Program Life: 2024 - Ongoing Short Term Plan: Launch program in 2024 and ramp up implementation through 2027.

Cost Effectiveness: 4-year TRC: 0.15 Long Term Outlook:
● HTR and underserved customers have
fair and equal access to energy
efficiency programs.
● HTR and underserved communities
leverage program resources and
incentives at an equal or greater rate
than customer base at large.

Proposed Annual Budgets for 2024-2027:
2024: $2,904,000
2025: $6,000,000
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
109
2026: $6,600,000
2027: $7,260,000
2024-2027 Total: $22,764,000
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Table 44. Program Card for Multifamily
Program Name: Multifamily
Program ID: SDREN-01-RES-MFM
New/Existing: New
Link to implementation plan if existing: N/A
Portfolio Segment: Equity Implementation Party: Third-party Implementer
Applicable Sector: Residential Market Sub-Sector: Multifamily buildings of two or more units.

Sector Challenge:
● HTR and underserved residents and
property owners often have limited
familiarity with existing EE and IDSM
technologies, programs, and service
offerings, especially electrification.
● Difficulty establishing trust with HTR
customers and within underserved
communities.
● Split incentives between renters and
property owners limit the
opportunities to reach
renter-occupied homes.
● No existing single-program solution to
meet the needs of a multifamily
dwelling.
● Local regulations and permitting
requirements can be major hurdles.
● Risks of tenant displacement as a
result of increased property values
and rising rents.

Sector Opportunity:
● Pair program opportunities with
external existing and emerging
programs for incentive stacking to
realize deeper savings and
decarbonization of multifamily
properties.
● Partner with trusted CBOs and
community partners for customer
outreach to explain program
opportunities.
● Focus on EE and IDSM offerings and
educational opportunities that result
in reduced energy costs and increased
non-energy benefits for residents.
● Reduce property owners’ energy and
operating costs to support
reinvestment into the building and
improve quality of life for tenants.
● Provide EE and IDSM education and
advisory services to property owners,
property management companies,
and tenants to address the split
incentive challenge.
110
● Provide no cost installations through a
direct install offering, with a focus on
electrification measures to support
HTR and underserved communities
decarbonize.
● Work to protect tenants from
potential increased rents that can
result from property investments.
● Coordinate directly with PAs and
implementers to apply the latest
lessons learned from other
multifamily programs prior to
implementation.

Known Equity Concerns in the Selected
Markets: Multi-family residents and property
owners in HTR and underserved communities
often receive limited outreach from EE
programs, which results in limited awareness
and knowledge of available energy program
services and potential benefits. Residents and
property owners also often hold the
perception that EE and IDSM measures are
too capital intensive to pursue; they may not
fully understand the savings benefits or
long-term payback considerations.

Programs may also be inaccessible to
community members due to insufficient
consideration of equity and inclusion in
program outreach and educational materials.

Proposed Solutions to Equity Concerns: To
make information more accessible to all
community members, the program will
prioritize marketing materials that are
in-person, equitable, and inclusive. These
materials will be thoughtfully designed,
taking into consideration diverse needs such
as in-language content, cultural
understanding, accommodations for vision
and hearing impaired customers, etc.

Recognizing the importance of community
trust and engagement, the program will
partner with trusted CBOs and community
partners for strategic outreach. By working
alongside organizations deeply rooted in the
community, the program can leverage their
existing networks and credibility to foster
community trust and engagement.

Program Description: SDREN’s Multifamily program will target multi-family property owners/managers as well as tenants to address facility upgrades that impact both common area maintenance (CAM) and renter-specific in-unit utility bill savings.

For property owners and property managers, the program will provide customizable engagement strategies tailored to the decision-maker for property upgrades. The program will promote benefits such as energy bill savings, operating cost savings, return on investment, and increased property value, as well as non-energy benefits such as health and comfort. The program will also offer technical assistance to property owners and managers in the form of un-biased program staff support throughout the project lifecycle. This turnkey service will 111
engage decision-makers in energy upgrade decisions and ensure that projects achieve their intended energy cost savings and benefits.

The program will offer a systems tune-up assessment as an outreach strategy that will identify “quick-win” savings with project payback of less than two years. Building upgrades will be focused on impacts to CAM areas by providing energy audits to identify opportunities for energy efficiency measures. Recommended upgrades will be presented to the property owner or manager alongside corresponding costs, savings, and financial metrics. The program will offer rebates that can be stacked onto other applicable utility, regional, state, or federal program incentives, and will also provide financial resources to help secure external funding and financing, including for IDSM opportunities. Property owners and managers will receive guidance on state and municipal building code requirements and compliance, including reach codes and any upcoming Title 24 updates, to help guide upgrade decisions. Additionally, the program will offer unbiased reviews of contractor quotes to help make a contractor selection.

Specific to renters, the program seeks to meaningfully engage with the renter community—a group historically left out of traditional energy programs—by offering a package of free energy efficiency upgrades (direct install measures) for their residences. These upgrades will reduce residents’ energy consumption and lower their energy bills, and can complement other existing state programs aimed at reducing income-qualified resident utility bills, such as the Energy Assistance Savings program. Rebates for additional energy efficiency measures will also be available. Targeted efficiency measures include attic and wall insulation, LED lighting, duct testing and sealing, low-flow shower heads, and faucet aerators. The program will also focus on improved indoor air quality for residents through electrification by targeting heat pump water heaters, induction stoves, heat pump clothes dryers. The program will target smart thermostats to support demand response and demand flexibility for residents. The program will leverage local contractors for installations to stimulate the local economy and support local workforce development.

The program will provide energy efficiency kits and educational opportunities for renters to create awareness of the benefits of energy conservation, energy efficiency, electrification, clean and renewable energy, DR program participation, and low-GWP refrigerants.

Educational topics may include energy efficiency technologies, why the technologies are eligible for incentives, a sample project scenario with stacked incentives, and energy, financing, and policy-related terms.

The program aims to improve multi-family facilities while protecting tenants from potential increased rents that can result from property investments. As such, the program will partner with CBOs and trusted community partners with subject matter expertise alongside local municipalities to create awareness of existing and help inform new anti-displacement policies.

An informed and community approach to anti-displacement policies will create a network involving tenants, property owners, and community partners where feedback is shared and incorporated, allowing all stakeholders to participate and prioritize the overall needs and long-term shared vision for the community.
112
Intervention Strategy:

Downstream – Technical assistance,
incentives (both rebates and Direct Install),
education, training, and outreach.
● Personal project support for property
owners and managers through
turnkey technical assistance.
● Equitable and inclusive outreach and
marketing materials, targeted and
customized to property owners,
managers, and tenants.
● Educational materials, including an EE
starter kit for customers.
● Direct install of selected EE measures.
● Rebates for selected EE measures that
can stack with, or meet gaps of, other
program rebate offerings.

Program Metrics:
● kWh
● Therms
● TSB
● GHG reductions
● Number of EE kits delivered to
participants
● Number of system tune-up
assessments delivered
● Number of outreach strategies
conducted
● Number of equity target participants
expressing interest via one or more
engagement channels
● Percent of disadvantaged community
and HTR customer participants
● Number of and type of program
referrals
● Sum of equity target and non-equity
participants’ expected first-year bill
savings
● Number of partners engaged
High-level description of delivery workforce including necessary scale and its risks: SDREN staff and the program implementer staff will guide program participants through the SDREN residential program offerings and services in partnership with subcontracted engineering consultants, CBOs, and other community partners. Licensed local contractors, electricians, and equipment manufacturers will support the direct installation of energy efficiency measures. There are no known workforce related risks to the successful implementation of the program, though a delay in manufacturing and delivery (or high demand) of equipment could pose a risk to project completion timelines. Additional partners and stakeholders not under contract may include trade associations, chambers of commerce, and municipalities.

Market actors necessary for success:
● Third party implementer(s).
● Trade professionals.
● Local contractors.
● Equipment manufacturers.
● Community based organizations and community outreach partners. ● Property owners.
● Property managers.
● Tenants.

Solicitation Strategy: Third-party Solicited Transition Plan: Not applicable 113
Expected Program Life: 2024 - Ongoing Short Term Plan: Launch program in 2024 and ramp up implementation through 2027.

Cost Effectiveness: 4-year TRC: 0.12 Long Term Outlook:
● HTR and underserved customers,
specifically renters, have fair and
equal access to programs.
● HTR and underserved communities
leverage program resources and
incentives at an equal or greater rate
than customer base at large.
● Property owners and property
managers are aware of program
offerings and resources and have the
policies to support energy efficiency
upgrades.

Proposed Annual Budgets for 2024-2027:
2024: $1,549,000
2025: $3,200,000
2026: $3,520,000
2027: $3,872,000
2024-2027 Total: $12,141,000
Anticipated directional and scale changes in
budget for years 2028-2031: SDREN will
continue to maintain program steady-state
beyond 2027. For years 2028-2031, budgets
will increase at a moderate 4% to address
inflation and to meet increasing customer
demand.

Implementation Plan: Implementation Plans for all SDREN programs will be developed after CPUC approval of SDREN’s application and before implementation begins.

Portfolio Management
Strategies to Optimize Portfolio and Manage Risk
A comprehensive set of goals and metrics, as outlined in this Business Plan and Portfolio Application, is central to SDREN’s strategy for optimizing its portfolio. SDREN’s approach to integrate these goals and metrics into our portfolio management is guided by several key strategies, as detailed below.

Establishing a Strong Foundation through Systems and Tracking: We recognize the critical importance of robust tracking and reporting systems to maintain a comprehensive record of program participation and results. These systems will ensure that all aspects of our portfolio are systematically monitored and evaluated. This foundational approach will allow us to maintain transparency, accountability, and a complete understanding of the impact of our programs.

Regular Access to Metrics and Progress: To ensure that our portfolio remains dynamic and adaptable, we will develop data systems capable of generating automated reports for reporting and analysis. This real-time performance tracking will provide us with up-to-date insights into 114
the progress of our programs. It allows us to promptly identify successes and challenges, offering opportunities for continuous improvement. This timely feedback loop will benefit both SDREN and our program implementers, empowering us to make informed decisions and adjust strategies as needed, while also informing our future planning activities.

Prioritization of Goals and Metrics that are Clearly Understood: We recognize that clarity is paramount in our goal-setting and metric selection. Prioritizing goals and metrics that are clearly understood by all stakeholders involved ensures that everyone is working toward a common purpose. This clear understanding fosters alignment and shared commitment to achieving the desired outcomes.

Adaptability and Adjustment to New Metrics and Goals: Our portfolio approach will remain nimble in order to adapt to any new metrics and goals as directed by the CPUC. We will also adjust targets based on evolving market trends or the unique needs of local communities. This adaptability ensures that our programs remain responsive to changing circumstances and are well positioned to achieve their objectives.

Goal Setting and Regular Progress Reporting from Implementers: Our strategy places strong emphasis on goal setting and regular progress reporting by our program implementers. SDREN will set regular reporting schedules while also adhering to any CPUC reporting timelines and requirements. Regular reflection on progress toward programmatic goals will ensure that all stakeholders are informed of successes and challenges, which can open dialogue to pivot and/or enhance implementation activities.

Adjustments to Programs to Optimize Delivery of Goals and Priority Metrics: SDREN seeks to optimize the delivery of goals. Strategies that may be implemented to accomplish this aim include modifying program strategies, reallocating resources, or introducing new initiatives to ensure that we are consistently on track to achieve our targets, while continuing to ensure programs comply with REN CPUC directives.

Our approach to using goals and metrics for portfolio optimization is built upon a foundation of systematic tracking, regular reporting, and evaluation of progress. These strategies ensure that we are not only meeting our goals but are also continuously refining and enhancing our programs to maximize their impacts.

How SDREN Will Stay On-Target
As described above, SDREN recognizes the importance of establishing systems and procedures for tracking and reporting to monitor portfolio progress and ensure it stays on track to achieve its targets. One key element of these plans involves SDREN’s implementation of a customer relationship management (CRM) software platform. SDREN’s CRM will track progress across all SDREN programs. This platform will form the backbone for collecting, storing, and managing data related to program targets. Further, third party implementers will be expected to use their own tracking databases when appropriate; their data will be shared with SDREN for upload and import to their internal CRM.

To oversee data collection and reporting, a dedicated reporting lead will collaborate closely with program implementers. The lead will be responsible for coordinating the data collection efforts 115
across various programs, ensuring that data is collected accurately and in a timely manner, while ensuring adherence to any CPUC reporting requirements.

SDREN is committed to ongoing assessment and analysis of portfolio reports. These reports will be broken down by sector, segment, and individual program, enabling a granular evaluation of performance. The reports will cover key performance metrics and status, including but not limited to energy savings, Total Resource Cost (TRC), and Total Societal Benefit (TSB), among others. Continuous assessment will ensure that the program is informed of progress and allows for timely identification of potential areas of concern. Any targets appearing to be at risk of not meeting the 4-year portfolio goals will be promptly flagged. SDREN will subsequently initiate a structured process and request that implementers develop a corrective action plan that specifies the actions, strategies, and resources needed to get the targets back on track.

Approach to Risk Management
As the threat of climate change looms, it is imperative for any program portfolio to have a risk management strategy in place. The San Diego region, like many others in the state, has faced a range of unpredictable events, including pandemics, wildfires, flooding, and droughts. These occurrences have underscored the necessity of proactive planning for unforeseen challenges.

As a CCA, SDCP is familiar with the risks and liabilities associated with handling customer data.

SDREN will leverage SDCP’s experience and customer data confidentiality policy to protect customer information and mitigate the risk of data breaches.

The County of San Diego’s Office of Sustainability and Environmental Justice (OSEJ) is a PA of SDREN. This relationship equips SDREN to conduct region-wide assessments following any unpredictable event. Through these assessments, we can swiftly gauge the impacts of events such as natural disasters or crises, enabling SDREN to make data-informed decisions on program adjustments and resource allocations. SDREN is also able to quickly coordinate with SDG&E in these circumstances so resources can be mutually mobilized as needed.

While unpredictable events can present challenges, they also create opportunities for targeted and creative solutions. Such events may lead to increased program participation as communities seek solutions to address their immediate needs. SDREN is positioned to identify and implement approaches that address the evolving priorities of our stakeholders and provide value during times of crisis.

SDCP was not administering customer programs during COVID as SDCP officially launched its service and began enrolling customers in March of 2021. Although SDCP was not administering programs during COVID, best practices were adopted that will be applied to SDCP’s management approach. The COVID-19 pandemic demonstrated the importance of adaptability, resilience, and community focused solutions including:
● Similar to other agencies, to limit the spread of COVID-19 SDCP adopted best practices like remote work which has remained post COVID.
● Taking measures to avoid any breakdowns in IT security. ● Staff are equipped with tools to be able to work collaboratively. 116
The County of San Diego has developed a robust COVID-19 response that is rooted in health equity. Through data examination, the County identified disparities among race/ethnic groups, age, zip code and other factors. This data helped to inform strategies to ensure equity.

Components of the County’s COVID-19 response include the Test, Trace, Treat (T3) strategy, a large-scale public health strategy which uses collaborative effort to achieve collective impact in protecting the public’s health and ensuring the continuity of such protection throughout all stages of the region’s reopening. The T3 Strategy includes accessible COVID-19 testing, culturally competent disease investigation, and assistance with safe isolation with individualized services.

Throughout all COVID-19 response activities, multiple strategies have been employed including:
● A focus on equity.
● Early, active, and sustained engagement of community partners. ● Utilization of scientific evidence and data.
● Proactive transparency and communication.
● Clear goals and measurable results.
● Culturally responsive hiring and staffing practices.

Approach to Flexible Portfolio Management
SDREN has set forth clear high-level goals and crafted portfolio, segment, and sector-specific strategies to deliver outcomes that align with our overarching vision. As a smaller non-IOU program administrator, SDREN is well positioned to respond to unexpected events or market adjustments, enabling us to remain agile in the face of change.

Drawing lessons from other regional energy networks that have showcased their ability to remain nimble and adjust program offerings, incentives, or open and close programs to respond to market changes, SDREN is similarly committed to managing our portfolio, segments, and sectors with adaptability in mind. Our primary focus will be on overall management across different levels, ensuring that each program contributes to our overall vision and adheres to SDREN’s core values.

San Diego Community Power, serving as the lead program administrator, will oversee, manage and regularly assess if adjustments are necessary within the portfolio to properly manage portfolio, sector or segment level outcomes. These assessments will occur via forecasts, tracking and regular evaluation of outcomes, and review of schedules and costs against established forecasts. SDREN’s Advisory Committee, made up of local and regional governments, and community based organizations will also provide feedback on these assessments and recommend portfolio enhancements. SDREN will consider forming sector-specific ad hoc committees that include subject matter experts who will be informed on program assessments.

These experts will guide and advise sector strategies to ensure alignment with the overarching portfolio vision.

SDREN will monitor market trends and emerging opportunities to identify where SDREN could effectively fill gaps. This includes any changes to the SDG&E EE portfolio, such as the closing of a third party program. SDREN will regularly coordinate with SDG&E on opportunities to fill gaps, 117
including opportunities to develop offerings that leverage additional programs or funding opportunities for San Diego communities. If an issue or opportunity is identified, SDREN will work collaboratively with appropriate partners to make adjustments to scopes, budgets or schedules to meet the portfolio’s needs. This adaptability extends to the closing or developing of new programs as circumstances dictate. All of these activities will focus on both administrative efficiency and portfolio effectiveness.

Planned Procedures and Course Correction if Off-Track
As detailed above and in Exhibit 1, San Diego Community Power will oversee the SDREN portfolio, taking responsibility for both the oversight and management of goals and outcomes, including key metrics. While it’s important to note that as a regional energy network, SDREN is not subject to specific cost-effectiveness requirements, we are committed to managing the portfolio to deliver on key metrics. These metrics include TSB, SDREN’s unique value metrics, and program specific metrics, all of which will be achieved within budget over the 4-year program period. We also recognize that joint program administrators will be filing a joint Advice Letter by March 25, 2024, which is intended to support the adoption of common long-term market support and equity goals and associated metrics. SDREN intends to engage in this process, since the majority of SDREN’s portfolio falls within the equity and market support segments. Once these goals and metrics are finalized, SDREN will also oversee progress toward their achievement.

All programs will be implemented by third party implementers, so when metrics are off track, SDCP will work closely with the implementer to course correct and ensure that goals are achieved. Specific thresholds necessitating corrective actions will be determined depending on the priority of the goal itself. These thresholds will be individually established in each program’s manual once the portfolio is approved and programs are launched. In the event that SDREN’s portfolio, segment, or programs are noted to be off target based on the regular assessments described in the section above, SDREN will engage its implementer(s) to develop a corrective action plan. SDREN will embed guidance into its contractual documents with each implementer that will specify and outline procedures for the implementer to initiate the plans. Once reviewed and approved, the implementer will put the plan into action and the issue will be monitored until it is resolved. As appropriate, SDREN will engage the Advisory Committee and sector specific ad hoc committees on the proposed improvement plan for feedback and guidance.

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