AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER AGENDA
Regular Meeting of the Board of Directors of
San Diego Community Power (Community Power)
Thursday, May 22, 2025
5:00 p.m.
Don L. Nay Port Administration Boardroom
3165 Pacific Hwy.
San Diego, CA 92101
The meeting will be held in person at the above date, time and location(s). Members of the Board of Directors 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, Community Power 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 speakers provide their 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 a 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. 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 to [email protected]. Please indicate a specific agenda item when submitting your comment. All written comments received prior to the meeting will be provided to Members of the Board. In the discretion of the Chair, the first ten (10) submitted comments shall be stated into the record of the meeting. 1 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 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 Members of Board, and be part of the public record.
If members of the public wish to have documentation be distributed to the Board, please send it to [email protected].
The public may participate using the following remote options:
Teleconference Meeting Webinar https://sdcommunitypower-org.zoom.us/j/94274587066 Telephone (Audio Only) (669) 900-6833 or (346) 248-7799 | Webinar ID: 94274587066
CALL TO ORDER
ROLL CALL
PLEDGE OF ALLEGIANCE
REPORT ON CLOSED SESSION
SPECIAL PRESENTATIONS AND INTRODUCTIONS
• Introduction of New Community Power Staff
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. Approve April 24, 2025, Meeting Minutes
2. Receive and File Treasurer’s Report for Period Ending March 31, 2025
3. Receive and File Update on Programs
2 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER
4. Receive and File Update on Power Services
5. Receive and File Update on Customer Operations
6. Receive and File Update on Human Resources
7. Receive and File Update on Marketing, Public Relations, and Local Government Affairs
8. Receive and File Update on Regulatory and Legislative Affairs
9. Receive and File Community Advisory Committee Monthly Report
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.
10. Community Advisory Committee Report
Recommendation: Receive and file the Community Advisory Committee (CAC) Quarterly Report.
11. Presentation of Draft of FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan
Recommendation: Receive and File Preliminary Draft of FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan.
12. Approve Amended and Restated Renewable Power Purchase Agreement with Pelicans Jaw Solar, LLC
Recommendation: Approve the proposed Second Amended and Restated Power Purchase Agreement with Pelicans Jaw Solar, LLC to modify the Commercial Operation Date (“COD”), adjust pricing based on COD, and make additional minor amendments, and authorize the Chief Executive Officer to execute the agreement.
13. Approve Amended and Restated Power Purchase Agreement with Noble Solar, LLC
Recommendation: Approve the proposed Second Amended and Restated Power Purchase Agreement with Noble Solar, LLC to amend the Commercial Operation Date (“COD”), increase the security and pre-COD liabilities, and make additional minor amendments, and authorize the Chief Executive Officer to execute the agreement. 3 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER
14. Approve EEI Master Agreement, Confirmation and Collateral Annex with Clean Power Alliance of Southern California
Recommendation: Approve the proposed Edison Electric Institute (EEI) Master Power Purchase and Sale Agreement (Master Agreement), 10-year EEI Confirmation, and associated Paragraph 10 Collateral Annex with Clean Power Alliance of Southern California (CPA), referred to herein collectively as “VAMO Swap Agreements” or “VAMO Swap”, in substantially final form for California RPS-eligible electric energy and associate Green Attributes, and authorize the Chief Executive Officer to execute the agreements.
CHIEF EXECUTIVE OFFICER REPORT
Community Power Management may briefly provide information to the Board and the public. The Board may engage in discussion if the specific subject matter of the report is identified below, but the Board may not take any action other than to place the matter on a future agenda. Otherwise, there is to be no discussion or action taken unless authorized by law.
DIRECTOR COMMENTS
Board Members may briefly provide information to other members of the Board and the public, ask questions of staff, request an item to be placed on a future agenda, or report on conferences, events, or activities related to Community Power business. There is to be no discussion or action taken on comments made by Directors unless authorized by law.
CLOSED SESSION
1. PUBLIC EMPLOYEE PERFORMANCE EVALUATION PURSUANT TO
GOVERNMENT CODE SECTION 54957
Title: Chief Executive Officer
Title: General Counsel
2. CONFERENCE WITH LABOR NEGOTIATORS PURSUANT TO GOVERNMENT CODE SECTION 54957.6
Agency designated representative(s): Paula de Sousa, Best Best & Krieger Unrepresented employee: Chief Executive Officer and General Counsel
OPEN SESSION
ROLL CALL
REPORT ON CLOSED SESSION
4 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER
ADJOURNMENT
The San Diego Community Power Board of Directors will adjourn to a regular meeting scheduled on Thursday, June 26, 2025, at 5 pm.
Compliance with the Americans with Disabilities Act
San Diego Community Power 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 San Diego Community Power, P.O.
BOX 12716, San Diego, CA 92112. The documents may also be posted on Community Power’s website. Such public records are also available for inspection, by contacting [email protected] to arrange an appointment. 5 SAN DIEGO COMMUNITY POWER (COMMUNITY POWER)
BOARD OF DIRECTORS
Don L. Nay Port Administration Boardroom
3165 Pacific Hwy.
San Diego, CA 92101
REGULAR MEETING MINUTES
April 24, 2025
______________________________________________________________________
WELCOME
CALL TO ORDER
Chair Aguirre called the Community Power Board of Directors regular meeting to order at 5:00 p.m.
ROLL CALL
PRESENT: Chair Aguirre, City of Imperial Beach; Vice Chair Lawson-Remer, County of San Diego (arrived at 5:10 p.m.); Alternate Director LaCava, City of San Diego; Director Inzunza, City of Chula Vista; Director San Antonio, City of Encinitas (arrived at 5:10 p.m.); Director Suzuki, City of La Mesa; and Director Yamane, City of National City
ABSENT: None
Staff Present: Chief Executive Officer Burns; Chief Commercial Officer Vosburg; General Counsel Tyagi; Director of Regulatory & Legislative Affairs Fernandez; Senior Policy Manager Cissna; Regulatory Manager Gunther; Senior Strategic Policy Manager Kinports; Senior Legislative Manager Welch; Program Manager Lomeli; Clerk of the Board Hernandez; and Assistant Clerk of the Board Vences
PLEDGE OF ALLEGIANCE
Chair Aguirre led the Pledge of Allegiance.
6 SPECIAL PRESENTATIONS AND INTRODUCTIONS
• Introduction of New Community Power Staff
Chair Aguirre welcomed new employees Cody Harrison, Senior Program Associate, Jeb Spengler, Strategic Finance Manager, and Marlene Maurer to introduce themselves.
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
1. Approve March 27, 2025, Meeting Minutes
2. Receive and File Treasurer’s Report for Period Ending February 28, 2025
3. Receive and File Update on Programs
4. Receive and File Update on Power Services
5. Receive and File Update on Customer Operations
6. Receive and File Update on Human Resources
7. Receive and File Update on Marketing, Public Relations, and Local Government Affairs
8. Receive and File Community Advisory Committee Monthly Report There were no public comments on Consent Item Nos. 1-8.
Motioned by Director Inzunza and seconded by Director Yamane to approve Consent Calendar Item Nos. 1 through 8. The motion carried 5/0 as follows:
AYES: Chair Aguirre, Directors Inzunza, Suzuki, Yamane, and Alternate Director LaCava
NOES: None
ABSTAINED: None
ABSENT: Vice Chair Lawson-Remer and Director San Antonio 7 REGULAR AGENDA
9. Quarterly Update on Regulatory and Legislative Affairs Ms. Fernandez introduced the item and turned it over to Mr. Welch, Ms. Cissna, Mr.
Kinports, and Mr. Gunther to provide the update on Regulatory and Legislative Affairs.
There were no public comments on Item No. 9.
After Board member questions, discussion and comments, the quarterly update on Regulatory and Legislative Affairs was received and filed.
10. Adopt Resolution No. 2025-03, Authorizing the Chief Executive Officer to: (1) Execute the Memorandum of Understanding (“MOU”) in Substantially Final Form with Los Angeles County, through its Internal Services Department and to Negotiate and Execute any Amendments, Extensions or Renewals of the MOU; (2) Accept, Appropriate, and Expend the Equitable Building Decarbonization (“EBD”) Funds in an Amount not to exceed $1,409,316 in the FY 2025-26 Capital Budget and FY 2025-29 Capital Investment Plan; and (3) Take all Necessary Action to Administer, Monitor, Manage and Ensure Compliance with the MOU and to Negotiate and Execute Agreements with Third-Parties to Implement the MOU or Use of Funds in Accordance with Applicable Policies, Including the Procurement Policy
Mr. Lomeli presented an overview of Memorandum of Understanding with Los Angeles County for Equitable Building Decarbonization.
There were no public comments on Item No. 10.
After Board member questions, discussion and comments, Vice-Chair Lawson-Remer motioned and seconded by Director Yamane to adopt Resolution No. 2025-03, Authorizing the Chief Executive Officer to: (1) Execute the Memorandum of Understanding (“MOU”) in substantially final form with Los Angeles County, through its Internal Services Department and to negotiate and execute any amendments, extensions or renewals of the MOU; (2) accept, appropriate, and expend the Equitable Building Decarbonization (“EBD”) funds in an amount not to exceed $1,409,316 in the FY 2025- 26 Capital Budget and FY 2025-29 Capital Investment Plan; and (3) take all necessary action to administer, monitor, manage and ensure compliance with the MOU and to negotiate and execute agreements with third-parties to implement the MOU or use of funds in accordance with applicable policies, including the Procurement Policy. The motion carried unanimously as follows:
AYES: Chair Aguirre, Vice Chair Lawson-Remer, Directors Inzunza, San Antonio, Suzuki, Yamane, and Alternate Director LaCava
NOES: None
8 ABSTAINED: None
ABSENT: None
11. Updates to San Diego Community Power Board and Committee Compensation and Reimbursement Policy
Chair Aguirre presented updates to the Board and Committee Compensation and Reimbursement Policy.
After Board member discussion, Director Yamane motioned and seconded by Director Inzunza to adopt Resolution No. 2025-04, amending San Diego Community Power Board and Committee Compensation and Reimbursement Policy (“Policy”) to increase the per diem compensation for advisory committee members; increase the cap on monthly per diem compensation for members who sit on more than one Board, Committee, or Working Group; allow committee members to receive a per diem for activities attended on behalf of Community Power, including outreach. The motion carried with six affirmative votes with one abstention as follows:
AYES: Chair Aguirre, Directors Inzunza, San Antonio, Suzuki, Yamane, and Alternate Director LaCava
NOES: None
ABSTAINED: Vice-Chair Lawson-Remer
ABSENT: None
CHIEF EXECUTIVE OFFICER REPORT
Ms. Burns reported on Community Power’s ongoing efforts and recent activities and events. She announced Mr. Vosburg’s departure, thanked him for his contributions, and congratulated him on his next journey.
DIRECTOR COMMENTS
Directors shared updates on their ongoing efforts within their respective member agencies, and thanked Community Power staff.
Chair Aguirre expressed appreciation to Mr. Vosburg for his contributions.
Mr. Vosburg shared remarks on his journey with Community Power. 9 ADJOURNMENT
The Board of Directors adjourned at 6:27 p.m. to the next regular meeting scheduled for Thursday, May 22, 2025, at 5 p.m.
_____________________________
Maricela Hernandez, MMC, CPMC
Clerk of the Board
10 SAN DIEGO COMMUNITY POWER
Staff Report – Item 2
____________________________________________________________________________________ TO: Board of Directors
FROM: Dr. Eric W. Washington, Chief Financial Officer/Treasurer VIA: Karin Burns, Chief Executive Officer
SUBJECT: Treasurer’s Report for Period Ending March 31, 2025 DATE: May 22, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and File Treasurer’s Report for Period Ending March 31, 2025.
BACKGROUND:
San Diego Community Power (Community Power) maintains its accounting records on a full accrual basis in accordance with Generally Accepted Accounting Principles (GAAP) as applicable to governmental enterprise funds. Community Power has prepared its year-to-date financial statements for the nine-month period ended March 31, 2025, along with budgetary comparisons.
Additionally, on May 25, 2023, the Community Power Board of Directors (Board) adopted the Community Power Investment Policy, which was subsequently revised on June 27, 2024. The objectives of the Investment Policy are to (1) safeguard the principal of investment funds, (2) meet the liquidity needs of Community Power, (3) achieve a return on funds invested, and (4) exercise a high standard of care on investment funds. The Investment Policy additionally includes provisions for regular reporting to the Financial and Risk Management (FRMC) which will be included in the Treasurer’s Report.
In an effort to increase public transparency and in alignment with section 1.a of the Community Power Delegated Contract Authority Policy, Community Power will also report newly executed contracts between $50,000 and $125,000 for goods and services in the Treasurer’s Report.
Community Power 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 presented during Financial and Risk Management Committee (FRMC) meetings.
11 On June 27, 2024, the Community Power Board of Directors (Board) approved the Fiscal Year 2024-25 Operating Budget that included net operating revenues of $1,177,925,889 total expenses of $1,143,919,262 and a resulting net position of $34,006,627. The approved Fiscal Year 2024-25 budget also includes a capital budget to fund 16 projects, totaling 23 active projects during the fiscal year for $16,434,280.
Subsequently, on February 27, 2025, the Board approved an amendment to the FY 2024- 25 Operating Budget to increase total net operating revenues to $1,221,258,172 and total expenses to $1,187,090,169, resulting in a net position of $34,168,003. Additionally, the Board approved an amendment to the FY 2024-25 Capital Budget to increase total expenses to $144,212,340 and an amendment to the FY 2025-29 Capital Investment Plan (CIP) to $155,910,762.
ANALYSIS AND DISCUSSION:
Financial Results
Actual financial results for the period ended March 31, 2025: $965.0 million in net operating revenues were reported compared to $967.1 million budgeted for the period. $933.0 million in total expenses were reported (including $894.7 million in energy costs) compared to $964.7 million budgeted for the period (including $907.4 million budgeted for energy costs). After expenses, Community Power’s change in net position of $31.9 million was reported year-to-date for Fiscal Year 2024-25. The following is a summary of the actual results compared to the Fiscal Year 2024-25 Amended Budget.
Table 1: Budget Comparison Versus Actual Result
• Net operating revenues finished $2.0 million (or 0.2 percentage points) under the budget and was largely in line with expectations.
• Operating expenses finished $31.6 million (or 3.0 percentage points) under the budget due to the lower unhedged volume energy prices. In addition to substantial invoices that are scheduled for future payment.
YTD FY25 as of
3/31/25 (9 months)
FY25 YTD Budget
Amended
Budget Variance
($) Budget (%)
Net Operating Revenues $ 965,031,942 $ 967,110,664 $ (2,078,722) 99.8% Total Expenses $ 933,057,887 $ 964,689,480 $ (31,631,593) 97% Change in Net Position $ 31,974,055 $ 2,421,184 $ 29,552,871 Budget Comparison
12 Figure 1: Budget Comparison versus Actual Results
For the Nine-month period ending March 31, 2025, Community Power contributed $31,974,055 to its net position compared to the expected contribution of $2,421,184 per the Fiscal Year 2024-25 budget. Total Community Power reserves at the end of the period were $319,127,244 based on cash and cash equivalents – unrestricted, and total available liquidity (including lines of credit) was $531,627,244. Community Power has a total Fiscal Year 2024-25 year-end reserve target of $575,822,041 which is equivalent to 180-days of total operating expenses as set in Community Power’s Reserve Policy and Strategic Goals
Investment Portfolio Report
Chandler Asset Management manages Community Power’s investment portfolio. As of March 31, 2025, the market value of the portfolio was $61.4 million compared to the $51.1 million market value as February 28, 2025. The rise in market value is also reflective of an additional $10.0 million transferred into the investment account and accrued interest during the month. The following is a snapshot of overall characteristics of the portfolio. $-
$200,000,000
$400,000,000
$600,000,000
$800,000,000
$1,000,000,000
$1,200,000,000
Net Operating Revenues Total Expenses Change in Net Position YTD FY25 Results v. Budget
YTD FY25 as of 3/31/25 (9 months) FY25 YTD Budget Amended 13 Contract Execution between $50,000 and $125,000
In April 2025, Community Power executed an Agreement with the San Diego Wave Fútbol Club for $95,600 for a 2025 Local Sponsorship Agreement. 14 Metrics
Figure 2: Participation Rates as of 5/1/2025
The Phase 4 mass enrollment process in National City and Unincorporated County of San Diego for Non-Net Energy Metering (NEM) customers was officially completed as of May 2023. The participation rate for Community Power reflects full enrollment of current member agencies. 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 the state of Community Power Arrearages related to financial risk for FRMC consideration and for regular review. Additional metrics can be added by request. The below arrearage data includes Community Power’s Receivables aged 120+ Days as of May 1, 2025.
15 Figure 3: State of Community Power Arrearages as of 5/1/2025 Figure 4: State of Community Power Arrearages Residential vs Commercial as of 5/1/2025 FISCAL IMPACT:
N/A
ATTACHMENTS:
A: 2025 Year-to-Date Period Ended March 31, 2025, Financial Statements. 16 ITEM 2
ATTACHMENT A
17 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 March 31, 2025, and the related statement of revenues, expenses, and changes in net position, and the statement of cash flows for the nine months then ended in accordance with accounting principles generally accepted in the United States of America. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the accompanying statements nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, we do not express an opinion, conclusion, nor provide any assurance on these financial statements.
Management has elected to omit substantially all of the 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
May 9, 2025
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com 18 Current assets
Cash and cash equivalents - unrestricted 319,127,244$
Cash and cash equivalents - restricted 14,233,326
Accounts receivable, net of allowance 102,423,140
Accrued revenue 45,001,796
Prepaid expenses 2,043,913
Other receivables 15,687,109
Deposits 9,977,229
Investments 2,302,943
Total current assets 510,796,700
Noncurrent assets
Cash and cash equivalents - restricted 647,000
Investments 53,600,114
Capital assets, net of depreciation and amortization 1,606,134 Total noncurrent assets 55,853,248
Total assets 566,649,948
Current liabilities
Accrued cost of electricity 120,455,365
Accounts payable 4,325,683
Other accrued liabilities 1,653,883
State surcharges payable 588,526
Deposits - energy suppliers 3,313,000
Lease liability 780,689
Advances from grantors 13,733,326
Total current liabilities 144,850,472
Noncurrent liabilities
Lease liability 820,498
Deposits - energy suppliers 4,410,450
Total noncurrent liabilities 5,230,948
Total liabilities 150,081,420
Restricted for security collateral 14,880,326
Unrestricted 401,688,202
Total net position $ 416,568,528
NET POSITION
SAN DIEGO COMMUNITY POWER
STATEMENT OF NET POSITION
As of March 31, 2025
ASSETS
LIABILITIES
See accountants' compilation report. 2
19 OPERATING REVENUES
Electricity sales, net $ 963,788,684
Grant revenue 1,150,491
Other income 1,243,258
Total operating revenues 966,182,433
OPERATING EXPENSES
Cost of electricity 894,737,509
Contract services 14,954,668
Staff compensation 12,007,013
Other operating expenses 12,196,668
Depreciation and amortization 437,763
Total operating expenses 934,333,621
Operating income 31,848,812
NON-OPERATING REVENUES (EXPENSES)
Investment income 9,768,364
Interest expense (431,030)
Nonoperating revenues (expenses), net 9,337,334
CHANGE IN NET POSITION 41,186,146
Net position at beginning of year 375,382,382
Net position at end of year $ 416,568,528
SAN DIEGO COMMUNITY POWER
STATEMENT OF REVENUES, EXPENSES
AND CHANGES IN NET POSITION
Nine Months Ended March 31, 2025
See accountants' compilation report. 3
20 CASH FLOWS FROM OPERATING ACTIVITIES
Receipts from customers $ 998,621,781
Receipts from grantors 14,883,817
Receipts of supplier security deposits 15,187,455
Other operating receipts 1,221,064
Payments to suppliers for electricity (907,248,507)
Payments for other goods and services (27,588,597)
Payments for deposits and collateral (1,924,371)
Payments for staff compensation (11,534,492)
Payments of state surcharges (1,822,861)
Net cash provided by operating activities 79,795,289
CASH FLOWS FROM NONCAPITAL FINANCING ACTIVITIES
Proceeds from bank note 55,500,000
Principal payments - bank note (55,500,000)
Interest payments (393,961)
Net cash provided (used) by noncapital
financing activities (393,961)
CASH FLOWS FROM CAPITAL AND RELATED
FINANCING ACTIVITIES
Payments of lease liability (489,102)
Net cash used by capital and related financing activities (489,102)
CASH FLOWS FROM INVESTING ACTIVITIES
Investment income received 8,852,908
Proceeds from investment sales and maturities of investments 642,757 Purchase of investments (55,842,431)
Net cash provided (used) by investing activities (46,346,766) Net change in cash and cash equivalents 32,565,460
Cash and cash equivalents at beginning of year 301,442,110 Cash and cash equivalents at end of year $ 334,007,570
Reconciliation to the Statement of Net Position
Cash and cash equivalents (unrestricted) $ 319,127,244
Restricted cash - current 14,233,326
Restricted cash - noncurrent 647,000
Cash and cash equivalents $ 334,007,570
NONCASH INVESTING ACTIVITIES
Unrealized appreciation and timing differences in investment income $ 915,456
NONCASH CAPITAL AND RELATED
FINANCING ACTIVITIES
Acquisition of lease asset $1,284,053
SAN DIEGO COMMUNITY POWER
STATEMENT OF CASH FLOWS
Nine Months Ended March 31, 2025
See accountants' compilation report. 4
21 Operating income $ 31,848,812
Adjustments to reconcile operating income to net
cash provided by operating activities
Depreciation and amortization expense 437,763
(Increase) decrease in:
Accounts receivable, net 1,089,025
Accrued revenue 31,861,627
Prepaid expenses 32,974,487
Other receivables (9,586,178)
Deposits 2,184,970
Increase (decrease) in:
Accrued cost of electricity (27,660,950)
Accounts payable (682,195)
Advances from grantors 13,733,326
Other accrued liabilities 490,568
State surcharges payable 59,584
Deposits - energy suppliers 3,044,450
Net cash provided by operating activities $ 79,795,289
SAN DIEGO COMMUNITY POWER
STATEMENT OF CASH FLOWS (continued)
Nine Months Ended March 31, 2025
RECONCILIATION OF OPERATING INCOME TO NET
CASH PROVIDED BY OPERATING ACTIVITIES
See accountants' compilation report.
22 5
1 ACCOUNTANTS’ COMPILATION REPORT
Board of Directors
San Diego Community Power
Management is responsible for the accompanying operating fund and capital investment program fund budgetary comparison schedules of San Diego Community Power (SDCP), a California Joint Powers Authority, for the nine months ended March 31, 2025 and for determining that the budgetary basis of accounting is an acceptable financial reporting framework. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the accompanying statement nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, we do not express an opinion, a conclusion, nor provide any assurance on this special purpose budgetary comparison statement.
These special purpose statements are 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
May 9, 2025
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com 23 Amended
Budget Actual
Amended
Budget Variance
(Under) Over
Actual/
Amended
Budget %
Amended
Budget
Amended
Budget
Remaining
REVENUES AND OTHER SOURCES
Gross Ratepayer Revenues 984,336,553 980,955,404$ (3,381,149) 100% 1,243,010,863 $ 262,055,459Less: Uncollectible Customer Accounts (17,225,889) $ (17,166,720) 59,169 100% (21,752,690) (4,585,970) Other Income 1,243,258 - 1,243,258 na (1,243,258) - Total Revenues and Other Sources 967,110,664 965,031,942 (2,078,722) 1,221,258,173 256,226,231
OPERATING EXPENSES
Cost of Energy 907,455,490 894,737,509 (12,717,981) 99% 1,116,836,549 222,099,040 Professional Services and Consultants 18,259,767 13,764,019 (4,495,748) 75% 24,346,342 10,582,323Personnel Costs 13,925,916 11,138,341 (2,787,575) 80% 18,567,895 7,429,554 Marketing and Outreach 2,233,956 1,430,291 (803,665) 64% 2,978,593 1,548,302 General & Administrative 3,682,321 2,106,217 (1,576,104) 57% 4,909,761 2,803,544 Total Operating Expenses 945,557,450 923,176,377 (22,381,073) 1,167,639,140 244,462,763 Operating Income (Loss) 21,553,214 41,855,565 20,302,351 53,619,033 11,763,468
NON-OPERATING REVENUES (EXPENSES)
Investment Income 9,768,364 - 9,768,364 na (9,768,364) - Interest and Related Expenses (957,000) (1,474,844) (517,844) 154% (1,276,000) 198,844Transfer to Capital Investment Program (18,175,030) (18,175,030) 100% (18,175,030) - - Total Non-Operating Revenues (Expenses) (19,132,030) (9,881,510) 9,250,520 (19,451,030) (9,569,520) NET CHANGE $ 2,421,184 $ 31,974,055 $ 29,552,871 $ 34,168,003 $ 2,193,948
SAN DIEGO COMMUNITY POWER
BUDGETARY COMPARISON SCHEDULE
Nine Months Ended March 31, 2025
OPERATING FUND
Year-to-Date Annual
See accountants' compilation report.
24 SAN DIEGO COMMUNITY POWER
Staff Report – Item 3
____________________________________________________________________________________ TO: Board of Directors
FROM: Jack Clark, Chief Operating Officer
Colin Santulli, Director of Programs
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Update on Programs
DATE: May 22, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and file update on customer energy programs.
BACKGROUND:
Staff will provide regular updates to the Board of Directors (“Board”) regarding the following Community Power customer energy programs: Commercial Programs, Residential Programs, Flexible Load Programs, Solar + Energy Storage Programs, and San Diego Regional Energy Network.
ANALYSIS AND DISCUSSION:
Updates on customer energy programs are detailed below.
Commercial Programs
Commercial Application Assistance Pilot Project
Status and Next Steps: Please refer to Item 3 of the April 2025 Board agenda for the most recent update on this pilot project. Staff intend to bring a comprehensive pilot update to the June 2025 Board meeting.
Efficient Refrigeration Pilot Project
Status and Next Steps: Please refer to Item 3 of the March 2025 Board agenda for the most recent update on this pilot project.
25 Residential Programs
California Energy Commission (“CEC”) Equitable Building Decarbonization Direct Install (“EBD DI”) Program
Status: At the April 2025 meeting, the Board of Directors adopted Resolution No. 2025- 03 that authorized staff to execute a Memorandum of Understanding (“MOU”) between Community Power and Los Angeles County. The MOU was signed by Community Power and is currently awaiting countersignature from LA County.
Staff are working with the Public Affairs team to activate the Power Network and partner with community-based organizations to conduct marketing, outreach, and educational activities.
Next Steps: Staff will continue to work with LA County and the Southern California Equitable Building Decarbonization Coalition to prepare for the launch of the EBD program, anticipated summer 2025.
Flexible Load Programs
Smart Home Flex Pilot Project
Status and Next Steps: Please refer to Item 3 of the April 2025 Board agenda for the most recent update on this pilot project.
EV Flex Connect Pilot Project (formerly Managed Charging Pilot Project) Status and Next Steps: Please refer to Item 3 of the March 2025 Board agenda for the most recent update on this pilot project.
Solar and Energy Storage Programs
Disadvantaged Communities–Single-Family Affordable Solar Homes (“DAC-SASH”) Readiness Pilot Project Status and Next Steps: Please refer to Item 3 of the February 2025 Board agenda for the most recent update on this pilot project. Staff intend to bring a comprehensive pilot update to the June 2025 Board meeting.
Net Energy Metering (“NEM”) and Net Billing Tariff (“NBT”) Status and Next Steps: Please refer to Item 2 of the December 2023 Board agenda for the most recent update on this program.
Solar Battery Savings (“SBS”) Program
Status and Next Steps: Please refer to Item 20 of the January 2025 Board staff report for the most recent update on this program.
26 Solar Advantage Program
Status: An update on the Solar Advantage Program, formerly the Disadvantaged Communities Green Tariff (“DAC-GT”), was provided at the May meeting of the Community Advisory Committee. Following a CPUC decision that modified the Green Access Program, the Community Solar Green Tariff (“CSGT”) program was discontinued, and its remaining capacity was transferred to the DAC-GT, now the Solar Advantage Program, resulting in a total capacity of 20.16 MW for Community Power. Staff have secured its first Power Purchase Agreement (PPA) for a 1.7 MW project in Chula Vista and a second Request for Offers (RFO) for additional Solar Advantage Program resources was recently in April 2025.
Next Steps: Staff successfully negotiated a PPA with the additional eligible offer from the first Solar Advantage RFO. Staff are bringing this PPA to the May 2025 Board of Directors meeting for review and approval.
San Diego Regional Energy Network (“SDREN”)
SDREN
Status: Staff continue activities required for the successful launch of SDREN programs with a focus on procurement. In December 2024, staff developed a phased schedule to release solicitations for program implementers. The Phase 1 solicitations (administrative, regulatory, and reporting support and cross-cutting sector programs) were released on February 4, 2025, and closed on March 25, 2025. The Phase 2 solicitations (residential and public sector programs) were released on March 6, 2025, and closed on April 24, 2025. The Phase 3 solicitation (commercial sector programs) was released on May 8, 2025, and is planned to close on June 26, 2025.
Next Steps: Staff anticipate awarding contracts for the Phase 1 and Phase 2 solicitations in or before Q3 CY 2025, and the Phase 3 solicitation in Q4 CY 2025.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
27 SAN DIEGO COMMUNITY POWER
Staff Report – Item 4
TO: Board of Directors
FROM: Kenny Key, Director of Power Contracts
Andrea Torres, Director of Origination
Jennine Camara, Director of Portfolio Management
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Update on Power Services
DATE: May 22, 2025
RECOMMENDATION:
Recommendation to receive and file update on Power Services.
BACKGROUND:
Staff provide the updates below to the Board of Directors regarding Community Power’s 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 Community Power not only to solicit, negotiate, and administer contracts for energy supply effectively, but also to monitor market activity, manage risk, bring in-house several activities that have historically been completed by consultants, and to dedicate additional resources to local and distributed energy procurement and development efforts. The Power Services team is now fourteen people strong. The Power Services team has two open positions currently, and is excited to continue stable, prudent growth through 2025.
Administrative Amendment Updates
In May 2025, the CEO signed an administrative amendment to the Sunzia Power Purchase Agreement to allow the developer, Pattern Energy, to operate the turbines at a higher nameplate capacity to facilitate maximum import capacity expansion.
Long-term Renewable Energy Solicitations
As Community Power strives to meet its environmental, financial, and regulatory compliance goals and requirements, long-term power purchase agreements (PPAs) are three renewable generation facility developers with the certain revenue stream against which they can finance up-front capital requirements, so each long-term PPA that 28 Community Power 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 Community Power can build its power supply portfolio while also providing power supply cost certainty. Moreover, the California Renewable Portfolio Standard (RPS), as modified in 2015 by Senate Bill 350, requires that Community Power provide 65% of its RPS-required renewable energy from contracts of at least ten years in length.
Finally, in California Public Utilities Commission (CPUC) Decision (D.) 21-06-025, the 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 CPUC D.23-02-040.
In pursuit of long-term contracts for renewable energy and storage, over the past 24 months, staff have released several Requests for Offers (RFOs) and Requests for Proposals (RFPs). Staff issued an “All-Source RFO” in September 2024 with an emphasis on clean, firm resources to meet MTR requirements and enhance the Community Power portfolio. Staff shortlisted and waitlisted projects in December 2024 using Community Power’s Energy Project Evaluation Criteria and has since kicked off negotiations. Staff issued an RFO targeted for clean-firm resources (e.g. geothermal, bioenergy potential) in April to help achieve MTR requirements and increase technology diversity in Community Power’s portfolio
Staff remain in negotiations for additional resources that are expected to be online between 2026 and 2029. Staff and the Energy Contracts Working Group (ECWG) evaluate all submissions from solicitations prior to entering negotiations with selected participants. Assuming that staff and shortlisted developer(s) can agree to mutually agreeable contracts consistent with terms authorized by the ECWG, staff then review draft terms with the Community Power Board for approval and authorization to execute the relevant documents.
Local Development
Community Power’s rolling Local RFI remains open and has yielded eight Board-approved contracts for local generation and storage facilities. After consultation with the ECWG, Community Power Board of Directors has approved a portfolio of PV PPAs and energy storage and service agreements and is actively negotiating with several local projects submitted to the Local RFI in Q4 2024. Community Power also released an RFO for distributed renewable energy resources (DERs), focusing on a broad range of distribution-level renewable projects within San Diego County. Additional agreements resulting from the RFO are expected and will be presented to the Board when ready.
Other ongoing local initiatives include a Feed-in-Tariff Program revamp and expansion, expected in the first half of this year, and continued collaboration with member agency staff and other local agencies to identify strategic opportunities to further infill development.
As Program Administrators of the CPUC’s Disadvantaged Communities Green Tariff (DAC-GT) program, Community Power completed its first solicitation last year. The first DAC-GT PPA, with Luminia LLC, a local developer, was presented to and approved by 29 the Board in January with a second portfolio of projects being presented at May’s Board meeting. The second DAC-GT solicitation round was released on April 7th and will be accepting offers through September 8th.
Community Power’s Local RFI and Feed-in Tariff remain open. More information is available about each at the links below:
• https://sdcommunitypower.org/resources/solicitations/ • https://sdcommunitypower.org/programs/feed-in-tariff/ Short-Term RPS Procurement
Community Power staff continues to actively manage its environmental portfolio and closely monitor the market for opportunities to optimize its renewable and carbon-free portfolios. Community Power has recently been evaluating solicitation offers, bilateral offers, and products that meet needs for multiple portfolios – creating greater value for its customers. Community Power will continue to prioritize environmental targets while also ensuring value for our customers.
Market Update
Due to limited resource availability in the broader Western Interconnection, lingering supply chain impacts and long interconnection queues that have delayed development of new-build energy resources, and implementation of tariffs and duties on foreign imports, the market for renewable energy and resource adequacy (RA) continues to be exceptionally tight and expensive. Staff are working with developers, industry groups, the CPUC, and CA Governor’s Office and legislators to i) develop near-term solutions while also actively procuring short-term energy and capacity products and long-term energy resources to meet Community Power 's portfolio needs practically and cost-effectively, and ii) to establish a portfolio of resources that will provide value to Community Power and California's clean, reliable energy needs into the future.
Near-term California power markets have been on a slight decline due to relatively mild weather and light heating demand but remain sensitive to extreme temperatures and unexpected supply shortages.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
30 SAN DIEGO COMMUNITY POWER
Staff Report – Item 5
____________________________________________________________________________________ TO: Board of Directors
FROM: Jack Clark, Chief Operating Officer
Lucas Utouh, Senior Director of Data Analytics and Customer Operations
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Update on Customer Operations
DATE: May 22, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and file an update on various customer operations’ initiatives.
BACKGROUND:
Staff will provide regular updates to the Community Advisory Committee (“CAC”) centered around tracking customer opt actions (i.e., opt outs, opt ups, opt downs, and re-enrollments) as well as customer engagement metrics. The following is a brief overview of items pertaining to customer operations.
ANALYSIS AND DISCUSSION:
A) Enrollment Update
As of April 21, 2025, Community Power is serving a cumulative total count of 956,724 active accounts.
Customers with newly established accounts or who have moved into a new service address within any and all of our member jurisdictions receive two post-enrollment notices through the mail at their mailing address on file within 60 days of their account start date to notify them that they have defaulted to Community Power electric generation service. 31 B) Customer Participation Tracking
The below charts summarize customer elections into San Diego Community Power’s four (4) available service levels:
32 33
34 35
36 37
D) Contact Center Metrics
As anticipated, call volumes have continued to decrease as a result of the temperate weather and lower winter electricity rates.
38 The chart below summarizes contact made by customers into the Contact Center broken down by month:
San Diego Community Power anticipates the trend of customers calling into the 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 Community Power’s website for processing opt actions will continue to account for over 65% of all instances. The remaining portion of customer calls are connected to Customer Service Representatives to answer additional questions, assist with account support, or process opt actions. 39 As of this latest reporting month, Community Power has 10 Dedicated Customer Service Representatives staffed at the Contact Center and 1 Supervisor. Robust Quality Assurance (QA) procedures are firmly in place to ensure that customers are getting a world-class customer experience when they contact Community Power.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
40 SAN DIEGO COMMUNITY POWER
Staff Report – Item 6
____________________________________________________________________________________ TO: Board of Directors
FROM: Chandra Pugh, Sr. Director of People Operations and Administration VIA: Karin Burns, Chief Executive Officer
SUBJECT: Human Resources Update
DATE: May 22, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and file update on Human Resources.
BACKGROUND:
We are actively recruiting for the following roles:
Chief Commercial Officer
Data Analyst
Sr. Rates Analyst
This month we welcome our new Procurement Analyst, Krystal Carranza.
In her role, Krystal will support Community Power’s non-energy procurement and contracting efforts, ensuring that our non-energy procurement and contracting function continues to scale with the agency’s needs.
Krystal comes to Community Power with extensive experience in procurement and contracting. She has worked at the San Diego Association of Governments (SANDAG) and the Port of San Diego, where she provided guidance on procurement methods, coordinated with project managers to develop and manage solicitations, and facilitated the timely completion of contracts. She also has experience providing procurement training and conducting audits.
HR is assisting with the administration of the performance evaluation and contract review process for CEO, Karin Burns and General Counsel, Veera Tyagi. This process includes self-review, peer review and Board member feedback. Survey results will be provided in aggregate to Chair Aguirre for review during today’s closed session. 41 ANALYSIS AND DISCUSSION:
N/A
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
42 SAN DIEGO COMMUNITY POWER
Staff Report – Item 7
____________________________________________________________________________________ TO: Board of Directors
FROM: Jack Clark, Chief Operating Officer
Jen Lebron, Senior Director of Public Affairs
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Update on Marketing, Public Relations, and Local Government Affairs DATE: May 22, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and file an update on marketing, public relations, and local government affairs activities for San Diego Community Power (Community Power).
BACKGROUND:
Community Power 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:
Community Power’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
Las Palmas Senior Food Distribution
Transportation Justice Expo
Olivewood Gardens Clean Energy Project Fundraiser
Intertribal Earth Day
Startup San Diego First Mondays
Chula Vista Community Collaborative
National City Collaborative
Sunset Sweet: Manzanita Canyon Cleanup
New Children’s Museum Innovators LAB Grand Opening
South Bay Earth Day
43 Taste of City Heights
City of San Diego Climate Equity Working Group
San Diego Regional Climate Collaborative
County of San Diego Earth Day Fair
Imperial Beach Collaborative
La Mesa Earth Day
Sony Electronics Earth Day
Nature Day at El Toyon Elementary
Roots & Renewal: The Environmental Health Coalition’s 45th Anniversary Spring Valley Day
Ramona Earth Day Festival
South County Economic Development Corporation Economic Summit Chicano Federation Annual Unity Luncheon
Infocast California Energy Transition Summit
San Diego Regional Chamber of Commerce Small Business Summit San Diego Regional Economic Development Corporation Annual Dinner Discover Fallbrook Community Expo
Cyclovia Encinitas
North San Diego County Business Chamber
Equality California San Diego Equality Awards
EcoFest Encinitas
Connect San Diego Summer Social
Chula Vista Chamber of Commerce Installation Dinner
San Diego Regional Chamber Congressional Luncheon
Suncoast Imperial Beach Farmers Market
Sustainable Solutions Fair
San Diego Padres
Imperial Beach Chamber of Commerce
Marketing, Communications and Outreach
The Public Affairs team has been working diligently behind the scenes to support programmatic efforts, including the launch of the San Diego Regional Energy Network and relaunch of the Solar Battery Savings program. It is also ramping up efforts to promote pilot programs, including one that helps customers repair their roofs to be ready for solar installations, and another that will distribute grants to small businesses that would benefit from more efficient refrigerators. The Public Affairs team is working closely with internal and external stakeholders to encourage participation in these programs and leveraging relationships with community partners to amplify our marketing and outreach efforts.
Community Power has continued its efforts to connect with local leaders through meetings and at community events.
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 44 and brand awareness efforts, and provide timely, accurate information across multiple channels.
Local Government Affairs
Community Power continues to meet with and work with local governments and tribal nations throughout the greater San Diego region. It has made a concerted effort to reach out to newly elected officials in all seven member agencies to provide education about the organization.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
45 SAN DIEGO COMMUNITY POWER
Staff Report – Item 8
______________________________________________________________________ TO: Board of Directors
FROM: Jack Clark, Chief Operating Officer
Laura Fernandez, Senior Director of Regulatory and Legislative Affairs VIA: Karin Burns, Chief Executive Officer
SUBJECT: Update on Regulatory and Legislative Affairs
DATE: May 22, 2025
______________________________________________________________________ RECOMMENDATION:
Receive and file the update on regulatory and legislative affairs.
BACKGROUND:
Staff provides regular updates to the Board regarding Community Power’s regulatory and legislative engagement
ANALYSIS AND DISCUSSION:
A) Regulatory Updates
Power Charge Indifference Adjustment
On April 8, 2025, the Assigned Commissioner for the new order instituting rulemaking (OIR) on the Power Charge Indifference Adjustment (PCIA) and other matters related to the Energy Resource Recovery Account (ERRA) annual forecast and compliance proceedings issued a Scoping Memo and Ruling. The Scoping Memo confirmed a narrow scope for Track 1: consideration of adjustments to the Resource Adequacy (RA) Market Price Benchmark (MPB) methodology and data. On April 21, 2025, Community Power’s trade association, the California Community Choice Association (CalCCA) filed Opening Briefs primarily arguing that the CPUC should only apply a modified RA MPB prospectively and that applying a modified methodology to the 2025 rate true-up would constitute retroactive ratemaking, which is prohibited. CalCCA filed Reply Briefs on April 30 and a proposed decision on Track One issues is expected in late May 2025. 4646
Integrated Resource Planning
On April 29, 2025, the CPUC issued a Ruling requesting comment on the Reliable and Clean Power Procurement Program (RCPP) Staff Proposal within the Integrated Resource Planning Proceeding. The goal of RCPPP is to give load serving entities (LSE) a more predictable regulatory framework to procure their share of the resources needed to meet electric system reliability and greenhouse gas (GHG) emission reduction goals at least cost.
The Staff Proposal is divided into two main parts: a proposal for reliability purposes and a proposal for GHG reduction purposes. Each of the two main parts address the key elements noted in the Figure below.
Commission staff will hold a workshop to present the Staff Proposal and answer parties’ questions on May 16. Comments are due June 5 and reply comments are due June 26, 2025.
Renewables Portfolio Standard
On April 17, 2025, the Assigned Commissioner issued a Ruling on the content and schedule for 2025 Renewables Portfolio Standard (RPS) Procurement Plans. • Draft RPS Plans are due June 30
• Comments on Draft RPS Plans are due July 28 and reply comments are due August 11
• Motions to update Draft RPS Plans are due August 11
• A Proposed Decision is expected in Q4 2025
• Final RPS Plans will be due 30 days after a Final Decision is issued. 47 The required 2025 RPS Plan format includes significant revisions in the form of clarifications to RPS Plan requirements and reorganization of some RPS Plan sections.
As part of the new Compliance Period that starts in 2025, the 2025 RPS Plan filings should inform the Commission of the retail seller’s activities and plans to procure 65% of RPS resources from long-term contracts of 10 or more years for all compliance periods beginning with the current compliance period.
CPUC Energy Division staff will hold a webinar to discuss questions from retail sellers related to the templates and 2025 RPS Plans’ requirements no later than June 9, 2025.
Green Access Proceeding
On April 28, 2025, Community Power jointly filed opening comments with six other CCAs in response to the CPUC Ruling, which asked for party input on questions regarding implementation and associated issues for a Community Renewable Energy (CRE) Program and the modified Green Tariff Program established by Decision 24-05-065. The Joint CCAs offered proposals on how to align the CRE program with requirements for receiving the $250 million in grant funds awarded to the State of California through the U.S. Environmental Protection Agency’s (EPA) Solar for All competition. The Joint CCAs also included details on their proposed tariff structure for the CRE program.
Community Power also filed comments jointly with Clean Energy Alliance (CEA) to respond to a specific question regarding cost recovery of under-collected legacy costs from San Diego Gas & Electric’s (SDG&E) Green Tariff program. Community Power, CEA, and SDG&E all agreed that this issue should be resolved in SDG&E’s 2023 Energy Resource Recovery Account (ERRA) Compliance Case, which is already included in the scope. Reply Comments are due May 8, 2025.
SDG&E’s Cost of Capital Application
SDG&E filed its Cost of Capital Application requesting that the CPUC approve its proposed cost of capital for Test Year 2026 for cost of equity and cost of long-term (LT) debt. SDG&E proposes an overall weighted average cost of capital/return on rate base of 8.21%. SDG&E’s proposal would increase its overall rate of return by 0.76% and its annual revenue requirement by $96.45 million.
The CPUC adopted a uniform cost of capital mechanism (CCM) for PG&E, SCE, and SDG&E in D.08-05-035, which established the 3-year cost of capital proceeding cycle and provided two mechanisms for cost of capital adjustments during interim years:
Formula Adjustment Mechanism, which operates based on changes in market interest rates relative to a benchmark; and an application process based on extraordinary or catastrophic events.
Responses to the application were filed on April 24 by multiple stakeholders, including ratepayer advocates, environmental groups, and consumer advocates highlighting the following deficiencies in SDG&E’s proposal:
4848
• SDG&E proposes an unjustified wildfire premium based on an overstatement and already adequately mitigated risk through existing state protections and ratepayer investments;
• SDG&E’s requested return on equity significantly exceeds industry norms and unfairly increases customer burden;
• SDG&E’s financial and economic analysis are inconsistent and rely on outdated methodologies, unrealistic growth assumptions, and market biases, failing to reflect realistic investor expectations;
• SDG&E relies on zero-cost capital (deferred taxes, depreciation/amortization), provided annually by ratepayers, significantly reducing the utilities need for capital and undermining its case for increased investor returns; • SDG&E’s proposal is unnecessary, unreasonable and does not fully take into account the escalating affordability crisis faced by California ratepayers SDG&E Energy Resource Recovery Account (ERRA) Compliance The purpose of the ERRA Compliance proceeding is to review SDG&E's actual energy procurement performance in the previous year against their approved forecast for that year. Any difference between the forecasted costs and the actual costs is tracked in a balancing account. This mechanism ensures that customers ultimately pay for the actual costs incurred by SDG&E.
SDG&E 2023 ERRA Compliance Case
SDG&E held a “meet and confer” with intervening parties and it was agreed upon based on the record that evidentiary hearings would not be necessary and that the proceeding could be resolved by the CPUC based on the record. As such, the Administrative Law Judge cancelled evidentiary hearings. Opening Briefs were submitted on April 18 by San Diego Community Power/Clean Energy Alliance and SDG&E. The Community Power and Clean Energy Alliance brief argued that the CPUC should require SDG&E to recover Green Tariff program under collections from former program participants or SDG&E shareholders, and that corrections should be made to distribution-related battery accounting. SDG&E’s brief argues that the CPUC should find that their fuel and purchased power expenses complied with SDG&E’s Commission-approved procurement plan and were recorded accurately. Reply briefs are due May 9, 2025. A Proposed Decision is expected in the third quarter of 2025.
Self-Generation Incentive Program (SGIP)
On April 28, the CPUC issued a ruling describing the process for the close-out of the SGIP program and requesting party comment on the process. Comments are due May 12 and Reply comments are due May 19. The ruling addresses both the ratepayer funded portion of the program and the portion of the program funded by the Greenhouse Gas Reduction Fund (GGRF). The ruling poses questions related to implementation of the program and 4949
procedural process for closing out the program. The ruling also provides a draft proposal for the final program Measurement and Evaluation plan.
Order Instituting Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and Perform Long-Term Gas System Planning (“Long Term Gas Planning”)
On September 26, 2024, the California Public Utilities Commission (CPUC or Commission) issued an Order Instituting Rulemaking (OIR) to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and Long-Term Gas System Planning (Long Term Gas Planning proceeding). A key purpose of the proceeding is to plan for the transition from gas to decarbonized energy sources.
Community Power is currently participating in this proceeding via a Joint CCA group (as opposed to the California Community Choice Association, CalCCA).
On November 13, 2024, the CPUC issued a Ruling Seeking Comments Regarding Interim Actions to decarbonize before the Commission. In comments, the Joint CCAs recommend leveraging General Rate Case (GRC) and Energy Resources Recovery Account (ERRA) proceedings for transparency in gas system costs and urge utilities to share detailed data on gas distribution infrastructure changes in CCA service areas. The Joint CCAs encourage the Commission to focus on retiring most fossil fuel infrastructure, suggesting the use of securitization to manage costs, and advocate for incorporating California Energy Commission (CEC) demand forecasts into planning. Additionally, the Joint CCAs propose requiring demand forecast tables in GRC proceedings and evaluating non-pipeline alternatives to uphold a comprehensive approach to utilities' service obligations.
Reply Comments were filed on April 1, 2025. The Joint CCAs did not file reply comments.
On March 11, 2025, parties filed Opening Comments in the CPUC’s Natural Gas Planning proceeding on the Natural Gas System Mapping procedures outlined in Appendix A of the recently issued Assigned Commissioner’s Ruling on Senate Bill 1221 Mapping Staff Proposal and Directions to Utilities (Ruling). In short, Senate Bill 1221 requires mapping of current gas infrastructure data that will ultimately help identify pilot decarbonization zones. In Opening Comments, Joint CCAs argued that interactive maps should be updated semi-annually and integrate data from electrification efforts to align with state climate goals. The Joint CCAs recommend coordination among utilities and local governments to manage electric circuit impacts and advocate for a standardized methodology to prioritize pipeline replacements, reducing gas dependency. Additionally, the Joint CCAs say that IOUs should collaborate with communities and governments to refine mapping accuracy, incorporating feedback through regular public workshops.
On March 18, the Joint CCAs filed Reply Comments expressing agreement with the staff proposal and stakeholders’ expressed need for data beyond the "planned retirement" of gas infrastructure. The Joint CCAs support Cal Advocates (a.k.a. Public Advocates Office) that the CPUC should require the inclusion of leak data in gas system mapping and endorse the staff proposal's method for providing detailed, current data. The Joint CCAs also advocate for explicit access to this data for Local Energy Suppliers, including CCAs.
However, the Joint CCAs refute the gas utilities' claim that sharing the data is unsafe. 5050
Building Decarbonization
On March 26, 2025, the CPUC issued Phase 4 Track A [Proposed] Decision Establishing New Electric Service Line Upsizing Rules, Modifying Electric Line Extension Rules and Reporting Requirements, and Implementing Assembly Bill 157. This proposed decision approves $5M in funding annually through 2029 to cover service line upsizing costs for “under-resourced” customers pursuing full electrification of their home or business, with allocations across IOU service areas as follows:
Customers must be enrolled in an electrification program to qualify, and the definition of “under-resourced” is deferred to the program administrator (e.g., Regional Energy Network (REN), community choice aggregator (CCA), investor-owned utility (IOU), etc.) managing the program in which the customer is enrolled. Specifically, the definition is based on “need-based eligibility criteria established by the applicable program(s) through which the customer will receive incentives towards electrification measures” (Proposed Decision at page 16).
Parties filed opening comments on April 15, 2025. In opening comments, Sierra Club, California Environmental Justice Alliance, and Natural Resources Defense Council (together, the Joint Parties) encouraged the CPUC to increase the budget to $10M in total, reserving half of the budget for under-resourced residential customers and small businesses in disadvantaged communities (DACs), with the other half being accessible to customers of all income levels. On April 21, 2025, Community Power, on behalf of San 51 Diego REN (SDREN), filed reply comments with Northern Rural Energy Network (together, the Joint RENs). The Joint RENs encourage the CPUC to maintain the eligibility constraints as described in the proposed decision, stating deferral to program administrators for the definition of “under-resourced” is prudent, as it will maximize reach to customers least able to electrify and will also ensure definitions are appropriately tailored to local communities. Adopting the Joint Parties’ suggestion to narrow the definition of “under-resourced” to customers living in DACs would greatly limit the number of REN customers that can access funding.
The soonest the Commission will vote on this proposed decision is May 15, 2025.
Energy Efficiency
On April 24, 2025, the CPUC approved a new Order Instituting Rulemaking (OIR) for Oversight of Energy Efficiency Portfolios, Policies, Programs, and Evaluation.
The proceeding names the large IOUs, all Regional Energy Networks (including San Diego Regional Energy Network), and MCE as respondents which grants party status.
The OIR is the primary forum for addressing policy and implementation issues related to CPUC-jurisdictional market-rate energy efficiency programs. The scope emphasizes cost-effectiveness and affordability, in line with the Governor’s Executive Order N-5-24.
Key Policy Issues:
• Natural Gas & Electric Alternatives: Staff will propose guidance in Q2 2025 on viable electric alternatives to gas.
• CCA Oversight: Updates to the budget formula and oversight of CCA elect-to-administer portfolios are expected, with a staff proposal in Q4 2025. • 2026 Portfolio Applications: All administrators must file 2026 applications for portfolios spanning 2028-2031; guidance is forthcoming. • Portfolio Oversight: The CPUC will align oversight practices with State Auditor recommendations.
• Multifamily Programs: A workshop in Q3 2025 will address this sector’s unique needs.
• Other Topics: Potential updates to third-party solicitation, Regional Energy Network (REN) oversight, statewide program rollout, financing, cost-effectiveness metrics, and Aliso Canyon closure efforts.
Key Implementation Issues:
• Potential & Goals Study: A study released on May 1st will inform portfolio planning and IOU energy savings goals; it is scheduled for Commission adoption by August. 5252
• Oversight of 2024–2027 Portfolio Plans
• Other Topics: Oversight of market transformation, demand-side integration, program evaluation, and database improvements will also be addressed as needed.
Opening comments are due on May 19th and reply comments are due on May 29th.
B) State Legislative Activities Update
Update on Legislation Supported by Community Power
The Legislature’s house of origin policy committee deadline is May 16, meaning each bill must have received a committee hearing for it to move forward in the legislative process.
Here is an update on bills that Community Power is supporting:
• AB 259 (Rubio): This would extend teleconferencing procedures under the Brown Act. It was approved by the Assembly Committee on Local Government. • SB 239 (Arreguin): This would simplify teleconferencing procedures for subsidiary bodies like the Community Advisory Committee. It was approved by the Senate Committee on Local Government.
• SB 302 (Padilla): This would align California tax law, so it treats transferable clean energy tax credits in a manner that is consistent with federal law. It was approved by the Senate Committee on Revenue & Taxation and subsequently placed on the Senate Committee on Appropriations Suspense File.
• SB 330 (Padilla): This would set up a process for the Governor to establish a public financing mechanism for transmission projects. It passed the Senate Committee on Energy, Utilities and Communications and the Senate Committee on Environmental Quality.
• SB 540 (Becker): This would allow the California Independent System Operator (CAISO) to participate in an independent regional electricity market. It was approved by the Senate Committee on Energy, Utilities and Communications and the Senate Committee on Judiciary. The bill was significantly amended by the Senate Committee on Judiciary in a manner that expands the requirements that must be met for the CAISO to participate in an independent regional electricity market. Community Power staff are reviewing the amendments. • SB 740 (Blakespear): This would extend the sunset on a property tax exclusion for solar and storage systems. It is set for a hearing in the Senate Committee on Revenue & Taxation on May 14.
Energy Storage Safety Legislation
Community Power is monitoring six bills that pertain to safety standards for energy storage. The bills are:
• SB 283 (Laird): This would require fire department consultation and inspection of energy storage systems and would require that those systems meet a fire code 5353
standard, known as NFPA 855. It would further stipulate that energy storage systems could only be approved if they are in noncombustible, dedicated-use buildings. It was approved by the Senate Committee on Energy, Utilities, and Communications.
• AB 303 (Addis): This would prohibit the approval of battery storage energy storage projects within 3,200 feet of sensitive receptors and environmentally sensitive sites. It would also disallow battery energy storage systems from being eligible for a state-level opt-in permitting process. A hearing was postponed by the Assembly Committee on Utilities & Energy, and it is not expected to advance past the house of origin deadline.
• AB 434 (DeMaio): This would impose a 2-year moratorium on battery energy storage facilities while the State Fire Marshal adopts guidelines and minimum standards. It was referred to the Assembly Committee on Utilities & Energy, but has not been set for a hearing. It is not expected to advance past the house of origin deadline.
• AB 588 (Patel): This would create a working group to recommend potential solutions to enhance building safety with respect to lithium batteries. It was approved by the Assembly Committee on Emergency Management. • AB 841 (Patel): This would create a working group to develop recommendations about personal protective equipment used by firefighters when responding to lithium-ion batteries. The bill was approved by the Assembly Committee on Labor and Employment.
• AB 1285 (Committee on Emergency Management): This would require the State Fire Marshal to develop fire prevention response, and recovery measures for utility grade lithium-ion battery storage facilities. It was approved by the Assembly Committee on Emergency Management.
Update on Legislative Focus on Ratepayer Affordability
Both the Senate Committee on Energy, Utilities and Communications and the Assembly Committee on Utilities & Energy previously held oversight hearings (Senate hearing materials can be found here and Assembly hearing materials can be found here) on matters related to ratepayer affordability. New legislation from Senator Becker, the chair of the Senate Committee on Energy, Utilities, and Communications, is an outcome of the legislative affordability conversations. He recently introduced SB 254 (Becker) to put forward various affordability proposals. In summary, the bill addresses the following:
• Public financing of transmission powerlines. Creates the Clean Energy Infrastructure Authority to develop transmission and other infrastructure. The Authority, which is exempt from California Public Utilities Commission (CPUC) oversight, can “finance, plan, develop, acquire, own, maintain, sell, or operate eligible clean energy infrastructure (including transmission and storage) necessary or useful” in the state’s transition to 100% clean energy. It includes public financing of transmission that would be operated and maintained by the IOUs. • Modifies oversight of IOU wildfire mitigation. Overhauls the framework for the oversight of IOU wildfire mitigation project review, introduces the need to evaluate 5454
wildfire investments based on cost efficiency, and exempts undergrounding from the California Environmental Quality Act (CEQA).
• Restricts earning a rate of return on certain investments. Prevents the IOUs from including in their rate base their proportional share of $5 billion of fire risk mitigation capital expenditures and $10 billion of energization capital expenditures approved by the CPUC on or after January 1, 2025.
• Enhances a bi-annual bill credit. Increases the California Climate Credit for customers on low income rates and concentrates the credit on peak bill months. • Seeks to fund certain societal programs with state revenues. Establishes the Policy-Oriented and Wildfire Electric Reimbursement (POWER) program that will use appropriated funds, if any, to reimburse CPUC programs “driven by public policy goals, that provide benefit to the general public and not just to ratepayers, and that are not required for the safe and reliable delivery of electricity to the ratepayers….” (e.g. transportation electrification, building decarbonization, energy efficiency, low-income discounts, and wildfire mitigation). This does not change the ratepayer funding source for programs, such as those that will be offered by the San Diego Regional Energy Network. Rather, the bill creates a ratepayer reimbursement mechanism should the state be able to appropriate funds. • Clarifies reporting requirements on demand-side management programs. Modifies the CPUC’s reporting responsibility for demand-side management programs it oversees or that are paid for by ratepayers of the IOUs or CCAs by specifying that “public interest impacts” include nonenergy effects, emissions reductions, or equity considerations.
• Changes the general rate case process. Heightens the burden of proof for proposed IOU costs in excess of inflation to “clear and convincing” evidence and increases reporting requirements for the CPUC if such costs are authorized. • Sets up programmatic environmental review for certain projects. Requires the California Energy Commission (CEC) to prepare a program environmental impact report (EIR) to analyze the development of classes of facilities, including solar, wind, energy storage, and thermal generation so that other agencies considering approval of specific facilities within the class may rely and build on the program EIR rather than doing their own. It also broadens the scope of energy projects that fall within the exclusive jurisdiction of the CEC for permitting by reducing the capital investment requirement for discretionary projects from $250 million to $100 million and extends eligibility to come within the CEC’s jurisdiction from mid-2029 to mid-2034. The bill also makes other material changes to the certification process.
Community Power's initial review of the legislation indicates that the bill would not have an impact on Community Power’s procurement or rate setting. The core impact of the bill appears to be primarily on IOU delivery-related costs and oversight thereof. The California Community Choice Association is supporting the bill.
C) Federal Activities Update
Community Power staff continue to monitor and engage in Congressional and executive matters.
5555
White House Office of Management and Budget (OMB) Releases Discretionary Budget Request
Prior staff reports indicated there will likely be congressional action through the budget reconciliation process on energy tax credit matters. Related, on May 2 the White House OMB released their discretionary budget proposal. The proposal focuses on disbursements of appropriated funds and does not deal with energy tax credit issues. It does include proposals to rein in spending on what OMB labels as the “Green New Scam.” The OMB proposal seeks to end the U.S. Environmental Protection Agency’s Justice40 program, and to claw back energy related funds from the Infrastructure Investment and Jobs Act (IIJA). Community Power is not in receipt of any IIJA funds.
Thirty-eight Members of the House Majority Party Call for Ending Inflation Reduction Act (IRA) Energy Tax Credits
The 38 members of Congress sent a letter to Jason Smith, the Chair of the House Ways & Means Committee, which has jurisdiction over tax policy. The letter, which is included as an attachment, notes that the majority party “ran – and won – on a promise to completely dismantle the IRA and end the left’s green welfare agenda.” No members of Congress from California signed the letter.
In March, 21 members of the House majority party sent a competing letter to the chair of the House Ways and Means Committee stating that repeal of tax credits “would increase utility bills the very next day.” Three members of Congress from California signed the letter. The two letters represent competing views among the majority party in the House of Representatives.
Related, on April 29, a group of 272 business, renewables, and utility stakeholders sent a letter to Congress urging them to “retain the existing energy tax credits which are vital to unleashing American energy to lead the world on economic growth, AI, and manufacturing.” The letter is included as an attachment.
The IRA tax credits – such as the Investment Tax Credit and the Production Tax Credit – are expected to be considered during the budget reconciliation process, which could wrap up as soon as July 4.
FISCAL IMPACT:
N/A
ATTACHMENTS:
A: March 9 Congressional Letter on IRA Tax Credits
B: May 1 Congressional Letter on IRA Tax Credits
C: April 29 Coalition Letter on IRA Tax Credits
5656
ITEM 8
ATTACHMENT A
57 March 9, 2025
The Honorable Jason Smith
Chairman
Ways & Means Committee
U.S. House of Representatives
Washington, D.C. 20515
Dear Chairman Smith:
As Members of the House Republican Conference, we write to emphasize the importance of prioritizing energy affordability for American families and keeping on our current path to energy dominance amid efforts to repeal or reform current energy tax credits.
We strongly support the Administration’s America First national energy dominance initiative.
Continued energy expansion and innovation is necessary to bolster national security, create good-paying American jobs, and guarantee energy independence. The United States continues to produce energy from a myriad of sources that are cleaner and more efficient than anywhere else in the world.
As our conference has long believed, an all-of-the-above energy approach, combined with a robust advanced manufacturing sector, will help support the United States’ position as a global energy leader.
Countless American companies are utilizing sector-wide energy tax credits – many of which have enjoyed broad support in Congress – to make major investments in domestic energy production and infrastructure for traditional and renewable energy sources alike. Both our constituencies and the energy industry alike remain concerned about disruptive changes to our nation’s energy tax structure.
Many credits were enacted over the course of a ten-year period, which allowed energy developers to plan with these tax incentives in mind. These timelines have been relied upon when it comes to capital allocation, planning, and project commitments, all of which would be jeopardized by premature credit phase outs or additional restrictive mechanisms such as limiting transferability. As energy demand continues to skyrocket, any modifications that inhibit our ability to deploy new energy production risk sparking an energy crisis in our country, resulting in drastically higher power bills for American families. This is especially true for energy credits with direct passthrough benefit to ratepayers, where such repeals would increase utility bills the very next day. As our conference works to make energy prices more affordable, tax reforms that would raise energy costs for hard working Americans would be contrary to this goal. Further, affordable and abundant energy will be critical as the President works to onshore domestic manufacturing, supply chains, and good paying jobs, particularly in Republican run states due to their business-friendly environments. Pro-energy growth policies will directly support these objectives.
At the same time, there are plenty of shortcomings in our tax code that can and should be addressed to rein in spending and promote fiscal responsibility in the upcoming reconciliation bill.
With all this in mind, we request that any proposed changes to the tax code be conducted in a targeted and pragmatic fashion that promotes conference priorities without undoing current and 58 future private sector investments which will continue to increase domestic manufacturing, promote energy innovation, and keep utility costs down. We believe we can work together so that all these goals are achievable.
We appreciate your work to unite House Republicans on this important matter. We hope you can consider us partners in modernizing and improving our nation’s tax policies to unleash American energy and protect families from higher energy costs.
Sincerely,
Andrew R. Garbarino
Member of Congress
Jennifer Kiggans
Member of Congress
Juan Ciscomani
Member of Congress
Gabe Evans
Member of Congress
David G. Valadao
Member of Congress
Mark E. Amodei
Member of Congress
Michael V. Lawler
Member of Congress
Young Kim
Member of Congress
Don Bacon
Member of Congress
Vince Fong
Member of Congress
59 Jeff Hurd
Member of Congress
Thomas H. Kean, Jr.
Member of Congress
Nick LaLota
Member of Congress
John James
Member of Congress
Ryan Mackenzie
Member of Congress
Rob Bresnahan, Jr.
Member of Congress
Mariannette J. Miller-Meeks,
M.D.
Member of Congress
Earl L. "Buddy" Carter
Member of Congress
Dan Newhouse
Member of Congress
Erin Houchin
Member of Congress
David P. Joyce
Member of Congress
60 ITEM 8
ATTACHMENT B
61 May 1, 2025
The Honorable Jason Smith
Chairman
Ways & Means Committee
U.S. House of Representatives
Washington, D.C. 20515
Dear Chairman Smith:
As fellow Members of the House Republican Conference, we write to underscore the urgent need to fully repeal the Inflation Reduction Act (IRA) and its green energy subsidies, which will cost taxpayers approximately $1 trillion over the next decade. We are deeply concerned that President Trump’s commitment to restoring American energy dominance and ending what he calls the “green new scam” is being undermined by parochial interests and short-sighted political calculations.
The IRA contains eight major energy subsidies, each of which burdens taxpayers, inflates energy costs, and threatens the reliability of our power grid. Each of these subsidies props up unreliable energy sources while displacing dependable, proven energy like coal and natural gas.
Republicans ran—and won—on a promise to completely dismantle the IRA and end the left’s green welfare agenda. The first chapter of our 2024 platform reaffirms our commitment to “terminating the Socialist Green New Deal.”1
Despite our previously unified stance, some
Members of our conference now feel compelled to defend wind and biofuel credits, advocate for carbon capture and hydrogen subsidies, or protect solar and electric vehicle giveaways. Keeping even one of these subsidies opens the door to retaining all eight. How do we retain some of these credits and not operate in hypocrisy? The longstanding Republican position has been to allow the market to determine energy production. If every faction continues to defend their favored subsidies, we risk preserving the entire IRA because no clearly defined principle will dictate what is kept and what is culled.
Leaving IRA subsidies intact will actively undermine America’s return to energy dominance and national security. In 2024 alone, solar represented 61% of all new electricity generation in our nation, with more expected this year.2
By the end of this year, wind generation in the U.S. is 1 https://prod-static.gop.com/media/RNC2024-Platform.pdf. 2 https://www.eia.gov/todayinenergy/detail.php?id=64586. 62 expected to increase 11% from 2023 because of these subsidies.3 These numbers do not reflect a
natural market shift. They are the result of government subsidies that distort the U.S. energy sector, displace reliable coal and natural gas and the domestic jobs they produce, and put the stability and independence of our electric grid in jeopardy.
To see the consequences of this path, we need only to look at Europe’s overreliance on renewables, which has left them vulnerable and reliant on Russian oil and gas. Meanwhile, China gladly sells us solar panels and electric vehicle components while expanding its own coal capacity to maintain grid stability and economic advantage. If we do not course correct, we will trade American energy dominance for dependence on hostile regimes.
Our path forward is clear. We must fully repeal the IRA’s green subsidies. Doing so will:
• Save Taxpayers $1 trillion. Estimates project the Inflation Reduction Act will cost between $825 billion—according to the Congressional Budget Office as of January 2025— and over $1 trillion, per analysts at Goldman Sachs, over the next decade.4 Eliminating these subsidies will allow us to rein in the debt and reallocate funds to genuine national priorities.
• Ease inflation and spur economic growth. IRA subsidies exacerbate inflation and push up interest rates, making it harder for Americans to buy homes and cars and start businesses. Repealing them will provide immediate financial relief and create a stronger economic environment.
• Restore energy affordability and security. IRA subsidies force utilities to overbuild solar and wind capacity, weakening grid reliability and increasing energy costs. Ending these subsidies will restore affordability and stability to our energy supply.
This is our only opportunity for an IRA repeal. Without effectively fully repealing all IRA subsidies, as envisioned under the House reconciliation framework, we would jeopardize America’s return to energy dominance and passage of an extension of the expiring Tax Cuts and Jobs Act (TCJA) provisions, as well as the President’s other tax priorities. Failure to act undermines the mandate given to us by the American people.
We urge our colleagues to stand firm in the upcoming reconciliation process. We must reject half-measures and deliver a full repeal of the IRA’s energy subsidies for the sake of American taxpayers and for the future of American energy.
Sincerely,
3 https://www.eia.gov/outlooks/steo/.
4 https://www.reuters.com/business/energy/us-clean-energy-tax-subsidies-cost-825-billion-over-10-years-cbo-says-2025-01-17/; https://www.goldmansachs.com/pdfs/insights/pages/gs-research/carbonomics-the-third-american-energy-revolution/report.pdf. 63 _______________________ _______________________
Josh Brecheen Chip Roy
Member of Congress Member of Congress
_______________________ _______________________
Andy Biggs Paul A. Gosar, D.D.S.
Member of Congress Member of Congress
_______________________ _______________________
Mary E. Miller Pat Fallon
Member of Congress Member of Congress
_______________________ _______________________
Andy Harris, M.D. Byron Donalds
Member of Congress Member of Congress
_______________________ _______________________
Tim Burchett Marjorie Taylor Greene
Member of Congress Member of Congress
64 _______________________ _______________________
Barry Moore Clay Higgins
Member of Congress Member of Congress
_______________________ _______________________
Thomas Massie Eric Burlison
Member of Congress Member of Congress
_______________________ _______________________
Rich McCormick, M.D., MBA Eli Crane
Member of Congress Member of Congress
_______________________ _______________________
Scott Perry Andy Ogles
Member of Congress Member of Congress
_______________________ _______________________
Ben Cline Mark Harris
Member of Congress Member of Congress
65 _______________________ _______________________
Lauren Boebert Warren Davidson
Member of Congress Member of Congress
_______________________ _______________________
Brandon Gill Andrew S. Clyde
Member of Congress Member of Congress
_______________________ _______________________
Lance Gooden Anna Paulina Luna
Member of Congress Member of Congress
_______________________ _______________________
Nancy Mace Keith Self
Member of Congress Member of Congress
_______________________ _______________________
Cory Mills Ralph Norman
Member of Congress Member of Congress
66 _______________________ _______________________
Tom Tiffany Marlin Stutzman
Member of Congress Member of Congress
_______________________ _______________________
Michael Rulli Harriet M. Hageman
Member of Congress Member of Congress
_______________________ _______________________
Victoria Spartz Nick Begich
Member of Congress Member of Congress
_______________________ _______________________
Mark E. Green, M.D. Randy Fine
Member of Congress Member of Congress
CC: President Donald J. Trump
Vice President J.D. Vance
House Speaker Mike Johnson
67 ITEM 8
ATTACHMENT C
68 April 29, 2025
The Honorable Mike Johnson, Speaker
U.S. House of Representatives
521 Cannon House Office Building
Washington, DC 20515
The Honorable Hakeem Jeffries, Minority Leader
U.S. House of Representatives
2267 Rayburn House Office Building
Washington, DC 20515
The Honorable Jason Smith, Chair
House Ways and Means Committee
1011 Longworth House Office Building
Washington, DC 20515
The Honorable Richard Neal, Ranking Member
House Ways and Means Committee
372 Cannon House Office Building
Washington, DC 20515
Dear Speaker Johnson, Leader Jeffries, Chairman Smith, and Ranking Member Neal:
We, the undersigned companies and trade organizations, urge Congress to retain the existing energy tax credits which are vital to unleashing American energy to lead the world on economic growth, AI, and manufacturing. Collectively, the signatories to this letter represent business interests in 43 states, and the companies alone represent over $450 billion in capital and more than 165,000 employees.
These credits are the basis for significant manufacturing investment and jobs in the United States, promot-ing greater efficiency, growth in energy production, and the delivery of the capacity needed to keep our country at the leading edge of global energy innovation.
The United States is already experiencing sharp increases in energy demand coupled with concerns about rising energy costs. A recent report by S&P Global Commodity Insights predicts that U.S. electricity demand will surge by 35-50% over the next few decades, driven by AI, data centers, and the onshoring of U.S. manufacturing.
A broad portfolio of supply-side and demand-side energy solutions is ready to meet this new load. Clear, predictable, and long-term tax policy is essential for market confidence and unlocking significant in-vestments quickly in our nation’s energy production and infrastructure. This will lead to greater energy abundance and lower energy bills for Americans.
Energy tax policies – many of which are the product of bipartisan tax legislation over the past 20 years – have leveraged billions of dollars of private capital and have helped to create millions of good-paying American jobs.
Companies plan with these tax incentives in mind and rely upon them for capital allocation, planning, and project commitments – all of which would be jeopardized by premature credit phase outs or additional restrictions. Further, these tax credits are critical to expanding economic development and growing the economy. Companies can lower their capital costs and increase investment in research and development to maintain the nation’s competitiveness.
Any tax policy changes that inhibit new production and demand-side solutions from coming online also risk the reliability and affordability of our nation’s energy.
According to a new report by Energy Innovation, repealing federal energy tax credits would increase annual energy bills for U.S. households by more than $6 billion in 2030 and more than $9 billion in 2035. 1 69
Similarly, NERA Economic Consulting estimates that electricity bills for businesses would increase by about 10% by 2026 if the tax credits are repealed, with costs likely passed on to consumers in the form of higher prices for goods and services.
We need every form of energy available to unleash America’s full potential. We must act quickly to modernize and expand the energy system to supply the data centers, artificial intelligence, and domestic manufacturing that are vital to our economic and innovative edge.
Now is not the time to disrupt the market by changing the current energy tax structure. We urge Congress to support sector-wide energy tax credits as it considers tax policy changes this year.
Sincerely,
SolaRay Farms, Inc. - Phoenix, AZ
Capital Power - Phoenix, AZ
Kiterocket - Phoenix, AZ
Learning Edge, LLC - Paradise Valley, AZ
Arevon Energy, Inc. - Scottsdale, AZ
Grannus, LLC - Tucson, AZ
JA Roth Consulting, LLC - Tucson, AZ
Willdan Energy Solutions - Anaheim, CA
GOGETIT LLC - Calabasas, CA
Sapphire Technologies, Inc. - Cerritos, CA
Air Voltaics LLC - Fallbrook, CA
Terra-Vista Wildfire Defense - Lafayette, CA
Salton Energy Inc. - Lake Forest, CA
Woods Bagot - Los Angeles, CA
Climate Forward Strategies - Oakland, CA
Pacific Gas and Electric Company - Oakland, CA
Terrajoule Energy Inc. - Palo Alto, CA
Amy’s Kitchen - Petaluma, CA
Green Energy Solutions Team - Rancho Cucamonga, CA
EVO Power USA, Inc. - Rancho Santa Margarita, CA
California Hydrogen Business Council - Sacramento, CA
HMC Architects - Ontario, CA
RNG Coalition - Sacramento, CA
Sacramento Municipal Utility District - Sacramento, CA
(W)right On Communications - San Diego, CA
Long Duration Energy Storage Council - San Francisco, CA Metrus Energy - San Francisco, CA
Powertree Services Inc. - San Francisco, CA
QuitCarbon - San Francisco, CA
Next Energy Technologies, Inc. - Santa Barbara, CA
Open Doors Management - Solana Beach, CA
Force Energy Corporation - Sonora, CA
SVI Group - Sunnyvale, CA
Bailte Construction - West Hollywood, CA
Scout Clean Energy - Boulder, CO
Rebound-Tech - Commerce City, CO
Akku Energy Devices LLC - Denver, CO
Big Glasses Consulting - Denver, CO
Cowboy Clean Fuels - Denver, CO
Koloma - Denver, CO
Perfect Energy, Inc. - Denver, CO
Gevo, Inc. - Englewood, CO
Tap Energy LLC - Denver, CO
Joelson Consulting - Fort Collins, CO
Atlasta Solar Center - Grand Junction, CO
Senergy Builders - Grand Junction, CO
Headwaters Companies - Littleton, CO
CORE Electric Cooperative - Sedalia, CO
The SLAM Collaborative - Glastonbury, CT
Empere, LLC - Norwich, CT
Alliance to Save Energy - Washington, DC
American Biogas Council - Washington, DC
American Biomass Energy Assoc. - Washington, DC
American Clean Power Assoc. - Washington, DC
American Council on Renewable Energy - Washington, DC
Business Council for Sustainable Energy - Washington, DC Carbon Capture Coalition - Washington, DC
Cellulose Insulation Manufacturers Assoc. - Washington, DC Clean Energy Business Network - Washington, DC
E2 - Washington, DC
Electric Drive Transportation Assoc. - Washington, DC
Federal Performance Contracting Coalition - Washington, DC Heat is Power Assoc. - Washington, DC
Lucey Consulting LLC - Washington, DC
2 70
National Assoc. of Energy Service Companies - Washington, DC National Hydropower Assoc. - Washington, DC
Portland Cement Assoc. - Washington, DC
Solar Energy Industries Assoc. - Washington, DC
The Ultra Low Carbon Solar Alliance - Washington, DC
U.S. Green Building Council - Washington, DC
WATT Coalition - Washington, DC
Structural Insulated Panel Assoc. - Fort Lauderdale, FL RS&H - Jacksonville, FL
Hydrokinetic Energy Corp. - Key West, FL
ecoPreserve - Orlando, FL
Penn Renewables - Pompano Beach, FL
Utility Saving Solutions, Inc. - Alpharetta, GA
Assoc. of Energy Engineers - Atlanta, GA
Better Tomorrow Solar - Atlanta, GA
BONA Investment Properties, LLC - Atlanta, GA
Teverra LLC - Atlanta, GA
TVS - Atlanta, GA
Sigma Thermal, Inc. - Marietta, GA
Axle Plus - Conyers, GA
Ampacimon - Cumming, GA
ElectraTherm, Inc. / BITZER USA - Flowery Branch, GA
RE Innovations LLC - Loganville, GA
Hawaii Fish Company Inc. - Waialua, HI
Eocene Environmental Group - West Des Moines, IA
Frontline BioEnergy, LLC - Nevada, IA
Verdant Resolutions - Boise, ID
Synergy ECOHUB Solutions, Inc. - Nampa, ID
Kazadi Enterprises Ltd. - Batavia, IL
GRP WEGMAN Company - Bethalto, IL
Clear Sky Energy Solutions - Chicago, IL
Greater Englewood Chamber Foundation - Chicago, IL
Midwest Energy Efficiency Alliance - Chicago, IL
Studio Nigro LLC - Chicago, IL
WJW Architects - Chicago, IL
Open Hydrogen Initiative - Des Plaines, IL
FM Energy Consulting Inc. - Naperville, IL
Avid Solutions Intl - Peoria, IL
Geothermal Alliance of Illinois - Springfield, IL
Geothermal Exchange Organization - Springfield, IL
Clean Energy Business Council - Hutchinson, KS
Orange EV - Kansas City, KS
Rice-Stromgren Architects - Lawrence, KS
The Bowersock Mills & Power Co. - Lawrence, KS
Sunflower Fuels - Lexington, KY
Concord Energy Strategies, LLC - Louisville, KY
Rain CII Carbon LLC - Covington, LA
Mavel Americas, Inc. - Boston, MA
Schneider Electric - Boston, MA
Shepley Bulfinch - Boston, MA
Cleantech Leaders Roundtable - Cambridge, MA
Ameresco - Framingham, MA
Ambri - Marlborough, MA
Viridi Edge - Newton, MA
Greentown Labs - Somerville, MA
Pecos Wind Power - Somerville, MA
Save Energy Systems, Inc. - Westborough, MA
Good Clout Consulting - Cambridge, MA
AIA Maryland - Annapolis, MD
Hord Coplan Macht - Baltimore, MD
Luminace - Baltimore, MD
Oceantic Network - Baltimore, MD
Resource Management Associates - Bethesda, MD
WindRun Strategies, LLC - Bethesda, MD
CoolPact Capital - Baltimore, MD
GHG Engineering, LLC - Rockville, MD
Princeton Energy Resources International LLC - Rockville, MD ClearlyEnergy - Severna Park, MD
Alliance for Green Heat - Takoma Park, MD
ClimateWork Maine - Portland, ME
Dynamic Grid - Portland, ME
Energy Alliance Group - Ann Arbor, MI
Quinn Evans - Ann Arbor, MI
Peaker Services, Inc. - Brighton, MI
Utility Transformation Consortia - Clinton Township, MI Heiss Consulting Services LLC - Detroit, MI
Newman Consulting Group, LLC - Farmington Hills, MI
Michigan Sustainable Business Forum - Grand Rapids, MI
Sesame Solar Inc. - Jackson, MI
Absolute Solar - Lansing, MI
Cedar Creek Energy - Coon Rapids, MN
Winkelman Solar LLC - Brainerd, MN
Conners Consulting - Eden Prairie, MN
EcoThrive LLC - La Crescent, MN
Clean Energy Economy Minnesota - Minneapolis, MN
Energy Aspects LLC - Minneapolis, MN
3 71
HGA - Minneapolis, MN
Multistudio - Kansas City, MO
Populous - Kansas City, MO
Hellmuth & Bicknese Architects - St. Louis, MO
Accelerate Wind, Inc. - St. Louis, MO
ROCKWOOL North America - Byhalia, MS
Mississippi Energy Developers - Lena, MS
Sweetgrass Associates - Big Timber, MT
High Plains Architects, P.C. - Billings, MT
High Ridge Leadership, LLC - Missoula, MT
Oasis Montana Inc. - Stevensville, MT
Intelli-Products Inc. - Asheville, NC
Pisgah Energy Inc. - Asheville, NC
EIP Storage - Chapel Hill, NC
Anchor Tree Development, LLC - Charlotte, NC
Little Diversified Architectural Consulting - Charlotte, NC Trane Technologies - Davidson, NC
Carolina Solar Energy LLC - Chapel Hill
LEO A DALY LLC - Omaha, NE
Tenaska, Inc. - Omaha, NE
Propane Gas Assoc. of New England - Epsom, NH
Energy Efficient Investments, Inc. - Merrimack, NH
Merit SI LLC, dba Merit Controls - Somerville, NJ
Spar Systems - Montvale, NJ
Fujitsu General America - Pine Brook, NJ
Utopio Inc. - Princeton, NJ
Anax Power - Wharton, NJ
Equiterra Regenerative Design - Albuquerque, NM
OE Solar - Albuquerque, NM
The Reno + Sparks Chamber of Commerce - Reno, NV
ecoLong LLC - Albany, NY
Aphra Communications - Brooklyn, NY
Basis Climate - New York, NY
Dollaride - Brooklyn, NY
FXCollaborative - Brooklyn, NY
Buffalo Renewables Inc. - Tonawanda, NY
Siva Powers America Inc. - Buffalo, NY
Dimensional Energy - Ithaca, NY
Centrica Business Solutions - Malta, NY
Lighthouse Solar - New Paltz, NY
Blue Lake Clean Energy Group LLC - New York, NY
Brookfield Renewable - New York, NY
Build Efficiently, LLC - New York, NY
CannonDesign - New York, NY
CleanCapital - New York, NY
Emotiva - New York, NY
HLW International - New York, NY
IPPsolar LLC - New York, NY
Lexden Capital, LLC - New York, NY
MAC Energy Advisors LLC - New York, NY
New York Angels, Inc. - New York, NY
VL Harmon Advisors - New York, NY
RED Rochester LLC - Rochester, NY
Storke, LLC - Springwater, NY
Special Power Sources - Alliance, OH
Harmony Architecture - Cincinnati, OH
Hubay Dougherty - Cleveland, OH
Moody Nolan, Inc. - Columbus, OH
Concho Energy - Freedom, OK
Bergey Windpower Co. LLC - Norman, OK
Elexity - Bend, OR
NLine Energy, Inc. - Bend, OR
Sun Raven LLC - Bend, OR
Basque Beginnings LLC - Maupin, OR
Brockman Climate Strategies LLC - Portland, OR
ZGF Architects LLP - Portland, OR
Michael W Grainey Consulting LLC - Salem, OR
Windurance, LLC - Coraopolis, PA
Alternative Energy Development Group, LLC - Malvern, PA Philadelphia Solar Energy Assoc. - Philadelphia, PA
BLD:ac - Pittsburgh, PA
RER Energy Group - Reading, PA
LAC-TER - Scranton, PA
Cooperativa de Energia La Margarita - Abeyno Coop - Salinas, PR Copacity, Inc. - Providence, RI
LS3P - Charleston, SC
Rosebud Energy Services Company - Rosebud, SD
GenPro Energy Solutions, LLC - Piedmont, SD
TerraShares - Morristown, TN
Conservative Texans for Energy Innovation - Austin, TX
Terra Lumina Consulting - Austin, TX
JSJ Services - Belton, TX
Green Careers Texas - Dallas, TX
HKS, Inc. - Dallas, TX
Huitt-Zollars - Dallas, TX
MM Solar Advisory, LLC - Dallas, TX
4 72
The Beck Group - Dallas, TX
Kanin Energy - Houston, TX
NRG Energy Inc. - Houston, TX
NXTClean Fuels, Inc. - Houston, TX
Redfield Consulting Services - San Antonio, TX
Inergy - Orem, UT
Particle Flux Analytics Inc. - Park City, UT
GlycoSurf, Inc. - Salt Lake City, UT
North American Insulation Manufacturers Assoc. - Alexandria, VA National Electrical Manufacturers Assoc. - Arlington, VA New Energy Venture Associates - Arlington, VA
Polyisocyanurate Insulation Manufacturers Assoc. - Arlington, VA Responsible Alpha - Arlington, VA
The Stella Group, Ltd - Arlington, VA
Sheet Metal & AC Contractors National Assoc. - Chantilly, VA BrightView Energy - Charlottesville, VA
Cobalt Growth Advisory - Falls Church, VA
Copper Development Assoc. - McLean, VA
Synurja LLC - Vienna, VA
Encore Renewable Energy - Burlington, VT
Eocycle America Corporation - Swanton, VT
Forest Concepts, LLC - Auburn, WA
Silfab Solar Inc. - Burlington, WA
Brad Thompson Company - Kirkland, WA
Appropriate Technology Group - Seattle, WA
DLR Group - Seattle, WA
Ever.green - Seattle, WA
Omnidian - Seattle, WA
Svante - Seattle, WA
NAC Architecture - Spokane, WA
CarbonQuest - Spokane Valley, WA
Cheq Bay Renewables - Bayfield, WI
Weather Blanket Insulation - Fond du Lac, WI
A. O. Smith - Milwaukee, WI
Johnson Controls - Milwaukee, WI
Franklin Energy - Washington, WI
5 73
SAN DIEGO COMMUNITY POWER
Staff Report – Item 9
____________________________________________________________________________________ TO: Board of Directors
FROM: Jack Clark, Chief Operating Officer
Jen Lebron, Senior Director of Public Affairs
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Community Advisory Committee Monthly Report
DATE: May 22, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and file the Community Advisory Committee (CAC) monthly report.
BACKGROUND:
Per Section 5.10.3 of the San Diego Community Power (Community Power) Joint Powers Authority 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 a venue for ongoing citizen support and engagement in the strategic direction, goals, and programs of SDCP.
At the direction of the Board Chair, the CAC provides quarterly presentations to the Board of Directors in the regular agenda and monthly reports in the consent agenda. The next quarterly update is expected to take place at the May 22, 2025 Board meeting.
ANALYSIS AND DISCUSSION:
During the May 8, 2025, regular CAC meeting:
• Chair Vasilakis (City of San Diego) welcomed new Community Power staff, and led the unanimous approval of the consent agenda, which included updates on Customer Operations, Marketing, Public Relations and Local Government Affairs, Power Services, Programs, and Regulatory and Legislative Affairs. • The CAC received a presentation from the Programs team on Vehicle-Grid Integration. Members had questions around battery warranty, charging fleet inventory and needs from member agencies, program marketing and enrollment 74 strategies, and local automaking presence, with the suggestion of creating partnerships that foster workforce training on emerging technologies. • Members also heard an update on the Solar Advantage Program. Members asked about battery inclusion in the solicitation, upfront financing, and collaboration with member agencies to augment project benefits. Member Sclafani (City of Chula Vista), who represents the member agency where the Luminia project is in, congratulated staff for repurposing a community hub previously used for a public good during the pandemic, and asked clarifying questions on the enrollment priority system, encouraging Community Power to take a more collaborative approach with developers that ends up in more community projects that directly benefit the neighboring communities.
• The Chair shared as an announcement that Community Power visited Orange County Power Authority’s CAC earlier in May to provide an overview of how members inform decision-making. No Board of Directors items were recommended.
As of May 22, 2025, the CAC has one vacancy representing the City of Chula Vista.
Members of the public must be residents, community leaders, and/or business owners of the respective jurisdictions and may submit their applications electronically. The vacancy continues to be advertised at meetings, community events, and through Community Power’s social media.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
75 SAN DIEGO COMMUNITY POWER
Staff Report – Item 10
______________________________________________________________________ TO: Board of Directors
FROM: Jack Clark, Chief Operating Officer
Jen Lebron, Senior Director of Public Affairs
Xiomalys Crespo, Sr. Community Engagement Manager
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Community Advisory Committee Report
DATE: May 22, 2025
______________________________________________________________________ RECOMMENDATION:
Receive and file the Community Advisory Committee (CAC) quarterly report.
BACKGROUND:
Per Section 5.10.3 of the San Diego Community Power (Community Power) 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 Community Power.
At the direction of the Chair of Community Power’s Board of Directors, the CAC, via staff, provides monthly updates and quarterly reports during the regular meetings of the Board of Directors. The last quarterly update was provided during the February 27, 2025, regular meeting.
ANALYSIS AND DISCUSSION:
At the February 27, 2025, regular meeting of the Board of Directors, staff and the Chair of the CAC presented a summary of CAC activities from October through January. This report summarizes February through April.
February: Due to lack of agenda items, the meeting was canceled at the recommendation of the CAC Chair.
7676
March: Chair Vasilakis (City of San Diego) welcomed new CAC member Ross Pike (unincorporated San Diego County). Community Power CEO Karin Burns provided an update on Strategic Planning Goals for FY2026-2028; CAC members had an opportunity to provide feedback on this process earlier this year via individual briefings. The CAC unanimously voted to recommend Board approval of the item. Members also received a presentation on 2025 Rate Adjustments, as approved by the Board in February. Finally, members heard from the 2024 and 2025 cycles of the Community Clean Energy Grant Program, and a member sought clarification on the year-to-year difference in the program budget.
April: The CAC welcomed new member Shaun Sumner (City of La Mesa). The Regulatory and Legislative Affairs team provided its quarterly presentation, in which members asked questions around financing and undergrounding provisions on 47 Senate bills being supported by Community Power and recognized the work of the Regulatory and Legislative Affairs team, offering up their support in representing their communities when advocating for critical issues at different decision-making levels. Members also received a presentation on Equitable Building Decarbonization Direct Install Program, which is only open to low-income communities and will include renters. Lastly, the Power Services team provided an overview of items they will bring to the CAC in the coming months, which include those that the CAC has previously expressed interest in, such as local infill procurement, progress towards achieving 100% renewable energy by 2035, battery safety, and the Energy Proposal Evaluation Criteria. Members thanked Chief Commercial Officer Byron Vosburg for his contributions to the agency as he departs Community Power and requested future presentations on feed-in tariff programs and battery storage safety concerns.
As of May 6, 2025, the CAC has a vacancy representing the City of Chula Vista.
Prospective members of the CAC must be residents, community leaders, and/or business owners of the respective jurisdictions and may submit their applications electronically.
The vacancy continues to be advertised at meetings, community events, and through Community Power’s social media.
Staff will return to the Board of Directors in the summer of 2025 to report on quarterly activities for the rest of the fiscal year.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
7777
SAN DIEGO COMMUNITY POWER
Staff Report – Item 11
TO: Board of Directors
FROM: Dr. Eric Washington, Chief Financial Officer
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Presentation of Draft of FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan DATE: May 22, 2025
RECOMMENDATION:
Receive and File Preliminary Draft of FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan.
BACKGROUND:
On October 1, 2019, the Founding Members of San Diego Community Power (Community Power) adopted the Joint Powers Agreement (JPA) which was amended and restated on December 16, 2021. Section 4.6.2 of the JPA specifies that the Community Power Board of Directors (Board) shall adopt an annual budget prior to the commencement of the fiscal year. The JPA further provides that Community Power’s fiscal year runs from July 1 to June 30, unless changed by the Board.
Section 7.3.1 of the JPA requires that Community Power budgets be prepared and approved by the Board in accordance with its fiscal management policies that should include a deadline for approval.
On July 28, 2022, the Board adopted a budget development schedule as part of the Community Power Budget Policy. This development schedule includes an annual budget review in May by the Financial and Risk Management Committee (FRMC), which occurs prior to the Community Power Board of Directors (Board) previewing the budget in May and prior to the Board potentially adopting the budget in June. 7878
Table 1. Current Budget Development Schedule
Table 2 illustrates the proposed FY 2025-2026 budget in comparison to Community Power’s budgets from prior years. Note that the CIP is included in Total Expenses.
Table 2. Community Power Budget History
ANALYSIS AND DISCUSSION:
The proposed FY 2025-2026 operating budget includes net operating revenue of $1,199,619,579 and total expenses of $1,034,189,011, resulting in net position of $165,430,569.
The proposed FY 2025-2026 capital budget includes revenue and expenses of $54,390,333 to fund 12 projects in FY 2025-2026 totaling 21 active projects during the fiscal year.
The proposed FY 2026-2030 capital investment plan includes 21 projects that will receive funding in the five-year period, totaling $304.3 million in investments. The first year of the FY 2026-2030 CIP comprises the FY 2025-2026 capital budget. Additionally, $10.3 million in unspent continuing funds were appropriated by the Board in prior fiscal years and is represented as carryforward revenue.
The proposed budget includes the key assumptions outlined below.
Operating Revenue
Community Power’s net operating revenue consists primarily of revenues from sales of electricity. Assumptions regarding net operating revenue include:
• Enrollment of customers is complete from all member jurisdictions.
Operating Budget Net Revenues Total Expenses Net Position FY 2020-2021 Amendment $26,286,909 $33,778,000 ($7,848,092) FY 2021-2022 Amendment $378,053,506 $341,177,063 $35,876,443 FY 2022-2023 Amendment $929,791,929 $772,078,710 $157,713,219 FY 2023-2024 Amendment $1,304,274,067 $1,070,891,284 $233,382,783 FY 2024-2025 Amendment $1,221,258,172 $1,187,090,169 $34,168,003 FY 2025-2026 Proposed $1,199,619,579 $1,034,189,011 $165,430,569 7979
• 95% participation rate across all jurisdictions.
• A 1.75% uncollectible rate which remains the same as last fiscal year. • Rates that were set and approved by the Board on February 7, 2025.
Cost of Energy includes all the various services purchased from the power market through our counterparties to supply energy to Community Power’s customers.
Operating Expenses
Community Power’s non-energy operating expenses fall into four categories: “personnel costs”, “professional services and consultants”, “marketing and outreach”, and “general and administration.” Expense assumptions include the following:
• Personnel include salaries, payroll taxes, benefits, and excused absence and paid time off for staff. The recruitment strategy includes the addition of approximately 7 new staff members during the FY 2025-26 budget cycle, growing the agency to 94 total staff.
• Professional Services and Consultants include SDGE fees, data management fees from Calpine, technical support (for rate setting, load analysis, energy scheduling, etc.), legal/regulatory services and other general contracts related to IT services, audits and accounting services.
• Marketing and Outreach includes expenses for mandatory notices, communication consultants, mailers, printing, sponsorships, and partnerships to inform the community of Community Power.
• General and Administration budget covers the cost of office space, equipment, membership dues, and other general operational costs.
Non-Operating Expenses
Community Power’s budget also includes non-operating expenses related to interest and related expenses used to finance its operations. These costs are comprised of associated interest costs as well as potential renewal fees on debt or letters of credit.
Capital Investment Program (CIP)
In FY 2025-2026 Community Power is continuing its Capital Investment Program (CIP) which contains all the individual capital projects, equipment purchases, and major programs for the agency that are intended to span multiple years. The FY 2025-2026 operating budget proposes a one-time portion of net operating revenues be transferred to the CIP as a continuing fund in which any unspent funds are kept within that fund and carried forward to the subsequent fiscal year. Additionally, the first year of the CIP is the proposed FY 2025-2026 capital budget.
Net Income
The proposed FY 2025-26 budget results in a net position of $165,430,569. 8080
The following table illustrates Community Power’s proposed FY 2025-26 operating budget compared to the amended budgets for FY 2023-24 and FY 2024-25.
Table 3. FY 2025-26 Proposed Budget compared to the FY 2023-24 and FY 24-25 Amended Budgets.
FY24 Amended FY25 Amended FY26 Proposed
Gross Revenue 1,365.7 1,243.0 1,221.0
Less Uncollectible Accounts -61.4 -21.8 -21.4
Net Operating Revenues 1,304.3 1,221.3 1,199.6
Cost of Energy 1,020.8 1,116.8 956.7
Non-Energy Costs 43.8 50.8 54.3
Subtotal Operating Expense 1,064.6 1,167.6 1,010.9
Debt Service 2.4 1.3 1.9
Capital Investment Program (Transfer
Out) 4.7 18.2 21.4
Total Expenses 1,071.0 1,187.1 1,034.2
Net Position 233.3 34.2 165.4
Amounts displayed in
millions, $
The next table illustrates Community Power’s proposed FY 2026-2030 capital investment plan. The first year of the FY 2026-2030 capital investment plan represents Community Power’s FY 2025-2026 capital budget.
Table 4. Community Power FY 2026-2030 Capital Investment Plan Carry-forward 5-Year Capital Investment Plan
FY25 FY26 FY27 FY28 FY29 FY30 Total
External Funding
Regional Energy
Network 0.3 31.8 59.5 51.4 42.0 43.7 228.7
DAC-GT 0.5 0.3 0.5 0.5 0.5 0.5 2.7
CDFA 0.5 - - - - - 0.5
Equitable Building
Decarbonization 1.5 - - - - - 1.5
Other - 0.9 - - - - 0.9
Subtotal 2.8 33.0 60.0 51.9 42.5 44.2 234.4
Solar Battery Savings 2.7 18.8 11.1 10.4 8.3 8.5 59.8
Energy Efficiency - - - - - - -
8181
Pilot Programs 1.7 - - - - - 1.7
Grants 0.7 0.8 - - - - 1.5
DER 0.1 - - - - - 0.1
Flexible Load 0.2 0.3 0.6 0.6 0.8 0.7 3.1
IT Projects 2.0 1.5 - - - - 3.5
Community Education 0.0 - - - - - 0.0
App Assistance - 0.3 - - - - 0.3
Program Evaluation - 0.3 - - - - 0.3
Other - 0.2 - - - - 0.2
Subtotal 7.5 21.4 11.7 11.0 9.1 9.2 69.9
CIP Expense Total 10.3 54.4 71.7 62.9 51.6 53.4 304.3
FISCAL IMPACT:
The proposed FY 2025-26 budget is expected to result in a net position of $165.4 million, with resulting total cash reserves of $572.8 million, or 207-days cash on hand by the end of FY 2025-2026, based on the agency’s current projections which are subject to change, especially as energy markets fluctuate.
Community Power additionally proposes a one-time investment of $21.4 million into the agency’s Capital Investment Program. The large majority of this one-time investment is meant to fund $18.8 million for the Solar Battery Savings program, which offers upfront and performance-based incentives for home battery systems that boost resilience and reduce grid demand. The program was recognized in the U.S. Department of Energy’s 2025 Virtual Power Plant Liftoff Report as a model for customer-centered innovation in distributed energy and offers incentives savings to customers while also reducing energy costs for Community Power during peak periods of demand.
ATTACHMENTS:
A: Draft FY 2025-2026 Operating Budget Book
B: Draft FY 2026-2030 Capital Investment Plan
8282
ITEM 11
ATTACHMENT A
83 ITEM 12
ATTACHMENT c
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026
FISCAL YEAR
2025
2026
SAN DIEGO COMMUNITY POWER
Resolution 2025-XX Proposed June 26, 2025
Fiscal Year 2025–2026
Operating Budget
84 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Contents ii Contents
How to Use This Book 1
A Letter from the Chief Executive Officer 2
Overview of San Diego Community Power 5
Who We Are 5
About Community Choice 6
How It Works 6
Serviced Communities 7
County Population 7
Governance and Structure 9
Organizational Structure 10
Executive Team 10
Budget Process 12
Annual Budget Cycle 12
Strategic Planning 13
Community Outreach Strategy 17
Budget Guidelines 19
Budget Structure 20
Fund Structure 22
FY 2025–2026 Budget Principles 23
Budget Overview 25
Budget in Brief 25
Proposed Operating Budget 25
Operating Revenue 26
Operating Expenses 28
Operating Expenses by Department 28
Personnel by Department 29
Proposed Capital Budget 30
About the CIP 32
Five-Year Financial Plan 35
Budget by Department 37
Executive 37
Operations 38
Power Services 39
Finance 40
85 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Contents iii Customer Operations 41 IT and Data Analytics 42 Public Affairs 43 Programs 44
Regulatory and Legislative Affairs 45
Human Resources and Administration 46 Legal 47
Budget by Level 2 and Level 3 49
Operating Revenue 49
Cost of Energy 50 Professional Services and Consultants 51 Personnel Costs 52 Marketing and Outreach 52 General and Administration 53 Programs 53
Debt Financing 55
Credit Facility 55 Debt Considerations 55
Financial Policies 58
Budget Policy 58
Financial Reserves Policy 60 Policy Guidelines 60 Definitions 60 Conditions for Use of Reserves 60 Procurement Policy 61 Debt Policy 64 Investment Policy 72 Rate Development Policy 82 Glossary of Terms 85
Budget Resolution 93 Acknowledgments 95
86 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Contents iv List of Figures
FIGURE 1. CCAS IN CALIFORNIA 6
FIGURE 2. SAN DIEGO MAP IN SAN DIEGO COUNTY 7
FIGURE 3. SAN DIEGO COUNTY POPULATION 8
FIGURE 4. PARTICIPATION BY JURISDICTION 9
FIGURE 5. PARTICIPATION RATES ACROSS CCAS 9
FIGURE 6. COMMUNITY POWER MEMBER AGENCIES 9
FIGURE 7. ORGANIZATIONAL STRUCTURE 10
FIGURE 8. EXECUTIVE TEAM 10
FIGURE 9. TYPICAL ANNUAL BUDGET PROCESS 12
FIGURE 10. BUDGET CALENDAR 13
FIGURE 11. SAN DIEGO COMMUNITY POWER MISSION STATEMENT 14 FIGURE 12. SAN DIEGO COMMUNITY POWER VISION STATEMENT 16 FIGURES 13 & 14. SOCIAL MEDIA OUTREACH 17
FIGURES 15, 16 & 17. COMMUNITY OUTREACH AND EDUCATION 18 FIGURE 18. KEY DOCUMENTS PAGE ON WEBSITE 19
FIGURE 19. BUDGET STRUCTURE — DEPARTMENT HIERARCHY 20
FIGURE 20. BUDGET STRUCTURE — BUDGET LEVEL HIERARCHY 21 FIGURE 21. COMMUNITY POWER FUND STRUCTURE 23
FIGURE 22. COMMUNITY POWER FUND AND BUDGET LEVEL HIERARCHY RELATIONSHIP 23 FIGURE 23. BUDGET PRINCIPLES 23
FIGURE 24. COMMUNITY POWER’S RATE PRODUCTS* 26
FIGURE 25. COMMUNITY POWER REVENUE TREND 27
FIGURE 26. COMMUNITY POWER’S DEPARTMENTS 30
FIGURE 27. CIP DEVELOPMENT PROCESS 32
FIGURE 28. OPERATING REVENUES VS. EXPENDITURES 34
FIGURE 29. OPERATING BUDGET 34
FIGURE 30. SAN DIEGO COMMUNITY POWER RESERVES 35
FIGURE 31. EXECUTIVE ORGANIZATIONAL STRUCTURE 37
FIGURE 32. OPERATIONS ORGANIZATIONAL STRUCTURE 38
FIGURE 33. POWER SERVICES ORGANIZATIONAL STRUCTURE 39
FIGURE 34. FINANCE ORGANIZATIONAL STRUCTURE 40
FIGURE 35. CUSTOMER OPERATIONS ORGANIZATIONAL STRUCTURE 41 FIGURE 36. IT AND DATA ANALYTICS ORGANIZATIONAL STRUCTURE 42 FIGURE 37. PUBLIC AFFAIRS ORGANIZATIONAL STRUCTURE 43
FIGURE 38. PROGRAMS ORGANIZATIONAL STRUCTURE 44
FIGURE 39. REGULATORY AND LEGISLATIVE AFFAIRS ORGANIZATIONAL STRUCTURE 45 FIGURE 40. HUMAN RESOURCES AND ADMINISTRATION ORGANIZATIONAL STRUCTURE 46 FIGURE 41. LEGAL ORGANIZATIONAL STRUCTURE 47
FIGURE 42. COMMUNITY POWER’S DEBT 2020–2024 56
FIGURE 43. COMMUNITY POWER’S DEBT BY MONTH 56
87 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Contents v List of Tables
TABLE 1. OPERATING BUDGET OVERVIEW 25
TABLE 2. OPERATING REVENUE BY BUDGET LEVEL 2 27
TABLE 3. OPERATING EXPENSES BY BUDGET LEVEL 2 28
TABLE 4. OPERATING EXPENSES BY DEPARTMENT 28
TABLE 5. PERSONNEL BY DEPARTMENT 29
TABLE 6. FY 2025–2026 CAPITAL BUDGET OVERVIEW 30
TABLE 7. OPERATIONS POSITIONS 39
TABLE 8: POWER SERVICES POSITIONS 40
TABLE 9. FINANCE POSITIONS 41
TABLE 10. CUSTOMER OPERATIONS POSITIONS 43
TABLE 11. IT AND DATA ANALYTICS POSITIONS 44
TABLE 12. PUBLIC AFFAIRS POSITIONS 45
TABLE 13. PROGRAMS POSITIONS 46
TABLE 14. REGULATORY AND LEGISLATIVE AFFAIRS 47
TABLE 15. HUMAN RESOURCES & ADMINISTRATION POSITIONS 48 TABLE 16. LEGAL POSITIONS 49
TABLE 17. OPERATING REVENUE BY BUDGET LEVEL 2 AND LEVEL 3 51 TABLE 18. COST OF ENERGY BY BUDGET LEVEL 2 AND LEVEL 3 52 TABLE 19. PROFESSIONAL SERVICES AND CONSULTANTS BY BUDGET LEVEL 2 AND LEVEL 3 53 TABLE 20. PERSONNEL COSTS BY BUDGET LEVEL 2 AND LEVEL 3 54 TABLE 21. MARKETING AND OUTREACH BY BUDGET LEVEL 2 AND LEVEL 3 54 TABLE 22. GENERAL AND ADMINISTRATION BY BUDGET LEVEL 2 AND LEVEL 3 55 TABLE 23. PROGRAMS BY BUDGET LEVEL 2 AND LEVEL 3 55
TABLE 24. DEBT PAYMENTS 57
88 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 How to Use This Book 1 How to Use This Book
Executive Summary
Includes the Chief Executive Officer’s Letter and the Executive Summary of the proposed operating budget and provides a high-level overview of the agency’s budget, the changes from the prior year and other high-level details on specific highlights and changes in the proposed operating budget.
Overview
Provides a high-level overview of Community Power’s
governance, structure and agency values and priorities.
Budget Process
Describes the various financial planning and budgeting
processes and reports that inform the budget process.
Budget Overview
Describes the budget in brief, financial data summarizing Community Power’s proposed budget, the Capital
Investment Plan and the agency’s five-year financial plan.
Budget Information and
Summary Tables
Provides technical information on the structure, policies and processes that govern Community Power’s budget
development and implementation as well as high-level
financial data summarizing Community Power’s proposed
budget. The tables detail changes over a two-year period:
FY 2024–2025 Amended Budget and the proposed
FY 2025–2026 Operational Budget. The variance column
measures the dollar and position differences between
fiscal years.
The San Diego Community Power (Community Power) Fiscal Year (FY) 2025–2026 operating budget contains agency budgetary and fiscal policy information as well as detailed operating budgets for agency divisions. The proposed operating budget is organized into the following sections:
Operational Budgets
Provides budgetary information and operational priorities for each of Community Power’s departments. Department
information is organized alphabetically by division name and includes the following information:
Mission and Services
Department Highlights
Professional Services Agreement
Objective Key Results
Department Positions
Organizational Chart — depicts the department’s
organizational structure
Budget Data Summary — shows a summary of total
expenditures and funded positions
Additional Resources
Provides additional information, including applicable
Community Power policies as well as a glossary of
commonly used terms.
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY2025–2026 89 How to Use This Book 1
A Letter from the Chief Executive Officer 2
At San Diego Community Power, we are shaping a future that is both sustainable and equitable. As a not-for-profit public agency and Community Choice Aggregator (CCA), we were created to bring competition to the local energy marketplace, offering cleaner energy at competitive rates and reinvesting revenues back into our communities.
Since launching in 2021, we’ve grown significantly in both reach and impact. In 2024, we remained focused on our mission: delivering reliable, clean power at competitive rates while advancing programs that make a tangible difference for our customers.
Affordability and long-term value remain central to our strategy. In February 2025, we reduced rates for the second year in a row — thanks to prudent financial planning and favorable market conditions — providing most customers with a discount compared with San Diego Gas & Electric’s electricity generation rates.
Every decision we make, from lowering rates to expanding service options, is grounded in the needs of our customers and communities. Last summer, we introduced two new service options: Power100 Green+, for commercial customers seeking the highest level of renewable energy, and PowerBase, a more affordable option that still meets California’s clean energy standards Even as we deliver near-term savings, we continue to plan for long-term energy security and stability. The broader power market remains volatile, shaped by a constrained statewide resource supply and uncertain federal tax credit and trade policies. Our Power Services team is navigating these challenges through disciplined procurement and long-range planning.
To date, we’ve executed 17 long-term power purchase and energy storage agreements that will deliver reliable, renewable electricity to nearly 1 million homes and businesses across our region. These investments not only support our goal of 100% renewable energy by 2035, but also help insulate customers from future price spikes.
In 2024, we marked a major milestone with the ribbon cutting of the Vikings Solar and Storage Project in Imperial County. Developed by Arevon, with Community Power as the offtaker, Vikings is more than just a solar generation site. As one of the first utility-scale solar peaker plants in the United States, the project is designed to keep the lights on and costs down when demand is at its highest — powering the equivalent of 50,000 San Diego homes with clean, affordable energy. It exemplifies our broader procurement strategy: securing long-term renewable power while creating local and regional economic opportunity.
In addition to expanding customer choice and value, we’ve made progress on delivering innovative solutions that support customers across the region. Last summer, we launched our largest customer program to date, Solar Battery Savings, which offers upfront and performance-based incentives for home battery systems that boost resilience and reduce grid demand during peak hours. The program was recognized in the U.S. Department of Energy’s 2025 Virtual Power Plant Liftoff Report as a model for customer-centered innovation in distributed energy.
We also secured approval from the California Public Utilities Commission to launch the San Diego Regional Energy Network (SDREN) in partnership with the County of San Diego. SDREN will generate nearly $125 million in energy efficiency resources for the region through 2027 and marks the final major population area in California to establish a Regional Energy Network.
A Letter from the
Chief Executive Officer
90 A Letter from the Chief Executive Officer 3
Chief Executive Officer
San Diego Community Power
As we grow, we’re also investing in the internal systems and strategic planning necessary to scale effectively, operate efficiently and remain accountable to the public.
The FY 2025–2026 proposed budget reflects these priorities, with a focus on smart investment and sustainable growth:
1. Expanding Programs and Incentives — Scaling Solar Battery Savings and launching the SDREN portfolio to support clean energy adoption, equity and resilience
2. Capital Investment Planning — Advancing our Capital Investment Plan to guide infrastructure development and ensure transparency
3. Stable, Competitive Rates — Maintaining affordability through disciplined operations, long-term procurement and financial foresight
4. Customer-Centered Services — Deepening engagement, broadening access and tailoring offerings to meet diverse community needs
5. Organizational Sustainability — Strengthening our internal capacity to support long-term strategy and service delivery
6. Fiscal Sustainability — Continuing to work toward our reserves goals to ensure long-term financial strength As we look ahead, our focus remains on driving measurable impact: accelerating the region’s clean energy transition, supporting local climate goals and building a more just and resilient energy system.
With the continued leadership of our Board of Directors, Community Advisory Committee and dedicated staff, San Diego Community Power is proud to power the path toward a cleaner, more resilient future — together.
Thank you for your continued trust and partnership.
91 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Overview of San Diego Community Power 4 v
Overview of
San Diego
Community
Power
01 92
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Overview of San Diego Community Power 5 Who We Are
Our Story
San Diego Community Power is a Community Choice
Aggregator (CCA) that gives customers an option to power their homes and businesses with significantly higher levels of renewable power at competitive rates. Since 2021,
Community Power has grown to serve nearly 1 million
residential, business and municipal power customers in the cities of San Diego, Chula Vista, Encinitas, Imperial Beach, La Mesa and National City as well as the unincorporated communities of San Diego County.
With support from local communities, Community Power
was established as a Joint Powers Authority by five cities within the San Diego region. Community Power submitted
an implementation plan to the California Public Utilities Commission, outlining the intended organizational structure, operations and funding. Once approved, our Board of Directors began to meet regularly, and implementation activities began.
In 2020, a sixth city and the County of San Diego elected to join Community Power.
Through phased enrollment from 2021
through 2023, Community Power
gradually became the official clean
energy provider for our member agencies.
Customers were automatically enrolled
in our service and received two notices
before and two notices after enrollment.
Community Power serves
nearly 1 million customers with
competitively priced clean
energy; we are beginning to offer
customer programs and rebates
as well as supporting San Diego
County’s energy efficiency goals
through the San Diego Regional
Energy Network (SDREN).
Overview of San Diego Community Power
Community Power is a not-for-profit public agency that
provides affordable clean energy and invests in its local communities to create an equitable and sustainable future for the San Diego region.
Learn more at www.sdcommunitypower.org.
FORMATION ENROLLMENT 2021–2023 TODAY
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY2025–2026 93 Overview of San Diego Community Power 5
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Overview of San Diego Community Power 6 About Community Choice
Community
Power
purchases electricity
from renewable sources.
delivers power and
manages services.
enjoy cleaner power
at competitive rates.
SDG&E You
San Diego Community Power is a Community Choice
Aggregator (CCA) — one of dozens that have formed
throughout California over the past 20 years. There are currently 25 CCAs serving over 14 million customers
in California.
CCAs are making good on their commitments to invest
in new renewable energy facilities throughout California.
To date, CCAs have contracted for more than 18,000
megawatts (MW) of new clean generation capacity through long-term power purchase agreements (PPAs) with terms of 10 years or more. CCA PPAs equate to:
• More than 18 gigawatts (GW) of new solar, wind, energy storage, geothermal and demand response resources
• Projects totaling more than 7,900 MW that are already operational and serving CCA customers
• More than $37 billion committed by CCAs to build and
operate clean energy resources
• Support for more than 36,000 construction jobs
How It Works
FIGURE 1. CCAS IN CALIFORNIA
Through CCAs, communities can join together to pool
(or aggregate) their electricity load in order to purchase clean energy and develop local clean energy projects and programs on behalf of their residents and businesses. CCAs like Community Power work in partnership with the region’s existing investor-owned utilities (SDG&E in our case), which continue to deliver power and maintain the grid.
94 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Serviced Communities 7 v
Serviced
Communities
02 95
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Serviced Communities 8 Serviced Communities
SERVICE AREA MAP
FIGURE 2. SAN DIEGO MAP IN SAN DIEGO COUNTY
County Population
San Diego County is the southernmost major metropolitan area in California and boasts a diverse and vibrant
population. According to the State of California Department of Finance, as of May 2022, San Diego County’s estimated population on January 1, 2022, stood at 3.29 million. This figure represents a decline of 0.85% (approximately 28,000 individuals) from the January 1, 2021, estimates reported in May 2021. San Diego County ranks as the second-largest
California county by population and the fifth-largest county nationwide. These rankings are based on data from the U.S.
Census Bureau, which relies on the 2021 population estimate.
Looking ahead, population estimates from the San Diego
Association of Governments (SANDAG) project significant growth. By the year 2035, the San Diego regional population is expected to reach approximately 3.62 million, reflecting a substantial 28.7% increase compared to the year 2000, or a
10.1% increase compared to the year 2022.
96 Overview of San Diego Community Power 8
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Overview of San Diego Community Power 9 San Diego County Population
COUNTY/CITY 4/1/2020 1/1/2021 1/1/2022 1/1/2023 1/1/2024 San Diego County
Carlsbad 115,029 115,373 115,033 115,045 114,319
Chula Vista 275,127 275,498 275,427 276,813 278,247
Coronado 23,504 22,415 22,082 22,272 21,589
Del Mar 3,951 3,927 3,909 3,918 3,919
El Cajon 106,321 106,112 105,171 104,804 104,180
Encinitas 61,506 61,593 61,283 61,254 61,028
Escondido 151,289 151,371 150,419 150,571 150,002
Imperial Beach 26,577 26,336 26,163 26,109 26,096
La Mesa 60,637 60,620 60,412 60,753 60,620
Lemon Grove 27,386 27,333 27,109 27,517 27,568
National City 58,643 58,524 58,545 58,374 58,555
Oceanside 173,283 173,354 172,463 172,186 171,483
Poway 48,781 48,637 48,515 48,620 49,273
San Diego 1,383,020 1,377,960 1,375,687 1,383,623 1,385,379 San Marcos 94,287 93,456 93,851 94,823 95,998
Santee 59,654 59,140 58,886 59,574 59,195
Solana Beach 12,931 12,890 12,792 12,831 12,887
Vista 98,690 99,320 99,997 100,113 99,723
Balance of County 518,018 513,021 510,986 511,223 511,040 Incorporated 2,780,616 2,773.859 2,767,744 2,779,200 2,780,061 County Total 3,298,634 3,286,880 3,278,730 3,290,423 3,291,101 Source: U.S. Census, 2010 data; California Department of Finance 2021 estimates as of May 2, 2021, and May 2, 2024.
FIGURE 3. SAN DIEGO COUNTY POPULATION
97 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Serviced Communities 10 Participation by Jurisdiction
Participation Rates Across CCAs
100%
95.6%
City of
Chula Vista
City of
Encinitas
City of
Imperial
Beach
City of
La Mesa
95.9% 95.1%
City of
San Diego
96.5%
County of
San Diego
91.7%
National
City
98.2%
93.0%
90%
80%
100%
95%
90%
85%
80%
75%
70%
98%
96% 96% 96% 96% 96% 95% 95% 94% 94% 93% 93% 92% 91% 90% 90% 90% 90% 87% 86% 86%
84% 83%
76%
San Jose Clean Energy
Clean PowerSF
Peninsula Clean Energy
Rancho Mirage Energy Authority
San Diego Community Power
Silicon Valley Clean Energy
Ava Community Energy
Clean Energy Alliance
Santa Barbara Choice Energy
Clean Power Alliance
Prime
Pomona Choice Energy
Redwood Coast Energy Authority
Palmdale EPIC Energy
Lancaster Energy
San Jacinto Power
Valley Clean Energy
MCE
Apple Valley Choice Energy
Sonoma Clean Energy
Pioneer Community Energy
Desert Community Energy
OCPA
3CE
FIGURE 4. PARTICIPATION BY JURISDICTION
FIGURE 5. PARTICIPATION RATES ACROSS CCAS
FIGURE 6. COMMUNITY POWER MEMBER AGENCIES
JURISDICTION SERVICE
OPTION
DEFAULT
ELIGIBLE
ACCOUNTS
ENROLLED
ACCOUNTS
PARTICIPATION
RATE
City of Chula Vista PowerOn 98,635 94,255 95.6%
City of Encinitas Power100 28,804 26,792 93%
City of Imperial Beach PowerOn 10,852 10,403 95.9%
City of La Mesa PowerOn 29,514 28,066 95.1%
National City PowerOn 19,431 19,085 98.2%
City of San Diego PowerOn 624,704 603,071 96.5%
County of San Diego PowerOn 190,214 174,419 91.7%
Total 1,002,154 956,091 95.4%
Governance
and Structure
Source: https://cal-cca.org/. Current as of December 2023.
In September 2019, the cities
of San Diego, Chula Vista,
Encinitas, Imperial Beach and
La Mesa adopted an ordinance
and resolution to form San
Diego Community Power,
a California Joint Powers
Authority (JPA). In 2021,
National City and the County
of San Diego voted to join
Community Power.
Community Power’s Board of
Directors is composed of an
elected representative from
each member jurisdiction,
with each member having
an alternate from the agency
they represent. The Board
is publicly accountable to
Community Power ratepayers
and hosts monthly Board
meetings, where it establishes
policy, sets rates, determines
power purchase options and
maintains fiscal oversight.
As a public agency, Community
Power is designed to be fully
transparent with all official
meetings and information
open or available to the public.
98 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Serviced Communities 11 Organizational Structure
Executive Team
BOARD OF DIRECTORS
Paloma Aguirres
Chair
Sean Elo-Rivera
Councilmember
Michael Inzunza
Councilmember
Ditas Yamane
Councilmember
Terra Lawson-Remer
Vice Chair
Marco San Antonio
Councilmember
Genevieve Suzuki
Councilmember
CHIEF EXECUTIVE OFFICER
Karin Burns
LEGAL
General Counsel
OPERATIONS
Chief Operating Officer
FINANCE
Chief Financial Officer/
Treasurer
POWER
SERVICES
Chief Commercial
Officer
HUMAN RESOURES
& ADMINISTRATION
Senior Director of
People Operations &
Administration Data Analytics &
Account Services
Public Affairs Programs
Regulatory &
Legislative Affairs
Clerk of the Board
Finance & Risk
Management Committee
Community Advisory Committee
FIGURE 7. ORGANIZATIONAL STRUCTURE
FIGURE 8. EXECUTIVE TEAM
Karin Burns
Chief Executive
Officer
Eric Washington
Chief Financial Officer
and Deputy Chief
Executive Officer/
Treasurer
Jack Clark
Chief Operating
Officer
Veera Tyagi
General Counsel
Vacant
Chief Commercial
Officer
99 SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 12 v
Budget
Process
03 100
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 13 Annual Budget Cycle
Budget Process
On October 1, 2019, the Founding Members of San Diego
Community Power adopted the Joint Powers Agreement
(JPA), which was amended and restated on December 16,
2021. Section 4.6.2 of the JPA specifies that the Community Power Board of Directors (Board) shall adopt an annual
budget prior to the commencement of the fiscal year. The JPA further provides that Community Power’s fiscal year runs from July 1 to June 30, unless changed by the Board. Section
7.3.1 of the JPA additionally specifies that the Board may revise the budget from time to time as may be reasonably necessary to address contingencies and unexpected expenses.
The Community Power Boards adopted the Community
Power Budget Policy on July 28, 2022, which formally
outlined the agency’s budget preparation steps and timeline.
The chief financial officer (CFO) begins the annual budget process in February of each year. The Finance Department develops initial revenue and expense estimates and updates its short-term financial plan. In March and April, Community Power staff develops and refines budget proposals in
order to develop an initial budget baseline for the Agency’s upcoming budget year. The budget is further refined through strategic planning sessions and through the Community
Power Finance and Risk Management Committee (FRMC).
The CFO is then required to prepare and submit to the
Board a draft proposed budget for the next following fiscal year in May or no later than the second month immediately preceding the start of the respective fiscal year. The budget shall be in alignment with established goals and shall reflect all activities including operating programs, revenues and expenditures. The budget shall be approved by the Board at a public meeting in June or no later than the month
immediately preceding the start of the respective fiscal year.
FEB MAY JUN JUL
MAR
-
APR
Develop Operating
Revenue Estimate
Develop Operating
Expense Estimate
Staff develop
operation budgets
Baseline budget
is developed
Community Power
Board Preview and
Public Budget Hearing
Finance and Risk
Management
Committee Review
Community Power
Board Approval
July 1 Budget
Implemented
FIGURE 9. TYPICAL ANNUAL BUDGET PROCESS
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY2025–2026 101
Budget Process 13
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 14 Budget Calendar
Strategic Planning
DATE MILESTONE
January 2025 Finance Department prepares for February launch of the annual budget cycle.
February 2025 Budget process begins. Initial revenue and expense estimates are developed.
March to April 2025 Departments propose unconstrained expense requests for review.
April 2025 Staff sets initial budget baseline.
May 22, 2025 FY 2025–2026 budget is reviewed by the Board of Directors as an information item.
June 12, 2025 Community Advisory Committee reviews the FY 2025–2026 budget and provides feedback.
June 12, 2025 Finance and Risk Management Committee reviews the FY 2025–2026 budget and provides final feedback.
June 26, 2025 FY 2025–2026 budget is potentially adopted by the Board of Directors as an action item.
July 1, 2025 FY 2025–2026 budget is implemented.
FIGURE 10. BUDGET CALENDAR
San Diego Community Power’s budgeting process is directly informed by its Strategic Plan — a document co-created
by our Board, our CAC, our executives and our team — that translates community priorities into actionable goals. The Strategic Plan is a critical management tool, helping to align resources, guide operational decisions and drive long-term organizational focus across every department and initiative.
Now three years into our first strategic planning cycle, Community Power has reached a pivotal inflection point.
Since the adoption of our 2023–2027 Strategic Plan in
June 2022 and its subsequent update in April 2023, we’ve achieved many of the ambitious goals we set, made
meaningful progress on others and thoughtfully recalibrated where needed. From October 2024 to March of 2025 we
embarked on a revision and update to our strategic plan, setting aggressive new goals while continuing to focus our efforts, build our organization and deliver on the promise of community choice.
What hasn’t changed is our mission, vision and core values.
These foundational statements continue to guide our work even as we refine our priorities and strategies to reflect new opportunities, challenges and lessons learned. With our team, customer base and clean energy infrastructure significantly expanded, we now turn toward a new two- to three-year horizon — one defined by sustained growth,
increased financial responsibility and a deeper investment in the people and systems that power our organization.
As we evolve, we continue to ask a simple but powerful
question: Does this activity serve our purpose? Every
program, investment and initiative we pursue should answer “yes” to at least one of the following:
• Does it make energy more affordable for our customers? • Does it make things easier for our customers?
• Does it make our energy more renewable?
• Does it maintain or improve the health of our organization? • Does it build trust with our communities, stakeholders and local governments?
These questions — and the values underlying them — serve as a filter and a guidepost, helping to ensure that our Strategic Plan remains grounded in what matters most to our customers and communities.
102
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 15 Mission Statement
To provide affordable clean energy
and invest in the community to
create an equitable and sustainable
future for the San Diego region.
FIGURE 11. SAN DIEGO COMMUNITY POWER MISSION STATEMENT
As part of this new planning phase, Community Power has identified four overarching themes to guide our work:
Together, these priorities inform the structure of our proposed FY 2025–2026 budget and the evolution of our Strategic Plan. That work is organized around seven long-term Strategic Goals that anchor the agency’s planning and performance management. These goals guide not only how we invest our resources but also how we measure our progress as a public agency accountable to the communities we serve.
Fiscal Sustainability
We remain committed to building strong
financial reserves, managing risk and
pursuing strategies like clean energy prepay
transactions that can reduce long-term costs
for customers.
Infrastructure Investment
This includes both internal infrastructure,
such as IT, legal, data and policy capacity, and
external infrastructure, including local battery
storage, distributed energy resources and
virtual power plant development.
Customer Affordability
Affordability remains the top concern
voiced by our community and is front of
mind with every power purchase, financial
hedge, compliance obligation or additional
long-term power resource we contract
with to support our short- and long-term
procurement efforts. Our additional activities
— ranging from the development of targeted
rates like PowerBase to launching the San
Diego Regional Energy Network — will
continue to focus on reducing energy bills
while meeting state policy goals.
People
As we grow, so does our responsibility to
ensure a resilient and inclusive workplace
culture. We are investing in management
training, professional development and
succession planning to ensure strong
continuity and a high level of staff retention.
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY2025–2026 103
Budget Process 15
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 16 Core Strategic Goals
1. Fiscal Sustainability
Practice fiscal strategies to promote long-term
organizational sustainability.
• Execute at least six clean prepayment transactions over the next three years to generate $30 million in annual
power cost savings.
• Obtain a public investment-grade credit rating by
November 2027.
• Grow reserves by $150 million to maintain 180 days’
cash on hand by December 2027.
• Build a $70 million Rate Stabilization Reserve to
mitigate cost volatility.
• Strengthen financial controls across contracting, risk management and procurement.
2. Energy Portfolio Development
Provide sufficient, affordable and clean electricity
to our customers.
• Reach 100% renewable energy by 2035 with interim
goals of 75% by 2027 and 85% by 2030.
• Support development of 1 gigawatt of new local clean
energy capacity by 2035, including 300 MW of infill
and distributed energy resources (DERs).
• Ensure reliable and cost-effective compliance with all regulatory requirements.
• Create good-paying local jobs in clean energy sectors.
3. Community Program Delivery
Implement programs that reduce greenhouse gas
emissions, align energy supply and demand and benefit
our diverse communities.
• Deliver 150 MW of local DER capacity (of the 300 MW
total goal) by 2035 through programs like Solar Battery Savings.
• Launch all San Diego Regional Energy Network
(SDREN) programs by FY 2026.
• Implement a robust program evaluation framework
by FY 2026.
• Expand external funding for clean energy programs.
4. Legislative and Regulatory Advocacy
Advance policies that support Community Power’s
mission and customer goals.
• Educate policymakers and regulators to influence
outcomes consistent with our policy platform.
• Support and sponsor legislation aligned with our values and needs.
• Remain an active participant in coalitions such as
CalCCA to amplify our voice.
• Strategically pursue public funding aligned with
agency goals.
5. Trusted Brand Building
Build a trusted brand that supports engagement,
participation and program success.
• Position San Diego Community Power as a
collaborative public agency rooted in transparency.
• Grow the Power Network of nonprofit and community-based partners to expand community reach. • Elevate brand awareness through education
and outreach.
• Empower customers to take advantage of savings and
services through awareness, education and ongoing
communication programs.
6. Customer Care
Ensure high customer satisfaction and retention.
• Refine rate structures to balance affordability,
clean energy and fiscal prudence.
• Resolve SDG&E billing issues and improve
customer experience.
• Explore options for a best-in-class customer
service model.
• Address arrearages and connect customers to
available resources.
7. Organizational Excellence
Foster an innovative, inclusive and resilient workplace. • Transition into a learning organization by late 2026
with robust staff development.
• Maintain a high level of employee satisfaction through engagement and continuous feedback.
• Launch a new internship program for local college
students by FY 2027.
104
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 17 Vision Statement
A global leader inspiring innovative
solutions to climate change by
powering our communities with
100% clean energy while prioritizing
equity, sustainability and high-quality jobs.
FIGURE 12. SAN DIEGO COMMUNITY POWER VISION STATEMENT
Core Strategic Goals
Fiscal Sustainability Energy Portfolio
Development
Community Program
Delivery
Trusted Brand Building Legislative and Regulatory
Advocacy Customer Care Organizational Excellence
1 4 5 6 7
2 3
105
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 18 Community Outreach Strategy
As a public agency with a deep commitment to transparency and community accountability, San Diego Community
Power approaches outreach not as a one-time event, but as a continuous, year-round effort. Our budget process is informed by this ongoing engagement with customers, stakeholders and local leaders, ensuring our financial planning reflects the needs and priorities of the people we serve.
Public Meetings and Oversight
Core to our transparency is the public nature of our
governance. Per our Rate Development Policy, rate setting is done via a public process, developed by staff and ultimately approved by our Board of Directors (Board) — all through open meetings where the public is invited to participate. Our Board is publicly accountable to Community Power ratepayers and hosts monthly Board meetings, where it not only sets rates, but also establishes policy, determines power options and maintains fiscal oversight. Similarly, our Board is informed by a subset of members on the Finance and Risk Management
Committee (FRMC), and the Community Advisory Committee
(CAC) advises the Board and provides a venue for ongoing citizen support and engagement in Community Power.
These monthly public forums offer meaningful opportunities for community input and serve as a foundation for budget development and agency decision-making.
Customer Notices and Transparency Tools
We also ensure customers have access to clear and timely information about their energy service. The annual Joint Rate Comparison — published in coordination with SDG&E
— provides side-by-side rate and service comparisons to help customers make informed choices. Similarly, our Power Content Label offers a breakdown of the energy sources
we procure on behalf of our customers, highlighting our commitment to cleaner energy and sustainability.
Our website is another key transparency tool, offering
customers easy access to rate options, program details, meeting materials and more. Specifically, the bill comparison calculator offers customers an opportunity to evaluate
Community Power rates alongside those of SDG&E. As part of our continued commitment to improving the customer
experience, we are currently undertaking a website redesign to make resources easier to find, understand and apply.
Targeted Outreach and Engagement
Beyond formal governance, Community Power regularly
provides updates to our member agencies and their elected bodies, including 2025 updates, which are currently underway.
These presentations offer a transparent look at our progress, priorities and evolving initiatives.
We also continue to expand and refine our outreach efforts across the service territory to engage more residents and businesses. In 2024 alone, Community Power participated in more than 151 community events, resulting in 18,539
unique interactions with the public through in-person
engagement. These efforts are bolstered by strategic
partnerships, sponsorships and targeted media outreach, including our ongoing partnership with CBS 8’s “Working for Our Communities” campaign, which helps us reach new audiences and share critical information about our programs and services.
Our quarterly newsletter provides regular updates on new initiatives, energy-saving tips and agency milestones. One of our more impactful recent engagement efforts has been the launch of a comprehensive customer feedback survey as part of our brand refresh and website redesign. This survey invites customers to share their priorities, service expectations and clean energy goals — insights that will help shape future programs and guide long-term planning.
Together, these efforts create a strong feedback loop between our agency and the public, ensuring our budget reflects both fiscal responsibility and community values and that every customer has a voice in building a clean, affordable and equitable energy future for our region.
FIGURES 13 & 14. SOCIAL MEDIA OUTREACH
106
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 19 FIGURES 15, 16 & 17. COMMUNITY OUTREACH AND EDUCATION
107
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 20 v
Budget
Guidelines
04 108
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 21 Joint Powers Agreement
On October 1, 2019, the Founding Members of Community
Power adopted the Joint Powers Agreement (JPA),
which was amended and restated on December 16, 2021.
Several sections of the JPA guide the development
and management of the budget.
Section 4.6 Specific Responsibilities of the Board. The specific responsibilities of the Board of Directors (Board) shall be as follows:
4.6.2 Formulate and adopt an annual budget prior to the commencement of the fiscal year.
Section 7.2 Depository
7.2.3 All expenditures shall be made in accordance with the approved budget and upon the approval of any officer so authorized by the Board in accordance with its policies and procedures.
Section 7.3 Budget and Recovery Costs
7.3.1 Budget. The initial budget shall be approved by the Board.
The Board may revise the budget from time to time as may be reasonably necessary to address contingencies and unexpected expenses. All subsequent budgets of Community Power shall be prepared and approved by the Board in accordance with its fiscal management policies that should include a deadline for approval. Section 4.6.2 of the JPA specifies that the Community Power Board shall adopt an annual budget with a fiscal year that runs from July 1 to June 30.
On July 28, 2022, the Community Power Board adopted
the Community Power Budget Policy, which outlined the
timeline for annual budget preparation and for discretionary budget adjustments. This Policy was adopted pursuant to Government Code Section 6508 et seq.
Budget Policy
Discretionary Budget Adjustments. The CEO or CFO will
have the discretion to authorize expense transfers from line items between and within Community Power’s Budget Level 2 categories as established and approved in the annual budget process by the Community Power Board, provided that net transfers total $150,000 or less from the budget category.
The CEO under his or her discretion may still require approval of the Board for any budget changes that may fall under the discretion of the Policy. Amendments to the annual budget as approved by the Board will reset the original appropriation (revenue or expense) for the fiscal year for the purposes of the Policy.
Budget Guidelines
A budget amendment is expected to occur in February of each calendar year to adjust the original appropriation as necessary and in alignment with Community Power’s rate-setting policy in which Community Power’s rates are expected to be adjusted in January, the month prior.
Balanced Budget. A balanced budget shall exist when the total projected revenues are greater than or equal to total projected expenses. Total revenues shall include all revenues from retail and wholesale sales of electricity. Total expenses shall include all operating expenses, program expenses, and contributions to reserve funds. Any year-end surplus will be used to maintain reserve levels. Any decrease in revenues and or increase in expenditures that causes the budget to become imbalanced will require an amended budget. The CFO shall prepare a proposed amended budget and submit to the Board for approval.
The Agency also maintains several policies posted to its Key Documents page on its website that provide further
fiscal guidance.
• Budget Policy
• Financial Reserves Policy
• Procurement Policy
• Debt Policy
• Investment Policy
• Rate Development Policy
Other related policies that may directly affect Community Power’s finances include:
• Energy Risk Management Policy
• Delegated Contract Authority
• Total Compensation Policy
• Board and Committee Compensation
Reimbursement Policy
• Net Energy Metering (NEM) Program Policy
• Sponsorship Policy
• Renewable Energy Self-Generation Bill Credit Transfer (RES-BCT) Tariff Terms and Conditions of Service+
• Net Billing Tariff (NBT)
• Collections and Delinquent Accounts Policy
• Member Agency Grant Program Policy
FIGURE 18.
KEY DOCUMENTS
PAGE ON WEBSITE
109
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 22 Budget Structure
Community Power’s basis of budgeting is the accrual
method. This method means planning that includes
revenues and expenses in the budget of the year in which the underlying economic events are expected to occur, not necessarily in the year in which the related cash is expected to be received or paid.
Community Power’s basis of accounting, similarly, in its financial statements is as an enterprise fund under the economic resources measurement focus and accrual basis
of accounting, in accordance with Generally Accepted
Accounting Principles (GAAP) for proprietary funds, as
prescribed by the Governmental Accounting Standards
Board (GASB).
Department Hierarchy
Community Power’s budget is developed as a line-item
budget and is organized by department to indicate the
agency’s organizational responsibility.
DEPARTMENT
Executive
Finance
Power Services
Legal
Human Resources and Administration
Operations
Data Analytics & Customer Operations
Public Affairs
Programs
Regulatory & Legislative Affairs
FIGURE 19. BUDGET STRUCTURE — DEPARTMENT HIERARCHY
Budget Level Hierarchy
Additionally and separately, the budget is also organized by budget levels to organize expenses into relevant,
related categories.
1. Operating Revenues
For the first time since conception, Operating Revenues allow for revenues from sales of electricity to customers completed. Assumptions include an overall 5% opt-out rate.
2. Operating Expenses
Community Power’s operating expenses fall into five
categories: cost of energy, personnel costs, professional services and consultants, marketing and outreach, and
general and administration.
I. Cost of Energy — Includes all the various services
purchased from the power market through our
suppliers to supply energy to Community Power’s
customers.
II. Personnel — Includes salaries, payroll taxes, benefits, and excused absence and paid time off for staff.
The recruitment strategy includes the addition of
approximately seven new staff members during the
FY 2025–2026 budget cycle.
III. Professional services and consultants — Includes
SDG&E billing service fees, data management fees
from Calpine, technical support (for rate setting, load analysis, energy scheduling, etc.), legal/regulatory
services and other general contracts related to IT
services, audits and accounting services. Funding
is also included for a program consultant to guide
future program investments in the community.
Professional services and consultants are further
broken down into these Budget Level 3 categories:
a. Data Management
b. SDG&E Fees
c. Technical Support
d. Legal/Regulatory
e. Other Services
f. Programs Consultants
IV. Marketing and Outreach — Includes expenses for
mandatory enrollment notices, communication
consultants, mailers, printing, sponsorships,
and partnerships to inform the community of
Community Power. Marketing and outreach are
further broken down into these Budget Level 3
categories:
a. Printing
b. Sponsorships and Local Memberships
c. Communications Consultants
110
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 23 V. General and Administration — Costs include leasing
office space, industry fees or memberships (e.g.,
bank fees, CalCCA dues), equipment and software
as well as other general operational costs including
Board and Committee expenses, Board stipends,
staff travel or professional development, logo gear,
and team building.
VI. Programs — Includes funding to support initial pilot programs, grants to community organizations,
investments that generate equitable energy-related
benefits, education campaigns, opportunities for
increased collaboration with member agencies and
funding for a potential new CPUC energy-efficiency
program.
3. Non-Operating Expenses
Community Power’s budget also includes non-operating
expenses related to interest and related expenses
used to finance its operations. These costs comprise
repayment of loan principal associated interest costs as well as potential renewal fees on debt or letters of credit.
4. Capital Investment Plan (CIP)
Community Power’s budget also includes non-operating
expenses related to a Capital Investment Plan. These
expenses may be paid with internal or external fund
sources and are considered one-time projects or programs.
The first year of the CIP is the agency’s capital budget.
FIGURE 20. BUDGET STRUCTURE — BUDGET LEVEL HIERARCHY
BUDGET LEVEL 1 BUDGET LEVEL2 BUDGET LEVEL 3
Revenue
Revenue
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Operating Expenses
Non-Operating Expenses
CIP
Gross Ratepayer Revenues
(Less 1.75% Uncollectible Customer Accounts)
Cost of Energy
Personnel Costs
Personnel Costs
Personnel Costs
Personnel Costs
Professional Services and Consultants
Professional Services and Consultants
Professional Services and Consultants
Professional Services and Consultants
Professional Services and Consultants
Professional Services and Consultants
Professional Services and Consultants
Marketing and Outreach
Marketing and Outreach
Marketing and Outreach
General and Administration
General and Administration
General and Administration
General and Administration
Programs
Debt Service
CIP
Gross Ratepayer Revenues
(Less 1.75% Uncollectible Customer Accounts)
Cost of Energy
Salaries
Benefits (retirement/health)
Payroll Taxes
Accrued PTO
Legal/Regulatory
Technical Support
Programs Consultant
Other Services
SDG&E Fees
Data Management
Contingency
Communications Consultants
Printing
Sponsorships/Local Memberships
CalCCA Dues
Insurance
Rent
Other G & A
Programs
Interest and Related Expenses
CIP
111
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 24 Fund Structure
A fund is defined as a separate accounting entity with a self-balancing set of accounts recording cash and other financial resources together with related liabilities. Each fund was established for the purpose of accounting for
specific activities in accordance with applicable regulations, restrictions or limitations. Community Power has two types of funds:
1. Operating Fund — Accounts for activities that are
supported by ratepayer funds. All of Community Power’s
general operating activities are included in the Operating Fund, which functions very similarly to the enterprise
fund of a city or county. The Operating Fund is the
primary fund of Community Power and is considered
an annual fund in which all unused funds at the end of a fiscal year revert to the agency’s fund balance.
The only source for the Operating Fund is from
ratepayer funding. Community Power believes strongly
in maintaining a structurally balanced budget in which
all ongoing operating activities are supported only by
stable, ongoing revenue such as ratepayer funding.
Community Power offers four service levels to its
customers that, taken together, ultimately comprise the source of ratepayer funds for the agency:
1. PowerOn, our standard service offering that provides 55% renewable power (and 11.7% carbon free) and
provides a 3% discount compared with SDG&E’s rates
2. Power100, our premium service that provides
customers with 100% renewable and carbon-free
energy and is currently priced at a $0.01/kWh added
to the PowerOn service
3. Power100 Green+, our stand-alone 100% renewable
and carbon-free service that is Green-e® certified,
available only to commercial and industrial customers
and currently priced at a $0.02/kWh adder to the
PowerOn service
4. PowerBase, our most affordable service option
with renewable content that is intended to meet
or exceed that of SDG&E whenever possible and
provides customers with a 5% discount compared
with SDG&E’s rates currently in effect as of
February 1, 2025
2. Continuing Fund — Accounts for one-time
activities in Community Power’s Capital Investment
Plan and that are supported by one-time funds. The
Continuing Fund is considered a continuing fund in
which all unused funds at the end of the fiscal year
continue to the next fiscal year. This fund is used to
account for and report financial resources that are
restricted, committed or assigned to expenditure for
governmental capital assets or other one-time efforts.
Community Power’s Continuing Fund is composed of
the following revenue sources:
• Community Power Operating Transfers — Through
the annual budget process, the Community Power
Board may approve an appropriation of funds to be
transferred out of the operating budget and transferred into the CIP. These funds will remain in a Community
Power continuing fund to be used across multiple fiscal years given that CIP projects generally last longer than one year.
• California Public Utilities Commission (CPUC) DAC-GT — The Disadvantaged Communities Green Tariff DAC-GT program enables income-qualified, residential
customers in DACs who may be unable to install solar
on their roof to benefit from utility-scale clean energy and receive a 20% bill discount. Funding originates
from state Greenhouse Gas (GHG) Auction Proceeds
and Public Purpose Program funds.
• CPUC Regional Energy Network (REN) — Public Purpose
Program Surcharge funds are available for RENs. On
August 7, 2024, the CPUC issued Decision 24-08-003,
which approved and authorized Community Power’s
San Diego Regional Energy Network (SDREN) as a
new Energy Efficiency Portfolio Administrator. This
decision approved Community Power’s application in
its entirety, including 2024–2027 energy savings goals
and funding, as well as a 2024–2031 Strategic Business
Plan. SDREN will offer 10 energy-efficiency programs
across San Diego County. These programs will be
available, regardless of service provider and will focus on achieving energy savings, reducing emissions, enhancing grid reliability and educating customers on how to
reduce energy usage.
• California Department of Food and Agriculture
(CDFA) Healthy Refrigeration Grant — The CDFA
notified Community Power that it was awarded
partial funding in the amount of $710,000 to support
Community Power in providing technical assistance
and refrigeration units to stock healthy foods at stores throughout Community Power’s service territory.
112
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 25 FIGURE 21.
COMMUNITY POWER FUND STRUCTURE
FIGURE 22.
COMMUNITY POWER FUND AND BUDGET LEVEL HIERARCHY RELATIONSHIP FUND STRUCTURE FUND STRUCTURE BUDGET LEVEL 1
Operating Fund
Continuing Fund
Operating Fund
Operating Fund
Operating Fund
Continuing Fund
Continuing Fund
Operating Revenue
Operating Expenses
Non-Operating Expenses
CIP Revenue
CIP Expenses
FY 2025-2026 Budget Principles
Fiscal Responsibility
Maintain a fiscally responsible budget in accordance
with Community Power Budget Policy.
Sufficient Funding
Ensure sufficient funding to meet procurement needs,
sustain operational needs and support sustained growth
while delivering clean energy to the communities
we serve.
Build Community Power Reserves
Build Community Power reserves and develop
policies that consider future economic conditions.
Understandable and Transparent
Provide an understandable and transparent operating
budget for internal and external users.
People and Community
Develop a budget that will ultimately prioritize people and our communities.
Informed
Keep the Community Power Board of Directors and staff
informed of Community Power’s fiscal condition.
FIGURE 23. BUDGET PRINCIPLES
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY2025–2026 113
Budget Guidelines 25
v
Budget
Overview
05 114
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 27 Budget in Brief
The proposed FY 2025–2026 Operating Budget is the
second full fiscal year of full enrollment from Community Power’s member jurisdictions, inclusive of net-energy
metering customers, within the San Diego region. This
budget therefore provides the second year of representation in anticipated full revenues and expenses, moving forward.
As Community Power has scaled to full enrollment, the
agency has thoughtfully grown to 87 staff in the current fiscal year. Total staffing for the FY 2025–2026 period includes eight positions that are externally funded and in the Capital Investment Plan (CIP), and 86 positions supporting core operations. By the end of FY 2025–2026, Community
Power is expected to have a similar operating budget and staffing levels compared to its peer CCAs of similar customer and load size. Additionally, by the end of FY 2025–2026, Community Power is likely to achieve its strategic goal of having 180 days’ cash on hand, which will equip Community Power to earn and maintain a credit rating. This can translate to Community Power being better positioned to negotiate Proposed Operating Budget
The Community Power FY 2025–2026 Proposed Operating Budget is presented in further detail in the following pages. The table below summarizes the revenue and expense budgets proposed for FY26 in comparison to the FY25 and FY24 Amended Budgets.
Budget Overview
and secure better and more favorable terms in our Power Purchase Agreements that can help reduce electricity
rates for customers in the long term while also protecting the long-term solvency of Community Power. Given the
positive financial landscape, Community Power expects to maintain minimal, if any, debt during the fiscal year and does not anticipate needing to use its credit facility to finance operations in FY 2025–2026.
The Proposed FY 2025–2026 Operating Budget furthermore
includes continued outreach through community events,
sponsorships and advertising to inform customers about
Community Power.
Lastly, this budget continues to include a CIP that shifts one-time revenue and one-time expenses from programs and projects over multi-year periods from the operating budget to the CIP.
FY24 Amended FY25 Amended FY26 Proposed
Gross Revenue 1,365.7 1,233.4 1,221.0
Less Uncollectible Accounts (61.4) (54.5) (21.4)
Net Operating Revenues 1,304.3 1,177.9 1,199.6
Cost of Energy 1,020.8 1,073.7 956.7
Non-Energy Costs 43.8 53.8 54.3
Subtotal Operating Expense 1,064.6 1,127.5 1,010.9
Debt Service 2.4 1.3 1.9
Capital Investment Program (Transfer Out) 4.7 15.2 21.4 Total Expenses 1,071.0 1,143.9 1,034.2
Net Position 233.3 34.0 165.4
TABLE 1. OPERATING BUDGET OVERVIEW*
*Amounts displayed in millions of dollars
115
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 28 Operating Revenue
San Diego Community Power operates as a Joint Powers
Authority (JPA), providing clean energy to residents and businesses within its service area. Revenue is generated primarily through electricity sales, with a core financial principle of maintaining a balanced budget. This requires electricity sales revenue to cover power generation costs — especially from renewable sources — and operational
expenses. Financial sustainability is also pursued through strategies like building reserves.
Generally, operating revenue through electricity sales is derived by: 1) estimating Community Power’s energy load for the upcoming fiscal year; 2) applying the Board-approved generation rates to the energy load; and 3) applying a 1.75% uncollectible rate based on revenue that Community Power does not expect to collect — the result is Community Power’s operating revenue for the fiscal year.
As a JPA, Community Power functions under distinct
governing principles, unlike investor-owned utilities. Its primary goal is to deliver affordable, renewable power to diverse customers, ranging from large commercial and
industrial entities to individual residential customers, including those with financial constraints. Affordability for our communities is highly valued, significantly shaping operational and rate-setting decisions.
The latest financial projections, through January 2025, informed Community Power’s rate-setting process. The
staff-recommended rates were developed to reasonably
and appropriately cover operational expenses and projected revenues for fiscal years 2024–2025 and 2025–2026. These rates aim to balance customer affordability with the need to generate sufficient revenue to cover annual power supply and operating costs, debt service and a planned reserve margin contribution, ultimately achieving a balanced budget.
The rate recommendations also allow Community Power
to balance affordability for customers while maintaining reserves and progressing toward its 180-day cash-on-hand and reserve stabilization goals. Achieving these reserve targets is not feasible with additional rate discounts beyond the proposed rates. Furthermore, the proposed
rates and reserve targets enable Community Power to
meet key metrics for achieving an investment-grade credit rating, which is crucial for rate competitiveness by securing favorable terms for power procurement and credit activities.
Finally, the adopted rates ensure compliance with financial covenants in agreements with JP Morgan Chase Bank
(Revolving Credit Agreement), River City Bank (Security Agreement) and various power purchase agreements.
Community Power’s retail sales of electricity are composed of four rate products.
Power100 Green+ Power100 PowerOn PowerBase
PowerOn +
$0.02 per kWh
PowerOn +
$0.01 per kWh
$0.163 per kWh** $0.160 per kWh**
100% renewable,
carbon-free,
Green-e certified for
businesses looking to
meet LEED standards
100% renewable and
carbon-free for residents
and businesses who want
to minimize their carbon
footprint and support a
clean energy future
55% renewable content
at a competitive price
compared with SDG&E’s
service that is the default
rate for most Community
Power customers
45% renewable and
5% less expensive than
SDG&E’s default service
FIGURE 24. COMMUNITY POWER’S RATE PRODUCTS*
*Prices valid as of February 1, 2025
**Average rate across all Community Power rate schedules 116
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 29 FY 2024 $1,304,274,067
$1,221,258,172
$1,242,354,119
$1,133,066,388
$1,190,650,889
$1,244,153,744
$1,301,986,087
FY 2025 FY 2026 FY 2027 FY 2028 FY 2029 FY 2030
$1,000,000,000
$1,050,000,000
$1,100,000,000
$1,150,000,000
$1,200,000,000
$1,250,000,000
$1,300,000,000
$1,350,000,000
Net Revenue Net Revenue Trend
FIGURE 25. COMMUNITY POWER REVENUE TREND
Table 2 summarizes the revenues for the FY24 Amended Budget, FY25 Amended Budget and FY26 Proposed Operating Budget.
TABLE 2. OPERATING REVENUE BY BUDGET LEVEL 2*
FY24 Amended FY25 Amended FY26 Proposed
Gross Ratepayer Revenues 1,365.7 1,243.0 1,221.0
(FY24 Less 4.5% Uncollectible Customer
Accounts; FY25 & FY26 Less 1.75%)
(61.4) (21.8) (21.4)
Net Operating Revenues 1,304.3 1,221.2 1,199.6
*Amounts displayed in millions of dollars
117
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 30 Operating Expenses
Expenses in the Community Power Operating Budget fall into five budget level 2 categories: cost of energy, personnel costs, professional services and consultants, marketing and outreach, and general and administration.
Table 3, below, summarizes the expenses for the FY24 Amended Budget, FY25 Amended Operating Budget and FY26 Proposed Operating Budget.
Operating Expenses by Department
Table 4, below, summarizes the FY26 Proposed Operating Budget expenses by department. Several new departments were established as part of the development of the FY26 Proposed Operating Budget and therefore a comparison is not shown for the prior year.
TABLE 3. OPERATING EXPENSES BY BUDGET LEVEL 2*
TABLE 4. OPERATING EXPENSES BY DEPARTMENT
FY24 Amended FY25 Amended FY26 Proposed
Cost of Energy 1,020.8 1,116.8 956.7
Professional Services and Consultants 22.3 24.3 24.6
Personnel Costs 11.7 18.6 21.1
Marketing and Outreach 2.9 3.0 2.6
General and Administration 6.8 4.9 5.9
Programs 0.1 0.0 0.0
Subtotal Operating Expenses 1,064.7 1,167.6 1,010.9
Interest and Related Expenses 2.4 1.3 1.9
Capital Investment Program (Transfer Out) 4.6 18.2 21.4 Total Expenses 1,071.7 1,147.1 1,034.2
FY24 Amended FY25 Amended FY26 Proposed
Power Services 1,022.4 1,118.9 958.6
Operations 16.3 20.6 22.6
Customer Operations 18.1 19.3 19.8
Finance 3.3 2.1 3.4
Public Affairs 1.5 1.8 1.9
IT and Data Analytics 1.0 1.4 1.6
Regulatory and Legislative Affairs 1.1 0.7 0.7
Human Resources and Administration 0.9 0.7 0.7
Legal 0.0 1.8 1.4
Programs 0.1 0.0 0.0
Executive Team 0.0 0.2 0.2
Total Expenses 1,064.7 1,167.6 1,010.9
Amounts displayed in millions of dollars
*Amounts displayed in millions of dollars
118
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 31 Personnel by Department
Table 5, below, summarizes the actual personnel at the end of FY25 and the full-time equivalent (FTE) personnel in the FY26 Proposed Operating Budget. While personnel may be authorized, they may not yet be filled. Detailed information showing filled and proposed FTE transfers by department is included in the following Section. All of the Personnel budget is included within the Operations department.
TABLE 5. PERSONNEL BY DEPARTMENT
FY24 Amended FY25 Amended FY26 Proposed
Operating Fund
Power Services 17.0 16.0 17.0
Executive 1.0 5.0 5.0
Public Affairs 11.0 12.0 13.0
Programs 6.0 12.0 14.0
Finance 7.0 9.0 10.0
Customer Operations 6.0 8.0 5.0
Operations 6.0 5.0 4.0
IT and Data Analytics 6.0 9.0 12.0
Regulatory and Legislative Affairs 5.0 5.0 5.0
Human Resources and Administration 3.0 4.0 6.0
Legal 1.0 2.0 3.0
Subtotal Operating FTEs 70.0 87.0 94.0
External Funding (CIP)
Programs 1.0 3.8 5.0
Regulatory Affairs - 0.5 0.7
Finance - 1.0 1.0
Public Affairs - 1.0 1.0
Power Services - - 0.3
Subtotal External Funding FTEs 1.0 6.3 8.0
Total FTEs 70.01 80.7 86.0
1 14 FTEs were approved but not hired in FY24 and need to be reapproved in FY25. 119
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 32 FIGURE 26. COMMUNITY POWER’S DEPARTMENTS
Executive
Team
Operations Human
Resources and
Administration
Programs Regulatory
and Legislative
Finance
Power
Services
Public
Affairs
Customer
Operations
IT and Data
Analytics
Legal
Proposed Capital Budget
Continuing in FY 2025–2026 is the Community Power
Capital Investment Plan (CIP) for FY 2025–2029 that will contain all the individual capital projects, major equipment purchases and major programs for the agency that are
intended to span multiple years and that are considered one-time projects rather than recurring projects.
The first year of the FY 2025–2029 CIP represents the
amended FY 2025–2026 capital budget.
The FY 2025–2026 budget proposes a one-time portion of net operating revenues be transferred to the CIP as a continuing fund in which any unspent funds are kept within that fund and carried forward to the subsequent fiscal year.
The proposed FY 2025–2026 capital budget totals
$54.4 million and the FY 2025–2029 CIP total $304.3 million.
Additionally, $10.3 million in unspent continuing funds was appropriated by the Board in prior fiscal years and is represented as Carry Forward revenue. The FY 2025–2026
proposed capital budget includes funding for 21 projects in all program areas in various geographic areas of San Diego County.
TABLE 6. FY 2025–2026 CAPITAL BUDGET OVERVIEW*
Carry Forward[1] FY26 Authorized Budget FY26 Proposed Budget Operating Transfer Out 7.5 - 21.4
Regional Energy Network[2] 0.3 31.8 31.8
DAC-GT 0.5 0.3 0.3
CDFA 0.5 - -
Equitable Building Decarbonization 1.5 - -
Other - - 0.9
CIP Revenue 10.3 32.1 54.4
*Amounts displayed in millions of dollars
[1] The carry forward amount represents actual financial data through March 31, 2025, and will be reconciled at the close of fiscal year 2024-2025 [2] The Regional Energy Network was fully appropriated for $124M in January 2025 for Calendar Year 2024–2027 120
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 33 Beginning
Bal.
Expenses Carry
Forward [1]
5-Year Budget
FY25 FY25 FY25 FY26 FY27 FY28 FY29 FY30 Total
External Funding
Regional Energy
Network
2.1 1.8 0.3 31.8 59.5 51.4 42.0 43.7 228.7
DAC-GT 0.9 0.4 0.5 0.3 0.5 0.5 0.5 0.5 2.7
CDFA 0.7 0.2 0.5 - - - - - 0.5
Equitable Building
Decarbonization
1.5 - 1.5 - - - - - 1.5
Other - - - 0.9 - - - - 0.9
Subtotal 5.2 2.4 2.8 33.0 60.0 51.9 42.5 44.2 234.4
Internal Funding
Solar Battery
Savings
10.6 7.9 2.7 18.8 11.1 10.4 8.3 8.5 59.8
Energy Efficiency 0.3 0.3 - - - - - - -
Pilot Programs 3.0 1.3 1.7 - - - - - 1.7
Grants 0.8 0.3 0.7 0.8 - - - - 1.5
DER 0.1 0.0 0.1 - - - - - 0.1
Flexible Load 0.6 0.5 0.2 0.3 0.6 0.6 0.8 0.7 3.1
IT Projects 2.6 0.6 2.0 1.5 - - - - 3.5
Community
Education
0.1 0.0 0.0 - - - - - 0.0
Program Evaluation - - - 0.3 - - - - 0.3
Other - - - 0.2 - - - - 0.2
Subtotal 15.4 11.1 7.5 21.4 11.7 11.0 9.1 9.2 69.9
CIP Expense Total 20.6 13.5 10.3 54.4 71.7 62.9 51.6 53.4 304.3 [1] The carry forward amount represents actual financial data through March 31, 2025, and will be reconciled at the close of fiscal year 2024–2025 121
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 34 About the CIP
The Community Power Fiscal Year 2025–2029 Capital
Improvement Plan (CIP) includes 21 projects that will receive funding in the five-year period, totaling $304.3 million in investments across Community Power member
jurisdictions. More detail can be found within the companion FY 2025–2029 Capital Improvement Plan book. Projects
include a number of short- and medium-term programs
and projects that are largely pilot and planning studies. This allows Community Power to thoughtfully plan and design its projects and programs — based on community and agency
needs — to deliver programs and projects that provide
maximum public impact and that can potentially leverage other local, state and federal funds.
This plan continues Community Power’s commitment to
plan and finance programs and projects that align with
community and organizational priorities. The programs and projects compose a list that provides Community Power with the confidence to target a core set of program types focused on community needs. It also gives Community Power the
flexibility to co-design programs with community partners and to be responsive to external funding opportunities as they emerge.
This plan is not a final or absolute list of funded projects, and projects may not have funding identified. Each funded and partially funded project shows a potential source of funding but this does not necessarily indicate that actual funding of the project has occurred. As design requirements, budgets CIP Development Process
Community Power will update the CIP annually during its budget development process. Programs and projects are
included in the CIP based on alignment with Community
Power’s strategic goals and based on community
engagement.
The proposed capital budget and CIP undergo a public
outreach process comprising a wide range of stakeholder groups. Additionally, the CIP is a dynamic document that is intended to be updated regularly as needs shift or as fund availability changes. All subsequent updates to the CIP will be brought to the Community Power Board for approval.
FIGURE 27. CIP DEVELOPMENT PROCESS
and priorities change, the planned projects may also move within the plan or drop out entirely.
Likewise, this list is not all inclusive. Unexpected
requirements often cause unforeseen projects to be inserted into the design and execution process. Furthermore, funding sources identified in the CIP are potential funding sources that may not materialize. Projects, programs and funding are additionally subject to Board approval consistent with the JPA and the internal policies and programs of the agency. period total
investment
projects to
be funded
5-Year $304.3M 21
Across Community Power
member jurisdictions
Capital Investment Plan (CIP)
122
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 35 Operational Impact of Capital Projects
Projects outlined in Community Power’s Capital Investment Plan and Budget are generally designed to address the needs of existing assets without significantly impacting operational costs. However, if a technology or any project was planned that had a significant operational impact, projected costs would be reflected in Community Power’s Five-Year Financial Plan, issued annually.
Additionally, staffing, building maintenance, equipment maintenance and utility costs associated with these facilities would be approved as part of the annual Budget Process. As a result, these costs would be specified within the Budget document and categorized under the “Budget by Department” section and attributed to the relevant department sponsoring the project.
Capital improvements are strategic investments made by Community Power to enhance its physical assets, technology and infrastructure. These improvements are not just about upgrading facilities or equipment but are also aimed at driving efficiency within our organization’s operations over the long term. By investing in capital improvements, the organization seeks to optimize its processes, reduce costs and improve overall productivity.
Several projects driven by our IT and Data Analytics Department are at the forefront of these efforts. These projects are prioritized to leverage data and enable advanced data analytics techniques. The goal is to better understand the organization’s operations and discover operational efficiencies. Here’s how these projects contribute to long-term efficiency:
Data Collection and Integration — IT and Data Analytics focuses on collecting data from various sources within the organization. This includes data from production processes, supply chain activities, customer interactions and more. By integrating this data into a centralized system, the organization can gain a comprehensive view of its operations.
Advanced Data Analytics — With a robust data infrastructure in place, the IT and Data Analytics Department employs
advanced data analytics techniques such as machine learning, predictive analytics and big data analysis. These techniques help in identifying patterns, trends and anomalies in the data that might not be apparent through traditional analysis methods.
Operational Insights — The insights gained from data analytics are used to understand the efficiency of current operations.
For example, analytics can reveal bottlenecks in production, inefficiencies in supply chain management or areas where customer service can be improved. These insights are
crucial for making informed decisions about where to focus improvement efforts.
Process Optimization — Based on the operational insights, the organization can implement changes to optimize processes.
This might involve automating certain tasks, reallocating resources or redesigning workflows to eliminate inefficiencies.
The goal is to streamline operations and enhance productivity.
Continuous Improvement — Capital improvements driven
by data analytics are not one-time efforts. The organization continuously monitors its operations and uses data to identify new opportunities for improvement. This ongoing process ensures that the organization remains agile and can adapt to changing market conditions and technological advancements.
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY2025–2026 123
Budget Overview 35
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 36 Total revenues and other sources
Total operating expenses
$1,221M
(51.12%)
$1,168M
(48.88%)
$386M $329M
FY 2021/22
$891M $746M
FY 2022/23
$1,264M
$1,083M
FY 2023/24
Total operating revenues Total operating expenses
Multiyear Trends
This section presents a multi-year financial trend report for Community Power, reviewing the
actuals from Fiscal Years 2022,
2023 and 2024 and the Fiscal Year
2025 Amended Budget. The report
includes visualizations that illustrate
key financial trends and variances,
providing a clear and comprehensive
picture of the organization’s fiscal
trajectory over the past three
years. By examining these figures,
Community Power can gain insights
into revenue patterns, expenditure
changes and overall financial
stability. This analysis is essential for
understanding how past financial
outcomes align with future budgetary
goals, ensuring effective financial
planning and management.
Community Power has experienced
substantial growth in both operating
revenues and expenditures from
FY22 to FY24. In FY22, Community
Power’s operating revenues were
$386 million, increasing to $891
million in FY23, and further rising
to $1.1 billion in FY24. This growth
is primarily driven by expanding
electricity sales and an increased
customer base. Concurrently,
operating expenses have also
escalated, from $329 million in
FY22 to $746 million in FY23, and
reaching $1.083 billion in FY24,
reflecting higher costs associated
with electricity procurement and
use of contract services. Despite
these rising costs, Community
Power has consistently maintained a
positive operating income, indicating
effective financial management
and strategic planning. The FY25
Amended Budget continued growth
and stability, ensuring Community
Power’s ability to meet its operational
goals and effectively serve the
community.
FY 2021/22 FY 2022/23 FY 2023/24
OPERATING REVENUES
Electricity sales, net $383,800,198 $891,178,064 $1,252,787,768 Grant revenue $0 $0 $983,500
Liquidated damages $2,437,500 $0 $0
Other income $0 $0 $10,598,252
Total operating revenues $386,237,698 $891,178,064 $1,264,369,520
OPERATING EXPENSES
Cost of electricity $319,686,027 $720,327,704 $1,047,553,476 Contract services $3,520,098 $15,957,376 $19,750,534
Staff compensation $3,662,441 $6,726,270 $11,399,388
Other operating expense $2,098,031 $2,866,222 $3,261,424 Depreciation and amortization $0 $253,553 $727,567
Total operating expenses $328,966,597 $746,131,125 $1,082,692,389 TOTAL OPERATING INCOME $57,271,101 $145,046,939 $181,677,131 FIGURE 28. OPERATING REVENUES VS. EXPENDITURES
FIGURE 29. OPERATING BUDGET
Community Power’s FY25 amended budget reflects the organization’s strong financial growth and stability observed in past fiscal years. The budget included total operating revenues of $1.22 billion and total expenses of $1.17 billion, maintaining a balanced approach similar to previous years. Revenue growth, driven by expanding electricity sales and an increasing customer base, aligns with the upward trend seen from FY22 to FY24. Increased costs in FY25 are primarily due to higher electricity procurement expenses and investments in the CIP. Despite these rising costs, the positive net operating income highlights effective financial management and strategic planning. 124
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 37 FY26 FY27
1,600
1,400
1,200
1,000
800
600
400
200
0 $M
Net Position Total Expenses Excess Reserves 180-Day Expense 165.4 166.0
FY28
264.3
FY29
313.0
FY30
344.1
1,034.2
987.2
947.6
953.3
981.1
Five-Year Financial Plan
Community Power’s five-year financial plan projects that the agency will meet its 180-days cash-on-hand reserve
target in its Reserve Policy by October 2025. The current reserve policy supports the distribution of excess reserves for specific purposes, including funding a rate stabilization reserve. Additionally, the plan projects that Community Power will achieve its Strategic Plan goal of funding a Rate Stabilization Reserve by FY 2026–2027. The plan assumes that rates remain at the same level adopted by the Board on February 7, 2025, and are subject to change based on Community Power’s rate-setting cycle.
The Community Power Board reassesses its projections,
five-year financial plan and reserve targets annually during its rate-setting process in January and during its budget development process ending in June.
FIGURE 30. SAN DIEGO COMMUNITY POWER RESERVES
OPERATING BUDGET, $M FY26 FY27 FY28 FY29 FY30
Net Revenue 1,119.6 1,133.1 1,190.7 1,244.2 1,302.0
Total Expense 1,034.2 967.0 926.4 931.1 957.9
Annual Reserve (Net Position) 165.4 166.0 264.3 313.0 344.1 Cumulative Net Position 574.9 741.0 1,005.3 1,318.3 1,662.40 180-Day Expense 510.0 486.8 467.3 470.1 483.8
Projected Excess Reserves 64.9 254.1 538.0 848.2 1,178.6 Key assumptions in Community Power’s projections
and five-year financial plan include:
• Full enrollment of customers is complete from all
member jurisdictions
• A 95% participation rate across all jurisdictions
• A 1.75% uncollectible rate, which maintains the
same uncollectible rate from the fiscal year
2024–2025 amended budget approved by the
board February 27, 2025
• Trifurcation of rates continues to ensure a fair, equitable and balanced rate structure across customers with differing vintage years
• Rates in FY26 and beyond remain at the levels
adopted by the Board on February 7, 2025. Further
rate changes are subject to Board approval.
125
v
Budget by
Department
06 126
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 39 Mission and Services
The Executive team provides agency-wide leadership and
strategic direction for Community Power. Led by the chief executive officer and supported by the executive team,
the department ensures alignment across departments,
cultivates an inclusive and accountable culture and oversees implementation of the strategic plan.
The Executive team represents Community Power in
public forums, guides internal systems development and
advances partnerships with local governments, stakeholders and industry peers. Through consistent engagement with
member agencies, the Board of Directors and Community
Advisory Committee, and regional coalitions, the team builds trust and helps position Community Power as a leading voice in California’s clean energy transition.
Department Highlights
• Led development and rollout of the FY 2025–2026
strategic plan
• Continued engagement with CalCCA and participation in key state policy forums
• Oversaw internal management systems and staff training initiatives
• Supported cross-functional alignment through quarterly strategy check-ins
• Advanced initiatives to promote equity, transparency and operational integrity
Key Performance Indicators (KPIs)
• Strategic goals aligned across departments
(target: seven)
• Annual rate setting via public process
(target: effective Feb. 1)
• Reserve balance and days cash on hand
(target: 180 days by FY 2027)
• Number of external events attended by executive staff (target: 60)
Department Organizational Structure
Budget by Department
Chief Executive Officer
Chief Operating Officer
Chief Commercial Officer1
General Counsel
Chief Financial Officer and Deputy Chief
Executive Officer/Treasurer
KARIN BURNS
JACK CLARK
VACANT
VEERA TYAGI
ERIC WASHINGTON
FIGURE 31. EXECUTIVE ORGANIZATIONAL STRUCTURE
1 Formerly titled Managing Director Power Services
Executive
Providing strategic leadership to guide the agency and deliver on its mission 127
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 40 Department Description: Mission and Services
Operations ensures that Community Power functions
effectively and efficiently across all departments. Led by the chief operating officer and supported by senior directors and project management staff, Operations drives internal coordination, facilitates collaboration and operationalizes the agency’s strategic objectives.
The team oversees internal governance, agencywide
administrative systems and policy development. Operations is also responsible for engagement with the Community
Advisory Committee (CAC), ensuring transparency and
accountability. The newly created Project Management
Office (PMO), housed within Operations, leads efforts to align project execution with strategic priorities, standardize workflows, create efficiencies and improve internal delivery.
Operations Highlights
• Supported growth to 80 full-time positions with strategic resource planning
• Launched agencywide project intake and documentation
process through PMO
• Conducted internal process audits to identify operational bottlenecks
• Improved CAC and Board engagement through increased
coordination and support
• Advanced internal efficiency through cross-departmental collaboration systems
Operations
Improving internal operations and alignment to support strategic execution FY 2025–2026 Priorities
• Enhance internal systems and tools to support cross-functional execution • Improve agency-wide project visibility, reporting and governance
• Develop the internal infrastruct ure needed to scale
efficiently as Community Power grows
• Strengthen alignment between agency goals,
departmental workplans and staff resources
Key Performance Indicators (KPIs)
• Implement new project intake and tracking tools
(target: Q2 FY 2025)
• Maintain a cross-functional project schedule
(target: update quarterly)
• Implement a team utilization framework
(target: Q3 FY 2025)
• Develop and launch a centralized internal dashboard for tracking project and policy updates
(target: Q3 FY 2025)
• Conduct project reviews with the Executive team to ensure strategic alignment (target: review quarterly)
TABLE 7. OPERATIONS POSITIONS
FIGURE 32. OPERATIONS ORGANIZATIONAL STRUCTURE
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Operations 7.0 4.0
Operations
Programs Public Affairs Regulatory &
Legislative
Data Analytics
& Customer
Operations
Project
Management Office
Chief Operating Officer
Senior Director
of Programs
Senior Director
of Public Affairs Senior Director
of Regulatory &
Legislative Affairs
Senior Director
of Data Analytics &
Customer Operations
Project Operations
& Proposal Manager
Clerk of the Board
Department Organizational Structure
128
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 41 Department Description: Mission and Services
The Power Services Department is responsible for managing Community Power’s energy procurement and delivery
portfolio, ensuring that customers receive clean, reliable and competitively priced electricity. This includes all long- and short-term energy contracting, load forecasting, power
scheduling, wholesale market participation, energy risk management and compliance with state regulatory mandates.
Under the leadership of the chief commercial officer, Power Services oversees competitive solicitations and negotiation of power purchase agreements (PPAs) and Energy Storage Service Agreements (ESSAs), working to meet state mandates and
voluntary goals related to the Renewable Portfolio Standard (RPS) and Resource Adequacy (RA). The department also
plays a key role in diversifying supply, expanding clean energy development and accelerating the build-out of local energy infrastructure, including distributed energy resources (DERs).
Department Highlights
• Expanded to 16 team members to manage procurement,
forecasting and compliance functions
• Maintained energy hedging strategy to mitigate cost
volatility and market exposure in FY 2026 and beyond
• Procured Energy Trading Risk Management (ETRM) system • Worked with general counsel to bring transactional counsel in-house to support higher transaction volume and legal review of complex energy agreements
• Continued contracting for and managing developing long-term clean energy resources to meet Community Power’s 100% renewable energy goals
FY 2025–2026 Priorities
• Manage portfolio to manage risk, cost and reliability objectives through risk management tools, sufficient
staffing and staff training
• Advance toward a 100% renewable energy portfolio by
2035, with interim targets of 75% by 2027 and 85% by
2030
• Support development of 1 gigawatt of local clean energy capacity by 2035, including at least 300 megawatts from DERs enabled through programs, tariffs and procurement
• Ensure cost-effective compliance with RA and RPS
requirements and all other state regulatory obligations • Prioritize projects and partnerships that help create high-quality local jobs in the clean energy economy Power Services
Developing a clean energy portfolio that is reliable, affordable and increasingly renewable Key Performance Indicators (KPIs)
• Maintain alignment with Community Power's energy risk management policy
• Ensure timely filing of all resource adequacy month-ahead filings as well as the year-ahead filing due in October 2025 • Submit annual Integrated Resource Plan, Renewable
Portfolio Standard Plan and Mid-Term Reliability updates • Finalize and implement Feed-In Tariff 2.0 and secure
additional local energy contracts
• Implement and integrate an ETRM system to improve
energy risk management and internal analytics by Q3 2025 • Bring online the first Power Purchase Agreement
where SDCP has full control of scheduling coordinator
responsibilities
TABLE 8: POWER SERVICES POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Power Services 16.0 *17.0
*0.3 position will be externally funded in FY26
*Positions authorized in FY26
Department Organizational Structure
Power Services
Chief Commercial Officer
Director of Power Contracts
Director of Portfolio Management
Director of Origination
Associate Director-Load Forecast & Optimization
Principal Portfolio Manager
Senior Settlements Manager
Senior Local Development Manager
Senior Portfolio Manager
Senior Portfolio Manager
Origination Manager
Senior Settlements Analyst
Senior Quantitative Energy Analyst
Senior Compliance Analyst
Contract Management Associate
Contract Associate
*Portfolio Analyst Energy
*Senior Market and Modeling Analyst
FIGURE 33. POWER SERVICES ORGANIZATIONAL STRUCTURE
129
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 42 Department Description: Mission and Services
The Finance Department ensures the long-term fiscal health of Community Power through sound financial planning, risk management and transparency. The department manages
budgeting, accounting, cash flow, reserves, audits, financial policy implementation, debt financing including clean
prepayment financing, and fiscal compliance.
Finance supports the organization’s mission by maintaining strong financial controls, enabling informed decision-making and positioning the agency to invest in programs, infrastructure and operations that advance clean energy access and community benefits.
Department Highlights
• Continued focus on building reserves to meet the
180-day cash-on-hand goal
• Coordinated annual financial audit with no findings
in FY 2023
• Developed internal financial controls and contracts
tracking system
• Advanced implementation of the Capital Investment Plan • Supported the execution of multiple clean energy
prepay bond transactions
FY 2025–2026 Priorities
• Execute 3–5 clean prepay bond transactions to reduce
power costs by up to $30 million annually
• Contribute $80 million toward the reserve goal by
the end of FY 2025–26
• Build a Rate Stabilization Reserve to mitigate power
market volatility
• Launch a vendor and contracts tracking system to
strengthen fiscal controls
• Establish a Middle Office to enhance energy risk
monitoring and oversight
• Maintain fiscal transparency through regular public
reporting and committee updates
TABLE 9. FINANCE POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Finance 8.0 *10.0
*1.0 position will be externally funded in FY26
*Position authorized in FY26
Finance
Chief Financial Officer/Treasurer
Director of Finance
Procurement Manager
Risk Manager
Finance Manager
Strategic Finance Manager
Senior Financial Analyst
Financial Analyst
Financial Analyst
Procurement Analyst
*Senior Risk Manager
Department Organizational Structure
FIGURE 34. FINANCE ORGANIZATIONAL STRUCTURE
Finance
Promoting long-term organizational sustainability through sound fiscal management and strategic investment
Key Performance Indicators (KPIs)
• Reserve balance and days cash on hand (target: 180 days by FY 2027)
• Number of clean energy prepay transactions executed and savings achieved
• Reviewing budget-to-actuals to identify financial
efficiencies
• Achievement of investment-grade credit rating readiness benchmarks
130
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 43 Department Description: Mission and Services
The Customer Operations Department supports customer
satisfaction and retention by ensuring clear, timely and accurate billing, analyzing usage trends and delivering exceptional account management. Under the guidance of the chief operating officer and leadership of the senior director of data analytics and customer operations, the team manages contact center operations, supports key accounts and provides analytical insights to guide rate setting, forecasting and customer service enhancements.
The department plays a central role in delivering Community Power’s promise of clean, affordable energy through
customer-focused strategies. It supports interagency
coordination with SDG&E and Calpine to mitigate billing errors and maintains the tools and insights that drive high customer retention, satisfaction and service engagement.
Department Highlights
• Lowered electricity generation rates for the second
consecutive year for Community Power customers
• Launched two new rate offerings — PowerBase and
Power100 Green+ — to meet customer needs
• Oversaw more than $19 million in vendor service contracts, including Calpine and SDG&E
• Partnered closely with SDG&E and Calpine to improve
billing accuracy and address customer concerns
• Continued enhancements to internal data tools that track opt actions, revenues and customer engagement
• Played a pivotal role in maintaining customers’ participation rate of 95%+ over the last 3 years
FY 2025–2026 Priorities
• Evolve rate strategy to ensure competitiveness,
affordability and fiscal sustainability
• Develop targeted strategies to increase customer retention and promote opt-ups to Power100
• Resolve outstanding billing and communication issues with SDG&E that affect customer satisfaction
• Identify and evaluate potential enhancements to customer service delivery, including a future Energy Advisor Center • Implement measures to reduce customer arrearages and
improve long-term account health
• Support contact center training and performance
monitoring for consistent, high-quality service
Customer Operations
Ensuring high customer satisfaction and retention through responsive service, affordability and clear communication
Key Performance Indicators (KPIs)
• Customer retention rate (target: 90%+)
• Number of opt-ups to Power100 (target: 10% of total
load by 2027)
• Customer satisfaction score via surveys (target: score 9/10) • Rate of issue resolution and billing accuracy (target: 99%+ first-contact resolution)
• Close collaboration with SDG&E and the agency’s
collection vendor to reduce arrearages year over year
• Number of service enhancements implemented or piloted (target: 2–3 new initiatives in FY26)
TABLE 10. CUSTOMER OPERATIONS POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Customer Operations 7.0 5.0
Department Organizational Structure
Customer Operations
Senior Director of Data Analytics
and Customer Operations
Account Services Manager
Key Account Services Manager
Senior Account Services Analyst
Senior Key Account Analyst
FIGURE 35. CUSTOMER OPERATIONS
ORGANIZATIONAL STRUCTURE
131
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 44 IT and Data Analytics
Senior Director of Data Analytics
and Customer Operations
Associate Director of IT and Data Analytics
Data Analytics Manager
Rate and Strategy Manager
IT Manager
Senior Cybersecurity Analyst
Data Scientist
IT Systems Engineer
Data Engineer
IT Systems Analyst
Senior Rates Analyst
Data Analyst
Senior Integration System Ops Developer
Department Description: Mission and Services
The IT and Data Analytics Department empowers
Community Power through secure, scalable and modern
digital infrastructure. Reporting to the senior director of data analytics and customer operations and led by the associate director of IT and Data Analytics, the department manages enterprisewide systems, data and analytics platforms, and cybersecurity.
The team develops and maintains centralized, cloud-based tools that enable real-time, data-informed decisions across rate development, customer programs, marketing and
operations. By implementing robust security protocols and IT governance, the department ensures business continuity, system resilience and a strong data-driven culture throughout the agency.
Department Highlights
• Launched agencywide managed IT services with
cybersecurity protections
• Completed enterprise assessment to align systems with strategic goals
• Advanced development of an enterprise data platform
(EDP) to centralize analytics
• Supported implementation of improved forecasting
models that account for solar generation
• Partnered with the Project Management Office (PMO) to assess project management platforms
FY 2025–2026 Priorities
• Strengthen cybersecurity framework and conduct annual penetration testing
• Launch enterprise data platform with integration of critical data systems by Q4 FY 2025
• Finalize IT policies and governance procedures by Q2 FY 2025 • Select and implement a project management system with PMO support by Q2 FY 2025
• Expand in-house analytics support to additional
Community Power departments by FY 2026
IT and Data Analytics
Creating a secure and efficient environment that supports collaboration and innovation Key Performance Indicators (KPIs)
• Number of cybersecurity incidents reported (target: 0) • Percentage of critical retail operations data systems integrated into EDP (target: ≥ 98%)
• Project management system implemented and training
completed (target: Q3 FY 2025)
• Number of departments supported with internal analytics (target: ≥ four)
• Number of reporting dashboards deployed (target: four to six) • Percentage of IT incidents resolved within service level agreement (SLA) (target: ≥ 98%)
• Adoption of IT policy and governance framework (target:
approved by Q2 FY 2025)
TABLE 11. IT AND DATA ANALYTICS POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
IT and Data Analytics 8.0 12.0
Department Organizational Structure
FIGURE 36. IT AND DATA ANALYTICS ORGANIZATIONAL STRUCTURE 132
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 45 Department Description: Mission and Services
The Public Affairs Department connects Community Power
with the people and communities it serves. Through strategic communications, local partnerships and public engagement, the team builds awareness of Community Power’s mission, programs and benefits. The department also supports
customer education, agency branding and transparency in all public-facing materials.
Led by the senior director of public affairs and reporting to the chief operating officer, the department includes three core focus areas: strategic partnerships, community engagement, and marketing and communications. Together, these
teams advance Community Power’s brand identity, foster
connections with key audiences and ensure transparency
through outreach, media engagement and public education.
The department also supports the Community Advisory
Committee (CAC) and helps ensure local priorities are
reflected in agency decision-making.
Department Highlights
• Participated in 151 community outreach events in 2024, resulting in 18,539 unique interactions
• Achieved an estimated 1.2 million impressions through in-person outreach and strategic media and partner efforts, including CBS 8’s “Working for Our Communities” partnership • Supported the CAC and provided updates to member agency city councils
• Managed the agency’s brand refresh and website redesign efforts
• Produced quarterly newsletters, social media content
and other tools to increase customer understanding and
transparency
FY 2025–2026 Priorities
• Expand public understanding of Community Power’s clean energy programs and rate options
• Strengthen brand awareness and build community trust
across diverse audiences with the launch of Community
Power’s new website
• Partner with member agencies and community-based
organizations to reach underserved populations
• Support program launches and other resources through clear, multilingual and accessible messaging
• Ensure ongoing transparency through coordinated media outreach, digital engagement and community events
Public Affairs
Building a trusted public agency through strategic outreach, education and engagement Key Performance Indicators (KPIs)
• Number of public events attended or hosted
(target: 100 annually)
• Total impressions across digital and earned media
(target: 1.2 million)
• Newsletter open rate and click-through metrics
• (target: 40% open, 10% click-through)
• Number of reinvestments in in member agencies
through partnerships, sponsorships and engagements
(target: partner, sponsor or fund at least four engagements in each member agency annually)
• Number of earned media opportunities
(target: six annually)
Department Organizational Structure
Public Affairs
Senior Director of Public Affairs
Senior Manager Strategic Partnerships
Senior Manager Marketing & Communications
Senior Manager Community Engagement
Strategic Initiatives Manager
Local Government Affairs Manager
Marketing Manager
Marketing Manager
Community Engagement Associate
Communications Associate
Community Engagement Coordinator
Community Outreach Representative
*Communications Associate
FIGURE 37. PUBLIC AFFAIRS ORGANIZATIONAL STRUCTURE
TABLE 12. PUBLIC AFFAIRS POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Public Affairs 12.0 *13.0
*1.0 position will be externally funded in FY26
*Position authorized in FY26
133
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 46 Department Description: Mission and Services
The Programs Department designs and implements initiatives that reduce customer bills, increase energy resilience and expand access to clean energy. Under the guidance of the chief operating officer and the leadership of the senior director of programs, the team manages incentive programs, pilots and partnerships that serve residential, commercial and public agency customers across the region.
Program area focus and design are guided by Community Power’s Community Power Plan (CPP), Climate Action Plans from member agencies, and state and federal policy. From residential battery incentives to electric vehicle charging management, the department supports scalable, equitable decarbonization across sectors. The department works closely with community-based organizations, industry stakeholders and internal departments to ensure program design is equitable, cost-effective and scalable.
The department also leads the launch and administration of the San Diego Regional Energy Network (SDREN) in partnership with the County of San Diego, a transformative multi-year effort to deliver energy efficiency and demand-side management programs across San Diego County.
Department Highlights
• Launched the Solar Battery Savings program, recognized in the U.S.
Department of Energy’s 2025 Virtual Power Plant Liftoff Report, to create a 7 MW Virtual Power Plant via customer-owned residential battery storage
• Received approval for the San Diego Regional Energy Network (SDREN) application, generating nearly $125 million in program funding for the region through 2027
• Initiated customer-facing pilots in building decarbonization, flexible load management, healthy and efficient refrigeration and transportation electrification
• Built new strategies for vehicle-grid integration, virtual net billing and distributed energy resource deployment
• Executed state and federal grants, including the CDFA Healthy Refrigeration Grant and support for SANDAG’s Climate Pollution Reduction Grant proposal
• Partnered in strong cross-departmental collaboration to integrate customer, regulatory and operational inputs into program design FY 2025–2026 Priorities
• Deliver 150 megawatts of local capacity from distributed energy resources (DERs) and Community Power’s Virtual Power Plant (VPP) portfolio by 2035, including expansion of the Solar Battery Savings program
• Launch all SDREN programs and make them available to customers by the end of FY 2026
Programs
Implementing energy projects and programs that reduce emissions, align supply and demand, and deliver community benefit
• Develop and implement a formal program evaluation framework for all programs and pilots by FY 2026
• Secure new program funding from external sources, including state, federal and philanthropic entities
• Integrate Distributed Energy Resources Management System (DERMS) software and flexible load strategies into program implementation
• Support electrification and resiliency through targeted customer offerings in solar + storage, demand response and energy efficiency Key Performance Indicators (KPIs)
• DER capacity added through program implementation
(target: 20 MW in FY 2025–26, 150 MW by FY 29–30)
• Ten SDREN programs launched and available to customers (target: all core programs by FY 2025–26)
• Program evaluation framework completion and deployment (target: Q4 FY 2025–26)
• Equity-focused program participation from priority communities (target: 50% of total incentive funding)
Department Organizational Structure
Customer Programs
Senior Director of Programs
Senior Director of Programs
Associate Director of
Programs
Associate Director of
Programs - Flex Load
Senior Program Manager
Senior Program Manager
Senior Program Manager
Senior Program Manager
Program Manager
Program Manager -
Community Solar
Senior Program Associate
Senior Program Associate
Senior Program Associate
*Program Associate
*Senior Program Associate
FIGURE 38. PROGRAMS ORGANIZATIONAL STRUCTURE
TABLE 13. PROGRAMS POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Programs 11.0 *14.0
*5.0 positions will be externally funded in FY26
*Positions authorized in FY26
134
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 47 Department Description/Mission and Services
The Legislative and Regulatory Affairs Department monitors, engages in and influences proceedings, proposed policies and legislation that directly or indirectly impact Community Power’s operations and customers. Under the guidance of the chief operating officer and leadership of the senior director of Regulatory and Legislative Affairs, the department represents Community Power’s interests before the California Public Utilities Commission (CPUC), California Energy Commission (CEC),
California Air Resources Board (CARB), California Independent System Operator (CAISO), the state Legislature and Congress, as well as at the federal level with relevant federal agencies, including but not limited to the Department of Energy and Federal Energy Regulatory Commission (FERC).
The department also supports regulatory compliance across multiple state agencies, assists with agencywide understanding of policy impacts and develops strategies for securing external funding and favorable regulatory outcomes. Community Power participates in trade associations such as CalCCA and works collaboratively with member agencies, industry partners and stakeholders across the state to ensure community choice remains a resilient and effective tool for climate action and energy equity.
The department’s work is guided by Community Power’s
Regulatory and Legislative Platform, which outlines the agency’s values-based approach to policy and advocacy, anchored in accelerating deep decarbonization, promoting local development and stabilizing community choice energy. The platform provides clear guidance for consistent engagement at the local, state and federal levels and ensures that policy advocacy reflects Community Power’s mission and customer priorities. View the platform here.
Department Highlights
• Monitored and/or engaged in over 60 regulatory proceedings and associated policy working groups
• Provided analysis on approximately 150 pieces of legislation per year affecting Community Choice Aggregators and issued letters of support on approximately 10 pieces of legislation per year (all legislative letters issued by Community Power can be viewed here)
• Participated in CalCCA’s regulatory and legislative committees and tiger teams to advocate for inclusion of Community
Power policy priorities in trade association filings and letters • Developed Community Power’s federal funding strategy and assisted with competitive grant applications
Regulatory and Legislative Affairs
Advocating for policies that advance Community Power’s mission and protect local decision-making • Updated Community Power’s Regulatory and Legislative
Platform, available on Community Power’s website
FY 2025–2026 Priorities
• Continually engage policymakers to ensure alignment with Community Power’s strategic priorities
• Sponsor or support state and federal legislation that promotes affordability, equity and local clean energy
• Advance regulatory outcomes that uphold procurement and rate-making authority for Community Power
• Identify and pursue grant and funding opportunities that benefit customers and member agencies
• Actively participate in trade associations and multi-agency coalitions to shape the policy landscape
• Track and manage compliance obligations to ensure timely and accurate filings
Key Performance Indicators (KPIs)
• Number of regulatory proceedings tracked (target: 40+) • Number of bills analyzed (target: 100+)
• Legislative positions advanced in alignment with platform (target: 10+)
• Number of unique interactions with state and federal
policymakers (target: 50+)
• Grant or funding applications supported in coordination with internal and external partners (target: three or more)
Department Organizational Structure
Senior Director of Regulatory and Legislative Affairs
Associate Director of Legislative Affairs
Senior Policy Manager
Senior Strategic Policy Manager
Regulatory Manager
FIGURE 39. REGULATORY AND LEGISLATIVE AFFAIRS
ORGANIZATIONAL STRUCTURE
TABLE 14. REGULATORY AND LEGISLATIVE AFFAIRS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Regulatory and
Legislative Affairs
5.0 *5.0
*0.7 positions will be externally funded in FY26
Regulatory and Legislative Affairs
135
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 48 Department Description: Mission and Services
The Human Resources and Administration Department
serves as a strategic partner to leadership and staff, building the internal systems needed to support a high-performing, mission-aligned organization. The department combines
two core functions — human resources and administrative operations — under a unified team that enables employee success and ensures internal consistency and support across all departments.
Human Resources (HR) leads efforts in recruitment,
onboarding, benefits administration, compliance, professional development and performance management. These services
are delivered in alignment with Community Power’s values of integrity, innovation, servant leadership and collaboration.
The administrative team supports agencywide operations
by managing internal documentation, scheduling,
communications, executive support and coordination across departments. This function plays a vital role in maintaining day-to-day efficiency and ensuring smooth execution of
internal processes.
FY 2025–26 marks the first full year of operations with a fully in-house HR team. With the addition of the administrative function, the department is well-positioned to drive internal excellence and provide responsive, effective support to employees, leadership and the Board of Directors.
Department Highlights
• Brought the administrative team alongside the
internal HR team
• Established internal HR systems for onboarding,
hiring and staff support
• Partnered with Paychex and other vendors to
streamline benefits administration
• Rolled out agencywide training programs and began
design of a performance management framework
• Supported hiring and onboarding across the agency as
Community Power reached 80 authorized FTEs
FY 2025–2026 Priorities
• Evolve into a learning organization with robust professional development by Q4 2026
• Ensure that all staff receives annual safety and workplace training
Human Resources and Administration
Fostering a high-performing, inclusive workplace through strategic talent development and operational excellence
• Refine and launch internship program to attract students from local colleges and underrepresented communities
interested in the clean energy industry
• Finalize and implement a three-year staffing plan and internal job board
• Fully integrate administrative functions into the larger People Operations team
• Maintain employee satisfaction levels above 80% through annual surveys and onboarding feedback
• Develop a cadence for internal and external team events and activities that intentionally shapes our culture in alignment with our mission, vision, values and goals (MVVGs)
Key Performance Indicators (KPIs)
• Headcount (78)
• Hired (22)
• Departed (four)
• Turnover Rate (target 5.6%)
• Time-to-fill for key positions (target: 78 days)
Department Organizational Structure
Human Resources and Administration
Senior Director of People Operations & Administration
Human Resources Manager
Talent Acquisition and Learning Specialist
Human Resources Coordinator
Senior Executive Assistant
Office Manager
Administrative Assistant
FIGURE 40. HUMAN RESOURCES AND ADMINISTRATION
ORGANIZATIONAL STRUCTURE
TABLE 15. HUMAN RESOURCES & ADMINISTRATION POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Human Resources and
Administration
4.0 *6.0
*1 position will be externally funded in FY26
136
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 49 Department Description: Mission and Services
The Legal Department is led by Community Power’s general counsel, who reports directly to the Board of Directors and serves as a member of the Executive team. Under the leadership of the general counsel, the department provides legal guidance across a range of areas including public agency governance, regulatory compliance, contract law, employment law and risk management.
The department plays a critical role in supporting internal policy development, mitigating organizational risk and
maintaining transparency in all agency actions. As Community Power expands in scale and complexity, the department
ensures the agency’s decisions and operations remain aligned with local, state and federal legal requirements and uphold public trust.
Department Highlights
• Established Community Power’s first in-house Legal
Department under general counsel leadership
• Hired two in-house attorneys to expand internal
legal capacity
• Developed and implemented internal templates and
review processes for contracting and risk mitigation
• Provided legal review and support for long-term
power purchase agreements (PPAs) and clean energy
prepay transactions
• Reviewed and updated internal policies and supported
compliance with the Brown Act and other transparency laws FY 2025–2026 Priorities
• Support execution of three to five clean energy prepay transactions and associated legal review
• Provide legal guidance on long-term PPAs and related
procurement efforts
• Review and update Board policies, bylaws and internal procedures
• Provide support for the launch of major customer programs, including Solar Battery Savings and the San Diego Regional Energy Network (SDREN)
• Expand legal training and education for agency staff and elected officials
Legal
Providing legal guidance, ensuring compliance, transparency and accountability to support organizational integrity
Department Organizational Structure
Legal
General Counsel
Assistant General Counsel
Senior Counsel
*Paralegal
FIGURE 41. LEGAL ORGANIZATIONAL STRUCTURE
TABLE 16. LEGAL POSITIONS
DEPARTMENT
POSITIONS
FY25
Actual
FY26
Proposed
Legal 2.0 3.0
*Position authorized in FY26
137
v
Budget
by Level 2
and Level 3
07 138
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 51 Budget by Level 2 and Level 3
Operating Revenue
Community Power’s sole source of revenue currently is the retail sale of electricity to its customers. Revenue budgeted for FY 2025–2026 reflects a full fiscal cycle of retail sales to our commercial and industrial customer base as well as the majority of the residential customer base.
Generally, operating revenue through the retail sale of electricity is derived by: 1) estimating Community Power’s energy load for the upcoming fiscal year; 2) applying the Board-approved generation rates to the energy load; and 3) applying a 1.75% uncollectible rate based on revenue that Community Power does not expect to collect — the result is Community Power’s operating revenue for the fiscal year.
Community Power offers four service levels to its customers which, taken together, ultimately comprise the source of ratepayer funds for the agency:
1. PowerOn, our standard service offering that provides 55% renewable power (and 11.7% carbon free) and
provides a 3% discount compared with SDG&E’s rates
2. Power100, our premium service that provides customers with 100% renewable and carbon-free energy and is
currently priced at a $0.01/kWh added to the PowerOn
service
3. Power100 Green+, our stand-alone 100% renewable
and carbon-free service that is Green-e® certified,
available only to commercial and industrial customers
and currently priced at a $0.02/kWh adder to the
PowerOn service
4. PowerBase, our most affordable service option with
renewable content that is intended to meet or exceed
that of SDG&E whenever possible and provides
customers with a 5% discount compared with SDG&E’s
rates currently in effect as of February 1, 2025
Additional assumptions for net operating revenue include:
• Enrollment of customers is complete for all
member jurisdictions
• A 95% participation rate across all jurisdictions
• A 1.75% uncollectible rate that is a decrease from the
4.5% uncollectible rate assumed in the prior year budget • Trifurcation of rates continues to ensure a fair, equitable and balanced rate structure across customers with differing vintage years
• Rates remain at the levels adopted by the Board on February 7, 2025, retroactive to February 1, 2025. Any rate changes are subject to Board approval.
FY24 Amended FY25 Amended FY26 Proposed
Gross Ratepayer Revenues 1,365.7 1,233.4 1,233.4
(Less 4.5% Uncollectible Customer Accounts) (61.5) (55.5) (55.5) Net Operating Revenues 1,304.3 1,177.9 1,177.9
TABLE 17. OPERATING REVENUE BY BUDGET LEVEL 2 AND LEVEL 3* *Amounts displayed in millions of dollars
139
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 52 Cost of Energy
The cost of energy is Community Power’s largest expense.
Generally, the cost of energy is derived by: 1) estimating Community Power’s energy load for the upcoming fiscal
year; 2) applying energy already contracted for to the
projected energy load; and 3) applying forward market prices to the remaining energy load that Community Power has not yet contracted for — the result is Community Power’s cost of energy for the fiscal year.
Community Power prioritizes purchasing electricity that is generated from renewable sources like solar or wind. The agency purchases enough electricity to cover the needs of our customers. SDG&E delivers this electricity through its existing power lines and continues to provide meter reading, billing and line maintenance to customers.
While Community Power emphasizes its commitment to
clean energy, there are factors that can influence the cost of this energy for Community Power, impacting the overall cost of energy for the company. The following topics are key considerations:
• Market Fluctuations — Unlike traditional energy sources with more stable pricing, renewable energy sources like solar and wind are subject to fluctuations in the electricity market. This means that during periods of lower renewable energy production or higher demand, Community Power
may need to purchase additional power from the market,
potentially at a higher cost. These costs can then be passed on to customers.
• Seasonal Variations — San Diego could experience
significant heat waves in the summer months. During these periods, peak electricity demand rises due to increased usage of air conditioning. This can put a strain on renewable energy sources, forcing Community Power to supplement
with power from the market, potentially at a premium,
similar to market fluctuations.
• Increased Load — Community Power’s customer base is
projected to remain steady; however, the overall demand for electricity (load) is projected to increase as California transitions to sourcing from more renewable energy. To
maintain grid reliability, Community Power may need to
secure additional power sources, potentially impacting the cost of energy.
Beyond market-driven factors, regulations such as resource adequacy (RA) requirements play a role in Community
Power’s energy costs. The California Public Utilities
Commission (CPUC) mandates RA requirements. These
require Community Power to procure a predetermined
amount of electricity based on its projected load. This ensures a consistently reliable grid with sufficient energy available.
Meeting these RA requirements might necessitate purchasing additional power, especially during peak demand periods, potentially at higher costs.
The potential for cost increases due to these factors is a trade-off inherent in pursuing renewable energy. While costs may fluctuate, Community Power’s commitment to clean energy aligns with California’s sustainability goals.
It’s important to note Community Power strives to offer competitive rates compared with traditional energy providers.
The agency achieves this through various strategies, including long-term power purchase agreements and a diverse
renewable energy portfolio to mitigate market fluctuations.
FY24 Amended FY25 Amended FY26 Proposed
Cost of Energy 1,020.8 1,116.8 956.7
TABLE 18. COST OF ENERGY BY BUDGET LEVEL 2 AND LEVEL 3* *Amounts displayed in millions of dollars
140
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 53 Professional Services and Consultants includes SDG&E fees, data management fees from Calpine, technical support,
legal/regulatory services and other general contracts related to IT services, audits and accounting services.
• SDG&E Service Fees – Service fees paid to SDG&E consist of a charge of a fixed fee per account per month. The
roll out of all enrollment phases adds significant costs compared to FY 2025–2026. The fees cover SDG&E’s costs
associated with meter reading, additional data processing and bill coordination as mandated and regulated by the
California Public Utilities Commission (CPUC). There are also numerous small fees associated with data requests.
• Data Management – This is a broad scope of services
that includes all “back office” billing data validation, bill coordination with SDG&E, call center services and
billing technical support, customer enrollment database management, move-in/move-out services, customer
research for enrollment support, and many support
functions related to data reporting. With full enrollment from all phases, the cost for data management will be
higher compared to prior fiscal years.
Professional Services and Consultants
• Technical Support – Community Power engages
consultants to assist with load forecast and scheduling our energy purchases. After electric power is scheduled for delivery to customers and ultimately consumed by
those customers, the actual electricity consumption must be trued up against the forecasted and scheduled energy.
This true-up occurs through the settlement process.
Settlements also entail addressing a number of other
market and regulatory requirements.
• Legal/Regulatory Services – Community Power retains
legal counsel to assist with the complex aspects of the regulatory and compliance issues and power supply contract negotiations as well as its general legal needs. This line item will also allow for the retention of both a state and a federal lobbyist to support Community Power’s legislative and
regulatory efforts.
• Other Services – Community Power contracts or plans to contract for IT services, audit services (data and financial), accounting services and other services as needed.
Community Power continues to examine if these services
are more cost effective or efficient to bring in-house; in particular, Community Power is growing its internal
IT function and expecting a reduction in its IT Services professional services agreement.
FY24 Amended FY25 Amended FY26 Proposed
Data Management 13.5 14.6 14.8
SDG&E Fees 3.4 3.4 4.0
Legal/Regulatory 1.5 2.1 1.7
Other Services 2.1 2.1 2.0
Technical Support 1.3 2.1 2.1
Professional Services and Consultants 22.3 24.3 24.6
TABLE 19. PROFESSIONAL SERVICES AND CONSULTANTS BY BUDGET LEVEL 2 AND LEVEL 3* *Amounts displayed in millions of dollars
141
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 54 Personnel costs include salaries, payroll taxes, benefits, and excused absence and paid time off for staff. In addition, costs include assumptions from the Board-adopted compensation policy, including potential merit and cost-of-living increases.
Marketing and Outreach includes expenses for mandatory
rate mailers, communication consultants, mailers, printing, sponsorships, and partnerships to inform the community
of Community Power. Marketing and outreach are further
broken down into the following Budget Level 3 categories:
Printing — The agency is periodically required to send mailers to its customers notifying the community about several
aspects of rates including changes to rates through Joint Rate Comparisons.
Marketing and Communications — An important focus of
Community Power is ensuring the community is informed
about Community Power and that we build professional-Personnel Costs Marketing and Outreach
The recruitment strategy includes the addition of
approximately seven new staff members during the
FY 2025–2026 budget cycle, growing the agency to
94 total staff.
level name recognition and trust and provide education.
This also covers the design of all required notifications sent out to customers, including opt-out procedures and rate comparisons as well as other notices or educational or marketing information.
Partnerships/Sponsorships/Local Memberships — In
addition to required noticing, Community Power performs outreach to educate the community of the benefits of
community choice and to encourage awareness of our
mission. This comes in the form of media advertising,
sponsorships of community events and organizations, and mailers as well as targeted customer communications.
FY24 Amended FY25 Amended FY26 Proposed
Salaries 9.1 14.1 15.4
Benefits (retirement/health) 1.8 2.6 3.3
Payroll Taxes 0.6 1.0 1.2
Accrued PTO 0.1 0.9 1.2
Personnel Costs 11.7 18.6 21.1
FY24 Amended FY25 Amended FY26 Proposed
Printing 2.4 1.2 0.8
Partnerships/Sponsorships/Local Memberships 1.2 1.2 1.1 Marketing and Communications 0.6 0.7 0.8
Marketing and Outreach 4.1 3.0 2.6
TABLE 20. PERSONNEL COSTS BY BUDGET LEVEL 2 AND LEVEL 3* TABLE 21. MARKETING AND OUTREACH BY BUDGET LEVEL 2 AND LEVEL 3* *Amounts displayed in millions of dollars
*Amounts displayed in millions of dollars
142
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget by Department 55 General and
Administration
General and Administration costs
include leasing office space,
industry fees or memberships (e.g.,
CalCCA dues), equipment and
software as well as other general
operational costs including Board
and Committee expenses, Board
stipends, staff travel, professional
development, etc.
Programs
Given the small size of the Budget
Level 2 category for Programs,
Community Power is removing this
budget category in FY 2025–2026.
FY24
Amended
FY25
Amended
FY26
Proposed
Other G & A 5.7 3.6 4.0
Cal CCA Dues 0.4 0.5 0.6
Rent 0.4 0.7 0.9
Partnerships/Sponsorships/Memberships 0.0 0.0 0.0
Insurance 0.1 0.1 0.3
General and Administration 6.6 4.9 5.9
FY24
Amended
FY25
Amended
FY26
Proposed
Programs 0.7 0 0
Programs 0.7 0 0
TABLE 22. GENERAL AND ADMINISTRATION BY BUDGET LEVEL 2 AND LEVEL 3* TABLE 23. PROGRAMS BY BUDGET LEVEL 2 AND LEVEL 3*
*Amounts displayed in millions of dollars
*Amounts displayed in millions of dollars
143
v
Debt
Financing
08 144
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Debt Financing 57 Debt Financing
Credit Facility
On January 23, 2023, the Community Power Board approved a new credit agreement to implement a new line of credit of $150 million from a JP Morgan credit facility. Subsequently, on October 25, 2024, the Community Power Board approved an amendment to increase the credit facility to $250 million.
The Credit Agreement with JP Morgan provides for a $250 million multi-use revolving line of credit. This credit facility includes an up to 5-year term from the date of renewal. The funds are available for general corporate purposes including line-of-credit draws, collateral postings and postings for the provider of last resort collateral requirements.
Debt Considerations
The Community Power Board has taken several important
steps to potentially achieve an investment-grade credit rating that includes, among many items:
• Developing a Reserve Policy to increase liquidity
• Establishing and funding an Operating Reserve
• Adopting strategic goals that build to 180 days’ cash on hand, ultimately leading to an investment-grade
credit rating
• Approving rates effective February 1, 2025, that
potentially allow Community Power to achieve
180 days’ cash on hand in calendar year 2025
After an investment-grade credit rating is achieved,
Community Power will have an enhanced ability to issue tax-exempt or taxable bonds to finance ownership in energy-generation or energy-storage assets. Direct asset ownership may provide the opportunity to control energy cost.
Community Power’s ability to issue tax-exempt debt to
finance an ownership interest in a generating or storage facility is a distinct advantage over investor-owned utilities and direct access providers. There are no specific asset purchases currently under consideration by staff.
Community Power does not anticipate needing to use its
credit facility to finance operations in FY 2025–2026 but periodically may access the credit facility for one-time needs.
In FY 2024–2025, Community Power accessed $47.0 million from the credit facility and satisfied the loan payment in December 2024. Currently, Community Power has zero
debt. However, Community Power still pays debt service fees to maintain its $250 million credit facility and to satisfy fees related to standby letters of credit.
The Debt Policy enables Community Power to issue
bonds that will ultimately be subject to Board approval as a separate action. The Debt Policy will help Community
Power take advantage of ownership opportunities that may arise, especially in conjunction with state or federal funding that might be available. To date, Community Power has not issued debt.
The Debt Policy articulates:
• The situations and steps necessary for the issuance of debt • The types of debt that may be issued
• How the debt fits into Community Power’s strategic
plan and potential capital investment program
The Debt Policy also includes sections to:
• Facilitate decision making
• Establish basic parameters and principles
• Articulate and clarify other related aspects to guide future Boards, staff and consultants
Year ended June 30, 2025 Beginnings Additions Payments Ending Bank note payable - 47.0 47.0 -
Loans payable - - - -
Total - 47.0 47.0 -
TABLE 24. DEBT PAYMENTS*
*Amounts displayed in millions of dollars
145
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Debt Financing 58 • Green Bonds — To the extent possible, Community Power bond issuances shall be green bonds. A green bond is a type of fixed-income instrument that is specifically earmarked to raise money for climate and environmental projects. • 1.5x Max Annual Debt Service — While the specific formulation of the Additional Bonds Test may vary depending on the type of bonds being contemplated, Community Power will utilize an Additional Bonds Test that establishes a limitation on new issuances such that the pledged revenues are no less than one and a half times (1.5x) the maximum annual principal and interest and debt service for the aggregate outstanding senior lien bonds, including the debt service for the new issuance. • 5% Annual Debt Service Limit — Community Power will also seek to maintain aggregate annual debt service on long-term debt at a level not to exceed 5% of Community Power’s annual total operating expenses. The actual terms and conditions specific to each debt issue will be controlled by the applicable documents. $0
2024
$40,000,000
$35,000,000
$30,000,000
$25,000,000
$20,000,000
$15,000,000
$10,000,000
$5,000,000
$0
$5,990,082
2020
$5,000,000
2021
$31,340,082
2022
$35,730,000
2023
$0
Nov-23
$0
Dec-23
$0
Jan-24
$40,000,000
$35,000,000
$30,000,000
$25,000,000
$20,000,000
$15,000,000
$10,000,000
$5,000,000
$0
Jul-23
$35,730,000
Aug-23
$20,730,000
$20,730,000
Sep-23 Oct-23
$8,730,000
The Community Power debt policy also includes additional requirements as follows:
FIGURE 42. COMMUNITY POWER’S DEBT 2020–2024 FIGURE 43. COMMUNITY POWER’S DEBT BY MONTH 146
v
Financial
Policies
09 147
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 60 Budget Policy
Purpose
This policy (“Policy”) establishes San Diego Community
Power’s (SDCP’s) timeline for annual budget preparation and for discretionary budget adjustments. This Policy is adopted pursuant to Government Code Section 6508 et seq. and
must be adopted or amended by resolution.
Budget Guidelines
On October 1, 2019, the Founding Members of SDCP
adopted the Joint Powers Agreement (JPA) which was
amended and restated on December 16, 2021. There are
several sections of the JPA that guide the development and management of the budget.
• Section 4.6 Specific Responsibilities of the Board. 4.6.2 Formulate and adopt an annual budget prior to the
commencement of the fiscal year.
• Section 7.2 Depository. 7.2.3 All expenditures shall be made in accordance with the approved budget and
upon the approval of any officer so authorized by the
Board in accordance with its policies and procedures.
• Section 7.3 Budget and Recovery Costs. 7.3.1 Budget.
The initial budget shall be approved by the Board. The
Board may revise the budget from time to time as may
be reasonably necessary to address contingencies
and unexpected expenses. All subsequent budgets of
SDCP shall be prepared and approved by the Board
in accordance with its fiscal management policies that
should include a deadline for approval. Section 4.6.2
of the JPA specifies that the SDCP Board of Directors
(Board) shall adopt an annual budget with a fiscal year that runs from July 1 to June 30.
Financial Policies
Budget Preparation
The Chief Financial Officer (CFO) begins the annual
budget process in February of any given year. The Finance department develops initial revenue and expense estimates and updates its short-term financial plan. In March and April, SDCP staff develop and refine budget proposals to develop an initial budget baseline for the Agency for the upcoming budget year. The budget is further refined through strategic planning sessions and through the SDCP Finance and Risk Management Committee.
The CFO will then be required to prepare and submit to the SDCP Board of Directors (Board) a draft proposed budget for the next following fiscal year in May, or no later than the second month immediately preceding the start of the respective fiscal year. The budget shall be in alignment with established goals and shall reflect all activities including operating programs, revenues, and expenditures. The budget shall be approved by the Board at a public meeting in June, or no later than the month immediately preceding the start of the respective fiscal year.
CEO and CFO Authority
The Chief Executive Officer (CEO) or CFO will have the
discretion to authorize expense transfers from line items between and within SDCP’s budget level 2 categories as
established and approved in the annual budget process by the SDCP Board, provided that net transfers total $150,000 or less from the budget category.
For example, within the Professional Services and
Consultants budget level 2 category, the CFO may authorize that $150,000 move from the Data Management to the
Technical Support budget level 2 categories, provided that the total Professional Services and Consultants budget level 2 category remains the same.
148
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 61 TABLE 1. EXAMPLE: EXPENSE TRANSFERS WITHIN BUDGET LEVEL 2 CATEGORIES TABLE 2. EXAMPLE: EXPENSE TRANSFERS BETWEEN BUDGET LEVEL 2 CATEGORIES Professional Services and
Consultants
FY23 Original Budget FY23 Amended Budget Change
Data Management $10,541,810 $10,391,801 $(150,000)
Legal/Regulatory $1,330,000 $1,330,000 $ -
Other Services $1,111,000 $1,111,000 $ -
SDG&E Fees $2,563,226 $2,563,226 $ -
Technical Support $1,335,000 $1,485,000 $150,000
Total Prof. Svcs. Expenses $16,881,036 $16,881,036 $ -
Budget Level 2 FY23 Original Budget FY23 Amended Budget Change Cost of Energy $661,638,828 $661,638,828 $ -
General and Administration $2,591,363 $2,741,363 $150,000 Marketing and Outreach $4,164,167 $4,164,167 $ -
Personnel Costs $7,951,499 $7,951,499 $ -
Programs $1,395,000 $1,395,000 $ -
Debt Service $1,314,922 $1,314,922 $ -
Total Prof. Svcs. Expenses $695,936,815 $695,936,815 $ - Additionally, for example, the CEO may authorize that $150,000 move from the Professional Services and Consultants to the General Administration budget level 2 categories.
The CEO under his or her discretion may still require approval of the Board for any budget changes that may fall under the discretion of the Policy. Amendments to the annual budget as approved by the Board will reset the original appropriation (revenue or expense) for the fiscal year for the purposes of the Policy.
Balanced Budget
A balanced budget shall exist when the total projected
revenues are greater than or equal to total projected
expenses. Total revenues shall include all revenues from retail and wholesale sales of electricity. Total expenses shall include all operating expenses, program expenses, and
contributions to reserve funds. Any year-end surplus will be used to maintain reserve levels. Any decrease in revenues and or increase in expenditures that causes the budget to become imbalanced will require an amended budget. The
CFO shall prepare a proposed amended budget and submit
to the Board for approval.
149
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 62 Financial Reserves Policy
Purpose
San Diego Community Power (SDCP) will maintain Financial Reserves (Reserves) as described in this policy to:
• Meet SDCP’s strategic objectives
• Secure, maintain, and/or improve a standalone
investment grade credit rating
• Secure favorable terms with vendors, including power
producers
• Satisfy working capital requirements
• Adhere to contractual covenants
• Provide funds to cover unanticipated expenditures
• Support rate stability
Policy Guidelines
SDCP’s financial reserve goal is to secure 180-days of cash on hand.
The contribution to Reserves is determined through SDCP’s annual budget process as defined in the agency’s Budget Policy and/or SDCP’s rate setting process as defined in the agency’s Rate Development Policy. To the extent SDCP
is ability to meet operational expenses and maintain
competitive rates, SDCP will establish rates and adopt
budgets with the goal of building and maintaining Reserves at or above the 180-days of cash on hand target level.
Definitions
• Days cash on hand: unrestricted cash and cash
equivalents x 365 / (operating expenses for the current fiscal year)
• Reserves: Net position
• Use of Reserves: A projected or estimated reduction
in the amount of reserves by the end of a fiscal year
below the sum of the balance of the reserves at the
commencement of the fiscal year plus the projected
addition to the Reserves in the budget for the current
fiscal year.
Reserve Review
Reserves and annual contributions will be reviewed on an annual basis as part of SDCP’s budget process. Reserves will also be reviewed at the completion of SDCP’s annual audit to reconcile the Reserve balance.
Reserve Distribution
If reserves exceed the 180-days of cash on hand target level established in this policy, the Board may authorize reserve distributions as follows.
• Strategic Uses: Use excess funds for capital projects, financing programs, paying down existing debt, rate
reductions, or other strategic purposes.
• Stabilization Reserve: Use excess funds to fund a Rate Stabilization Reserve. A Stability Reserve mitigates
financial and cost of energy risk due to cyclical cost
of energy fluctuations and rate shocks and may
maintain compliance with financial covenants. The
purpose of this reserve would be to provide budgetary
stabilization and not to serve as an alternative funding source for new programs.
• Programmatic Reserve: Use excess funds to establish
a contingency for programs and projects. Specifically,
this Reserve could fund unforeseen and unexpected
needs such as cost overruns, local leveraging or
matching for external funds, or other programmatic
needs as required.
Conditions for Use of Reserves
• Temporary reductions in Reserves for cash flow purposes to even out the expected peaks or dips in revenues
and expenditures are normal cyclical occurrences to be
expected during the fiscal year, and do not constitute a use of reserves. Transfers to and from Reserves to account for such temporary cash flow fluctuations is within the discretion of the CFO.
• The CEO will have the discretion to authorize the use of reserves during the fiscal year up to the lesser of 10% of the year’s total budgeted costs, or $100 million, for the following purposes:
1. Cover increases in power supply expenses due
to spikes in costs and/or due to higher customer
demand;
2. Meet any margin or collateral posting requirements
under energy supply contracts; and
3. Provide resources to meet emergency expenditures.
• Any further use of reserves as necessary or desirable, must be recommended by the CEO to the Board for approval of
such use.
• Any use of the reserves under the CEO’s authority shall be reported to the Board at the next regularly scheduled meeting Policy Review
SDCP staff will complete a periodic review of this Financial Reserve Policy to ensure that the policy meets the needs of the organization.
150
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 63 Procurement Policy
Purpose
It is in the interest of San Diego Community Power (SDCP) to establish administrative procurement practices that facilitate efficient business operations and provide fair compensation and local workforce opportunities whenever possible within a framework of high quality, competitive service offerings.
Policy
1. Procurement of Professional Services
SDCP may contract for professional services, including
but not limited to consultant, legal, or design services, in its sole discretion. SDCP shall procure professional services in compliance with the Competitive Procurement Requirements in Section 5 of this Policy. SDCP shall
endeavor to secure the highest quality professional services available and is not required to award a contract for services to the lowest proposer.
2. Procurement of General Services
SDCP may contract for general services, including but
not limited to cleaning or maintenance services, in its sole discretion. SDCP shall procure general services
in compliance with the Competitive Procurement
Requirements in Section 5 of this Policy. Although SDCP shall not be required to award to the lowest proposer,
SDCP staff shall seek to procure general services at the lowest costs.
3. Procurement of Supplies
SDCP shall procure supplies in compliance with the
Competitive Procurement Requirements in Section 5 of
this Policy. Although SDCP shall not be required to award to the lowest proposer, SDCP staff shall seek to purchase supplies at the lowest costs. SDCP is encouraged to jointly procure supplies with other governmental agencies to
obtain the lowest cost when possible. In the event one
or more SDCP employees are designated as purchasing
agents, those individuals shall be included in SDCP’s
Conflict of Interest Code as persons who must file an
annual statement of economic interest.
4. Procurement of Public Works Projects
SDCP shall comply with California Public Contract Code
Section 20160 et seq. and other applicable laws and
regulations when procuring public projects in excess of $5,000. For purposes of this section, a “public project” shall have the same meaning as defined in Public Contract Code Section 20160, and includes, among other things,
projects for the erection, improvement, painting, or repair of public buildings and works.
5. Competitive Procurement Requirements
• Formal Bidding. SDCP shall issue a request for proposals (RFP), a request for qualifications (RFQ), or similar
competitive instrument for the purchase of goods or
services in excess of $125,000 in any given contract year or term. Proposals shall be evaluated in accordance with Section 7 of this Policy. These contracts are subject to Board approval before final execution.
a. Informal Bidding Procedures.
i. For contracts valued between $50,000 and
$124,999.99, staff shall solicit informal written
proposals from at least three providers,
if feasible. An informal written proposal
consists of a written proposal that includes
the provider’s name, address, phone number,
professional license number (if applicable),
the work to be performed, and the amount of
the proposal. A written proposal may be in an
electronic format.
ii. For contracts valued between $10,000 and
$49,999.99, staff shall solicit informal verbal
proposals from at least three providers. Staff
shall note the three verbal proposals by
including the provider’s name, address, phone
number, and amount of the verbal proposal
in SDCP’s records.
iii. For contracts valued at less than $10,000,
no formal or informal proposals shall be
required, but SDCP staff is directed to seek
the lowest cost supplies and the highest
quality services available.
iv. The Chief Executive Officer (“CEO”), at his or
her discretion, may direct that SDCP solicit
competitive procurements through the
formal bidding process for contracts under
$125,000.
b. Informal Bidding Procedures. The provisions
below shall apply to all methods of procurement
described above.
• When procuring goods and services utilizing state or
federal funds (e.g., grant or loan funds), SDCP shall
comply with all state or federal project requirements
in securing any goods or services necessary. If there is conflict between the foregoing, the more restrictive
requirements shall apply.
151
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 64 • SDCP shall not be required to award a contract to
purchase goods or services from the lowest responsible
bidder, unless required by California law.
• No SDCP officer or employee shall split purchases
into more than one purchase in order to avoid the
Competitive Procurement Requirements in this Policy
• No SDCP officer or employee shall accept, directly
or indirectly, any gift, rebate, money or anything else of value from any person or entity if such gift, rebate, money or anything of value is intended to reward or be an inducement for conducting business, placing orders with, or otherwise using the officer’s or employee’s position to secure a contract with SDCP.
c. Exceptions to Competitive Procurement
Requirements.
i. Based on the unique facts or circumstances
described below and a written justification
retained in SDCP’s records, the CEO, after
consultation with the General Counsel, may
waive one or more purchasing procedures
in this Policy and/or use sole source
procurement if the CEO determines that the
best interests of SDCP are served; provided,
however, that such method is not in violation
of applicable law or policy.
• Based on the unique facts or circumstances described
below and a written justification retained in SDCP’s
records, the CEO, after consultation with the General
Counsel, may waive one or more purchasing procedures
in this Policy and/or use sole source procurement if
the CEO determines that the best interests of SDCP
are served; provided, however, that such method
is not in violation of applicable law or policy. Sole
source purchasing is authorized when the goods or
services contemplated are capable of being supplied or
performed by a sole provider, such as the holder of an
exclusive patent or franchise, for purchase of unique or innovative goods or services including but not limited to computer software and technology, or for purchases of
goods or services when there is a demonstrated need for compatibility with an existing item or service. Sole source procurement may also be utilized when it is apparent that a needed product or service is uniquely available from the source, or for all practical purposes, it is justifiably in the best interest of SDCP to utilize sole source procurement.
The following factors shall not apply to sole source
procurements and shall not be included in the sole source justification: personal preference for product or vendor; cost, vendor performance, or local service (this may be considered an award factor in competitive procurements); features that exceed the minimum requirements for the
goods or services; explanation of the actual need and
basic use for the equipment, unless the information
relates to a request for unique factors.
ii. No competitive procurement shall be
required for goods or services valued at less
than $10,000 in any one contract term or
contract year.
iii. No competitive procurement shall be
required to rent or lease equipment.
• Competitive procurement shall not be required when the contract, goods or services will be provided by another governmental agency. SDCP can rely on the competitive
procurement process provided by another governmental
agency, provided that such agency’s procurement is in
compliance with California law.
iv. In the event of an emergency, the CEO
may suspend the normal purchasing and
procurement requirements for goods and
services related to abatement of the impacts
or effects of the emergency.
6. Signing Authority:
SDCP’s CEO and designated staff are authorized to execute contracts and related documents in accordance with
SDCP’s Delegated Contract Authority Policy.
7. RFP/RFQ Issuance and Proposal Evaluation
• Proposals received through formal bidding procedures
shall be subject to a set of criteria and a scoring system, reviewed and evaluated by relevant SDCP staff and an
evaluation committee selected by the CEO or, at the
discretion of the Board, members of a designated Board
committee. Proposals received shall be evaluated based
on competency to perform the scope of work, best fit,
price competitiveness, compliance with subsections i
(San Diego County Preference) and ii (Other Preferences) below, and other additional criteria added pursuant to
SDCP’s Inclusive and Sustainable Workforce Policy.
The preferences below may not apply to procurements
conducted jointly with other public agencies, and shall not apply when prohibited by state or federal statutes or regulations that require award to the lowest responsible bidder. Proposers may only pursue two of the four
preferences.
i. Businesses with office(s) located in San Diego
County and include at least 25% San Diego
County residents under their employment
shall receive a bonus of up to 5 points or
5% out of a 100-point scoring system in
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 65 competitive solicitations. To receive the
preference, a proposer must submit written
information relating to the location of
its office(s) in San Diego County and the
percentage of San Diego County residents
under its employment.
• Businesses certified as disabled veteran business
enterprises as by the Supplier Clearinghouse
(thesupplierclearinghouse.com) shall receive a bonus of up to 5 points or 5% out of a 100-point scoring system
in competitive solicitations. To receive the preference, a proposer must submit proof of current, valid certification by the Supplier Clearinghouse. Such proof shall be subject to verification by SDCP.
• Businesses certified as a Persons with Disabilities business enterprise by the Supplier Clearinghouse or Disability:IN shall receive a bonus of up to 5% or 5 points out of a
100 point scoring system in competitive solicitations. To receive the preference, a proposer must submit proof of current, valid certification by the Supplier Clearinghouse or Disability:IN. Such proof shall be subject to verification by SDCP.
• Businesses certified as small business by the Department of General Services shall receive a bonus of up to 5% or 5 points out of a 100-point scoring system in competitive solicitations. To receive the preference, a proposer
must submit proof of current, valid certification by the Department of General Services. Such proof shall be
subject to verification by SDCP.
• SDCP is committed to the highest standards of
responsible behavior and integrity in all of its business relationships. SDCP will consider a company’s business
practices, environmental record, and commitment to
fair employment practices and compensation in its
procurement decisions.
8. Nondiscrimination Contract Clause
Each SDCP contract and subcontract shall contain a
nondiscrimination clause that reads substantially as
follows: Contractor shall not discriminate on the basis of race, gender, gender expression, gender identity, religion, national origin, ethnicity, sexual orientation, age, or disability in the solicitation, selection, hiring, or treatment of subcontractors, vendors, or suppliers. Contractor shall provide equal opportunity for subcontractors to participate in subcontracting opportunities.
9. Information on Supplier Diversity
Public Utilities Code Section 366.2(m) requires certain community choice aggregators, including SDCP, to
annually submit to the CPUC: (1) a detailed and verifiable plan for increasing procurement from small, local, and
diverse business enterprises; and (2) a report regarding its procurement from women, minority, disabled veteran, and LGBT business enterprises.
General Order 156 (GO 156), adopted by the California
Public Utilities Commission (CPUC), requires certain
California public utilities to engage in outreach activities and meet specific procurement goals from women, minority,
disabled veteran, persons with disabilities, and LGBT
business enterprises. Qualified businesses become
GO 156 certified through the CPUC and are then added
to the GO 156 Supplier Clearinghouse database
(www.thesupplierclearinghouse.com).
To assist SDCP with its reporting obligations under Public Utilities Code Section 366.2(m) and with evaluating its supplier outreach and other activities, proposers that are awarded the contract will be asked to voluntarily disclose their certification status with the CPUC Clearinghouse, as well as their efforts to work with diverse business
enterprises, including WBEs, MBEs, DVBEs, and LGBTBEs.
Except as otherwise expressly provided under this Policy and/or required by applicable state or federal law or funding requirements (including, without limitation, any grant or loan conditions), SDCP shall not use any demographic
information received from potential vendors in any way
as part of its decision-making or selection process. Rather, SDCP will use such information solely for compliance
with its reporting obligations to the CPUC and evaluation of SDCP’s outreach and other activities consistent with applicable law. Pursuant to Article I, Section 31 of the California Constitution, SDCP shall not discriminate against or give preferential treatment to any individual or group on the basis of race, sex, color, ethnicity, or national origin except as otherwise allowed therein.
10. Procurement of Power and Energy Attributes
SDCP must secure sufficient power resources and energy
attributes to serve its customers, comply with State law, and meet Community Power’s and its member agencies’
goals. Community Power has adopted an Energy Risk
Management Policy authorizing certain Community
Power staff to enter into power purchase agreements and other agreements to secure power and energy attributes.
This Procurement Policy shall not apply to the acquisition of power or energy attributes.
11. Review and Approval as to Form by General Counsel
All SDCP agreements must be approved as to the form and content by the General Counsel or his/her designee prior to signature by any authorized individual.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 66 Debt Policy
Subject
Debt Policy
Policy Guidelines
This Debt Policy (“Policy”) establishes San Diego
Community Power’s (“SDCP”) Debt Policy. The Policy
articulates: (1) the situations and steps necessary for the issuance of debt; (2) the types of debt that may be issued; and (3) how the debt fits into SDCP’s capital investment program (CIP), Community Power Plan, integrated resource plan, or strategic policy goals.
This Policy is adopted pursuant to Senate Bill 1029
(Hertzberg, 2016) and Government Code Section 8855 et
seq. and must be adopted or amended by resolution. The
SDCP Board of Directors (“Board”) is required to adopt a formal Debt policy before any debt can be used.
Background
The SDCP Board adopts budgets and establishes and
adjusts rates, as appropriate, each fiscal year to provide sufficient revenues to pay all operating expenses, make required payments and comply with commitments on all
other debts or financial obligations of the Agency. SDCP is committed to long-term financial planning, maintaining appropriate reserve levels, and employing prudent practices in governance, management, and budget administration.
The Community Power Board further adopted its Strategic Plan on June 23, 2022, which included the goal to adopt financial controls and policies to meet or exceed best
practices and manage risk.
SDCP utilizes financial policies that foster financial stability, support fiscal discipline, and enable SDCP to maintain strong investment-grade credit ratings.
This Policy confirms the commitment of the SDCP Board,
management, staff, advisors and other decision makers to adhere to sound financial management practices, including full and timely repayment of all borrowings, allowing
continuing ready access to the capital markets to achieve the most effective cost of capital within prudent risk parameters.
The goals and objectives of this Policy are as follows:
• Maintain cost-effective access to capital markets
• Maintain a prudent level of financial risk
• Preserve future financial flexibility
• Finance capital projects, acquisitions, or improvements in a timely and cost-effective manner
• Manage debt effectively within SDCP Board
established objectives and parameters
• Maintain strong credit ratings and good
investor relations
• Maintain compliance with all relevant laws,
reporting, and and disclosure requirements
• Foster integrity in the debt management process
Further, this Policy is intended to comply with the regulatory requirements of California Government Code Section
8855 and Senate Bill 1029 which, among many things,
requires debt issuers to adopt a local debt policy governing the issuance of debt and to enhance the management of
government financial resources.
Scope and Authority
This Policy shall govern the issuance and management of all bonds and other forms of indebtedness of SDCP, together with any credit, liquidity, or other security instruments and agreements that may be executed in connection with the
issuance of bonds and other forms of indebtedness (“bonds” or “debt”). It also considers certain financial targets which SDCP and its Board may contemplate in the future in order to continue to implement its capital investment program and to support cost-effective borrowing.
While this Policy specifically governs debt issued directly by SDCP, SDCP may consider joint arrangements with other
municipal issuers or private parties to finance a project when it serves SDCP’s policy objectives. SDCP is authorized to join together with other municipal agencies to create a separate entity, such as a joint powers authority, to issue debt on behalf of SDCP or the project participants. Typically, joint venture debt is repaid through revenues generated by the project, and SDCP will be liable only for its share of debt service, as specified in a contract executed in connection with the joint venture debt. If the potential for a joint venture does exist, SDCP will examine and negotiate the financial arrangements, obligations, liabilities, tax issues and other factors that may arise in the context of impacts on SDCP and its direct debt obligations using this Policy and financial best practices as guidance. SDCP will comply with state law limitations and in general, avoid joint procurement situations if SDCP lends it credit or enhances the credit of another entity, unless doing so will result in other net tangible benefits to SDCP. Further, as with all SDCP debt, any joint venture debt would be subject to evaluation and authorization of the Board.
While adherence to this Policy is generally required, it is recognized that changes in the capital markets, SDCP programs and other unforeseen circumstances may from
time to time produce situations that are not covered by the Policy and will require modifications or exceptions to best achieve policy goals. In these cases, management flexibility 154
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 67 is appropriate, provided specific authorization from the SDCP Board is obtained.
This Policy shall be reviewed at least annually as described below and presented to the SCDP Board for approval of any changes as appropriate. This Policy will remain in effect as amended or restated in the future by the Board.
Notwithstanding anything in this Policy to the contrary, the failure of SDCP to comply with any provisions of this Policy shall not affect the authorization, validity, or enforceability of any debt or other forms of indebtedness that are otherwise issued in accordance with law.
Use of Debt
To achieve its objectives, SDCP may consider debt financing for the construction, acquisition, rehabilitation, replacement, or expansion of physical assets, including real and personal property, equipment, furnishings, and improvements. Debt may also be issued for other Board-approved needs or for the refunding of prior outstanding debt.
For example, SDCP may consider the use of debt to finance ownership interest in generating or storage assets if it is determined to be a cost-effective alternative to a standard power purchase agreement or if asset ownership may afford synergies between SDCP’S other objectives (e.g., resiliency, GHG free energy, etc.) or additional measurable advantages in terms of operational efficiency.
SDCP, under the direction of the Board, will retain full flexibility in determining the best funding approach on a case-by-case basis.
Types of Debt
Types of bond issuance, further described in the Appendix, include:
• New Money: Debt may be incurred to provide for
capital financing for future capital expenditures or
reimbursement of prior expenditures.
• Refunding: Refunding bonds may be issued to realize
debt service savings, restructure outstanding debt,
modify covenants, or for other debt management
purposes. Absent significant non-economic factors,
refunding transactions contemplated solely for debt
service savings must produce a minimum aggregate
net present value debt service savings of at least 3% of the par value of the refunded bonds, calculated using
the refunding issue’s true interest cost (“TIC”) as the discount rate. SDCP will work with its Municipal Advisor (“MA”) to assess potential refunding opportunities.
Bonds may be issued as taxable or federally tax-exempt:
• Tax-Exempt: Interest received by bondholders of
SDCP’s bonds issued on a federally tax- exempt basis
is exempt from federal income tax, and so typically
may be issued at lower interest rates, reducing SDCP’s
cost of borrowing. Additional interest rate advantages
may be available for bank qualified bonds (where
SDCP will issue less than $10 million of tax-exempt
bonds in a year). However, SDCP is limited by federal
tax law in the uses of tax-exempt bond proceeds
and must comply with additional federal tax law
requirements during the full term of any bond issue.
Uses of proceeds typically require a governmental
purpose and must be spent on capital improvements
rather than operating expenses. Tax implications
include having reasonable expectations for spending
proceeds at the time of issuance, limiting private use
of financed projects, and complying with arbitrage
restrictions on the bond proceeds.
• Taxable: Taxable debt’s interest is not exempt from
federal income tax, and so is typically issued at higher interest rates than tax-exempt debt. However, the
IRS restrictions described above do not apply, and
so SDCP may wish to use taxable debt in situations
where the project or purpose of borrowing may not
meet federal tax law requirements. SDCP may also
consider taxable tax credit or direct subsidy bonds,
such as Clean Renewable Energy Bonds, Qualified
Energy Conservation Bonds, etc., that offer lower costs of borrowing to SDCP through the issuance of taxable
debt that is supported by federal subsidy payments on
the interest expense to SDCP.
Method of Sale
SDCP may choose to issue bonds using either a competitive or negotiated sale process. SDCP may also sell bonds by means of a private placement or direct sale with a financial institution or other accredited investor when this method is expected to result in cost savings or provide other
advantages compared to a traditional public offering. SDCP staff will work with its Municipal Advisor to determine the most appropriate method of sale for each issuance. Please see the Appendix for a detailed description of the different methods of sale that SDCP may consider.
Structure and Term
The repayment schedule of a bond issue can vary greatly from one sale to another. The same is true for other debt instruments. SDCP will consider which structures meet
SDCP’s strategic goals, are cost effective, minimize the new 155
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 68 debt’s impact on SDCP’s overall debt service schedule,
future debt capacity, and other factors when deciding how to structure new debt. In addition to debt amortization terms, structuring options may include the addition and procurement of credit enhancement, the establishment
of reserves, the use of capitalized interest, and call or redemption options.
In structuring debt service, SDCP shall consider (1) current and forecasted revenues and any anticipated changes to
rates, charges and operating expenses, (2) future borrowing plans, (3) meeting the Credit Considerations described in the next section, and (4) feedback from the Municipal Advisor and rating agencies on a structure’s potential impacts to SDCP’s credit worthiness. Generally, but not a requirement under this Policy, SDCP prefers level debt service over time.
SDCP, consistent with tax law, will not structure debt with a maturity date that materially exceeds the average useful life of the assets or improvements being financed.
Green Bonds
To the extent possible, SDCP bond issuances shall be green bonds. A green bond is a type of fixed-income instrument that is specifically earmarked to raise money for climate and environmental projects. These bonds are typically asset linked and backed by the issuing entity’s balance sheet, so they usually carry the same credit rating as their issuers’ other debt obligations.
Credit Considerations
When SDCP issues debt, the Agency will have to execute
certain bond documentation and agreements (herein
generally referred to as ‘indentures’) that will bind SDCP to specific terms or requirements. Generally speaking,
SDCP will agree to abide by certain covenants written in the indenture which describes in detail the obligations and responsibilities of SDCP and the rights of the bondholders which are designed to protect bondholders by setting
standards by which SDCP agrees to comply. These types of covenants may require SDCP to meet certain requirements or, conversely, may forbid SDCP from undertaking certain activities that would jeopardize SDCP’s ability to repay its debt. An indenture defines SDCP’s contractual obligations and determines the parameters of SDCP’s permissible
financial behavior.
The incorporation of effective bond covenants into SDCP’s future bond issues and respective documentation signal
a commitment to abide by stated financial and operating parameters over the long-term and contribute towards
SDCP’s ability to maintain strong financial health. Credit ratings are ultimately statements about the likelihood of full and timely debt repayment. Because bond covenants govern an issuer’s ongoing financial behavior, the analysis of bond/ indenture covenants and their impact on the risk profile of a bond is an integral part of the credit rating process.
Credit ratings are fundamentally forward-looking opinions on the relative default risk associated with a particular issuer and its debt obligations. Credit ratings have a significant impact on the interest rates for SDCP debt, and therefore SDCP will work to address the cost and benefits of obtaining and maintaining strong credit ratings. Depending on the lien structure of the debt, some, or all, of the following factors may be included in its bond documentation in order to
obtain and maintain strong credit ratings that would broaden the appeal of and lower the cost of debt issued by SDCP. • Debt Service Coverage Ratio: The ability of an
agency to pay debt service (i.e. principal and interest on debt obligations) when due is often measured by
how much cash flow is available, after payment of
operating expenses, to cover debt service payments
(Debt Service Coverage Ratio). Debt Service Coverage
Ratio is a common financial metric used in the
utility industry and is used by the rating agencies
and investors to determine the ability of a utility to
fulfill its debt obligations and ensure that the utility generates sufficient revenues to make its debt secure.
SDCP’s future indentures will likely require cash flow
in excess of debt service, or a Debt Service Coverage
Ratio greater than 1.0x. Many public agencies target
a Debt Service Coverage Ratio in its financial and
debt policies higher than the minimum required by
its indenture to improve debt ratings and lower their
costs of borrowing. Should SDCP establish a minimum
Debt Service Coverage Ratio in its future indentures,
the Board may consider establishing a target ratio
in this Policy that is higher than the legal minimum.
Note, that a failure by SDCP to meet a target ratio
proposed in this Policy will not result in a default under the indenture so long as the minimum Debt Service
Coverage Ratio is achieved.
• Rate Covenant: A rate covenant is a promise to set
rates or fees at levels that are set to recover sufficient revenues at a designated threshold level to cover
operating expenses and debt service payments. This
designated threshold level is the same as the Debt
Service Coverage Ratio discussed previously. SDCP
may develop one or more rate covenants in order
to measure and govern operating performance. As
noted, future indentures may establish minimum
levels of coverage and SDCP’s Board-adopted financial
policies may establish internal goals that exceed these minimum coverage requirements.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 69 • Additional Bonds Test: If SDCP were to issue bonds
or other debt obligations, the indentures governing
those obligations may have covenants that stipulate
whether SDCP may sell additional bonds in the future
that share that same pledged revenue stream as
security. SDCP may develop conditions or standards
in its indentures that describe the parameters whereby
SDCP could issue additional bonds (referred to as an
“additional bonds test”). This test is intended to ensure that future bond issuance does not reduce bondholder
security by placing too high a burden on the revenue
stream. The additional bonds test may require that
SDCP demonstrate that it has sufficient revenues to
meet or exceed the designated Debt Service Coverage
Ratio before additional bonds can be issued.
While the specific formulation of the Additional Bonds
Test may vary depending on the type of bonds being
contemplated, the SDCP will utilize an Additional
Bonds which establishes a limitation on new issuances
such that the pledged revenues are no less than one
and a half times (1.5x) the maximum annual principal
and interest and debt service for the aggregate
outstanding senior lien bonds including the debt
service for the new issuance.
The Agency will also seek to maintain aggregate
annual debt service on long-term debt at a level not-to-exceed 5% of the Agency’s annual total operating expenses. The actual terms and conditions specific to
each debt issue will be controlled by the applicable
documents.
• Reserves: SDCP may maintain reserves including
those in compliance with GASB 62 such as the adopted
Operating Reserve Fund to act as a rate stabilization
fund that can help mitigate the impacts of revenue
variability. Depending on whether or not SDCP
incorporates a rate stabilization fund reserve into its indentures, this reserve may be used to help meet
Debt Service Coverage Ratio requirements during
times of revenue shortfalls. This fund can be a valuable tool to manage and mitigate the risk related to any
Debt Service Coverage Ratio requirements included
in future indentures and to address revenue and rate
volatility. There are other reserves that the Board may consider adopting in the future that, for example, may
be utilized for paying debt service, for funding specific capital projects, or for emergency purposes etc.
• Additional Ratio Targets: In the future the Board
will continue to monitor this Policy and will establish enhancements to further strengthen the financial
ratios and targets of SDCP. For example, while not a
ratio included in Indenture covenants, another ratio
that can help measure SDCP’s financial health and
position is the ratio of debt-funded capital to overall capital spending (i.e., debt to pay-go spending).
Prudent use of debt financing rather than pay-go funding of capital projects can facilitate better allocation of resources over time and ensure payment
equity across generations for the use of long-term
assets.
Financing Team and Professional Services
SDCP will assemble a financing team that will provide advice and support for the development and implementation of
debt issuance as well as ongoing analysis and support. The financing team will include both SDCP staff and outside professional consultants. When required by SDCP’s
procurement policy, SDCP will use a competitive process through a Request for Proposal (“RFP”) in the retention of professional consultants. Otherwise, SDCP will adhere to its best practices in contracting to procure such vendors. The professional consultants selected by SDCP could be engaged to help develop a credit strategy, issue debt and/or assist SDCP with its compliance with applicable federal and state statutes, and Internal Revenue Code at the time of issuance as well as on a continuing basis. Please see the Appendix for a detailed description of the outside professional consultants SDCP may include on its financing team.
Debt Administration
The Chief Executive Officer (“CEO”), or designee shall make recommendations on budget, stabilization transfers and rate adjustments. The Chief Financial Officer shall be responsible for the administration and implementation of this Policy and will have day-to-day responsibility for structuring, implementing and managing SDCP’s debt program.
Internal Control Procedures
When issuing debt, in addition to complying with the terms of this Policy, SDCP shall comply with any other applicable policies regarding initial bond disclosure, continuing
disclosure, post- issuance compliance, and investment of bond proceeds. Please see the Appendix for a detailed
description of SDCP’s internal control procedures.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 70 Post-Issuance Administration
SDCP will comply with requirements pertaining to initial bond disclosure, continuing disclosure, tax-exemption,
postissuance compliance, and investment of bond proceeds.
This includes any continuing disclosure undertakings
under Securities and Exchange Commission (“SEC”)
Rule 15c2-12; tax covenants and related federal tax
compliance requirements such as arbitrage restrictions
and rebate requirements; and all California State reporting requirements.
Please see the Appendix for a detailed description of SDCP’s Post-Issuance Compliance Policy and additional information on SDCP’s post-compliance procedures.
Training
The Chief Financial Officer shall provide training the
members of SDCP staff involved in the tax compliance and the initial or continuing disclosure process in coordination with the CEO, and the SDCP Board regarding their respective responsibilities for disclosure and tax compliance.
The Chief Financial Officer, or designee, shall arrange for periodic disclosure and tax training sessions conducted by SDCP’s disclosure counsel or other professionals (e.g., seminars) which shall include education regarding disclosure policies, SDCP’s disclosure obligations under applicable federal and state securities and tax laws, and the tax
compliance and disclosure responsibilities of SDCP.
Policy Review
In coordination with the CEO, the Chief Financial Officer, or designee, will be responsible for regularly reviewing and updating this Policy, and shall present any recommended revisions to the Board for consideration and adoption.
APPENDIX
Permitted Types of Debt
SDCP may legally issue both short-term and long-term
debt, through either a direct loan or through the public market, using the debt instruments described below. SDCP in consultation with its internal Counsel, Bond Counsel and Municipal Advisors, shall determine the most appropriate instrument for a proposed debt offering.
SDCP may issue the following types of tax-exempt or
taxable Debt:
• Long-Term Debt: Long-term debt generally includes
debt issued to finance capital expenditures with the
objective of structuring repayment within the expected
life of the financed asset. Debt may be used as a
tool for rate stabilization as repayment of the debt
is spread over the useful life of the financed project.
Long-term bonds may bear interest at fixed or variable
rates or structured with level debt service payments
or otherwise with term maturities. Long-term revenue
bonds are a type of debt that may be entered into
by SDCP and which may be secured by a lien on the
revenues of SDCP. SDCP may also enter into long-term loans with state or federal agencies. These loans typically have fixed interest rates. Government loan
programs may offer favorable interest rates and terms,
and should be considered as alternatives to market
rate debt when available. The use of longterm debt will be evaluated with pay-as-you-go capital investment
and would not be expected (absent extraordinary
circumstances) to fund non-capital operational
expenditures or operating deficits.
• Short-Term Debt: Short-term debt generally has a
maturity of less than 7 years and may take several
forms, including notes, commercial paper, direct bank
loans and other short-term products with either fixed
or variable rates. Short-term debt products are flexible cash management tools that are primarily used to
meet interim funding (pending the issuance of long-term debt). When approving short-term debt products, the Board may limit SDCP’s percentage of short-term
debt when compared to its long-term debt portfolio
taking into account future market access, term-out
provisions and retail rate stability.
• Variable-Rate Debt: In addition to interim financing, which includes commercial paper and similar short-term borrowing programs, it may be appropriate to issue long-term variable rate debt that bears an
interest rate that is reset periodically at predetermined intervals, including entering into revolving credit
facilities, to diversify the debt portfolio, to reduce
interest costs, and to improve the match of variable
rate assets (such as short-term investments and
reserves) to liabilities. The amount of variable rate
debt will generally not exceed a net 20% after
consideration of investments and cash equivalents of
the outstanding debt portfolio of SDCP.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 71 SDCP may consider the following types of fixed or variable rate debt:
• Revenue Bonds secured by general revenue
or project revenues
• Commercial Paper or other Interim Funding Notes
• Capital Leases
• Certificates of Participation/Lease Revenue Bonds
• Installment Sale or Purchase Agreements Revenue Bonds • Bond or Grant Anticipation Notes
• Tax and Revenue Anticipation Notes
• State and Federal Loans and Grants
• Direct Bank Loans or Lines of Credit
• Public Private Partnerships
This list is not meant to be inclusive of all options that may be available to SDCP as different circumstances may dictate.
SDCP may from time to time find that other types of debt would be beneficial to further its purposes and may approve such debt without an amendment to this Policy.
Method of Sale
SDCP may choose to issue bonds using either a competitive or negotiated sale process. SDCP may also sell bonds by means of a private placement or direct sale with a financial institution or other accredited investor when this method is demonstrated to result in cost savings or provide other advantages relative to a traditional public offering. SDCP staff will work with its Municipal Advisor to determine the most appropriate method of sale for each issuance.
• Competitive Sale: SDCP may elect to sell bonds in
the public market on a competitive basis depending
on market conditions, required size of issuance
and relative complexity of structure. The Bonds are
marketed to a wide audience of investment banking
(underwriting) firms. The underwriter is selected based on its bid for the securities. SDCP will award the sale of the competitively sold bonds on the basis of the
lowest true interest cost basis. Pursuant to this policy, The Chief Financial Officer, or designee, is authorized to sign the bid form on behalf of the SDCP fixing the
interest rates on bonds sold on a competitive basis.
• Negotiated Sale: SDCP may elect to sell bonds in
the public market on a negotiated basis depending
on market conditions, required size of issuance and
relative complexity of structure. SDCP staff selects the underwriter, or team of underwriters, of its securities in advance of the bond sale on the basis of responses to
a proposal review. With the assistance of the Municipal Advisor (MA), SDCP staff works with the underwriter
to bring the issue to market and negotiates all rates
and terms of the sale. In advance of the sale, SDCP
staff will determine compensation for and liability of
each underwriter employed and the designation rules
and priority of orders under which the sale itself will be conducted. Pursuant to this policy, the Chief Financial Officer or designee will be authorized to sign the bond purchase agreement on behalf of SDCP, fixing the
interest rates on bonds sold on a negotiated basis.
• Private placement: SDCP may elect to issue debt
on a private placement basis. Such method shall
be considered if it is demonstrated to result in cost
savings or provide other advantages relative to other
methods of debt issuance, or if it is determined that
access to the public market is unavailable and/or timing considerations require that a financing be completed
more quickly than required for a competitive or
negotiated sale.
Financing Team and Professional Services
SDCP will assemble a financing team that will provide advice and support for the best execution of each debt transaction.
The financing team may consist of multiple parties with distinct responsibilities and is generally comprised of both SDCP staff and outside professional consultants. These
outside professional consultants may include:
• Municipal Advisors: SDCP shall utilize the services
of independent MAs in connection with debt-related
issuances or projects. SDCP’s MA will not serve as an
underwriter on negotiated bond sales of SDCP.
• Underwriters: SDCP will utilize an underwriter in the sale of bonds on a competitive or negotiated basis. An
underwriter is a financial services firm that acquires (by purchase) bonds for resale in the public bond markets.
For a negotiated sale, SDCP will select an underwriter
through a request for proposal process; basing the
selection on value for SDCP including capital structure, underwriting capabilities, demonstrated expertise
and experience as well as proposed fees. SDCP may
also select an underwriting firm to act as placement
agent in connection with a private placement of bonds.
In a competitive sale, bonds are offered for sale at a
designated date and time, and multiple underwriters may submit bids. The bonds are awarded to the underwriter
(or group of underwriters) that submit the lowest bid.
• Disclosure Counsel: SDCP will endeavor to provide
complete and appropriate disclosure of financial and
legal condition in the issuance of debt. SDCP will also take steps and adopt policies in order to provide for
compliance with continuing disclosure requirements.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 72 Disclosure counsel, which may be Bond Counsel, shall
be responsible for assisting SDCP in the preparation of the Preliminary and Final Official Statements and any
other disclosure documents. SDCP will select, through
a request for proposal process, and retain qualified
and experienced counsel in achieving this objective of
appropriate disclosure.
• Bond Counsel: SDCP will retain qualified and
experienced legal counsel as representation of SDCP
to provide the customary opinions required for the
issuance of bonds and other financial obligations. Bond counsel shall be responsible for developing the legal
documents required for each transaction and draft and
review documentation sufficient to provide approving
legal opinions. Bond counsel will render customary
approving legal and tax opinions for each transaction.
• Bond Counsel: SDCP may select through a request for
proposal process the services of a financial institution, acting through its trust division, to act as trustee.
The trustee may hold, invest and disburse financing
proceeds as directed by SDCP. The trustee will act as
registrar as well as the paying agent for SDCP debt. The Chief Financial Officer or designee shall monitor the
services rendered by the trustee.
Internal Control Procedures
All debt transactions must be approved by the Board of
Directors. The proceeds of bond sales will be invested
until used for the intended project(s) in order to maximize utilization of the public funds. The investments will be made consistent with the following guidelines: (1) compliance with federal tax arbitrage requirements, as applicable; (2) safety of principal; (3) liquidity; (4) diversity; and (5) return on investment or yield, and may be held as cash.
SDCP’s Investment Policy guidelines and bond indentures will govern objectives and criteria for investment of bond proceeds. The Treasurer will oversee the investment of bond proceeds consistent with the foregoing guidelines.
Proceeds of debt will be held either by a third-party trustee or by SDCP. The trustee will disburse bond proceeds to
SDCP upon submission of one or more written requisitions signed by an authorized SDCP officer. If the funds are held directly by SDCP, they must be held and accounted for in a separate fund or account, the expenditure of which will be documented by SDCP and subject to established internal
controls consistent with SDCP’s applicable policies and procedures. These procedures will include, in connection with each requisition or expenditure of proceeds held by SDCP, a written record of the particular capital project or program or other expense to which the funds drawn were
applied or allocated.
For bond proceeds that are meant to reimburse SDCP
for previous expenditures, SDCP staff will provide
documentation that conform to tax requirements and other applicable regulations. To support this certification, staff will analyze capital expenditures and establish that requirements are met before the bond issuance takes place and maintain a written record of such analysis and the amount reimbursed to each particular capital project or program or other expense to which such reimbursed proceeds are to be allocated.
For bond proceeds intended to provide funding for ongoing or upcoming capital expenditures, SDCP staff will monitor the expenditure process. Staff will analyze the use of
proceeds on an annual basis or more frequently, if deemed appropriate, until the proceeds are completely spent and will perform monitoring and record-keeping in accordance with SDCP’s accounting guidelines and other applicable
regulatory requirements. Refunding bond proceeds are
generally held by a third-party trustee or fiscal agent to be applied in connection with written directions generally prepared by bond counsel. SDCP will maintain records of the directions to the trustee, and will review of fund statements and other records received from, the trustee.
Post-Issuance Administration
SDCP will comply with requirements pertaining to initial bond disclosure, continuing disclosure, tax-exemption, post-issuance compliance, and investment of bond proceeds.
This includes any continuing disclosure undertakings under SEC Rule 15c2-12; tax covenants and related federal tax compliance requirements such as arbitrage restrictions
and rebate requirements; and all California State reporting requirements.
• Post-Issuance Compliance Policy: SDCP will adopt a
Post-Issuance Compliance Policy (“PICP”) to provide
for ongoing monitoring and reporting with respect to
compliance with SEC requirements for publicly offered
indebtedness and with tax regulations applicable to
tax-exempt debt. The PICP will provide for the federal
disclosure requirements, responsibility for reporting,
training, and describe procedures for compliance with
continuing disclosure agreements entered into for each
such series of bonds from the date they are issued until the bonds are no longer outstanding. The PICP may
be administratively adopted and amended without
approval of the Board.
• Financial Disclosure: SDCP will comply with applicable deliverable obligations and financial disclosure
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 73 requirements, as specified in any and all bond and
debt-related documents. Staff has developed and will
maintain an updated schedule of the requirements
in compliance with SDCP’s internal record-keeping
processes. SDCP will post required documents to the
Municipal Securities Rulemaking Board’s (“MSRB”)
Electronic Municipal Market Access (“EMMA”) website
as required on a timely basis. SDCP, at its discretion, may also post documents voluntarily to EMMA. SDCP
will provide financial disclosure to rating agencies,
institutional and individual investors, other levels
of government, and the general public to share
clear, comprehensible, financial information using
the appropriate channels/policies/procedures. The
Chief Financial Officer is responsible for monitoring
the compliance by SDCP of applicable disclosure
requirements. SDCP also may contract with an outside
service provider to monitor disclosure postings.
• Tax Compliance: SDCP will comply with applicable
federal arbitrage and rebate regulations related
to its bonds and other debt instruments. These
responsibilities include monitoring the investment and
expenditure of bond proceeds, maintaining a system
of record-keeping and reporting and contracting
for the services of outside arbitrage consultants as
necessary. SDCP will establish and implement post-issuance procedures to guide its compliance with these requirements. The Chief Financial Officer is responsible for monitoring the compliance by SDCP of applicable
tax requirements for debt issued on a tax-exempt
basis.
• Record Keeping: A copy of all debt-related records
shall be retained at SDCP’s offices or otherwise
electronically. At a minimum, these records shall
include all official statements, bid documents, bond
documents/transcripts, indentures, resolutions, trustee statements, leases, and title reports for each financing (to the extent available). The following documents
shall be maintained for the term of each issue of bonds (including refunding bonds) plus at least three years:
– A copy of the bond closing transcript(s) and oth-er relevant documentation delivered to SDCP at or in connection with closing of the issue of
bonds;
– A copy of material documents relating to capital
expenditures financed or refinanced by bond
proceeds, including (without limitation) con-struction contracts, purchase orders, invoices, trustee requisitions and payment records, draw
requests for bond proceeds and evidence as to
the amount and date for each draw down of
bond proceeds, as well as documents relating
to costs paid or reimbursed with bond proceeds
and records identifying the assets or portion of
assets that are financed or refinanced with bond
proceeds, including a final allocation of bond
proceeds;
– A copy of all contracts and arrangements in-volving the use of bond-financed or refinanced assets; and
– A copy of all records of investments, investment
agreements, arbitrage reports and underlying
documents, including trustee statements, in
connection with any investment agreements,
and copies of all bidding documents, if any.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 74 Investment Policy
Subject
Investment Policy
Policy Guidelines
The San Diego Community Power (“SDCP”) Investment
Policy (“Policy”) establishes investment guidelines for protecting SDCP’s cash reserves, deposits, and investments (“Funds”) while producing a reasonable rate of return on investments.
The Policy articulates: (1) the objectives and priorities for SDCP investments; (2) the types of investments that are permitted and prohibited; and (3) the controls SDCP will implement to ensure assets are protected. This Policy is adopted pursuant to California Government Code Section
(“Section”) 53600-53608 and must be adopted or amended
by resolution. The SDCP Board of Directors (“Board”) is not required to adopt a formal Investment Policy by statute, however, it is in the best practice to ensure agency assets are protected.
Background
On October 1, 2019, the Founding Members of San Diego
Community Power (SDCP) adopted the Joint Powers
Agreement (JPA) which was amended and restated on
December 16, 2021. Section 3.2.12 of the JPA specifies that the SDCP Board of Directors (Board) may at its discretion adopt rules, regulations, policies, bylaws and procedures governing the operation of SDCP.
Further, Section 4.5.5 of the JPA states that one of the general purposes of the Board is to set policy.
Section 5.10.2(C) of the JPA finally states one of the primary purposes of the Financial and Risk Management Committee (FRMC) is to review and recommend to the Board financial policies and procedures to ensure equitable contributions by Parties consistent with a recommendation for Board
approval of the Investment Policy herein. Further, this section states the FRMC may have such other responsibilities as may be approved by the Board, including but not limited to advising the Chief Executive Officer on fiscal and risk management policies and procedures, rules and regulations governing investment of surplus funds, audits to achieve best practices in corporate governance and selection and designation of financial institutions for deposit of SDCP funds, and credit/depository matters.
Investment Objectives
To the extent possible, investments will align with SDCP’s mission, vision, value, and goals. When managing Funds, SDCP’s primary objectives shall be to (1) safeguard the principal of the Funds, (2) meet the liquidity needs of SDCP, (3) achieve a return on funds invested, and (4) exercise a high standard of care on Funds within SDCP’s control.
1. Safety: Safety of principal is the foremost objective of cash and investment management activities. The
investment of Funds shall be undertaken in a manner
that seeks to ensure the preservation of principal.
2. Liquidity: The Funds of SDCP shall remain sufficiently liquid to meet all operating needs that may be
reasonably anticipated. Since all possible cash demands cannot be anticipated, the investment of Funds in
deposits or instruments that are available on demand is recommended.
3. Return on Investments: SDCP’s deposit and investment portfolio shall be designed with the objective of
attaining a market rate of return throughout the
economic cycle while considering investment risk
and liquidity constraints. The return on deposits and
investments is of secondary importance compared
to the safety and liquidity objectives described in
Investment Objectives, Section A and Investment
Objectives, Section B, above.
4. Standard of Care: SDCP will manage Funds in
accordance with the “Prudent Investor Standard”
pursuant to California Government Code Section
53600.32
as follows:
“All governing bodies of local agencies or persons
authorized to make investment decisions on behalf of
those local agencies investing public funds are trustees and therefore fiduciaries subject to the prudent investor standard. When investing, reinvesting, purchasing,
acquiring, exchanging, selling or managing public funds, a trustee shall act with care, skill, prudence and diligence under the circumstances then prevailing, that a prudent person acting in a like capacity and familiarity with those matters would use in the conduct of funds of a like
character and with like aims, to safeguard the principal and maintain the liquidity needs of the agency. Within
the limitations of this section and considering individual investments as part of an overall strategy, investments may be acquired as authorized by law.”
2 All further statutory references are to the California Government Code unless otherwise stated.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 75 Delegation of Authority
Pursuant to Section 53607, the Board has the authority to delegate the responsibility to manage SDCP’s funds to the Treasurer. The Treasurer has authority to appoint Deputy Treasurer(s) as the Treasurer deems necessary to carry the duties in accordance with the Investment Policy. SDCP may engage the services from one or more external investment advisers, who are registered under the Investment Advisers Act of 1940, to assist in the management of SDCP’s
investment portfolio in a manner consistent with the SDCP’s Policy. External investment advisers may be granted discretion to purchase and sell investment securities in accordance with the investment objective set forth in this Policy.
Scope
This Investment Policy applies to all funds and investment under the direct authority of SDCP. This Policy does not apply to the investment of bond proceeds, which would be governed by any applicable bond documents and any other funds specifically exempted by SDCP’s Board of Directors.
Acceptable Investment Types: To the extent possible,
investments will align with SDCP’s mission, vision, value, and goals.
1. Deposits at Bank(s): Funds may be invested in non-interest-bearing depository accounts to meet SDCP’s operating and collateral needs and grant requirements.
Funds not needed for these purposes may be
invested in interest-bearing depository accounts or
Federal Deposit Insurance Corporation (FDIC) insured
certificates of deposit with maturities not to exceed
five (5) years. Banks eligible to receive deposits will be federally or state chartered and will conform to Section 53635.2 which requires that banks “have received an
overall rating of not less than ‘satisfactory’ in its most recent evaluation by the appropriate federal financial
supervisory agency of its record of meeting the credit
needs of California’s communities, including low- and
moderate-income neighborhoods, pursuant to Section
2906 of Title 12 of the United States Code.” As per
Section 53652, banks must collateralize the deposits of public agencies in an amount equal to no less than 110% of as currently stated in the value of the deposits. The Treasurer will monitor the credit quality of eligible banks holding SDCP deposits that exceed FDIC insurance
limits to ensure the safety of SDCP deposits.
2. Local Agency Investment Fund (LAIF): Funds may
be invested in the Local Agency Investment Fund
established by the California State Treasurer for
the benefit of local agencies. LAIF’s investments in
instruments prohibited by or not specified in SDCP’s
policy do not exclude the investment in LAIF itself from SDCP list of allowable investments, provided LAIF’s
reports allow the Treasurer to adequately judge the risk inherent in LAIF’s portfolio.
3. U.S. Treasury Obligations: Funds may be invested
in United States Treasury obligations with a term to
maturity not exceeding five (5) years and subject to the limitations set forth in Sections 53601 et seq. and 53635 et seq.
4. Federal Agency Securities: Funds may be invested in
Federal Agency Securities or Government-Sponsored
Enterprise (GSE) obligations with a term to maturity not exceeding five (5) years and subject to the limitations set forth in Sections 53601 et seq. and 53635 et seq. No more than 20% of the total portfolio may be invested
in callable agency securities and no more than 30% of
the total portfolio may be invested in any single Agency/ GSE issuer.
5. Bankers’ Acceptances: Funds may be invested in
Banker’s Acceptances provided that they are issued
by institutions which have short-term debt obligations
rated “A-1” or its equivalent of better by at least one Nationally Recognized Statistical Rating Organization
(NRSRO). Not more than 40% of the portfolio may be
invested in Bankers’ Acceptances, and no more than 5%
of the portfolio may be invested in any single issuer. The maximum maturity shall not exceed 180 days.
6. Negotiable Certificates of Deposit: Funds may
be invested in negotiable certificates of deposit in
accordance with the requirements of Section 53601 and
53601.8, and subject to the following limitations:
a. Issued by an entity as defined in Section 53601(i);
and
b. No more than 30% of the total portfolio shall be
invested in certificates of deposit, no more than
5% of the total portfolio may be invested in any
single issuer, and the maximum maturity does
not exceed 5 years.
7. Placement Service Deposits: Funds may be invested in deposits placed with a private sector entity that assists in the placement of deposits with eligible financial
institutions located in the United States (Section
53601.8). The full amount of principal and the interest that may be accrued during the maximum term of each
deposit shall at all times be insured by federal deposit insurance. The maximum portfolio exposure to the
deposits placed pursuant to this section shall be limited by Section 53601.8.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 76
8. Money Market Funds: Funds may be invested in money
market funds pursuant to Section 53601(l)(2) and
subject to Section 53601(l)(4). No more than 20% of
the portfolio may be invested in the shares of any one
Money Market Fund. No more than 20% of the total
portfolio may be invested in these securities.
9. Commercial Paper: Of “prime” quality of the highest
ranking or of the highest letter and number rating as
provided for by a NRSRO. The entity that issues the
commercial paper must meet all of the following
conditions in either paragraph A or paragraph B:
a. The entity meets the following criteria: (i) is
organized and operating in the United States as a
general corporation, (ii) has total assets in excess
of five hundred million dollars ($500,000,000),
and (iii) has debt other than commercial paper, if
any, that is rated in a rating category of “A” or its
equivalent or higher by an NRSRO.
b. The entity meets the following criteria: (i) is
organized within the United States as a special
purpose corporation, trust, or limited liability
company, (ii) has program-wide credit enhance-ments including, but not limited to, over collater-alization, letters of credit, or surety bond, and (iii) has commercial paper that is rated “A-1” or higher,
or the equivalent, by an NRSRO.
• No more than 10% of the outstanding
commercial paper of any single issuer.
• No more than 25% of SDCP’s investment
assets under management may be invested
in Commercial Paper. Under a provision
sunsetting on January 1, 2026, no more
than 40% of the total portfolio may be
invested in Commercial Paper if SDCP’s
investment assets under management are
greater than $100,000,000.
• No more than 5% of the total portfolio may
be invested in any single issuer. The maximum
maturity does not exceed 270 days.
10. Medium Term Notes (MTN): The issuer is a corporation organized and operating within the United States or by
depository institutions licensed by the United States
or any state and operating within the United States.
(Section 53601 et seq). The securities are rated in a rating category of “A” or its equivalent or better by at least one NRSRO. No more than 30% of the total portfolio
may be invested in MTNs, no more than 5% of the total
portfolio may be invested in any single issuer and the
maximum maturity does not exceed five (5) years.
11. Pass-Through Securities: Asset-Backed, Mortgage-Backed, Mortgage Pass-Through Securities, and Collateralized Mortgage Obligations (Section 53601
et seq) from issuers not defined in sections 3 and 4
of the Acceptable Investment Types section of this
policy, provided that: The securities are rated in a
rating category of “AA” or its equivalent or better by a NRSRO, no more than 20% of the total portfolio may
be invested in these securities, no more than 5% of
the total portfolio may be invested in any single Asset-Backed or Commercial Mortgage security issuer and the maximum maturity does not exceed five (5) years.
12. Municipal Securities: include obligations of SDCP,
the State of California and any local agency within
the State of California,(Section 53601) provided that:
The securities are rated in a rating category of “A” or its equivalent or better by at least one nationally recognized statistical rating organization (“NRSRO”)., no more than 5% of the total portfolio may be invested in any single issuer, no more than 30% of the total portfolio may be
in Municipal Securities and the maximum maturity does
not exceed five (5) years.
13. Municipal Securities: (Registered treasury notes or bonds) of any of the other 49 states in addition to
California, including bonds payable solely out of the
revenues from a revenue-producing property owned,
controlled, or operated by a state or by a department,
board, agency, or authority of any of the other 49 states, in addition to California (Section 53601). The securities are rated in a rating category of “A” or its equivalent or better by at least one NRSRO, no more than 5% of
the total portfolio may be invested in any single issuer, no more than 30% of the total portfolio may be in
Municipal Securities and the maximum maturity does
not exceed five (5) years.
14. Supranationals: Issues are U.S. dollar denominated
senior unsecured unsubordinated obligations issued or
unconditionally guaranteed by the International Bank
for Reconstruction and Development, International
Finance Corporation, or Inter-American Development
Bank. (Section 53601).The securities are rated in a
rating category of “AA” or its equivalent or better by a NRSRO, no more than 30% of the total portfolio may
be invested in these securities, no more than 10% of the total portfolio may be invested in any single issue and the maximum maturity does not exceed five (5) years.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 77 Prohibited Investment Types
Pursuant to Section 53601.6, SDCP shall not invest Funds in any security that could result in a zero-interest accrual, or less, if held to maturity. These prohibited investments include, but are not limited to, inverse floaters, range notes, or mortgage-derived interest-only strips. The purchase
of foreign currency denominated securities is prohibited.
The purchase of Crypto Asset Securities is prohibited.
The purchase of a security with a forward settlement
date exceeding 45 days from the time of the investment
is prohibited. Trading securities for the sole purpose of speculating on the future direction of interest rates is prohibited. Purchasing or selling securities on margin is prohibited. The use of reverse repurchase agreements,
securities lending or any other form of borrowing or leverage is prohibited. SDCP is prohibited from investing in any company or organization whose business do not align with SDCP’s mission, vision, value and goals.
Investment Portfolio Management
The term to maturity of any Funds invested shall not exceed five (5) years pursuant to Section 53601. The Treasurer will allocate Funds among authorized investments consistent with the objectives and standards of care outlined in this Policy.
Collateralization
Certificates of Deposit (CDs). SDCP shall require any
commercial bank or savings and loan association to deposit eligible securities with an agency of a depository approved by the State Banking Department to secure any uninsured portion of a Non-Negotiable Certificate of Deposit. The value of eligible securities as defined pursuant to California Government Code, Section 53651, pledged against a
Certificate of Deposit shall be equal to 150% of the face value of the CD if the securities are classified as mortgages and 110% of the face value of the CD for all other classes of security.
Bank Deposits. This is the process by which a bank or
financial institution pledges securities, or other deposits for the purpose of securing repayment of deposited funds.
SDCP shall require any bank or financial institution to comply with the collateralization criteria defined in California Government Code, Section 53651.
Risk Management and Diversification
SDCP’s investment portfolio will be diversified to avoid incurring unreasonable and avoidable risks associated
with concentrating investments in specific security types, maturity segment, or in individual financial institutions.
No more than 5% of the investment portfolio shall be in securities of any one issuer except for U.S. Treasuries, U.S.
Government Agency issues, Supranationals and investment pools such as LAIF, and money market funds.
a. Credit Risk: Credit risk, defined as the risk of loss due to failure of the insurer of a security, shall be
mitigated by investing in those securities with an
“A” or above rating and approved in the Invest-ment Policy and by diversifying the investment portfolio so that the failure of any one issuer
would not unduly harm SDCP’s cash flow.
b. Market Risk: Market risk or interest rate risk, de-fined as the risk of market value fluctuations due to overall changes in the general level of interest
rates, shall be mitigated by implementing a short
term and long-term investment strategies. It is
explicitly recognized herein, however, that in a
diversified portfolio, occasional measured losses
are inevitable and must be considered within the
context of overall investment return.
The duration of the portfolio will generally be approximately equal to the duration (typically, plus or minus 20%) of a Market Benchmark, an index selected by SDCP based on SDCP’s
investment objectives, constraints and risk tolerances.
Credit Rating
This Investment Policy sets forth minimum credit ratings for each type of security. These credit ratings apply to the initial purchase of a security and do not automatically force the sale of a security if the credit ratings of the security fall below the policy limits.
Minimum credit ratings:
a. For securities with maturities of 13 months or
less, the rating must be in the highest short-term
rating category (without regard to qualification of
such rating symbol such as “+” or “- “) by at least
one nationally recognized statistical rating organi-zation (the “NRSRO”). b. For securities with maturities greater than 13
months, the rating must be “A” or higher by at
least one NRSRO.
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 78 The monitoring of credit ratings consists of the following procedures:
1. When a credit rating downgrade occurs which results in a rating below the minimum credit requirement, SDCP’s
Finance Department or external investment adviser
will analyze and evaluate the credit rating to determine whether to hold or sell the investment.
2. In the event a security in the Fund receives a credit rating downgrade which results in a rating below the minimum
credit rating requirement, SDCP’s Treasurer will report the rating change to the Finance and Risk Management
Committee in the monthly public report. In the same
manner, the Finance and Risk Management Committee
will be informed on the decision to hold or sell a
downgraded security.
3. The Investment Officials or authorized employees
involved in the investment process and external
investment advisers shall meet at least quarterly to
review and update the approved list of securities and
establish credit criteria for each category of security.
To ensure that the Fund maintains the highest overall credit rating with the contracted NRSRO, the asset allocation and portfolio holdings will be provided to the contracted NRSRO on a monthly basis.
Brokers
The Treasurer shall endeavor to complete investment
transactions in accordance with Section 53601.5, institutions eligible to transact investment business with SDCP include:
a. Institutions licensed by the state as a broker-dealer. b. Institutions that are members of a federally
regulated securities exchange.
c. Primary government dealers as designated by
the Federal Reserve Bank and non-primary
government dealers.
d. Nationally or state-chartered banks.
e. The Federal Reserve Bank.
f. Direct issuers of securities eligible for purchase.
Broker/dealers shall be approved by the Chief Executive Officer upon recommendation by the Treasurer. Selection of broker/dealers shall be based upon the following criteria:
the reputation and financial strength of the company or financial institution, the reputation and expertise of the individuals employed, and pursuant to the requirements of Section 53601.5. The Treasurer shall require any selected broker, brokerage firm, dealer, or securities firm to affirm that it has not, within any 48-consecutive month period, made a political contribution to any member of the SDCP Board, or any candidate who may join the SDCP Board in an amount
exceeding the limitations contained in Rule G-37 of the Municipal Securities Rulemaking Board, the Political Reform Act, including section 84308, or any applicable SDCP Policy, as amended from time to time. The selected broker or
dealers shall be provided with and acknowledge receipt of this Policy.
Losses
Losses are acceptable on a sale before maturity and may be taken if required to meet the liquidity needs of SDCP or if the reinvestment proceeds will earn an income flow with a present value higher than the present value of the income flow that would have been generated by the original investment, considering any investment loss or foregoing interest on the original investment.
Delivery and Safekeeping
The delivery and safekeeping of all securities shall be made through a third-party custodian when practical and cost effective as determined by the Treasurer, or a duly appointed Deputy Treasurer, and in accordance with Section 53608.
The Treasurer shall review all transaction confirmations for conformity with the original transaction and monitor for excessive trading.
Ethics and Conflict of Interest
The Investment Officials or authorized employees involved in the investment process, shall act as custodians of the public trust and will refrain from personal business activities that could conflict with proper execution of the investment program, or which could impair their ability to make impartial decisions. Investment Officials and any external investment advisers acknowledge that all direct SDCP investments are subject to public review and evaluation.
SDCP Investment Officials involved in the investment
process shall refrain from personal business activity that could create a conflict of interest or the appearance of a conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions.
SDCP Investment Officials shall disclose to General Counsel or designee i) any material interests in financial institutions with which they conduct business, and ii) disclose any
personal investments with a direct, indirect or beneficial interest totaling $2,000 or more. Investment Officials
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SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 79 shall refrain from undertaking any personal investment
transactions with the same individual from the external investment adviser with whom business is conducted on
behalf of SDCP.
Investment Officials, pursuant with all applicable laws, shall not accept honoraria, gifts, and gratuities from advisers, brokers, dealers, bankers, or other entity with whom SDCP conducts business.
Any external investment adviser contracted by SDCP will comply with Municipal Securities Rulemaking Board Rule
G-37 and shall follow the Investment Adviser Fiduciary
Standard established by the U.S. Securities and Exchange Commission.
Internal Controls
The Treasurer is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the entity are protected from loss, theft or misuse.
The internal control structure shall be designed to provide reasonable assurance that these objectives are met.
Accordingly, the Treasurer shall establish and maintain internal controls that shall address the following points:
a. Control of Collusion: Collusion is a situation
where two or more employees are working in
conjunction to defraud their employer. To achieve
a segregation of duties, individuals who authorize
investment transactions shall not also record or
reconcile said transactions.
b. Clear Delegation of Authority to Subordinate
Staff Members: Subordinate staff members must
have a clear understanding of their authority
and responsibilities to avoid improper actions.
Clear delegation of authority also preserves the
internal control structure that is contingent on
the various staff positions and their respective
responsibilities.
c. Delivery-Versus-Payment (DVP): All investment
transactions shall be conducted on a delivery-versus-payment basis. d. Safekeeping and Custody: Securities purchased
from any bank or dealer, including appropriate
collateral (as defined by California Government
Code), that are not insured by the FDIC, shall
be placed with an independent third party
for custodial safekeeping. To protect against
potential losses due to failure of individual
securities dealers, and to enhance access to
securities, interest payments and maturity
proceeds, all cash and securities in SDCP’s
portfolio shall be held in safekeeping in SDCP’s
name by a third-party custodian, acting as
agent for SDCP under the terms of a custody
agreement executed by the bank and SDCP.
All investment transactions will require a
safekeeping receipt or acknowledgment
generated from the trade. A monthly report
will be received by SDCP from the custodian
listing all securities held in safekeeping with
current market data and other information.
The only exceptions to the foregoing shall be
depository accounts and securities purchases
made with: (1) local government investment
pools; (2) time certificates of deposit, (3) Local
Agency Investment Fund, and (4) mutual funds
and money market mutual funds, since these
securities are not deliverable.
e. Avoidance of Physical Delivered Bearer
Securities: Book entry securities are much
easier to transfer and account for since actual
delivery of a document never takes place. Bearer
securities must be properly safeguarded against
loss or destruction. The potential for fraud and
loss increases with such securities.
f. Written Confirmation of Telephone Wire
Transfers: Due to the potential for error and
improprieties arising from telephone transactions,
all telephone transactions should be supported
by written or electronic communications
and approved by the appropriate person.
Development of a Wire Transfer Agreement with
the Lead Bank or Third-Party.
g. Audits: SDCP’s Funds shall be subject to a
process of independent review by its external
auditors. SDCP’s external auditors shall review the
investment portfolio in connection with SDCP’s
annual audit for compliance with the Policy
pursuant to Section 27134. The results of the
audit shall be reported to the Treasurer.
167
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 80 Reports
a. Monthly: The Treasurer will perform a monthly
review of the investment function. Following the
commencement of investment transactions,
the Treasurer shall submit a monthly report
of all investment transactions to the Finance
and Risk Management Committee. Investment
transactions are defined as the purchase, sale or
exchange of securities.
b. Annually: The Treasurer will submit an annual
report to the Finance and Risk Management
Committee within 60 days of the end of a fiscal
year providing the following:
• A list of individual securities by investment
type, issuer, credit risk rating, CUSIP
number, settlement date of purchase, date
of maturity, par value and dollar amount
invested on all securities, the market value
and source of the market value information;
• A statement that the portfolio is in
compliance with this Policy and in
accordance with Section 53646 or the
manner in which the portfolio is not in
compliance; and
• A statement of SDCP’s ability to meet
anticipated cash requirements for the
upcoming 12 months.
• The Treasurer shall monitor and evaluate
the portfolio’s performance relative to the
chosen market benchmark(s), which will be
included in the Treasurer’s annual report.
The Treasurer shall select an appropriate,
readily available index to use as a market
benchmark. Benchmarks may change
over time based on changes in market
conditions or cash flow requirements.
c. Annual Review: This Policy will be reviewed
annually by the Treasurer. The Board is authorized
to approve changes to this Policy following the
review of proposed changes by the Finance Risk
Management Committee.
168
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 81 Glossary of Investment Terms
ASSET BACKED SECURITIES. Securities supported by
pools of installment loans or leases or by pools of revolving lines of credit.
BANKERS’ ACCEPTANCES. A short-term, negotiable,
unconditional, and time draft drawn on and accepted by a bank. It is typically used in trade to finance the purchase and sale of goods.
BENCHMARK. A comparison security or portfolio. A
performance benchmark is a partial market index, which
reflects the mix of securities allowed under a specific investment policy.
BROKER. A broker brings buyers and sellers together for a transaction for which the broker receives a commission. A broker does not sell securities from his own position.
CALLABLE. A callable security gives the issuer the option to call it from the investor prior to its maturity. The main cause of a call is a decline in interest rates. If interest rates decline, the issuer will likely call its current securities and reissue them at a lower rate of interest.
CERTIFICATE OF DEPOSIT (CD). A time deposit
with a specific maturity evidenced by a certificate. Large denomination CDs may be marketable.
CERTIFICATE OF DEPOSIT ACCOUNT REGISTRY
SYSTEM (CDARS). A private placement service that
allows local agencies to purchase more than $250,000 in CDs from a single financial institution (must be a participating institution of CDARS) while still maintaining FDIC insurance coverage. CDARS is currently the only entity providing this service. CDARS facilitates the trading of deposits between the California institution and other participating institutions in amounts that are less than $250,000 each, so that FDIC coverage is maintained.
COLLATERAL. Securities or cash pledged by a borrower
to secure repayment of a loan or repurchase agreement. Also, securities pledged by a financial institution to secure deposits of public monies.
COLLATERALIZED MORTGAGE OBLIGATIONS
(CMO). Classes of bonds that redistribute the cash flows of mortgage securities (and whole loans) to create securities that have different levels of prepayment risk, as compared to the underlying mortgage securities.
COMMERCIAL PAPER. The short-term unsecured debt
of corporations.
COUPON. The rate of return at which interest is paid on a bond.
CREDIT RISK. The risk that principal and/or interest on an investment will not be paid in a timely manner due to changes in the condition of the issuer.
CRYPTO ASSET. Digital assets that use public ledgers over the internet to prove ownership. They use cryptography, peer-to-peer networks and a distributed ledger technology (DLT) – such as blockchain – to create, verify and secure transactions.
CUSIP. Committee on Uniform Securities Identification
Procedures. A CUSIP number identifies most financial
instruments, including: stocks of all registered U.S. and Canadian companies, commercial paper, and U.S. government and municipal bonds.
DEALER. A dealer acts as a principal in security transactions, selling securities from and buying securities for his own position.
DELIVERY vs PAYMENT (DVP). A securities industry
procedure whereby payment for a security must be made at the time the security is delivered to the purchaser’s agent.
DISCOUNT. The difference between the par value of a
bond and the cost of the bond, when the cost is below par.
Some short-term securities, such as T-bills and banker’s acceptances, are known as discount securities. They sell at a discount from par, and return the par value to the investor at maturity without additional interest. Other securities, which have fixed coupons, trade at a discount when the coupon rate is lower than the current market rate for securities of that maturity and/or quality.
DIVERSIFICATION. Dividing investment funds among a
variety of investments to avoid excessive exposure to any one source of risk.
DURATION. The weighted average time to maturity of a
bond where the weights are the present values of the future cash flows. Duration measures the price sensitivity of a bond to changes in interest rates. (See modified duration).
FEDERAL FUNDS RATE. The rate of interest charged
by banks for short-term loans to other banks. The Federal Reserve Bank through open-market operations establishes it. 169
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 82 ISSUER. The entity identified as the counterparty or
obligator related to a security trade.
INVERSE FLOATER. A bond or other type of debt whose
coupon rate has an inverse relationship to a benchmark rate.
INVESTMENT OFFICIALS. This includes any applicable
SDCP staff participating in the investment process; SDCP Treasurer; SDCP Deputy Treasurer(s); and SDCP Board of
Directors.
LEVERAGE. Borrowing funds in order to invest in securities that have the potential to pay earnings at a rate higher than the cost of borrowing.
LIQUID. Term for securities that can be converted to cash quickly.
LIQUIDITY. The speed and ease with which an asset can be converted to cash.
LOCAL AGENCY INVESTMENT FUND (LAIF).
A voluntary investment fund open to government entities and certain nonprofit organizations in California that is managed by the State Treasurer’s Office.
LOCAL GOVERNMENT INVESTMENT POOL.
Investment pools that range from the State Treasurer’s Office Local Agency Investment Fund (LAIF) to county pools, to Joint Powers Authorities (JPAs). These funds are not subject to the same SEC rules applicable to money market mutual funds.
MARGIN. The difference between the market value of a
security and the loan a broker makes using that security as collateral.
MARKET RISK. The risk that the value of securities will fluctuate with changes in overall market conditions or interest rates.
MARKET VALUE. The price at which a security can
be traded.
MATURITY. The final date upon which the principal of a
security becomes due and payable.
MEDIUM TERM NOTES. Unsecured, investment-grade senior debt securities of major corporations which are sold in relatively small amounts on either a continuous or an intermittent basis. MTNs are highly flexible debt instruments that can be structured to respond to market opportunities or to investor preferences.
MODIFIED DURATION. The percent change in price for
a 100 basis point change in yields. Modified duration is the best single measure of a portfolio’s or security’s exposure to market risk.
MONEY MARKET. The market in which short-term debt
instruments (T-bills, discount notes, commercial paper, and banker’s acceptances) are issued and traded.
MORTGAGE BACK SECURITY. Debt obligations that
represent claims to the cash flows from pools of mortgage loans, most commonly on residential property.
MORTGAGE-DERIVED INTEREST-ONLY STRIPS.
A financial product created by separating the interest and principal payments of a mortgage-backed security.
MORTGAGE PASS-THROUGH SECURITIES.
A securitized participation in the interest and principal cash flows from a specified pool of mortgages. Principal and interest payments made on the mortgages are passed through to the holder of the security.
MUNICIPAL SECURITIES. Securities issued by state and
local agencies to finance capital and operating expenses.
MUTUAL FUND. An entity which pools the funds of
investors and invests those funds in a set of securities which is specifically defined in the fund’s prospectus. Mutual funds can be invested in various types of domestic and/or international stocks, bonds, and money market instruments, as set forth in the individual fund’s prospectus. For most large, institutional investors, the costs associated with investing in mutual funds are higher than the investor can obtain through an individually managed portfolio.
NATIONALLY RECOGNIZED STATISTICAL
RATING ORGANIZATION (NRSRO). A credit rating
agency that the Securities and Exchange Commission in
the United States uses for regulatory purposes. Credit rating agencies provide assessments of an investment’s risk. The issuers of investments, especially debt securities, pay credit rating agencies to provide them with ratings. The three most prominent NRSROs are Fitch, S&P, and Moody’s.
NEGOTIABLE CD. A short-term debt instrument that pays
interest and is issued by a bank, savings or federal association, state or federal credit union, or state-licensed branch of a foreign bank. Negotiable CDs are traded in a secondary market and are payable upon order to the bearer or initial depositor (investor).
170
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 83 PREMIUM. The difference between the par value of a bond and the cost of the bond, when the cost is above par.
RANGE NOTES. A structured investment where the
coupon is linked to the performance of a reference index REPURCHASE AGREEMENT. Short-term purchases of
securities with a simultaneous agreement to sell the securities back at a higher price. From the seller’s point of view, the same transaction is a reverse repurchase agreement.
SAFEKEEPING. A service to bank customers whereby
securities are held by the bank in the customer’s name.
SUPRANATIONAL. A Supranational is a multi-national
organization whereby member states transcend national
boundaries or interests to share in the decision making to promote economic development in the member countries.
TOTAL RATE OF RETURN. A measure of a portfolio’s
performance over time. It is the internal rate of return, which equates the beginning value of the portfolio with the ending value; it includes interest earnings, realized and unrealized gains, and losses in the portfolio.
U.S. TREASURY OBLIGATIONS. Securities issued by
the U.S. Treasury and backed by the full faith and credit of the United States. Treasuries are considered to have no credit risk, and are the benchmark for interest rates on all other securities in the U.S. and overseas. The Treasury issues both discounted securities and fixed coupon notes and bonds.
TREASURY BILLS. All securities issued with initial
maturities of one year or less are issued as discounted instruments, and are called Treasury bills. The Treasury currently issues three- and six-month T-bills at regular weekly auctions. It also issues “cash management” bills as needed to smooth out cash flows.
TREASURY NOTES. All securities issued with initial
maturities of two to ten years are called Treasury notes, and pay interest semi-annually.
TREASURY BONDS. All securities issued with initial
maturities greater than ten years are called Treasury bonds.
Like Treasury notes, they pay interest semi-annually.
VOLATILITY. The rate at which security prices change with changes in general economic conditions or the general level of interest rates.
YIELD TO MATURITY. The annualized internal rate of
return on an investment which equates the expected cash flows from the investment to its cost.
171
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 84 Rate Development Policy
Effective Date: November 17, 2022
Background
San Diego Community Power (SDCP) advocates for
ratepayers by providing a choice of electricity providers and shifting control of local energy decisions from profit-driven, incumbent utility into the hands of residents and businesses located in our service jurisdiction. This creates competition in rates that benefits customers, increased transparency and ensures a better overall customer experience.
Purpose
This policy provides the framework for SDCP’s Board of
Directors and staff to ensure SDCP’s rate design, development and implementation process remains transparent, fiscally responsible and centered on the customer.
As a public not-for-profit agency, SDCP must, at a minimum, set rates to recover costs associated with debt service and the purchase of power and operational costs. It is in the best interest of SDCP and its customers to design and implement rates that meet revenue requirements as well as targeted reserves, while maintaining rate competitiveness, stability and long-term financial viability.
General Criteria
SDCP has established various objectives and priorities that shall be considered as part of SDCP’s rate design process.
SDCP’s rate setting objectives are as follows:
1. Cost Recovery: rates must be sufficient to recover
all expenses, debt service and other expenditure
requirements.
• Reserves: rates must be sufficient to build prudent
reserves in line with SDCP’s Reserve Policy, which will provide funds to cover unanticipated expenditures,
secure favorable terms with vendors, secure a
standalone investment-grade credit rating and meet
strategic objectives.
• Rate Competitiveness and Customer Value: rates
must allow SDCP to successfully compete to retain
and attract customers while offering superior electricity service offerings with higher renewable content
compared to the incumbent investor-owned utility.
2. Rate Stability: rate changes should be minimized to
reduce customer bill impacts with a preference for annual rate adjustments. Additionally, a Rate Stabilization Fund may be established and over time sufficiently funded to help mitigate significant swings in rates.
3. Equity among customers: rate difference among
customers should be justified by differences in usage
characteristics and/or cost of service. Additionally, to the extent possible, rates shall be equalized from a value
proposition perspective among customers enrolled
during different Power Charge Adjustment Indifference
(PCIA) Vintage Years.
• Rate Structures: as new rates are developed,
emphasis shall be put on rate-design simplicity and
comparability as well as overall customer experience.
SDCP reserves the right to design pilot rates as
reviewed and approved by the Board.
• Transparency: SDCP’s Board will review and
approve rates at an open and public meeting held
in accordance with the Ralph M. Brown Act. SDCP
shall post a copy of the adopted rates in both English
and Spanish on its website within 14 calendar days
of approval or by the rates’ effective date, whichever
is sooner. SDCP shall also make any rate design
documents promptly available upon request under the
California Public Records Act.
• Cost Shifting: SDCP shall avoid, to the best of its
ability, cost shifting between customer classes.
• Cost of Service: SDCP may explore a cost-of-service
model for rate design. Cost-of-service studies are used to determine the total costs incurred by a utility in
providing service to its customers and the allocation
of those costs through rates back to customer classes.
Revenue collected from each customer class then
may be compared with that class’s cost responsibility
to determine the extent to which each class is
reimbursing the utility for the costs it incurred in
providing service.
SDCP's Rate Setting Timeline
SDG&E’s Energy Resource Recovery Account (ERRA)
application is usually approved by the CPUC in December, which provides the trajectory of bundled service commodity rates including the above market costs and other fees that will be passed on from SDG&E to all customers. Once the ERRA is approved, SDCP staff shall present proposed rates for the year to the Board in January of each year for review, deliberation and approval to be effective no later than February 15. With ever-changing market developments and regulatory climate, there may be instances where SDCP staff also proposes intra-year changes to rates. 172
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Financial Policies 85 To the greatest extent possible, SDCP’s rates will be competitive with SDG&E’s rates. With each SDG&E and SDCP rate change, both entities are required to work collaboratively to co-publish and post a Joint Rate Comparison on their respective websites to allow customers to easily see how rates compare.
Implementation of SDCP’s Rates
SDCP’s rate setting process is and will always be open and transparent to the public. SDCP’s Board of Directors, which is composed of a representative from each of its member agencies, will set rates according to agreed-upon strategic goals of SDCP and the cost of service.
Prior to the implementation of new rates, the Board will review and deliberate the proposed rates in a public setting and take comments from the public.
Once the Board approves proposed rates, the rates will be published on SDCP’s website in advance of their effective date, giving customers time to compare, budget and better understand what to expect on their bills going forward. For more information on SDCP’s rates, visit
sdcommunitypower.org/billing-rates/residential-rates/
for residential rates or
sdcommunitypower.org/billing-rates/commercial-rates/
for commercial rates.
Fees passed on by SDG&E to “departing load” customers such as SDCP include the Power Charge Indifference Adjustment (PCIA) and Franchise Fees. The PCIA is a charge to ensure that both SDG&E customers and those who have left SDG&E service to purchase electricity from other providers pay for the above market costs for electric generation resources that were procured by SDG&E on their behalf. “Above market” refers to expenditures for generation resources that cannot be fully recovered through sales of these resources at current market prices.
The Franchise Fee is a surcharge applied to electricity transported over SDG&E systems that are constructed in public streets and highways. SDG&E collects the surcharge from customers and remits them to the appropriate municipality. 173
v
Glossary
of Terms
10 174
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 87 Glossary of Terms
AB – Assembly Bill: An Assembly Bill is a piece of
legislation that is introduced in the Assembly. In other words, the Assembly (rather than the Senate) is the bill’s house of origin in the Legislature. In California, it is common for legislation to be referred to by its house of origin number even after it becomes law. However, because bill numbers “reset” and start again from 1 in each legislative session, it is less confusing to include chapter and statute information when referring to a bill that has become law; for example, SB 350 (Chapter 547, Statutes of 2015).
AL - Advice Letter: An Advice Letter is a request by a
California Public Utilities Commission (CPUC) jurisdictional entity for Commission approval, authorization or other relief.
ALJ – Administrative Law Judge: ALJs preside over
CPUC cases to develop the evidentiary record and draft
proposed decisions for Commission action.
ARB – Air Resources Board: The California Air
Resources Board (CARB or ARB) is the “clean air agency” in the state government of California. CARB is charged
with protecting the public from the harmful effects of air pollution and developing programs and actions to fight
climate change.
AReM – Alliance for Retail Energy Markets:
A not-for-profit corporation that advocates for continued development of successful customer choice in retail energy markets and provides a focused voice for competitive energy retailers and their customers in select public policy forums at the state level. AReM represents direct access providers such as Constellation NewEnergy and Direct Energy.
BayREN – Bay Area Regional Energy Network:
BayREN offers regionwide energy programs, services and
resources to members of the public by promoting energy
efficient buildings, reducing carbon emissions and building government capacity.
CAISO – California Independent System
Operator: A nonprofit public benefit corporation that
oversees the operation of the California bulk electric power system, transmission lines and electricity market generated and transmitted by its members (approximately 80% of
California’s electric flow). Its stated mission is to “operate the grid reliably and efficiently, provide fair and open transmission access, promote environmental stewardship
and facilitate effective markets and promote infrastructure development.” CAISO is regulated by the Federal Energy
Regulatory Commission (FERC) and governed by a five-member governing board appointed by the governor.
CalCCA – California Community Choice
Association: A statewide association, made up of
Community Choice Aggregators (CCAs), that represents
the interests of California’s community choice electricity providers.
CALSEIA – California Solar Energy Industries
Association: CALSEIA represents more than 200
companies doing solar-related business in California,
including manufacturers, distributors, installation contractors, consultants and educators. Members’ annual dues support professional staff and a lobbyist who represents the
common interests of California’s solar industry at the
Legislature, Governor’s Office and state and local agencies.
CALSLA – California City-County Street Light
Association: A statewide association representing cities, counties and towns before the CPUC that is committed to maintaining fair and equitable streetlight electricity rates and facilities charges and disseminating streetlight-related information.
CAM – Cost Allocation Mechanism: The cost
recovery mechanism to cover procurement costs incurred in serving the central procurement function.
CARB – California Air Resources Board: The
CARB is charged with protecting the public from the harmful effects of air pollution and developing programs and actions to fight climate change in California.
CARE – California Alternative Rates for Energy:
A state program for low-income households that provides a 30% discount on monthly energy bills and a 20% discount on natural gas bills. CARE is funded through a rate surcharge paid by all other utility customers.
CBE – Communities for a Better Environment:
An environmental justice organization that was founded
in 1978. The mission of CBE is to build people’s power
in California’s communities of color and low-income
communities to achieve environmental health and justice by preventing and reducing pollution and building green, healthy and sustainable communities and environments.
CCA – Community Choice Aggregator:
A community choice aggregator, sometimes referred to
as community choice aggregation, is an entity of local
governments that procure power on behalf of their residents, 175
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 88 businesses and municipal accounts from an alternative
supplier while still receiving transmission and distribution service from their existing utility provider. CCAs are an attractive option for communities that want more local
control over their electricity sources, more green power than is offered by the default utility, and/or lower electricity prices. By aggregating demand, communities gain leverage to negotiate better rates with competitive suppliers and choose greener power sources.
CCSF – City and County of San Francisco:
The City and County of San Francisco often engage in
joint advocacy before the CPUC. San Francisco operates
CleanPowerSF, a CCA.
CEC – California Energy Commission: The primary
energy policy and planning agency for California, whose core responsibilities include advancing state energy policy, achieving energy efficiency, investing in energy innovation, developing renewable energy, transforming transportation, overseeing energy infrastructure and preparing for energy emergencies.
CEE – Coalition for Energy Efficiency:
A nonprofit composed of U.S. and Canadian energy-efficiency administrators working together to accelerate the development and availability of energy-efficient products and services.
CLECA – California Large Energy Consumers
Association: An organization of large, high-load factor industrial customers located throughout the state; its
members are in the cement, steel, industrial gas, pipeline, beverage, cold storage, food packaging and mining industries and their electricity costs comprise a significant portion of their costs of production. Some members are bundled
customers, others are Direct Access (DA) customers, and some are served by Community Choice Aggregators (CCAs); a few members have onsite renewable generation.
CPUC – California Public Utility Commission:
A state agency that regulates privately owned electric, natural gas, telecommunications, water, railroad, rail transit and passenger transportation companies, in addition to
authorizing video franchises.
C&I – Commercial and Industrial: Business
customers. C&I customers generally consume much higher
volumes of electricity and gas. Many utilities segment their C&I customers by energy consumption (small, medium and
large).
CP – Compliance Period: Time period to become
Renewables Portfolio Standard (RPS) compliant, set by the California Public Utilities Commission (CPUC).
DA – Direct Access: An option that allows eligible
customers to purchase their electricity directly from third-party providers known as Electric Service Providers (ESPs).
DA Cap: The maximum amount of electric usage that may
be allocated to Direct Access customers in California or, more specifically, within an investor-owned utility service territory.
DACC – Direct Access Customer Coalition: A
regulatory advocacy group composed of educational,
governmental, commercial and industrial customers that
utilize direct access for all or a portion of their electrical energy requirements.
DA Lottery: A random drawing by which DA waitlist
customers become eligible to enroll in DA service under the currently applicable Direct Access Cap.
DA Waitlist: Customers that have officially registered their interest in becoming a DA customer but are not yet able to enroll in service because of DA cap limitations.
DAC – Disadvantaged Community: “Disadvantaged
communities” refers to the areas throughout California that most suffer from a combination of economic, health and
environmental burdens. These burdens include poverty, high unemployment, air and water pollution and the presence of hazardous wastes as well as high incidences of asthma and heart disease. One way that the state identifies these areas is by collecting and analyzing information from communities statewide. CalEnviroScreen, an analytical tool created by the California Environmental Protection Agency (CalEPA), combines different types of census tract-specific information into a score to determine which communities are the most burdened or “disadvantaged.”
DASR – Direct Access Service Request: Request
submitted by C&I customers to become direct access eligible.
Demand: The rate at which electric energy is delivered
to or by a system or part of a system, generally expressed in kilowatts (kW), megawatts (MW) or gigawatts (GW), at a given instant or averaged over any designated interval of time. Demand should not be confused with Load or Energy.
DER – Distributed Energy Resource: A small-scale
176
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 89 physical or virtual asset (e.g., EV charger, smart thermostat, behind-the-meter solar/storage, energy efficiency) that operates locally and is connected to a larger power grid at the distribution level.
Distribution: The delivery of electricity to the retail customer’s home or business through low-voltage
distribution lines.
DLAP – Default Load Aggregation Point: In the
CAISO’s electricity optimization model, DLAP is the node at which all bids for demand should be submitted and settled.
DR – Demand Response: An opportunity for
consumers to play a significant role in the operation of the electric grid by reducing or shifting their electricity usage during peak periods in response to time-based rates or other forms of financial incentives.
DRP – Distributed Resource Plans: Plans that
are required by statute and intended to identify optimal locations for the deployment of distributed resources.
DWR – Department of Water Resources: DWR is
the state agency charged with managing California’s water resources, systems and infrastructure in a responsible, sustainable way.
ECR – Enhanced Community Renewable: An
IOU program that reflects the “Community Solar” model
of renewable energy purchasing. Customers sign up to
purchase a portion of a local solar project directly from a developer at a level that meets at least 25% and up to 100% of their monthly electricity demand. The customer pays the developer for the subscribed output and receives a credit on their utility bill that reflects their enrollment level.
ED – Energy Division: The CPUC’s Energy Division
develops and administers energy policy and programs to
serve the public interest, advise the Commission and ensure compliance with Commission decisions and statutory
mandates.
EE – Energy Efficiency: The use of less energy to
perform the same task or produce the same result. Energy-efficient homes and buildings use less energy to heat and cool and run appliances and electronics, and energy-efficient manufacturing facilities use less energy.
ELCC – Effective Load Carrying Capacity: The
additional load met by an incremental generator while
maintaining the same level of system reliability. For solar and wind resources, the ELCC is the amount of capacity that can be counted for Resource Adequacy purposes.
EPIC – Electric Program Investment Charge:
The EPIC program was created by the CPUC to support
investments in clean energy technologies that provide
benefits to the electricity ratepayers of Pacific Gas and Electric (PG&E), San Diego Gas & Electric Company (SDG&E) and Southern California Edison Company (SCE).
ERRA – Energy Resource Recovery Account:
ERRA proceedings are used to determine fuel and purchased power costs that can be recovered in rates. The utilities do not earn a rate of return on these costs and recover only actual costs. The costs are forecast for the year ahead. If the actual costs are lower than forecast, then the utility gives money back, and vice versa.
ES – Energy Storage: The capture of energy produced
at one time for use at a later time to reduce imbalances between energy demand and energy production.
ESA – Energy Storage Agreement: A battery
services contract, a capacity contract, demand response contract or similar agreement.
ESP – Energy Service Provider: An energy entity
that provides service to a retail or end-use customer.
EV – Electric Vehicle: A vehicle that uses one or more
electric motors for propulsion.
FCR – Flexible Capacity Requirements: “Flexible
capacity need” is defined as the quantity of resources
needed by the CAISO to manage grid reliability during
the greatest three-hour continuous ramp in each month.
Resources will be considered as “flexible capacity” if they can sustain or increase output or reduce ramping needs during the hours of “flexible need.” FCR means the flexible capacity requirements established for LSEs by the CPUC pursuant to the CPUC decisions.
GHG – Greenhouse gas: Water vapor, carbon
dioxide, tropospheric ozone, nitrous oxide, methane and chlorofluorocarbons (CFCs), which are gases that cause the atmosphere to trap heat radiating from the earth. The most common GHG is carbon dioxide.
GRC – General Rate Case: Proceedings used to
address the costs of operating and maintaining the utility system and the allocation of those costs among customer classes. For California’s three large IOUs, the GRCs are 177
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 90 parsed into two phases. Phase I of a GRC determines the total amount the utility is authorized to collect, while Phase II determines the share of the cost each customer class is responsible for and the rate schedules for each class. Each large electric utility files a GRC application every three years for review by the Public Advocate’s Office and interested parties and for approval by the CPUC.
GTSR – Green Tariff Shared Renewables: The
GTSR program enables customers to receive 50 to 100
percent of their electricity demand from renewable sources.
The GTSR program has two components: the Green Tariff
(GT) component and the Enhanced Community Renewables
(ECR) component. Through GT, a customer may pay the
difference between their current generation charge and
the cost of procuring 50 to 100 percent renewables. With ECR, a customer agrees to purchase a share of a community renewable (typically solar) project directly from a developer and in exchange will receive a credit from their utility for the customer’s avoided generation procurement.
GWh – Gigawatt-hour: The unit of energy equal to
that expended in one hour at a rate of one billion watts.
One GWh equals 1,000 megawatt-hours.
ICA – Integration Capacity Analysis: The enhanced
integrated capacity and locational net benefit analysis quantify the capability of the system to integrate Distributed Energy Resources (DERs) within the distribution system.
Results are dependent on the most limiting element of the various power system criteria such as thermal ratings, power quality, system protection limits and safety standards of existing equipment.
IDER – Integrated Distributed Energy
Resources: A CPUC proceeding that aims to more
effectively coordinate the integration of demand-side
resources in order to better meet customer and grid needs, while enabling California to attain its greenhouse gas
reduction goals.
IDSM – Integrated Demand-Side Management:
An approach that joins together all the resources utilities have at their disposal to plan, generate and supply electricity in the most efficient manner possible.
IEPA – Independent Energy Producers
Association: California’s oldest and leading nonprofit
trade association, representing the interest of developers and operators of independent energy facilities and independent power marketers.
IMD – Independent Marketing Division: Under
state law, IOUs are prohibited from lobbying or marketing on community choice unless the IOU forms an independent marketing division funded by shareholders rather than
ratepayers. SDG&E and its parent company Sempra were
permitted by the CPUC to create such an independent
marketing division, which allowed SDG&E to lobby against plans to create a CCA program.
IOU – Investor-Owned Utility: A private electricity
and natural gas provider, such as SDG&E, PG&E or SCE,
which are the three largest IOUs in California.
IRP – Integrated Resource Plan: A plan that outlines
an electric utility’s resource needs in order to meet expected electricity demand long-term.
kW – Kilowatt: A measure of power where power (watts)
= voltage (volts) x amperage (amps) and 1 kW = 1,000 watts. kWh – Kilowatt-hour: This is a measure of
consumption. It is the amount of electricity that is used over some period of time, typically a one-month period for billing purposes. Customers are charged a rate per kWh of electricity used.
LCE – Lancaster Choice Energy: The CCA that serves
the City of Lancaster, California.
LCFS – Low Carbon Fuel Standard: A CARB
program designed to encourage the use of cleaner low-carbon fuels in California, encourage the production of those fuels and, therefore, reduce greenhouse gas emissions.
LCR – Local (RA) Capacity Requirements: The
amount of Resource Adequacy capacity required to be
demonstrated in a specific location or zone.
LMP – Locational Marginal Price: Each generator
unit and load pocket is assigned a node in the CAISO
optimization model. The model will assign a LMP to the node in both the day-ahead and real-time market as it balances the system using the least cost. The LMP is composed of three components: the marginal cost of energy, congestion and losses. The LMP is used to financially settle transactions in the CAISO.
LNBA – Locational Net Benefits Analysis: A cost-benefit analysis of distributed resources that incorporates location-specific net benefits to the electric grid.
178
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 91 Load: An end-use device or customer that receives power from an energy delivery system. Load should not be confused with Demand, which is the measure of power that a load
receives or requires. See Demand.
LSE – Load-serving Entity: Entities that have been
granted authority by state, local law or regulation to serve their own load directly through wholesale energy purchases and have chosen to exercise that authority.
LTPP – Long-Term Procurement Rulemaking:
This is an “umbrella” proceeding to consider, in an integrated fashion, all of the CPUC’s electric procurement policies and programs.
MCE – Marin Clean Energy: The first CCA in California,
which began serving customers in 2010. It serves customers in Contra Costa, Marin, Napa and Solano counties in Northern California.
MEO – Marketing Education and Outreach: A
term generally used to describe various strategies to inform customers, such as to motivate consumers to take action on energy efficiency or conservation measures and change their behavior.
MW – Megawatt: A megawatt hour (Mwh) is equal to
1,000 Kilowatt hours (Kwh) or 1,000 kilowatts of electricity used continuously for one hour.
MWH – Megawatt-hour: A measure of energy.
NAESCO – National Association of Energy
Service Companies: An advocacy and accreditation
organization for energy service companies (ESCOs). Energy service companies contract with private and public-sector energy users to provide cost-effective energy efficiency retrofits across a wide spectrum of client facilities.
NBC – Non-Bypassable Charge: Fees that are paid
on every kilowatt-hour of electricity that is consumed from the grid. These charges can be used to fund things like energy assistance programs for low-income households and energy efficiency programs. These charges apply even if customers buy grid-supplied power from an outside power company
such as a CCA.
NDA – Non-Disclosure Agreement: A contract by
which one or more parties agree not to disclose confidential information that they have shared with each other.
NEM – Net Energy Metering: A program in which solar
customers receive credit for excess electricity generated by solar panels.
NRDC – Natural Resources Defense Council: A
nonprofit international environmental advocacy group.
NP-15 – North Path 15: NP-15 is a CAISO pricing zone
usually used to approximate wholesale electricity prices in Northern California in PG&E’s service territory.
OIR – Order Instituting Rulemaking: A procedural
document that is issued by the CPUC to start a formal
proceeding. A draft OIR is issued for comment by interested parties and made final by vote of the five commissioners of the CPUC.
OSC – Order to Show Cause: An order requiring an
individual or entity to explain, justify or prove something.
ORA – Office of Ratepayer Advocates: The
independent consumer advocate within the CPUC, now called the Public Advocates Office.
PA – Program Administrator (for EE Business
Plans): IOUs and local government agencies authorized to implement CPUC-directed energy efficiency programs.
PCE – Peninsula Clean Energy Authority: A CCA
serving San Mateo County and all 20 of its cities and towns as well as the City of Los Banos.
PCC1 – RPS Portfolio Content Category 1: Bundled
renewables where the energy and Renewable Energy
Certificate (REC) are dynamically scheduled into a California Balancing Authority (CBA) such as the CAISO, also known as “in-state” renewables.
PCC2 – RPS Portfolio Content Category 2:
Bundled renewables where the energy and Renewable Energy Certificate (REC) are from out of state and not dynamically scheduled to a CBA.
PCC3 – RPS Portfolio Content Category 3:
Unbundled Renewable Energy Certificate (REC).
PCIA or “exit fee”: The Power Charge Indifference
Adjustment (PCIA) is an “exit fee” based on stranded costs of utility generation set by the California Public Utilities Commission. It is calculated annually and assessed to
customers of CCAs and paid to the IOU that lost those
customers as a result of the formation of a CCA.
PCL – Power Content Label: A user-friendly way of
displaying information to California consumers about the energy resources used to generate the electricity they sell, as required by AB 162 (Chapter 313, Statutes of 2009) and SB 1305 (Chapter 796, Statutes of 1997).
179
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 92 PD – Proposed Decision: A procedural document in a
CPUC Rulemaking that is formally commented on by parties to the proceeding. A PD is a precursor to a final decision voted on by the five commissioners of the CPUC.
PG&E – Pacific Gas & Electric: The IOU that serves
16 million people over a 70,000-square-mile service area in Northern California.
PHC – Prehearing Conference: A CPUC hearing to
discuss the scope of a proceeding, among other matters.
Interested stakeholders can request party status during these conferences.
Pnode – Pricing Node: In the CAISO optimization
model, this is a point where a physical injection or withdrawal of energy is modeled and for which an LMP is calculated.
PPA – Power Purchase Agreement: A contract
used to purchase the energy, capacity and attributes from a renewable resource project.
PRP – Priority Review Project: Transportation
electrification pilot projects approved by the CPUC pursuant to SB 350 (Chapter 547, Statutes of 2015).
PRRR – Progress on Residential Rate Reform:
Pursuant to a CPUC decision, the IOUs must submit to the CPUC and other parties periodic updates on the progress of their efforts to assist customers with residential rate design changes related to rate reform, including tier collapse and transition to a default time of use rate.
PUC – Public Utilities Code: A California statute that
contains 33 divisions; the range of topics within this code includes natural gas restructuring, private energy producers, telecommunication services, and specific municipal utility districts and transit authorities; the primary statute for governance of utilities as well as CCAs in California.
PURPA – Public Utilities Regulatory Policy Act:
A federal statute passed in 1978 by Congress in response to the 1973 energy crisis to encourage fuel diversity via alternative energy sources and to introduce competition into the electric sector. It was intended to promote energy conservation (reduce demand) and promote greater use of domestic energy and renewable energy (increase supply).
RA – Resource Adequacy: Under its Resource
Adequacy (RA) program, the California Public Utilities
Commission (CPUC) requires load-serving entities —
investor-owned utilities, electricity service providers and CCAs — to demonstrate in both monthly and annual filings that they have purchased capacity commitments of no less than 115% of their peak loads.
RAM – Renewables Auction Mechanism: A
procurement program the investor-owned utilities (IOUs) may use to procure RPS eligible generation. The IOUs may use RAM to satisfy authorized procurement needs, for
example, system Resource Adequacy needs, local Resource Adequacy needs, RPS needs, reliability needs, Local Capacity Requirements, Green Tariff Shared Renewables needs and
any need arising from commission or legislative mandates.
RE – Renewable Energy: Energy from a source that is
not depleted when used, such as wind or solar power.
REC - Renewable Energy Certificate: A REC is the
property right to the environmental benefits associated with generating renewable electricity. For instance, homeowners who generate solar electricity are credited with 1 solar REC for every megawatt-hour of electricity they produce. Utilities obligated to fulfill an RPS requirement can purchase these RECs on the open market.
RES-BCT – Renewables Energy Self-Generation
Bill Credit Transfer: This program enables local
governments and universities to share generation credits from a system located on one government-owned property
with billing accounts at other government-owned properties.
The system size limit under RES-BCT is 5 MW, and bill credits are applied at the generation-only portion of a customer’s retail rate.
RFO – Request for Offers: A competitive procurement
process used by organizations to solicit the submission of proposals from interested parties in response to a scope of services.
RPS - Renewable Portfolio Standard: A law that
requires California utilities and other load-serving entities (including CCAs) to provide an escalating percentage of California qualified renewable power (culminating at 33% by 2020) in their annual energy portfolio.
SB – Senate Bill: A piece of legislation that is introduced in the Senate. In other words, the Senate, rather than the Assembly, is the house of origin in the Legislature for the legislation.
SCE – Southern California Edison: The large IOU
that serves the Los Angeles and Orange County area.
180
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Glossary of Terms 93 SCP – Sonoma Clean Power Authority: The CCA
serving Sonoma County and surrounding areas in Northern California.
SDG&E – San Diego Gas & Electric: The IOU that
serves San Diego County and owns the infrastructure that delivers Community Power energy to our customers.
SGIP – Self-Generation Incentive Program: A
program that provides incentives to support existing, new and emerging distributed energy resources (storage, wind turbines, waste heat to power technologies, etc.).
SUE – Super User Electric: An electric surcharge
intended to penalize consumers for excessive energy use.
SVCE – Silicon Valley Clean Energy: The CCA
serving the communities in Santa Clara County.
TCR EPS Protocol – The Climate Registry
Electric Power Sector Protocol: Online tools
and resources provided by The Climate Registry to assist organizations to measure, report and reduce carbon
emissions.
TE – Transportation Electrification: For the
transportation sector, electrification means replacing fossil fuels with electricity as the means of powering light-duty vehicles and medium- and heavy-duty trucks and buses. The primary goal is to reduce greenhouse gas (GHG) emissions and, ultimately, contribute to mitigating the effects of climate change on the planet.
Time-of-Use (TOU) Rates: The pricing of delivered
electricity based on the estimated cost of electricity during a particular time block. Time-of-use rates are usually divided into three or four time blocks per 24 hour period (on-peak, mid-peak, off-peak and sometimes super off-peak) and
by seasons of the year (summer and winter). Real-time
pricing differs from TOU rates in that it is based on actual (as opposed to forecasted) prices that may fluctuate many times a day and are weather sensitive, rather than varying with a fixed schedule.
TM – Tree Mortality: A term that refers to the death of forest trees and provides a measure of forest health. In the context of energy, as part of the Governor’s Tree Mortality Emergency Proclamation, the CPUC is tasked with utilizing its authority to extend contracts and take actions to authorize new contracts on bioenergy facilities that receive feedstock from high hazard zones.
TURN – The Utility Reform Network: A ratepayer
advocacy group charged with ensuring that California IOUs implement just and reasonable rates.
Unbundled RECs: Renewable energy certificates that
verify a purchase of a MWH unit of renewable power where the actual power and the certificate are “unbundled” and sold to different buyers.
VPP – Virtual Power Plant: A cloud-based network
that leverages an aggregation of distributed energy resources (DERs) to shift energy demand or provide services to the grid. For example, thousands of EV chargers could charge at a slower speed and hundreds of home batteries could
discharge to the grid during a demand peak to significantly reduce the procurement of traditional supply resources.
VAMO – Voluntary Allocation, Market Offer: The
process for SDG&E to allocate a proportional share of its renewable portfolio to Community Power and other LSEs
within the service territory.
181
v
Budget
Resolution
11 182
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Resolution 95 Budget Resolution Pending
183
v
Acknowledgments
12 184
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Acknowledgments 97 Finance Department
San Diego Community Power’s Finance Department works to maintain a fiscally responsible budget in accordance with Community Power’s Budget Policy. The department ensures sufficient funding to meet procurement needs, sustain operational needs, and support sustained growth while delivering clean energy to the communities we serve. In addition, the team actively works to build Community Power’s reserves and develop policies that consider future economic conditions, provides an understandable and transparent operating budget for internal and external users, strives to keep the Community Power Board, committees and staff informed of Community Power’s fiscal condition and develops a budget that will ultimately prioritize people, transparency and our communities.
Acknowledgments
Board of Directors
Mayor Paloma Aguirre, Chair
Supervisor Terra Lawson-Remer, Vice Chair
Councilmember Sean Elo-Rivera, Director
Councilmember Marco San Antonio, Director
Councilmember Michael Inzunza, Director
Councilmember Genevieve Suzuki, Director
Councilmember Ditas Yamane, Director
Finance and Risk Management Committee
Councilmember Ditas Yamane, Chair
Councilmember Genevieve Suzuki, Vice Chair
Councilmember Michael Inzunza, Director
Community Advisory Committee
CHULA VISTA
• Anthony Sclafani
• (Vacant)
COUNTY OF SAN DIEGO
• Peter Andersen
• Ross Pike
ENCINITAS
• Gary L. Jahns
• Tara Hammond
IMPERIAL BEACH
• Ilian Sandoval
• Kenneth Hoyt
LA MESA
• David Harris
• Shaun Sumner
NATIONAL CITY
• Aida Castañeda
• Larry Emerson
SAN DIEGO
• Luis Montero-Adams
• Matthew Vasilakis
Community Power Executive Team
Karin Burns, Chief Executive Officer
Eric Washington, Chief Financial Officer and
Deputy Chief Executive Officer/Treasurer
Jack Clark, Chief Operating Officer
Veera Tyagi, General Counsel
Byron Vosburg, Chief Commercial Officer*
Finance Department
Eric Washington, Chief Financial Officer and
Deputy Chief Executive Officer/Treasurer
Tim Manglicmot, Director of Finance
Christopher Stephens, Procurement Manager
Diana Gonzalez, Risk Manager
Mark Alfaro, Finance Manager
Jeb Spengler, Strategic Finance Manager
Christopher Do, Senior Financial Analyst
Julissa Mercedes, Financial Analyst
Kevin Bateman, Financial Analyst
*Formerly titled Managing Director Power Services
185
ITEM 11
ATTACHMENT B
186
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Contents i Resolution 2025-XX Proposed June 26, 2025 Fiscal Years 2026–2030
SAN DIEGO COMMUNITY POWER
Capital Investment Plan (CIP)
FISCAL YEAR
2026
2030
187
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Contents ii Contents
How to Use This Book 1
A Letter from the Chief Executive Officer 2
Capital Investment Plan Overview 5
Overview of San Diego Community Power 8
Who We Are 8
About Community Choice 9
Governance and Structure 10
Organizational Structure 10
Capital Investment Plan (CIP) 12
About the CIP 12
CIP Development Process 12
Strategic Planning 14
Core Strategic Goals 15
Community Engagement 18
Community Engagement Process 18
Prioritizing Equity and Communities of Concern 20
Capital Program Areas 22
Program Type Overview 22
Program Type 1. Energy Awareness and Education 23
Program Type 2. Application Assistance 24
Program Type 3. Disadvantaged Communities Green Tariff 25 Program Type 4. Pilot Programs 26
Program Type 5. Grant Programs 27
Program Type 6. Building Electrification: Heat Pump Technology 28 Program Type 7. Planning & Studies 29
Program Type 8. Distributed Energy Resources: Energy Storage Systems 30 Program Type 9. Distributed Energy Resources: Demand Response 31 Program Type 10. Energy Efficiency 32
Program Type 11. Transportation Electrification: Infrastructure 33 Program Type 12. Transportation Electrification: Light-Duty Vehicles 34 Program Type 13. Transportation Electrification: Medium- and Heavy-Duty Vehicles 35 Program Type 14. Information Technology: Upgrades 36
188
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Contents iii Funding Guide 39
Internal versus External Funding 39
External Sources 40
Funding Guide 40
Budget Resolution 43
Acknowledgments 45
List of Figures
FIGURE 1. CCAS IN CALIFORNIA 9
FIGURE 2. COMMUNITY POWER MEMBER AGENCIES 10
FIGURE 3. ORGANIZATIONAL CHART 10
FIGURE 4. CIP DEVELOPMENT PROCESS 12
FIGURE 5. SAN DIEGO COMMUNITY POWER MISSION STATEMENT 14 FIGURE 6. SAN DIEGO COMMUNITY POWER VISION STATEMENT 14 FIGURE 7. CORE STRATEGIC GOALS 16
List of Tables
TABLE 1. FY 2025-2026 CAPITAL BUDGET 5
TABLE 2. FY 2026–2030 CIP PROGRAMS AND PROJECTS 6
TABLE 4. COMMUNITY NEEDS ASSESSMENT 19
TABLE 2. ENERGY AWARENESS AND EDUCATION PROJECTS 23
TABLE 3. APPLICATION ASSISTANCE PROJECTS 24
TABLE 4. DISADVANTAGED COMMUNITIES GREEN TARIFF PROJECTS 25 TABLE 5. PILOT PROGRAMS PROJECTS 26
TABLE 6. GRANT PROGRAMS PROJECTS 27
TABLE 7. BUILDING ELECTRIFICATION HEAT PUMP TECHNOLOGY PROJECTS 28 TABLE 8. PLANNING & STUDIES PROJECTS 29
TABLE 9. DISTRIBUTED ENERGY RESOURCES: ENERGY STORAGE SYSTEMS PROJECTS 30 TABLE 10. DISTRIBUTED ENERGY RESOURCES: DEMAND RESPONSE PROJECTS 31 TABLE 11. ENERGY EFFICIENCY PROJECTS 32
TABLE 12. TRANSPORTATION ELECTRIFICATION: INFRASTRUCTURE PROJECTS 33 TABLE 13. TRANSPORTATION ELECTRIFICATION: LIGHT-DUTY VEHICLES PROJECTS 34 TABLE 14. TRANSPORTATION ELECTRIFICATION: MEDIUM- AND HEAVY-DUTY VEHICLES PROJECTS 35 TABLE 15. INFORMATION TECHNOLOGY UPGRADES PROJECTS 36
TABLE 16. COMMUNITY POWER FUNDING GUIDE 40
189
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 How to Use This Book 1 How to Use This Book
Executive Summary
Includes the Chief Executive Officer’s Letter for the proposed CIP and provides a high-level overview of the agency’s cap-ital budget and other high-level details on specific projects and their benefits to the community.
Capital Investment Plan
Overview
Describes the CIP in brief, including summary tables that reflect the operating transfer into the CIP as well as the list of projects planned for the next five years.
Overview
Provides a high-level overview of Community Power’s
governance, structure and agency values and priorities.
Strategic Plan
Describes Community Power’s strategic planning process
and board-adopted strategic goals that provide the
foundation for the creation of the CIP.
The San Diego Community Power (Community Power) proposed Fiscal Years (FY) 2026–2030 Capital Investment Plan (CIP) contains agency budgetary and fiscal policy information as well as detailed agency capital investment plans. The proposed Capital Investment Plan is organized into the following sections.
Community Engagement
Outlines the outreach process to the community that
provided feedback and significant input into project and program design.
Program Types
Includes the 14 program types, projects and funding within these types falling into short-, medium- and long-term
segments that will be delivered within the CIP.
Funding Guide
Explains funding sources that fund the CIP as well as future potential funding sources that Community Power can
leverage and apply for to bolster CIP funding amounts.
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY25–26 190
How to Use This Book 1
A Letter from the Chief Executive Officer 2
At San Diego Community Power, we are shaping a future that is both sustainable and equitable. As a not-for-profit public agency and Community Choice Aggregator (CCA), we were created to bring competition to the local energy marketplace, offering cleaner energy at competitive rates and reinvesting revenues back into our communities.
Since launching in 2021, we’ve grown significantly in both reach and impact. In 2024, we remained focused on our mission: delivering reliable, clean power at competitive rates while advancing programs that make a tangible difference for our customers.
Affordability and long-term value remain central to our strategy. In February 2025, we reduced rates for the second year in a row — thanks to prudent financial planning and favorable market conditions — providing most customers with a discount compared with San Diego Gas & Electric’s electricity generation rates.
Every decision we make, from lowering rates to expanding service options, is grounded in the needs of our customers and communities. Last summer, we introduced two new service options: Power100 Green+, for commercial customers seeking the highest level of renewable energy, and PowerBase, a more affordable option that still meets California’s clean energy standards Even as we deliver near-term savings, we continue to plan for long-term energy security and stability. The broader power market remains volatile, shaped by a constrained statewide resource supply and uncertain federal tax credit and trade policies. Our Power Services team is navigating these challenges through disciplined procurement and long-range planning.
To date, we’ve executed 17 long-term power purchase and energy storage agreements that will deliver reliable, renewable electricity to nearly 1 million homes and businesses across our region. These investments not only support our goal of 100% renewable energy by 2035, but also help insulate customers from future price spikes.
In 2024, we marked a major milestone with the ribbon cutting of the Vikings Solar and Storage Project in Imperial County. Developed by Arevon, with Community Power as the offtaker, Vikings is more than just a solar generation site. As one of the first utility-scale solar peaker plants in the United States, the project is designed to keep the lights on and costs down when demand is at its highest — powering the equivalent of 50,000 San Diego homes with clean, affordable energy. It exemplifies our broader procurement strategy: securing long-term renewable power while creating local and regional economic opportunity.
In addition to expanding customer choice and value, we’ve made progress on delivering innovative solutions that support customers across the region. Last summer, we launched our largest customer program to date, Solar Battery Savings, which offers upfront and performance-based incentives for home battery systems that boost resilience and reduce grid demand during peak hours. The program was recognized in the U.S. Department of Energy’s 2025 Virtual Power Plant Liftoff Report as a model for customer-centered innovation in distributed energy.
We also secured approval from the California Public Utilities Commission to launch the San Diego Regional Energy Network (SDREN) in partnership with the County of San Diego. SDREN will generate nearly $125 million in energy efficiency resources for the region through 2027 and marks the final major population area in California to establish a Regional Energy Network.
A Letter from the
Chief Executive Officer
191
A Letter from the Chief Executive Officer 3
Chief Executive Officer
San Diego Community Power
As we grow, we’re also investing in the internal systems and strategic planning necessary to scale effectively, operate efficiently and remain accountable to the public.
The proposed FY 2026–2030 Capital Investment Plan (CIP), alongside the proposed FY 2025–2026 budget, reflects these priorities as we transition toward our mid-term program strategy, which focuses on optimizing customer energy use around time-of-use rate schedules and individual preferences. These efforts reduce participants’ bills while lowering major cost drivers like energy procurement and resource adequacy — creating system-wide savings that benefit all ratepayers. In the years ahead, we will continue building the tools and incentives that align customer behavior with grid needs, helping make our clean energy system smarter, more affordable and more resilient.
As we look ahead, our focus remains on driving measurable impact: accelerating the region’s clean energy transition, supporting local climate goals and building a more just and resilient energy system.
With the continued leadership of our Board of Directors, Community Advisory Committee and dedicated staff, San Diego Community Power is proud to power the path toward a cleaner, more resilient future — together.
Thank you for your continued trust and partnership.
192
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan Overview 4 v
Capital
Investment
Plan Overview
01 193
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan Overview 5 San Diego Community Power developed its first Capital
Investment Plan (CIP) for FY 2024–2028 and continues to grow it with the FY 2026–2030 CIP, which contains all the individual capital projects, major equipment purchases and major programs for the agency that are intended to span multiple years. The FY 2025–2026 budget proposes a one-time portion of net operating revenues be transferred to the CIP as a continuing fund in which any unspent funds are kept within that fund and carried forward to the subsequent fiscal year.
The CIP includes funding for local development feasibility studies, customer program pilot projects, community grants, a customer education platform and other areas as outlined in the short- and medium-term program areas. Given the
number of planning and pilot projects, the Community
Power CIP is largely funded by internal funding that allows maximum flexibility in the planning phase with designing programs and projects. This allows the agency to focus on Capital Investment Plan Overview
designing based on community and agency needs rather
than based on the requirements requested by a funding
agency. The planning phase of a program or project also requires less funding when compared with implementation or design and construction. As Community Power builds
reserve funds and endeavors to maximize impact,
Community Power will leverage the CIP to aggressively
pursue external funding from sources such as state and
federal agencies.
TABLE 1. FY 2025–2026 CAPITAL BUDGET*
Carry Forward 1 FY26 Authorized Budget FY26 Proposed Budget Operating Transfer In 7.5 - 21.4
Regional Energy Network 2 0.3 31.8 31.8
DAC-GT 0.5 0.3 0.3
CDFA 0.5 - -
Equitable Building Decarbonization 1.5 - -
Other - - 0.9
CIP Revenue 10.3 32.1 54.4
*Amounts displayed in millions of dollars
1 The Carry Forward amount represents actual financial data through March 31, 2025, and will be reconciled at the close of fiscal year 2024–2025. 2 The Regional Energy Network was fully appropriated for $124M in January 2025 for Calendar Years 2024–2027. 194
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan Overview 6 TABLE 2. FY 2026–2030 CIP PROGRAMS AND PROJECTS
Beginning
Bal.
Expenses Carry
Forward 1
5-Year Budget
FY25 FY25 FY25 FY26 FY27 FY28 FY29 FY30 Total
External Funding
Regional Energy
Network
2.1 1.8 0.3 31.8 59.5 51.4 42.0 43.7 228.7
DAC-GT 0.9 0.4 0.5 0.3 0.5 0.5 0.5 0.5 2.7
CDFA 0.7 0.2 0.5 - - - - - 0.5
Equitable Building
Decarbonization
1.5 - 1.5 - - - - - 1.5
Other - - - 0.9 - - - - 0.9
Subtotal 5.2 2.4 2.8 33.0 60.0 51.9 42.5 44.2 234.4
Internal Funding
Solar Battery
Savings
10.6 7.9 2.7 18.8 11.1 10.4 8.3 8.5 59.8
Energy Efficiency 0.3 0.3 - - - - - - -
Pilot Programs 3.0 1.3 1.7 - - - - - 1.7
Grants 0.8 0.3 0.7 0.8 - - - - 1.5
DER 0.1 0.0 0.1 - - - - - 0.1
Flexible Load 0.6 0.5 0.2 0.3 0.6 0.6 0.8 0.7 3.1
IT Projects 2.6 0.6 2.0 1.5 - - - - 3.5
Community
Education
0.1 0.0 0.0 - - - - - 0.0
Program Evaluation - - - 0.3 - - - - 0.3
Other - - - 0.2 - - - - 0.2
Subtotal 15.4 11.1 7.5 21.4 11.7 11.0 9.1 9.2 69.9
CIP Expense Total 20.6 13.5 10.3 54.4 71.7 62.9 51.6 53.4 304.3 1 The Regional Energy Network was fully appropriated for $124M in January 2025 for Calendar Years 2024–2027 but given the size of the program, it is reflected in this table as anticipated spending by fiscal year.
The first year of the CIP is appropriated as part of Community Power’s annual budget process and becomes the adopted capital budget for the fiscal year. The subsequent years of the CIP are planned expenses that are subject to Board approval during the annual budget process and are subject to change.
195
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Overview of San Diego Community Power 7 v
Overview of
San Diego
Community
Power
02 196
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Overview of San Diego Community Power 8 Who We Are
Our Story
San Diego Community Power is a Community Choice
Aggregator (CCA) that gives customers an option to power their homes and businesses with significantly higher levels of renewable power at competitive rates. Since 2021,
Community Power has grown to serve nearly 1 million
residential, business and municipal power customers in the cities of San Diego, Chula Vista, Encinitas, Imperial Beach, La Mesa and National City as well as the unincorporated communities of San Diego County.
With support from local communities, Community Power
was established as a Joint Powers Authority by five cities within the San Diego region. Community Power submitted
an implementation plan to the California Public Utilities Commission, outlining the intended organizational structure, operations and funding. Once approved, our Board of Directors began to meet regularly, and implementation activities began.
In 2020, a sixth city and the County of San Diego elected to join Community Power.
Through phased enrollment from 2021
through 2023, Community Power gradually
became the official clean energy provider
for our member agencies. Customers
were automatically enrolled in our service
and received two notices before and two
notices after enrollment.
Community Power serves
nearly 1 million customers with
competitively priced clean
energy; we are beginning to offer
customer programs and rebates
as well as supporting San Diego
County’s energy efficiency goals
through the San Diego Regional
Energy Network (SDREN).
Overview of San Diego Community Power
Community Power is a not-for-profit public agency that
provides affordable clean energy and invests in its local communities to create an equitable and sustainable future for the San Diego region.
Learn more at www.sdcommunitypower.org.
FORMATION ENROLLMENT 2021–2023 TODAY
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY25–26
197
Overview of San Diego Community Power 8
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Overview of San Diego Community Power 9 About Community Choice
Community
Power
purchases electricity
from renewable sources.
delivers power and
manages services.
enjoy cleaner power
at competitive rates.
SDG&E You
San Diego Community Power is a Community Choice
Aggregator (CCA) — one of dozens that have formed
throughout California over the past 20 years. There are currently 25 CCAs serving over 14 million customers
in California.
CCAs are making good on their commitments to invest
in new renewable energy facilities throughout California.
To date, CCAs have contracted for more than 18,000
megawatts (MW) of new clean generation capacity through long-term power purchase agreements (PPAs) with terms of 10 years or more. CCA PPAs equate to:
• More than 18 gigawatts (GW) of new solar, wind, energy storage, geothermal and demand response resources
• Projects totaling more than 7,900 MW that are already operational and serving CCA customers
• More than $37 billion committed by CCAs to build and
operate clean energy resources
• Support for more than 36,000 construction jobs
How It Works
FIGURE 1. CCAS IN CALIFORNIA
Through CCAs, communities can join together to pool
(or aggregate) their electricity load in order to purchase clean energy and develop local clean energy projects and programs on behalf of their residents and businesses. CCAs like Community Power work in partnership with the region’s existing investor-owned utilities (SDG&E in our case), which continue to deliver power and maintain the grid.
198
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Overview of San Diego Community Power 10 Organizational Structure
BOARD OF DIRECTORS
Paloma Aguirres
Chair
Sean Elo-Rivera
Councilmember
Michael Inzunza
Councilmember
Ditas Yamane
Councilmember
Terra Lawson-Remer
Vice Chair
Marco San Antonio
Councilmember
Genevieve Suzuki
Councilmember
CHIEF EXECUTIVE OFFICER
Karin Burns
LEGAL
General Counsel
OPERATIONS
Chief Operating Officer
FINANCE
Chief Financial Officer/
Treasurer
POWER
SERVICES
Chief Commercial
Officer
HUMAN RESOURES
& ADMINISTRATION
Senior Director of
People Operations &
Administration Data Analytics &
Account Services
Public Affairs Programs
Regulatory &
Legislative Affairs
Clerk of the Board
Finance & Risk
Management Committee
Community Advisory Committee
FIGURE 3. ORGANIZATIONAL CHART
Governance and Structure
In September 2019, the cities of San Diego, Chula Vista, Encinitas, Imperial Beach and La Mesa adopted an ordinance and resolution to form San Diego Community Power, a
California Joint Powers Authority (JPA). In 2021, National City and the County of San Diego voted to join Community Power.
Community Power’s Board of Directors is composed of an
elected representative from each member jurisdiction, with FIGURE 2. COMMUNITY POWER MEMBER AGENCIES
each member having an alternate from the agency they
represent. The Board is publicly accountable to Community Power ratepayers and hosts monthly Board meetings, where it establishes policy, sets rates, determines power purchase options and maintains fiscal oversight.
As a public agency, Community Power is designed to be fully transparent with all official meetings and information open or available to the public.
199
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan 11 v
Capital
Investment
Plan
03 200
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan 12 About the CIP
The Community Power Fiscal Year 2026–2030 Capital
Improvement Plan (CIP) includes 21 projects that will receive funding in the five-year period, totaling $304.3 million in investments across Community Power member jurisdictions.
Projects include a number of short- and medium-term
programs and projects that are largely pilot and planning studies. This allows Community Power to thoughtfully plan and design its projects and programs — based on community and agency needs — to deliver programs and projects that provide maximum public impact and that can potentially
leverage other local, state and federal funds.
This plan continues Community Power’s commitment to
plan and finance programs and projects that align with
community and organizational priorities. The programs and projects compose a list that provides Community Power with the confidence to target a core set of program types focused on community needs. It also gives Community Power the
flexibility to co-design programs with community partners and to be responsive to external funding opportunities as they emerge.
This plan is not a final or absolute list of funded projects and projects may not have funding identified. Each funded and partially funded project shows a potential source of funding but this does not necessarily indicate that actual funding of the project has occurred. As design requirements, budgets and priorities change, the planned projects may also move within the plan or drop out entirely.
CIP Development Process
Community Power will update the CIP annually during its budget development process. Programs and projects are
included in the CIP based on alignment with Community
Power’s strategic goals and based on community
engagement.
The proposed capital budget and CIP undergo a public
outreach process comprising a wide range of stakeholder groups. Additionally, the CIP is a dynamic document that is intended to be updated regularly as needs shift or as fund availability changes. All subsequent updates to the CIP will be brought to the Board for approval.
FIGURE 4. CIP DEVELOPMENT PROCESS
Likewise, this list is not all inclusive. Unexpected
requirements often cause unforeseen projects to be inserted into the design and execution process. Furthermore, funding sources identified in the CIP are potential funding sources that may not materialize. Projects, programs and funding are additionally subject to Board approval consistent with the JPA and the internal policies and programs of the agency. period total
investment
projects to
be funded
5-Year $304.3M 21
Across Community Power
member jurisdictions
Capital Investment Plan (CIP)
201
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan 13 v
Strategic
Planning
04 202
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan 14 Strategic Planning
San Diego Community Power’s budgeting process,
including its CIP, is directly informed by its Strategic Plan — a document co-created by our Board, our CAC, our executives and our team — that translates community priorities into actionable goals. The Strategic Plan is a critical management tool, helping to align resources, guide operational decisions and drive long-term organizational focus across every
department and initiative.
Now three years into our first strategic planning cycle, Community Power has reached a pivotal inflection point.
Since the adoption of our 2023–2027 Strategic Plan in
June 2022 and its subsequent update in April 2023, we’ve achieved many of the ambitious goals we set, made
meaningful progress on others and thoughtfully recalibrated where needed. From October 2024 to March 2025, we
embarked on a process of revising and updating our strategic plan, setting aggressive new goals while continuing to focus our efforts, build our organization and deliver on the promise of community choice.
What hasn’t changed is our mission, vision and core values.
These foundational statements continue to guide our work even as we refine our priorities and strategies to reflect new opportunities, challenges and lessons learned. With our team, customer base and clean energy infrastructure significantly expanded, we now turn toward a new two- to three-year horizon — one defined by sustained growth,
increased financial responsibility and a deeper investment in the people and systems that power our organization.
As we evolve, we continue to ask a simple but powerful
question: Does this activity serve our purpose? Every
program, investment and initiative we pursue should answer “yes” to at least one of the following:
• Does it make energy more affordable for our customers? • Does it make things easier for our customers?
• Does it make our energy more renewable?
• Does it maintain or improve the health of our organization? • Does it build trust with our communities, stakeholders and local governments?
These questions — and the values underlying them — serve as a filter and a guidepost, helping to ensure that our Strategic Plan remains grounded in what matters most to our customers and communities.
FIGURE 5. SAN DIEGO COMMUNITY POWER MISSION STATEMENT FIGURE 6. SAN DIEGO COMMUNITY POWER VISION STATEMENT Mission Statement
To provide affordable clean energy
and invest in the community to
create an equitable and sustainable
future for the San Diego region.
Vision Statement
A global leader inspiring innovative
solutions to climate change by
powering our communities with
100% clean energy while prioritizing
equity, sustainability and
high-quality jobs.
203
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan 15 As part of this new planning phase, Community Power has identified four overarching themes to guide our work:
Together, these priorities inform the structure of our proposed FY 2025–2026 budget and the evolution of our Strategic Plan. That work is organized around seven long-term Strategic Goals that anchor the agency’s planning and performance management. These goals guide not only how we invest our resources but also how we measure our progress as a public agency accountable to the communities we serve.
Fiscal Sustainability
We remain committed to building strong
financial reserves, managing risk and
pursuing strategies like clean energy prepay
transactions that can reduce long-term costs
for customers.
Infrastructure Investment
This includes both internal infrastructure,
such as IT, legal, data and policy capacity, and
external infrastructure, including local battery
storage, distributed energy resources and
virtual power plant development.
Customer Affordability
Affordability remains the top concern
voiced by our community and is front of
mind with every power purchase, financial
hedge, compliance obligation or additional
long-term power resource we contract
with to support our short- and long-term
procurement efforts. Our additional activities
— ranging from the development of targeted
rates like PowerBase to launching the San
Diego Regional Energy Network — will
continue to focus on reducing energy bills
while meeting state policy goals.
People
As we grow, so does our responsibility to
ensure a resilient and inclusive workplace
culture. We are investing in management
training, professional development and
succession planning to ensure strong
continuity and a high level of staff retention.
Core Strategic Goals
1. Fiscal Sustainability
Practice fiscal strategies to promote long-term
organizational sustainability.
• Execute at least six clean prepayment transactions over the next three years to generate $30 million in annual
power cost savings.
• Obtain a public investment-grade credit rating by
November 2027.
• Grow reserves by $150 million to maintain 180 days’
cash on hand by December 2027.
• Build a $70 million Rate Stabilization Reserve to
mitigate cost volatility.
• Strengthen financial controls across contracting, risk management and procurement.
2. Energy Portfolio Development
Provide sufficient, affordable and clean electricity
to our customers.
• Reach 100% renewable energy by 2035, with interim
goals of 75% by 2027 and 85% by 2030.
• Support development of 1 gigawatt of new local clean
energy capacity by 2035, including 300 MW of infill
and distributed energy resources (DERs).
• Ensure reliable and cost-effective compliance with all regulatory requirements.
• Create good-paying local jobs in clean energy sectors. 204
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Investment Plan 16
3. Community Program Delivery
Implement programs that reduce greenhouse gas
emissions, align energy supply and demand and benefit
our diverse communities.
• Deliver 150 MW of local DER capacity (of the 300 MW
total goal) by 2035 through programs like Solar Battery Savings.
• Launch all San Diego Regional Energy Network
(SDREN) programs by FY 2026–2027.
• Implement a robust program evaluation framework
by FY 2026–2027.
• Expand external funding for clean energy programs.
4. Legislative and Regulatory Advocacy
Advance policies that support Community Power’s
mission and customer goals.
• Educate policymakers and regulators to influence
outcomes consistent with our policy platform.
• Support and sponsor legislation aligned with our values and needs.
• Remain an active participant in coalitions such as
CalCCA to amplify our voice.
• Strategically pursue public funding aligned with
agency goals.
5. Trusted Brand Building
Build a trusted brand that supports engagement,
participation and program success.
• Position San Diego Community Power as a
collaborative public agency rooted in transparency.
• Grow the Power Network of nonprofit and community-based partners to expand community reach. • Elevate brand awareness through education
and outreach.
• Empower customers to take advantage of savings and
services through awareness, education and ongoing
communication programs.
6. Customer Care
Ensure high customer satisfaction and retention.
• Refine rate structures to balance affordability,
clean energy and fiscal prudence.
• Resolve SDG&E billing issues and improve
customer experience.
• Explore options for a best-in-class customer
service model.
• Address arrearages and connect customers with
available resources.
7. Organizational Excellence
Foster an innovative, inclusive and resilient workplace. • Transition into a learning organization by late 2026
with robust staff development.
• Maintain a high level of employee satisfaction through engagement and continuous feedback.
• Launch a new internship program for local college
students by FY 2027
FIGURE 7. CORE STRATEGIC GOALS
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY25–26 Capital Investment Plan 16 Fiscal Sustainability Energy Portfolio
Development
Community Program
Delivery
Trusted Brand Building Legislative and Regulatory
Advocacy Customer Care Organizational Excellence
1 4 5 6 7
2 3
205
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Community Engagement 17 v
Community
Engagement
05 206
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Community Engagement 18 Community Engagement Process
As a public agency with a deep commitment to transparency and community accountability, Community Power approaches outreach not as a one-time event, but as a continuous, year-round effort. Our financial planning, including the development of the Capital Investment Plan (CIP), is directly informed by ongoing engagement with customers, stakeholders and local leaders, ensuring our investments reflect the needs and priorities of the people we serve.
Community Power Plan (CPP)
A key milestone shaping Community Power’s customer
engagement and investment strategies is the Community
Power Plan (CPP), adopted by the Board of Directors on May 25, 2023. The CPP provides strategic direction for customer energy program development over a five-year time frame and is instrumental in guiding CIP investments.
As a not-for-profit public agency, Community Power is
committed to designing programs that are community-driven, with a particular focus on uplifting Communities of Concern. The CPP was built through extensive outreach and partnership building, helping Community Power strengthen ongoing relationships with residents, community-based
organizations and stakeholders across the region. Between May and November 2022, Community Power engaged more
than 3,450 community members through listening sessions, workshops, pop-up events and a customerwide survey —
prioritizing equity and reaching harder-to-engage populations.
The CPP’s foundational community needs assessment shaped both short-term priorities and a longer-term framework for program evaluation and design.
Rather than treating outreach and partnership building as a one-time effort, the CPP established a foundation for ongoing dialogue and partnership between Community Power and
the communities we serve — a commitment that continues
through the CIP and program design. This community-centered approach informs all areas of our work, including public meetings, partnerships with local organizations and targeted outreach efforts to ensure clean energy opportunities are accessible, equitable and responsive to community needs.
Public Meetings and Oversight
Core to our transparency is the public nature of our governance.
Per our Rate Development Policy, rate setting is conducted via a public process, developed by staff and approved by our Board of Directors — all through open meetings where the public is encouraged to participate. Our Board is publicly accountable to Community Power ratepayers and hosts monthly Board
meetings where it not only sets rates, but also establishes policy, determines power options and maintains fiscal oversight.
Similarly, our Board is informed by a subset of members on the Finance and Risk Management Committee (FRMC), and the
Community Advisory Committee (CAC) advises the Board and provides a venue for ongoing citizen support and engagement in Community Power. These monthly forums create meaningful opportunities for public input and serve as a foundation for budget and investment planning.
Community Engagement
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY25–26 207
Community Engagement 18
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Community Engagement 19 Customer Notices and Transparency Tools
We also ensure customers have access to clear, timely
information about their energy service. Our annual Joint Rate Comparison — published in coordination with SDG&E —
provides a side-by-side rate and service overview. The Power Content Label offers transparency into the energy sources we procure, reinforcing our commitment to cleaner energy.
Our website is another key transparency tool, offering
customers easy access to rate options, program details, meeting materials and more. Specifically, the bill comparison calculator offers customers an opportunity to evaluate
Community Power rates alongside those of SDG&E. As part of our continued commitment to improving the customer
experience, we are currently undertaking a website redesign to make resources easier to find, understand and apply.
Targeted Outreach and Engagement
Beyond formal governance, Community Power engages
directly with the communities we serve. We regularly present agency updates to our member cities’ elected bodies —
including updates in early 2025 — and actively participate in community events across the region.
In 2024 alone, Community Power participated in more than 151 community events, resulting in 18,539 unique public interactions through in-person engagement.
TABLE 4. COMMUNITY NEEDS ASSESSMENT
ENGAGEMENT
METHOD
Estimated
Number
Engaged
Community-Based Organization
Co-hosted Listening Sessions (2 Rounds)
325
Business, Key Stakeholders and Public
Listening Workshops
325
Unincorporated San Diego County
Pop-up Events
100
Community Needs Survey 2,980
Total 3,450
Our outreach efforts are bolstered by strategic partnerships and media initiatives, such as the ongoing “Working for Our Communities” campaign with CBS 8, helping extend our reach and impact.
Through quarterly newsletters, targeted sponsorships, social media campaigns and our new comprehensive customer
survey launched alongside our brand refresh, we continue to invite customers to shape Community Power’s path
forward. These efforts help maintain a strong feedback
loop, ensuring that our Capital Investment Plan and broader strategic initiatives reflect not only fiscal responsibility but also community vision, equity and shared clean energy goals. 208
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Community Engagement 20 Community Power is committed to making equity central to all outreach and investment planning. The Community Power Plan (CPP), adopted by the Board of Directors in 2023, was the foundation for many of the investments reflected in this Capital Investment Plan (CIP). As part of the CPP development process, Community Power prioritized meaningful and inclusive engagement with Communities of Concern to guide program and project priorities. This commitment continues to shape our work today.
To ensure authentic community participation, Community Power partnered with and compensated community-based organizations that work directly with underserved communities. The following engagement principles guided the development of the CPP and continue to inform our broader program and investment strategies.
Minimizing obstacles
Community Power designed outreach activities that met
people in their communities, building trust by minimizing barriers such as time commitments, technology access and transportation. Flexibility and adaptability remained priorities throughout the process.
Valuing community input
Local and lived experiences were central focuses during the engagement process. Community Power gathered insights on community goals, priorities and challenges to inform future program design and investment decisions.
Building partnerships
Community Power built strong relationships with community-based organizations across the region. These partnerships provided critical input on outreach strategies and deepened our understanding of the communities we serve.
Recognizing real-world challenges
Community Power recognized that urgent issues like rising utility bill costs, economic pressures and service insecurity often take precedence for households. Engagement efforts were designed to respect and reflect these lived realities while still advancing clean energy and sustainability goals.
Promoting accessibility
Outreach materials and activities were developed with
accessibility in mind, including considerations for language, technology access, physical ability and subject matter
familiarity. Materials were presented using clear, non-technical language.
Upholding language access
Community Power employed a language justice approach to ensure participants could fully engage in the languages they felt most comfortable using. Multilingual engagement and culturally relevant materials fostered greater inclusivity and trust throughout the planning process.
Prioritizing Equity and Communities of Concern
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY25–26 209
Community Engagement 20
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 21 v
Capital
Program Areas
06 210
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 22 Program Type Overview
The Community Power Plan (CPP) is the foundational
document that informs the Capital Program areas. Utilizing the input received during the CPP community needs
assessment and the other efforts conducted during the CPP development, strategies were developed for short-term,
medium-term and long-term programs.
Given the significant influence that timing of available funding imposes on program delivery, this five-year Plan approached programs using the following phases.
• Short-term (FY 2023–2024 – FY 2024–2025):
Program types that can be launched quickly with
available funding and/or with a manageable amount of
Community Power’s revenues to address immediate
needs identified in the community needs assessment.
• Medium-term (FY 2025–2026 – FY 2026–2027)
(current): Community Power has transitioned from
the short-term program strategy to the medium-term
program strategy as additional projects are funded by
one-time operating contributions. An overarching tenet
of the medium-term program strategy is the flexible
load program — a strategy that can be implemented
across a range of programs. The strategy outlines target end-use technologies, key points of integration with
existing/planned programs and a proposed software
architecture to drive device dispatch and control as well as a framework to guide dispatch and device operations.
The strategy is being designed to optimize customer
energy usage around time-of-use rate schedules and
customer preferences, directly reducing participants’
bills while decreasing major Community Power
cost drivers, such as energy and resource adequacy
procurement, which directly benefits all ratepayers.
The strategy also incorporates advanced analytics to
predict peak demand periods, allowing for proactive
adjustments to energy consumption that further
enhance cost savings for ratepayers. Additionally, by
promoting the adoption of renewable energy sources,
the strategy supports Community Power’s broader goals
of sustainability and reduced environmental impact.
• Long-term (FY 2027–2028+): Program types
that require more complex program design and
development, are dependent on Community Power
being more established and/or that support emerging
clean energy technologies.
The list of medium-term program types was selected due to their alignment with community and organizational goals.
Implementation of programs will largely be determined by funding considerations and other market developments.
Given that it is better to develop a small number of well-designed and impactful programs rather than trying to do everything, Community Power wants to be deliberate about which of the recommended program types to focus on, for which market sectors/customer types and in which order.
Capital Program Areas
Short-Term Program Types
(FY 2023–2024 – FY 2024–2025)
1. Energy Awareness and Education
2. Application Assistance
3. Disadvantaged Communities Green Tariff
4. Pilot Programs
5. Grant Programs
Medium-Term Program Types
FY 2025–2026 – FY 2026–2027)
1. Building Electrification:
Heat Pump Technology
2. Planning and Studies
3. Distributed Energy Resources:
Energy Storage Systems
4. Distributed Energy Resources:
Demand Response
5. Energy Efficiency
6. Transportation Electrification: Infrastructure
7. Transportation Electrification:
Light-Duty Vehicles
8. Transportation Electrification:
Medium- and Heavy-Duty Vehicles
9. Information Technology: Upgrades
211
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 23 Program Type 1. Energy Awareness and Education
Project Scope of Work Carry Forward FY26
Civic Spark Fellows Partnership with San Diego State University professor-led student cohorts to expand outreach for
key Community Power initiatives and programs while
providing workforce development opportunities
- $40,000
Equitable Building
Decarbonization
The Equitable Building Decarbonization Direct Install
Program (“EBD Program”) is a statewide initiative
that offers no-cost installation of electric appliances, energy efficiency measures, basic health and safety
improvements and electrical panel upgrades.
- $466,667
Total - $506,667
TABLE 2. ENERGY AWARENESS AND EDUCATION PROJECTS
Description
Community Power offers energy awareness and education
programs for its customers and workforce. Energy and
bill education programs teach customers about how to
understand their energy bill, how usage impacts costs, and the benefits of clean energy. Beyond energy bills and usage, educational efforts can provide customers with unbiased information about how to participate in the clean energy transition. For example, Community Power offers lists of qualified and vetted contractors and equipment installers from which to choose.
An educated workforce will be needed to support
the development, installation and operation of many
electrification technologies, especially with respect to building electrification programs. Providing education to contractors can ensure that workers are informed and knowledgeable
about the latest electrification technology to support broad adoption and acceptance.
Benefits
As a significant barrier cited in the CPP community
engagement process, building awareness about energy can support behavioral changes to promote energy efficiency and lower bills — a key issue for many community members.
Education can also lead to increased participation in rate-based programs (e.g., California Alternate Rates for Energy) that benefit Communities of Concern.
Many clean energy technologies face increased barriers
to adoption due to the lack of qualified contractors and equipment installers or lack of awareness in Communities of Concern. Education and awareness programs for contractors can help overcome these barriers and benefit customers.
Design Considerations
During the CPP community engagement process, many
expressed a lack of awareness about energy and the need for education, especially among Communities of Concern. Because many communities have a high level of distrust for government and utilities, partnering with trusted community-based
organizations on education programs can help increase access, build trust and deepen partnerships.
Education programs can also be paired with other program offerings to maximize awareness and participation.
Community Power may also consider contractor training
opportunities to support greater adoption of clean energy technologies, such as electric heat pumps, as contractor participation will be required to bring newer technologies to a broader market at scale.
Lastly, Community Power should consider partnering
with water agencies/authorities that offer water education programs to complement these programs and explain the
water-energy nexus.
212
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 24 Program Type 2. Application Assistance
Project Scope of Work Carry Forward FY26
Commercial Application
Assistance Program
Community Power's Commercial Application
Assistance Program is an initiative that aims to
support commercial customers in identifying ideal
energy solutions and programs that can help meet
the customer's needs and goals. The program aims
to help customers become aware of and apply for
publicly available and funded energy programs and,
if needed, to provide project management and
grant support.
- $250,000
Total - $250,000
TABLE 3. APPLICATION ASSISTANCE PROJECTS
Description
There are many existing energy programs that Community
Power customers may have access to through other local, state and federal agencies (i.e., third-party programs). SDG&E alone offers more than 80 energy efficiency and demand
response programs, though not all of them are relevant for each customer. The number of programs and the complexity of application processes can create barriers to access for many customers, including under-resourced community members
and small businesses/organizations that serve Communities of Concern; therefore, an opportunity exists for Community Power to assist with application processes for third-party programs.
Benefits
Funds are available from a variety of third-party programs that can currently help meet community needs. Since a lack of participation in existing programs was noted in the community needs survey, Community Power can help customers access the benefits of third-party programs to boost the success of the programs and help bring additional resources for a variety of energy measures to the San Diego region.
Design Considerations
Because there are many existing programs that each have their own intricacies, Community Power may consider working with partners to select a targeted list of program types to provide application assistance for, rather than trying to support all application types. Recommendations for program types to provide application assistance include energy efficiency, heat pump technology, transportation electrification infrastructure for income-qualified individuals and Communities of Concern and onsite solar and energy storage for Communities of
Concern. Examples of programs that align well with community needs could include SDG&E’s energy efficiency programs, like the Residential Energy Solutions program and Energy Savings Assistance program, the TECH Clean California program, the Self-Generation Incentive Program and the Disadvantaged Communities Single-family Affordable Solar Homes (DAC-SASH) program.
Application assistance can be a strategy to build partnerships with trusted community-based organizations and partners or other public agencies. While application assistance may be offered to all, outreach can be conducted in partnership with community-based organizations to target support for Communities of Concern.
213
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 25 Program Type 3. Disadvantaged Communities Green Tariff
Project Scope of Work Carry Forward FY26
CPUC Green Tariff To bring the benefits from local solar projects to those who may not be able to install solar on
their roofs and offer a 20% bill discount to eligible
residential customers in state-defined disadvantaged
communities
$166,747 $310,383
Total $166,747* $310,383
TABLE 4. DISADVANTAGED COMMUNITIES GREEN TARIFF PROJECTS Description
The Disadvantaged Communities Green Tariff (DAC-GT)
program provides the benefits of solar and provides a bill discount to income-qualified residential customers in under-resourced communities who have barriers to installing or are unable to install solar on their roof. Eligible communities are determined by the California Public Utilities Commission (CPUC)using the CalEnviroScreen tool, which identifies
“disadvantaged communities” as census tracts that are
disproportionately burdened by and vulnerable to multiple sources of pollution.
Benefits
The DAC-GT program is intended to further promote
the installation of renewable energy generation among
disadvantaged communities with a particular focus on low-income residents. The CPUC created the program to include a 20% bill discount so that low-income customers can
affordably access local renewable energy resources that they would not otherwise be able to access.
Design Considerations
As a CPUC program, many of the design elements of DAC-GT are already established and prescribed. Customers will be automatically enrolled in the program; therefore, some
participants may be unaware of the program, its benefits or their enrollment status. Additionally, participants may be skeptical and view the combination of benefits and bill savings as “too good to be true.” Partnering with trusted, local community-based organizations can help increase program awareness. Community Power has also named the program
Solar Advantage in customer-facing materials and will work to remove jargon so that participants understand the program and do not unsubscribe.
*$535,800 is the total carry forward amount through the agency but is subject to a true-up process with the CPUC in which the agency expects $166,747 in a resulting carry-forward amount.
214
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 26 Program Type 4. Pilot Programs
Project Scope of Work Carry Forward FY26
Customer Pilot Programs To test out program concepts and support implementation of high-impact projects that
Community Power may be able to scale with more
funding
$1,652,690 -
Clean Energy Asset
Feasibility Study
Community Power is undertaking a solar and
storage feasibility study, which will assess the
technical, economic and environmental viability
of integrating solar generation and/or energy
storage into Community Power's service territory.
The project will involve data collection and review,
technical analysis of potential solar locations and grid interconnection, economic modeling to assess costs
and savings, environmental impact assessment and
development of a preliminary implementation plan
with project size, timeline and cost estimates. The
final deliverables will include reports on technical
feasibility, economic analysis, environmental impact
and a preliminary implementation plan.
$200,300 -
Total $1,852,990 -
TABLE 5. PILOT PROGRAMS PROJECTS
Description
Pilot programs are small-scale, short-duration projects (6–18 months) that can provide Community Power and stakeholders data on program design, technology acceptance and other information helpful for broader program delivery. Pilot programs support Community Power staff's ability to properly and efficiently design and implement programs. Additionally, pilot programs can cover all customer segments (e.g., commercial residential) and a variety of technologies or activities (e.g., managed charging for electric vehicles, energy efficiency).
Benefits
Pilot programs broadly support the Program Department
goal to create a 150 MW Virtual Power Plant (VPP). The
VPP enables Community Power staff to reduce peak load
consumption via aggregated management of enrolled
behind-the-meter customer devices. Reducing peak load
consumption benefits all ratepayers by: 1) reducing demand when per-unit energy costs are the highest; and 2) reducing agency Resource Adequacy obligations and associated costs.
Pilot programs can provide a range of additional benefits, such as:
• Testing local acceptance of incentive projects that have successfully been implemented in other parts of the state or country
• Filling in gaps and facilitating bringing state funding into the region
• Demonstrating the efficacy of emerging technologies and/ or business models in the real world
• Evaluating innovative incentive delivery methods and
mechanisms
• Providing data on real-world scenarios, local project costs, barriers and opportunities
• Reducing risks of large-scale broad program delivery by providing lessons learned at a smaller scale
Design Considerations
Pilot programs can give Community Power the opportunity to flexibly invest defined amounts of internal resources to quickly learn about elements of a particular program before seeking significantly more investments for scaled programs. When developing pilot programs, Community Power will integrate opportunities to capture lessons learned throughout the process, whether that be through data capture, performance evaluation or ongoing stakeholder dialogue. Pilot programs can also provide the opportunity for Community Power to partner with, support and learn from community-based
organizations. Community Power will work with community-based organizations, where feasible, to design and implement pilot programs.
215
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 27 Program Type 5. Grant Programs
Project Scope of Work Carry Forward FY26
Member Agency Grants Grant programs to support both community organizations and its member agencies. Grants
focus on addressing the key priorities heard during
the community engagement process and provide
member agency grants to support regional climate
action goals.
$6,667 -
Community Grants To implement innovative program ideas from community-based organizations or specific clean
energy projects that help Community Power's
member agencies achieve their climate action goals
$662,421 $837,579
Total $669,088 $837,579
TABLE 6. GRANT PROGRAMS PROJECTS
Description
Grant programs allow Community Power to provide financial assistance to community-based organizations and member
agencies to implement clean energy projects or innovative program ideas. Grant programs require applicants to submit a proposal outlining their project or initiative and how it will meet the goals and objectives of the program.
Benefits
Grant programs can provide numerous benefits for
Community Power and the communities it serves, such as:
• Providing a source of funding to community-based
organizations and member agencies that may not have the resources to implement innovative projects.
• Encouraging and supporting creative ideas that may not be possible through traditional funding sources.
• Creating strong trust and relationship-building opportunities among Community Power, its member agencies and
community organizations.
• Increasing visibility of Community Power within the
communities it serves.
• Helping to achieve Community Power and member
agency sustainability goals by aligning grant programs with initiatives such as promoting clean energy, reducing carbon emissions and supporting local economic development.
• Exploring opportunities to develop the flex load strategy in areas of the community that may not otherwise have the
opportunity, which can optimize customer energy usage
around time-of-use rate schedules, and to directly reduce participant bills while decreasing costs for energy and resource adequacy procurement, which directly benefits all ratepayers.
Design Considerations
Community Power should consider creating grant programs to support both community organizations and its member
agencies. Community Power could provide community grants focused on addressing the key priorities identified during the community engagement process for this Plan and provide
member agency grants to support regional climate action goals. Community Power should consider partnering with
trusted and proven regional organizations to streamline grant program development and implementation while easing
administrative burden on staff.
216
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 28 Program Type 6. Building Electrification: Heat Pump Technology Project Scope of Work Carry Forward FY26
N/A N/A - -
Total - -
TABLE 7. BUILDING ELECTRIFICATION HEAT PUMP TECHNOLOGY PROJECTS Description
Heat pump technology programs encourage the installation of electric heat pumps for space heating, cooling and water heating in buildings.
Benefits
Conversion to heat pump technology supports buildings that are more efficient, cleaner, healthier and safer. Heat pump technology is more efficient than its natural gas counterparts and avoids the onsite use of natural gas, which is responsible for most building emissions and can cause negative health impacts due to indoor air pollution. Unlike traditional heating systems, heat pump technology can provide space heating and cooling from the same system, which can lower costs compared with installing separate systems. Heat pump
technology can especially benefit older homes because it can introduce incredibly efficient cooling capacity that has not typically existed previously in the home — a critical service for many residents in a changing and warmer climate. Switching to a heat pump water heater removes an additional source of pollution especially when it is located inside the home and can efficiently heat water.
To enable the installation of heat pump technology, electrical panel upgrades may be needed for buildings that have
outdated or constrained electrical panels. While panel
upgrades do not have direct environmental or health benefits, outdated panels are a barrier to electrification for many projects, as their cost can significantly increase project costs that may not be covered in other incentive programs.
Design Considerations
Community Power should consider supporting electrical
panel upgrades in addition to the installation of heat pump technology. Community Power, like other CCAs, should also consider smart control requirements to enable demand
response functionality because heat pump technology can be controlled to optimize its usage to save energy and lower costs.
To support income-qualified customers and owners of
multi-family affordable housing, who may have challenges accessing up-front capital and have limited capacity to research and implement projects, Community Power should consider direct installation programs. These customers often have limited cash flow and complex ownership structures that make it difficult to access capital through loans, which can result in maintenance backlogs that would need to be addressed before energy retrofits can be undertaken. As a result, they may not implement clean energy programs
without significant financial support and technical assistance.
Community Power should consider that residents of multi-family affordable housing may be overburdened by rent and utility costs and may be displaced if housing costs increase because of electrification.
Given the vulnerability of the occupants, programs should also include protections for renters. This may require Community Power to work closely with local housing departments or other agencies to ensure that Communities of Concern are supported in the transition.
One common barrier during program design is the lack of skilled labor and equipment being carried by contractors.
When older systems fail and need to be replaced, residential building owners generally cannot wait for contractors
to order new equipment. Direct installation programs
targeting efficiency and weatherization have traditionally leveraged entry-level skills, whereas the installation of heat pump technology requires more skilled labor, including
electricians, heating and ventilation technicians, and plumbers.
Community Power should consider providing contractor
training and mid-stream incentives to enable contractors to know how to install heat pumps correctly, have heat pumps on hand and offer competitive pricing.
217
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 29 Program Type 7. Planning & Studies
Project Scope of Work Carry Forward FY26
Building and Housing
Stock Analysis
Develop resources on existing building stock to
inform program design
$52,000 -
Local Development
Feasibility Study
Developing local infill planning, including receiving
feedback and guidance from Community Power
Board, Community Advisory Committee and other
stakeholders to confirm needs and goals, visiting
with member agencies to evaluate potential sites and
opportunities, and reviewing scope and schedule
$37,500 $37,500
Building and Housing
Stock Analysis
Develop resources on existing building stock to
inform program design
$52,000 -
Program Evaluation TBD $250,000
Total $52,000 $287,500
TABLE 8. PLANNING & STUDIES PROJECTS
Description
Program Department Planning and Studies are research
activities typically resulting in a report or study that will inform future Program Department activity.
Benefits
Program Planning and Studies can provide a range of benefits, such as:
• Determining feasibility of future pilots and programs that could promote the agency’s flexible load strategy and goals to reduce peak load consumption. Reducing peak load
consumption benefits all ratepayers by: 1) reducing demand when per unit energy costs are the highest and 2) reducing agency Resource Adequacy obligations and associated costs. • Enabling Community Power staff to reduce peak load
consumption via aggregated management of enrolled
behind-the-meter customer battery systems.
• Providing valuable data sets used to evaluate or design future pilots and programs.
• Evaluating Program Department pilots and projects.
• Generally informing future Program Department activities.
Design Considerations
Program Department planning and studies should be done in consultation and collaboration with industry, community-based organizations, academia and other public agencies,
as appropriate.
218
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 30 Program Type 8. Distributed Energy Resources:
Energy Storage Systems
Project Scope of Work Carry Forward FY26
Residential Solar Battery
Savings Program
Community Power's Residential Solar Battery
Savings Program is designed to help single-family
homeowners in Community Power's service territory
invest in clean energy and support the grid by
installing solar and battery storage in their homes
or complement an existing solar system with a new
battery system. The program provides two financial
incentives for participating customers: an upfront
incentive to minimize the initial cost of the battery
system and a performance incentive for a daily
discharge of the battery (during a specified dispatch
window during on-peak periods) to maximize
benefits for the customer and the grid.
$2,697,382 $18,750,000
Total $2,697,382 $18,750,000
TABLE 9. DISTRIBUTED ENERGY RESOURCES: ENERGY STORAGE SYSTEMS PROJECTS Description
Energy storage system programs support the installation of onsite energy storage systems to be paired with renewable energy resources (e.g., onsite solar).
Benefits
While the amount of solar-generated electricity available on the grid has increased dramatically in California, it is not being sufficiently captured during times of high production so that it can be used to meet needs when renewable energy resources are not available. This causes an imbalance — too much
energy on the grid at some times and not enough at others, requiring fossil fuel-based sources of electricity to make up the difference. Increasing the amount of energy storage that is paired with renewable energy generation helps make the electric grid cleaner.
Energy storage can help to increase the resilience of the grid by balancing supply and demand and can also be used for backup power during outages or emergencies. This can be especially beneficial for critical facilities, community resilience hubs and customers who need to have power permanently
available for medical devices, safety or emergency response.
The Solar Battery Savings program enables Community
Power staff to reduce peak load consumption via aggregated management of enrolled behind-the-meter customer
battery systems. Reducing peak load consumption benefits all ratepayers by: 1) reducing demand when energy costs are the highest; and 2) reducing agency Resource Adequacy obligations and associated costs.
Design Considerations
Multiple program pathways exist to support energy storage market development, depending on the level of resources available. For example, Community Power could work with local governments or others to implement energy storage systems at scale in critical facilities or community resilience hubs in ways that enable bulk purchasing of batteries and controls, including microgrids. Community Power may also provide technical
support to customers to enable comprehensive energy retrofits, including energy storage systems.
219
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 31 Program Type 9. Distributed Energy Resources: Demand Response Project Scope of Work Carry Forward FY26
Distributed Energy
Resources Management
Systems Software
Platform
Central to Community Power's Flexible Load
Strategy is the selection and implementation of a
Distributed Energy Resource Management System
(DERMS). A DERMS is a software platform that
incorporates various data points, such as weather,
market/price data and customer preferences,
to optimize the operation of distributed energy
resources (DERs) in support of various grid services.
Once operational, this system will allow Community
Power to help customers reduce usage during high-cost on-peak periods, while managing portfolio-wide power procurement and resource adequacy costs
and risk.
$158,321 $300,000
Total $158,321 $300,000
TABLE 10. DISTRIBUTED ENERGY RESOURCES: DEMAND RESPONSE PROJECTS Description
Demand response programs incentivize customers to reduce their electricity use when energy demand on the grid is at its peak. These types of programs can encourage behavioral changes to shift or reduce usage or can leverage smart devices to automatically take the desired action.
Benefits
Decarbonizing buildings requires more than just reducing the amount of energy used; it also requires changing the time when energy is used to maximize the use of renewable energy and minimize peak demand when the grid requires larger fossil-fuel generation to come online. Demand response technologies enable this shift in energy use timing, helping customers control costs and making the best use of renewable energy when it is available. Additionally, demand response technologies can enable buildings to help increase overall grid resiliency by helping operators shift loads during peak times, reducing the likelihood of power outages during extreme heat events.
The DERMS platform enables Community Power staff to
reduce peak load consumption via aggregated management of enrolled customer devices. Reducing peak load consumption benefits all ratepayers by: 1) reducing demand when per unit energy costs are the highest; and 2) reducing agency Resource Adequacy obligations and associated costs.
Design Considerations
A gap exists around support for installation of smart controls on other systems, such as heat pump technology, electric vehicle chargers and energy storage systems. Many CCAs require or encourage the equipment they incentivize to have demand response capabilities. Community Power should require that incentivized equipment be grid interactive. By establishing technology requirements across other programs, Community Power could provide the most future-proofing and flexibility to enable customers to participate in demand response programs. 220
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 32 Program Type 10. Energy Efficiency
Project Scope of Work Carry Forward FY26
Regional Energy Network The San Diego Regional Energy Network (SDREN) is an initiative of Community Power, in partnership
with the County of San Diego, to offer a portfolio of
energy efficiency programs to residents, businesses
and public agencies throughout San Diego County.
The 10 SDREN programs will be managed by
Community Power staff and all activities will be
cost recoverable through CPUC funds. SDREN is
approved by the CPUC. Program implementation for
Phase 1 and Phase 2 is set to begin in Q4 2025.
$357,250 $31,845,256
CDFA Healthy
Refrigeration Grant
The program funds energy efficient refrigeration
units in corner stores, small businesses and food
donation programs in low-income or low-access
areas in the state to stock California-grown fresh
produce, nuts, dairy, meat, eggs and minimally
processed and culturally appropriate foods. The
purpose of the program is to improve access to
healthy foods in underserved communities, while
promoting California-grown agriculture.
$532,499 -
Total $889,749 $31,845,256
TABLE 11. ENERGY EFFICIENCY PROJECTS
Description
Energy efficiency programs promote a wide range of strategies that can reduce the amount of energy buildings use.
Benefits
Energy efficiency is a critical decarbonization strategy with multiple co-benefits: reduced energy demand, reduced customer energy bills, increased indoor air quality and increased indoor comfort. Weatherization efforts, including insulation, improved windows and doors and cool roofs can help keep indoor environments safe and comfortable longer when power outages occur — and less energy demand means customers can install smaller renewable energy generating systems (e.g., onsite solar), which leads to lower installation costs.
Design Considerations
With SDG&E offering a multi-year energy efficiency program portfolio, Community Power should develop complementary programs that fill gaps and avoid duplication. Community Power should consider opportunities to provide free or low-cost energy efficiency upgrades for income-qualified customers and residents in Communities of Concern to be responsive to community priorities. Energy efficiency programs for multi-family buildings can help fill a gap, as these buildings often have complex ownership structures and other barriers that make it difficult to access traditional programs; this is especially notable for affordable multi-family housing.
Community Power should consider that residents of inefficient buildings may be overburdened by rent and utility costs and may end up displaced if housing costs increase because of energy efficiency upgrades.
Given the vulnerability of the occupants and the importance of keeping people housed, energy efficiency programs should include protections for renters. This may require Community Power to work closely with local housing departments or other agencies. While challenging, these considerations can help support Communities of Concern.
221
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 33 Program Type 11. Transportation Electrification: Infrastructure TABLE 12. TRANSPORTATION ELECTRIFICATION: INFRASTRUCTURE PROJECTS Description
Transportation electrification infrastructure programs support the deployment of electric vehicle (EV) charging stations and related technologies (e.g., Vehicle-to-Grid) to enable light-, medium- and heavy-duty vehicle transportation electrification.
Benefits
Expansion of the EV charging network is needed to support customers switching from fossil fuel-powered cars, which are associated with both carbon emissions and local air pollution.
Increasing access to charging infrastructure can increase customer confidence to make the transition to EVs, especially for residents of multi-family buildings and in rural areas, as noted during the community needs assessment.
Design Considerations
Community Power should focus transportation electrification infrastructure programs on locations where the private sector is not currently prioritizing development (i.e., geographical areas or market sectors). Gaps in access to EV charging infrastructure could be filled through strategies such as direct installation of equipment for multi-family buildings located in Communities of Concern. In some cases, Community Power
should provide additional funding to residents to stack on existing funding from incentive programs for all applicants or some sectors (e.g., Communities of Concern). In light of significant funding becoming available for public charging infrastructure, Community Power should partner with member agencies to expand public access to charging infrastructure in locations underserved by public charging and/or that could serve residents of multi-family buildings. Creative approaches for deploying charging infrastructure on member agency-owned land could create benefits (e.g., lower charging costs and more charging locations) relative to charging infrastructure on commercial properties. Community Power also should consider offering technical assistance and incentives for commercial charging infrastructure to support the transition of medium-and heavy-duty vehicles to electric.
Funding Considerations
Significant focus has been placed on transportation
electrification by state and federal agencies, creating many opportunities for Community Power to seek external
infrastructure incentive programs. The California Public Utilities Commission’s Locally Invested Transportation Equity funding offers a chance to test innovative program designs with a focus on community partnerships. The California
Energy Commission is expected to provide additional
opportunities for creative incentive design and delivery through future Vehicle-to-Grid funding and the Electric Program Investment Charge program.
Community Power should continue to collaborate with the San Diego Association of Governments and San Diego County Air Pollution Control District through the regional Accelerate to Zero Emissions Collaboration and in their efforts to incentivize charging infrastructure. Lastly, Community Power can support member agencies in their efforts to seek funding through opportunities such as the Clean Mobility Options program.
Project Scope of Work Carry Forward FY26
N/A N/A - -
Total - -
222
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 34 Program Type 12. Transportation Electrification: Light-Duty Vehicles TABLE 13. TRANSPORTATION ELECTRIFICATION: LIGHT-DUTY VEHICLES PROJECTS Description
Light-duty vehicle electrification programs support customers in the transition from fossil fuel-powered cars to EVs.
Examples of light-duty vehicles include sedans, sport utility vehicles and pickup trucks.
Benefits
The switch from fossil-fuel powered cars toward EVs has the dual benefit of locally reducing carbon emissions and air pollution. Compared to light-duty fossil-fuel cars, light-duty EVs are easier to maintain and have an overall lower lifetime cost of operation. With the right rate structures and technology, EVs also present the opportunity to serve as energy storage systems and help with grid resiliency.
Design Considerations
Community Power should prioritize expanding access to EVs for income-qualified customers, such as offering incentives for used EVs to increase affordability. Previously leased EVs can be good options for used EVs if they are in good condition. Community Power should consider partnering with car dealerships to offer point-of-sale incentives on used EVs.
Community Power should avoid providing after-sale rebates because these require customers to have the upfront capital and ability to wait for a rebate. It should be noted that point-of-sale incentives can be more challenging to implement and Community Power will need to do additional work to support this type of delivery mechanism.
In addition, Community Power should focus on ways to reduce other barriers to EV adoption, such as providing favorable financing options. EV programs can be paired with support for charging infrastructure in Communities of Concern. Lastly, Community Power should consider designing programs that reduce other barriers to EV adoption by providing point-of-sale incentives or other types of up-front assistance instead of after-sale rebates. Community Power should also consider how best to fill in the gap of financing options for income-qualified customers.
Funding Considerations
Internal revenues may be required to create incentives to supplement available State funding for EV adoption (i.e., Clean Vehicle Rebate Project and Clean Vehicle Assistance Program) or the future regional vehicle-scrap program
(i.e., Clean Cars 4 All). As with transportation electrification infrastructure programs, the regional Accelerate to Zero Emissions Collaboration initiative will be involved in all aspects of bringing funding to the region — both for Community Power to potentially access for self-administered programs and for its customers to access via third-party programs.
Project Scope of Work Carry Forward FY26
N/A N/A - -
Total - -
223
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 35 Program Type 13. Transportation Electrification:
Medium- and Heavy-Duty Vehicles
TABLE 14. TRANSPORTATION ELECTRIFICATION: MEDIUM- AND HEAVY-DUTY VEHICLES PROJECTS Description
Medium- and heavy-duty vehicle electrification programs encourage the transition away from fossil fuel-powered
commercial vehicles and toward electric alternatives.
Examples of medium- and heavy-duty vehicles include
delivery and shuttle vans (Class 2–6), diesel shipping trucks (Class 7–8), school and transit buses, transport refrigeration trucks, drayage trucks and forklifts.
Benefits
The electrification of medium- and heavy-duty vehicles
reduces carbon emissions and local air pollution. Air pollution tends to be high around ports and logistics corridors, where heavy commercial vehicles regularly travel and often spend time idling. These places are also where large portions of Communities of Concern can be found, leading to
disproportionate impacts on the health of these communities.
Transitioning these vehicles has the added benefit of reducing noise pollution.
Design Considerations
Community Power should analyze which fleets of medium- and heavy-duty vehicles have the highest impact on Communities of Concern. The Port of San Diego is a clear partner given its location, business operations and recent policy direction in the Maritime Clean Air Strategy. Working with transit agencies, school districts and public agencies, SDCP can support the transition of fleets that serve the public to create the co-benefit of exposing more of the public to electric transportation.
Community Power should also create medium- and heavy-duty vehicle electrification programs targeting businesses that operate their fleets primarily in Communities of Concern.
While some medium-duty EV types are now cost competitive, others are far more expensive and will require more support and resources to transition. In addition, because medium- and heavy-duty vehicles vary in the distance they can travel on each charge, Community Power should work with commercial customers to determine which vehicle options would work well based on their specific need, travel patterns and markets served. Community Power also needs to consider the need for appropriate charging infrastructure to support the conversion.
Funding Considerations
Community Power should consider working with customers
to implement innovative business models that lower the cost of EVs. It should also consider leveraging internal funding to capture new funding opportunities and maximize impact.
Project Scope of Work Carry Forward FY26
N/A N/A - -
Total - -
224
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 36 Program Type 14. Information Technology: Upgrades
Project Scope of Work Carry Forward FY26
Customer Relationship
Management Setup
The Customer Relationship Management project will
establish a centralized system to enhance service
delivery and community engagement, with a focus
on energy management and customer support. This
initiative, excluding confidential security work, will
streamline operations across Community Power’s
service area and reduce long-term costs.
$750,000 -
Contact Center
Enhancements
Community Power is exploring initiatives to enhance
customer service operations to improve services
responsiveness and increase customer satisfaction.
$200,000 -
Enterprise Data Platform Community Power is set to establish a centralized data infrastructure to improve data access and
analytics for staff, aiming to enhance control and
reduce costs. The project encompasses capital
investment, staff training, data migration and
cybersecurity enhancements. Deliverables include
a functional data platform, trained personnel and
detailed progress reports. The initiative will proceed
through planning and implementation phases,
excluding confidential security-sensitive details.
$850,000 -
Amazon Web Services
Infrastructure and
Security Layer
Community Power will develop an Amazon Web
Services Infrastructure and Security Layer to ensure
robust, scalable cloud services with enhanced
security for customer data. This project will provide
a reliable and secure foundation for all Community
Power digital services, improving customer trust and
service efficiency.
$250,000 -
Energy Trading Risk
Management and
Portfolio Analytics
Implementation
Community Power has licensed and will be
deploying an Energy Trading Risk Management
(ETRM) system to help manage its power portfolio
and financial and budget processes. This system will
support various activities such as recording trades,
monitoring positions, assessing value, generating
reports, managing risks, processing settlements and
integrating with the budget. The system is designed
to manage diverse power agreements and contracts,
ensuring comprehensive coverage of Community
Power’s energy dealings.
$162,843 $567,157
TABLE 15. INFORMATION TECHNOLOGY UPGRADES PROJECTS
225
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Capital Program Areas 37 Description
Information Technology Upgrades programs are designed
to modernize and enhance the digital infrastructure of
organizations, improving efficiency, security and the ability to adapt to new technological advancements.
Benefits
The advancement of Information Technology (IT)
Upgrades significantly enhances operational efficiency
and cybersecurity. In areas with high concentrations
of technological activity, outdated systems can lead to increased vulnerabilities and inefficiencies. Upgrading these systems not only fortifies the security and enhances the performance of various sectors, but also promotes a more dependable and sophisticated technological framework.
Moreover, the transition to modern IT infrastructure aids in minimizing electronic waste through the adoption of
energy-efficient and long-lasting equipment, contributing to environmental sustainability and public health benefits.
Design Considerations
Our organization is committed to creating a world-class IT and data ecosystem with the mission of harnessing the power of data to drive sustainable energy solutions that benefit local communities while making a global impact. By ensuring the integrity, accessibility and security of our data, we empower decision-makers with actionable insights. Projects are selected to construct and manage robust data repositories, interactive dashboards and comprehensive visualizations to monitor
objective key results.
Community Power receives a vast amount of data from its vendors and partners, including SDG&E and Calpine (our
back-office provider). To best utilize this data to effectively run our operations, make data-driven decisions and optimize the customer experience, the Information Technology: Upgrades program type develops and expands the data analytics
platform comprising a set of analytical tools built on a cloud-based platform that helps with customer management, load forecasting, rate design, program marketing and accounting.
Enterprise Resource
Planning (ERP)
The Enterprise Resource Planning (ERP) project
aims to implement an ERP system for Community
Power to streamline budgeting, enhance reporting,
manage procurement and contracts and improve
overall operational efficiency. The major deliverables
of the ERP project include a fully implemented and
functional ERP system; system documentation
including configuration details, user manuals and
training materials; trained staff capable of effectively using the ERP system; and a post-implementation
review report.
$83,333 $916,667
Total $2,296,177 $1,483,823
226
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Funding Guide 38 v
Funding
Guide
07 227
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Funding Guide 39 San Diego Community Power can fund programs in two main ways — through its own internal revenues or by applying for external funding. Funding programs with internal revenues would provide the greatest amount of flexibility for Community Power to design programs in ways that specifically meet community needs; however, as a newer organization, Community Power must also balance building a strong financial foundation, meeting reserve targets, customer affordability and other organizational priorities. In the short term, the amount of revenue that Community Power can direct to customers in the form of programs will be limited, but this amount is expected to grow over time.
Furthermore, internal funding allows maximum flexibility in the planning phase of designing programs and projects, whereby the agency can focus on designing based on community and agency needs rather than the requirements of a funding agency.
The planning phase of a program or project also requires less funding when compared with implementation or design and construction.
To maximize impact while building reserve funds, Community Power will need to pursue external funding from sources such as state and federal agencies. External funding takes more work to apply for and administer and is less flexible than internal revenues, but the total dollar amounts from external sources can be much higher. The main sources of external funding include the California Public Utilities Commission and California Energy Commission as well as other state and federal agencies.
Internal versus External Funding
Funding Guide
When considering funding for administering programs,
Community Power must evaluate using internal revenues
and applying for external funding, which both have impacts that need to be thoroughly considered. Investing internal revenues into programs would be done over other potential organizational priorities. That said, investing revenues back into the community through programs provides arguably
the most equitable distribution of revenues to customers and undoubtedly provides the highest level of certainty and flexibility for Community Power to administer programs.
External funding typically uses a competitive bid process, requiring additional resources for application writing and grant tracking and creating risk for long-term program
planning due to the uncertainty of grant awards.
Additionally, many of the potentially cumbersome
administrative elements of external funding (e.g., reporting, program design and timelines) can be less burdensome when funding programs with internal revenues. This flexibility is particularly important when considering Community Power’s equity commitments because external funding sources may have requirements that can make it difficult to effectively deliver programs to customers in Communities of Concern.
Research across the CCA landscape shows a variety of
different approaches when considering program funding
sources. Some CCAs aggressively spend their own revenues on programs with little use of outside funds due to the administrative burden and complexity associated with
external funds, among other reasons. Others spend a
relatively limited amount of revenues on programs, instead relying almost solely on external funding sources. As a young organization, Community Power should prioritize finding a middle ground between these two options and adjust its strategy as the organization matures.
In the short term, Community Power has committed to
building financial reserves of $575.8 million (180-days cash on hand based on its FY 2024-2025 amended budget),
because one of the organization’s strategic goals is to obtain a credit rating. This attention to building a strong financial position is important to enable Community Power to
effectively meet the long-term needs of the community. As reserve targets are met, the ability of Community Power to invest revenues back into communities through programs
will increase.
Meeting financial reserve targets will give Community Power the ability to offer programs with larger budgets and provide financial incentives using internal revenues. Additionally, internal revenues can support increased external funding; for example, by developing pilot programs that can be expanded with external resources, or by supplementing external funding with additional funds to support full project needs. Doing so can make Community Power’s internal dollars go farther. 228
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Funding Guide 40 External Sources
Community Power can apply for funds from a variety of sources to supplement its own investments in programs. These external sources vary in the level of funding resources they provide, the complexity of the application process and the flexibility they offer in how funds are distributed.
New funding opportunities will become available as the budget is allocated through state legislation. Community Power will monitor funding opportunities that are a good fit to pursue, based on community and organizational priorities, and apply for them in the short term, while understanding that funding may not become available until beyond the short term. For some external funding opportunities, Community Power may be able to partner with other regional agencies and partners to share the administrative burden.
Community Power should explore the viability of capturing funding from the sources below.
Funding Guide
Funding Source Description
Community Power
Operating Transfers
Through the annual budget process, the Community Power Board may approve an appropriation of funds to be out of the operating budget and transferred into the CIP. These funds will remain in a Community Power continuing fund to be used across multiple fiscal years, given that CIP projects generally last longer than one year.
CPUC Apply to Administer
(ATA)
Community Power could offer energy efficiency programs that do not duplicate SDG&E’s current offerings with all programs required to meet strict cost-effectiveness tests. Cost-effectiveness requirements can limit program offerings to residential customers and especially to customers in Communities of Concern.
CPUC DAC-GT The Disadvantaged Communities Green Tariff (DAC-GT) program enables income-qualified residential customers in DACs who may be unable to install solar panels on their roof to benefit from utility-scale clean energy and receive a 20% bill discount. Funding originates from state Greenhouse Gas (GHG) Auction Proceeds and Public Purpose Program funds.
CPUC Regional Energy
Network (REN)
Public Purpose Program Surcharge funds are available for Regional Energy Networks (RENs). The San Diego Regional Energy Network (SDREN) is an initiative of Community Power, in partnership with the County of San Diego, to offer a portfolio of energy efficiency programs to residents, businesses and public agencies throughout San Diego County. The 10 SDREN programs will be managed by Community Power staff and all activities will be cost recoverable through CPUC funds.
SDREN is approved by the CPUC. Program implementation for Phase 1 and Phase 2 is set to begin in Q4 2025.
CEC Demand Side Grid
Support Program
The Demand Side Grid Support Program is currently under development and will ultimately offer incentives to electricity customers who provide load reduction and back-up power generation to support the state’s electric grid during extreme heat events.
Community Power
Revenue Bond
Section 3.2.8 of the JPA states that Community Power at the discretion of the Board may issue revenue bonds and other forms of indebtedness. Upon receipt of an investment-grade credit rating, Community Power may have the ability to issue debt, such as a revenue bond, given that Community Power can demonstrate the ability to meet potential debt payment obligations through the credit rating. Under the Community Power Debt Policy, Community Power may issue a revenue bond in the next five years up to approximately $700 million that will be guided by planning and pilot projects and programs and that will require Board authorization.
TABLE 16. COMMUNITY POWER FUNDING GUIDE
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SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Funding Guide 41 CEC Electric Program
Investment Charge (EPIC)
The CEC’s Electric Program Investment Charge (EPIC) program is a consistent funding opportunity to advance new and innovative clean energy solutions. The EPIC program invests $130 million annually in a variety of technology research. The CEC has awarded EPIC funding to CCAs for various projects. Most notably, Sonoma Clean Power received a $5 million EPIC grant in 2018 to support its Advanced Energy Center and associated energy-efficiency programs.
CEC Vehicle-to-Building/
Grid Integration (V2B or
V2G)
The CEC is a potential source of funding for Vehicle-to-Building/Grid Integration (V2B or V2G) pilots that will become more valuable to Community Power in the future, from both a customer program perspective and potentially from an energy procurement perspective.
CDFA Healthy
Refrigeration Grant
The California Department of Food and Agriculture (CDFA) awarded Community Power funding to support Community Power in providing technical assistance and refrigeration units to stock healthy foods in stores throughout Community Power’s service territory.
Equitable Decarbonization
Program
The Equitable Building Decarbonization (“EBD”) Direct Install (“DI”) Program is a Statewide initiative to accelerate large-scale residential building decarbonization efforts in a just and equitable transition for single-family homes, multifamily properties, manufactured housing and public housing in under-resourced communities in Community Focus Areas.
EPA Greenhouse Gas
Reduction Fund
The Inflation Reduction Act (IRA) established the federal Environmental Protection Agency’s Greenhouse Gas Reduction Fund to provide competitive grants for mobilizing financing and private capital for clean energy projects. The Greenhouse Gas Reduction Fund emphasizes projects that benefit low-income and disadvantaged communities. In 2024, the EPA announced $27 billion awarded in competitive grants and financial and technical assistance to enable communities to deploy or benefit from zero-emission technologies.
Other Federal Funds Community Power is eligible to pursue forms of funding not available to for-profit entities such as traditional investor-owned utilities. Several funding opportunities are now clear to Community Power, and more may arise as details continue to emerge during program development.
CEC Demand Side Grid
Support Program
The Demand Side Grid Support Program is currently under development and will ultimately offer incentives to electric customers that provide load reduction and back-up power generation to support the State’s electrical grid during extreme heat events. 230
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Budget Resolution 42 v
Budget
Resolution
08 231
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Budget Resolution 43 Budget Resolution Pending
232
v
Acknowledgments
09 233
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Acknowledgments 45 Finance Department
The San Diego Community Power (Community Power) Finance Department works to maintain a fiscally responsible budget in accordance with Community Power Budget Policy. The department ensures sufficient funding to meet procurement needs, sustain operational needs and support sustained growth while delivering clean energy to the communities we serve. In addition, the team actively works to build Community Power reserves and develop policies that consider future economic conditions, provides an understandable and transparent operating budget for internal and external users, strives to keep the Community Power Board and staff informed of Community Power’s fiscal condition and develops a budget that will ultimately prioritize people, transparency and our communities.
Acknowledgments
Board of Directors
Mayor Paloma Aguirre, Chair
Supervisor Terra Lawson-Remer, Vice Chair
Councilmember Sean Elo-Rivera, Director
Councilmember Marco San Antonio, Director
Councilmember Michael Inzunza, Director
Councilmember Genevieve Suzuki, Director
Councilmember Ditas Yamane, Director
Finance and Risk Management Committee
Councilmember Ditas Yamane, Chair
Councilmember Genevieve Suzuki, Vice Chair
Councilmember Michael Inzunza, Director
Community Advisory Committee
CHULA VISTA
• Anthony Sclafani
• (Vacant)
COUNTY OF SAN DIEGO
• Peter Andersen
• Ross Pike
ENCINITAS
• Gary L. Jahns
• Tara Hammond
IMPERIAL BEACH
• Ilian Sandoval
• Kenneth Hoyt
LA MESA
• David Harris
• Shaun Sumner
NATIONAL CITY
• Aida Castañeda, Secretary
• Larry Emerson, Vice Chair
SAN DIEGO
• Luis Montero-Adams
• Matthew Vasilakis, Chair
Community Power Executive Team
Karin Burns, Chief Executive Officer
Eric Washington, Chief Financial Officer and
Deputy Chief Executive Officer/Treasurer
Jack Clark, Chief Operating Officer
Veera Tyagi, General Counsel
Byron Vosburg, Chief Commercial Officer
Finance Department
Eric Washington, Chief Financial Officer and
Deputy Chief Executive Officer/Treasurer
Tim Manglicmot, Director of Finance
Christopher Stephens, Procurement Manager
Diana Gonzalez, Risk Manager
Mark Alfaro, Finance Manager
Jeb Spengler, Strategic Finance Manager
Christopher Do, Senior Financial Analyst
Julissa Mercedes, Financial Analyst
Kevin Bateman, Financial Analyst
234
SAN DIEGO COMMUNITY POWER
Staff Report – Item 12
TO: Board of Directors
FROM: Kenny Key, Director of Power Contracts
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Approve Amended and Restated Renewable Power Purchase Agreement with Pelicans Jaw Solar, LLC
DATE: May 22, 2025
RECOMMENDATION:
Approve the proposed Second Amended and Restated Power Purchase Agreement (“A&R PPA”) with Pelicans Jaw Solar, LLC to modify the Commercial Operation Date (“COD”), adjust pricing based on COD, and make additional minor amendments, and authorize the Chief Executive Officer to execute the agreement.
BACKGROUND:
As San Diego Community Power (Community Power) strives to meet its environmental, financial, and regulatory compliance goals and requirements, long-term power purchase agreements (PPAs) of at least ten years in duration are 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 Community Power 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 Community Power can build its power supply portfolio while also providing power supply cost certainty around which Community Power can develop its pro forma financial model.
Moreover, the California Renewable Portfolio Standard (RPS), as modified in 2015 by Senate Bill 350, requires that Community Power provide 65% of its RPS-required renewable energy from contracts of at least ten years in length. 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. Further, as adopted March 23, 2023, Community Power has established a procurement target of 100% renewable by 2035. 235 83
In January 2024 Community Power Board of Directors approved a PPA for the Pelicans Jaw project. That PPA originated from a request for proposals Community Power issued in early 2023. Community Power engaged with SB Energy (“SBE”) on the Pelicans Jaw project under development by Pelicans Jaw Solar, LLC, a subsidiary of SBE after short-listing. The original PPA, approved in January 2024, was for capacity and renewable energy benefits from a portion of the Pelicans Jaw project, representing 226 MW of solar generation and 118 MW (472 MWh) of storage capacity.
After the original PPA was executed by the parties, staff were informed that additional volumes of solar and storage capacity could be available from the project. In April 2024, the Community Power Board of Directors approved the first amended and restated power purchase agreement to increase the volumes from 226 MW of solar generation to 440 MW and to increase the storage capacity from 118 MW to 238.5 MW.
SBE and Community Power began discussing this A&R PPA in late 2024. In 2025, SBE engaged with Community Power on moving the contractual commercial operation date to an earlier date in 2026 since the project now expects to be online in 2026.
ANALYSIS AND DISCUSSION:
Staff negotiated the attached A&R PPA for the purchase of renewable energy and capacity attributes from a 440 MW solar photovoltaic electricity generating facility, along with a 238.5 MWAC 4-hour (954 MWh) battery energy storage facility in Kern County.
Renewable energy produced by the facility will provide approximately 1,200,000 MWh annually of long-term renewable energy deliveries for Community Power’s power supply.
Further, while Community Power is increasing efforts to target and encourage local project development for Community Power’s generation portfolio, Community Power expects a certain amount of geographic diversity among its power supply to help mitigate risks that might be experienced locally or regionally from weather, project site and/or wholesale market conditions.
Below is additional information regarding SBE and the proposed A&R PPA.
Background on SBE:
• SBE is a California-based solar and storage developer, owning and operating 1.4 GWac of solar projects in US, including 450 MWac of solar projects operating in California with 3 GWac of solar and 4.8 GWac of storage in its California pipeline, including the Pelicans Jaw project.
• Founded in 2019, SBE is backed by SoftBank Group Corp. and Ares Climate Infrastructure, allowing SBE to finance 100% of the projects it develops, owns, and operates.
• In December 2023, SBE received "Renewables Deal of the Year" award from Project Finance International (PFI) for reaching financial close on 1.3 GWs of solar projects and being among the first to take advantage of the domestic content 236 84
adder, a provision in the IRA designed to strengthen America’s manufacturing base.
• SBE is sourcing solar modules, trackers, and structural steel domestically for several of its projects.
Contract Overview – Pelicans Jaw:
• Project: 440 MW solar photovoltaic electricity generating facility, along with a 238.5 MWAC 4-hour (954 MWh) battery energy storage facility
• Project location: Kern County
• Original Guaranteed commercial operation date: April 1, 2027 • Contract term: 15 years
• Expected annual energy production: approximately 1,200,000 MWhs • Pricing: Fixed pricing with no escalation
• Community Power would receive financial compensation in the event of seller’s failure to successfully achieve certain development milestones as well as seller’s failure to meet the guaranteed energy production.
Community Benefits and Workforce Development:
• The project is estimated to create approximately 800 temporary construction jobs and 6-8 permanent jobs.
• The project has a fully executed Project Labor Agreement with:
o Operating Engineers Local 12 – San Diego, CA
o Southwest Regional Council of Carpenters – Los Angeles, CA o Southern California District Council of Laborers and its affiliated Local Union 220 – Bakersfield, CA
o IBEW Local 428 – Bakersfield, CA
o IBEW Local Union 47 – Diamond Bar CA
o Ironworkers Locals 416 and 433 – Norwalk, CA & City of Industry, CA • The project has committed $500,000 to a community benefit fund to benefit Community Power customers.
Scope of Amendment:
• Modify commercial operation date to September 1, 2026. If that date is missed, the contract allows for price adjustments based on the actual commercial operation date.
• Adjust pricing to account for earlier commercial operation date. • Update resource adequacy language to account for slide of day regulations.
COMMITTEE REVIEW:
In Q4 2024 the ECWG reviewed the A&R PPA for the project and recommended staff to move forward with the execution of this A&R PPA.
237 85
FISCAL IMPACT:
The competitive energy and capacity pricing of the A&R PPA are confidential, but the long-term purchase of renewable energy and capacity will provide Community Power with significant value and cost certainty over the term of this A&R PPA.
ATTACHMENTS:
A: Second Amended and Restated Renewable Power Purchase Agreement with Pelicans Jaw Solar, LLC
238 86
ITEM 12
ATTACHMENT A
239
SECOND AMENDED AND RESTATED RENEWABLE POWER PURCHASE AND
ENERGY STORAGE SERVICE AGREEMENT
COVER SHEET
Seller: Pelicans Jaw Solar, LLC (“Seller”)
Buyer: San Diego Community Power, a California joint powers authority (“Buyer”) Description of Facility: A 440 MW solar photovoltaic electricity generating facility, along with a 238.5 MW/954 MWh battery energy storage facility, all located in Kern County, in the State of California, as further described in Exhibit A, and subject to reduction in size as described in Exhibit B.
Milestones:
Milestone Date for
Completion
Evidence of Site Control Complete
CEC Pre-Certification Obtained Complete
Obtain federal and state discretionary permits:
[ ] CEQA, [ ] Cat Ex, [ ]Neg Dec, [ ] Mitigated Neg Dec, [ ] EIR
Complete
Seller’s receipt of Phase I and Phase II Interconnection study results for Seller’s Interconnection Facilities Complete Executed Interconnection Agreement Complete
Guaranteed Construction Start Date 1/31/26
Procure Major Equipment Complete
Expected Commercial Operation Date 4/1/27
Guaranteed Commercial Operation Date 4/1/27
Delivery Term: 15 Contract Years.
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241
242
243
TABLE OF CONTENTS
ARTICLE 1 DEFINITIONS ....................................................................................................... 1
1.1 Contract Definitions ............................................................................................... 1
1.2 Rules of Interpretation ......................................................................................... 25 ARTICLE 2 TERM; CONDITIONS PRECEDENT.............................................................. 26
2.1 Contract Term. ..................................................................................................... 26
2.2 Conditions Precedent ........................................................................................... 27
2.3 Development; Construction; Progress Reports .................................................... 28
2.4 Remedial Action Plan .......................................................................................... 29 ARTICLE 3 PURCHASE AND SALE .................................................................................... 29
3.1 Purchase and Sale of Product ............................................................................... 29
3.2 Sale of Green Attributes. ...................................................................................... 29
3.3 Imbalance Energy. ............................................................................................... 29
3.4 Ownership of Renewable Energy Incentives. ...................................................... 29
3.5 Future Environmental Attributes. ........................................................................ 30
3.6 Test Energy. ......................................................................................................... 31
3.7 Capacity Attributes. ............................................................................................. 31
3.8 Resource Adequacy Failure ................................................................................. 33
3.9 CEC Certification and Verification. .................................................................... 34
3.10 Reserved. .............................................................................................................. 34
3.11 Non-Modificable Standard Terms and Conditions. ............................................. 34
3.12 Compliance Expenditure Cap. ............................................................................. 35
3.13 Project Configuration ........................................................................................... 36 ARTICLE 4 OBLIGATIONS AND DELIVERIES................................................................ 36
4.1 Delivery................................................................................................................ 36
4.2 Title and Risk of Loss. ......................................................................................... 37
4.3 Forecasting ........................................................................................................... 37
4.4 Dispatch Down/Curtailment. ............................................................................... 39
4.5 Charging Energy Management ............................................................................ 40
4.6 Reduction in Energy Delivery Obligation ........................................................... 42
4.7 Guaranteed Energy Production. ........................................................................... 43
4.8 Storage Availability and Efficiency Rate. ........................................................... 43
4.9 Storage Capacity Tests ......................................................................................... 44
4.10 WREGIS .............................................................................................................. 45
4.11 Interconnection .................................................................................................... 46
4.12 Green-E Certification ........................................................................................... 46 ARTICLE 5 TAXES .................................................................................................................. 46
5.1 Allocation of Taxes and Charges. ........................................................................ 46
5.2 Cooperation. ......................................................................................................... 47 ARTICLE 6 MAINTENANCE OF THE FACILITY ............................................................ 47 244
6.1 Maintenance of the Facility. ................................................................................ 47
6.2 Maintenance of Health and Safety. ...................................................................... 47
6.3 Shared Facilities ................................................................................................... 47 ARTICLE 7 METERING ......................................................................................................... 48
7.1 Metering. .............................................................................................................. 48
7.2 Meter Verification. ............................................................................................... 48 ARTICLE 8 INVOICING AND PAYMENT; CREDIT ........................................................ 48
8.1 Invoicing. ............................................................................................................. 48
8.2 Payment................................................................................................................ 49
8.3 Books and Records. ............................................................................................. 49
8.4 Invoice Adjustments. ........................................................................................... 49
8.5 Billing Disputes. .................................................................................................. 50
8.6 Netting of Payments. ............................................................................................ 50
8.7 Seller’s Development Security. ........................................................................... 50
8.8 Seller’s Performance Security. ............................................................................. 50
8.9 First Priority Security Interest in Cash or Cash Equivalent Collateral ................ 51
8.10 Financial Statements. ........................................................................................... 52 ARTICLE 9 NOTICES ............................................................................................................. 52
9.1 Addresses for the Delivery of Notices ................................................................. 52
9.2 Acceptable Means of Delivering Notice .............................................................. 52 ARTICLE 10 FORCE MAJEURE........................................................................................... 52
10.1 Definition ............................................................................................................. 52
10.2 Termination Following Force Majeure Event ...................................................... 53
10.3 Notice for Force Majeure. .................................................................................... 54
10.4 No Liability If a Force Majeure Event Occurs .................................................... 54 ARTICLE 11 DEFAULTS; REMEDIES; TERMINATION ................................................ 54
11.1 Events of Default ................................................................................................. 54
11.2 Remedies; Declaration of Early Termination Date. ............................................. 59
11.3 Termination Payment ........................................................................................... 59
11.4 Notice of Payment of Termination Payment or Damage Payment ...................... 60
11.5 Disputes With Respect to Termination Payment ................................................. 60
11.6 Limitation on Seller’s Ability to Make or Agree to Third-Party Sales from the Facility after Early Termination Date ............................................................ 60
11.7 Rights And Remedies Are Cumulative ................................................................ 61
11.8 Mitigation ............................................................................................................. 61 ARTICLE 12 LIMITATION OF LIABILITY AND EXCLUSION OF
WARRANTIES ............................................................................................ 61
12.1 No Consequential Damages. ................................................................................ 61
12.2 Waiver and Exclusion of Other Damages. ........................................................... 61
12.3 Limitation on Pre-COD Liability. ........................................................................ 62 245
ARTICLE 13 REPRESENTATIONS AND WARRANTIES; AUTHORITY ..................... 62
13.1 Seller’s Representations and Warranties. ............................................................ 62
13.2 Buyer’s Representations and Warranties ............................................................. 63
13.3 General Covenants ............................................................................................... 64
13.4 Prevailing Wage ................................................................................................... 64
13.5 Workforce Development and Supplier Diversity ................................................ 64
13.6 Community Benefits ............................................................................................ 64 ARTICLE 14 ASSIGNMENT .................................................................................................. 65
14.1 General Prohibition on Assignments ................................................................... 65
14.2 Collateral Assignment .......................................................................................... 65
14.3 Permitted Assignment by Seller ........................................................................... 67
14.4 Permitted Assignment by Buyer .......................................................................... 67 ARTICLE 15 DISPUTE RESOLUTION ................................................................................ 68
15.1 Governing Law. ................................................................................................... 68
15.2 Dispute Resolution. .............................................................................................. 68
15.3 COD Expedited Dispute Resolution. ................................................................... 69 ARTICLE 16 INDEMNIFICATION ....................................................................................... 70
16.1 Indemnity ............................................................................................................. 70
16.2 Claims. ................................................................................................................. 70 ARTICLE 17 INSURANCE...................................................................................................... 71
17.1 Insurance .............................................................................................................. 71 ARTICLE 18 CONFIDENTIAL INFORMATION ............................................................... 72
18.1 Definition of Confidential Information ................................................................ 72
18.2 Duty to Maintain Confidentiality ......................................................................... 73
18.3 Irreparable Injury; Remedies ............................................................................... 73
18.4 Disclosure to Lenders, Etc. .................................................................................. 73
18.5 Press Releases ...................................................................................................... 73 ARTICLE 19 MISCELLANEOUS .......................................................................................... 73
19.1 Entire Agreement; Integration; Exhibits .............................................................. 73
19.2 Amendments ........................................................................................................ 74
19.3 No Waiver ............................................................................................................ 74
19.4 No Agency, Partnership, Joint Venture or Lease ................................................. 74
19.5 Severability .......................................................................................................... 74
19.6 Mobile-Sierra ....................................................................................................... 74
19.7 Counterparts ......................................................................................................... 74
19.8 Electronic Delivery .............................................................................................. 75
19.9 Binding Effect ...................................................................................................... 75
19.10 No Recourse to Members of Buyer ..................................................................... 75
19.11 Forward Contract ................................................................................................. 75 246
19.12 Further Assurances............................................................................................... 75
19.13 Change in Electric Market Design ....................................................................... 75
19.14 Service Contract ................................................................................................... 76
EXHIBITS
A. FACILITY DESCRIPTION ................................................................................................. A-1 B. MAJOR PROJECT DEVELOPMENT MILESTONES AND COMMERCIAL
OPERATION ............................................................................................... B-1 C. COMPENSATION................................................................................................................ C-1 D. SCHEDULING COORDINATOR RESPONSIBILITIES ................................................... D-1 E. PROGRESS REPORTING FORM ........................................................................................ E-1 F-1. AVERAGE EXPECTED ENERGY ................................................................................... F-1 F-2. AVAILABLE CAPACITY ................................................................................................. F-2 G. GUARANTEED ENERGY PRODUCTION DAMAGES CALCULATION ..................... G-1 H. FORM OF COMMERCIAL OPERATION DATE CERTIFICATE ................................... H-1 I. FORM OF INSTALLED CAPACITY CERTIFICATE .......................................................... I-1 J. FORM OF CONSTRUCTION START DATE CERTIFICATE ............................................ J-1 K. FORM OF LETTER OF CREDIT ........................................................................................ K-1 L. FORM OF GUARANTY ....................................................................................................... L-1 M. FORM OF REPLACEMENT RA NOTICE ....................................................................... M-1 N. NOTICES … ..................................................................................................................... N-1 O. STORAGE CAPACITY TESTS .......................................................................................... O-1 P. ANNUAL STORAGE AVAILABILITY CALCULATION ................................................. P-1 Q. OPERATING RESTRICTIONS ........................................................................................... Q-1 R. METERING DIAGRAM ...................................................................................................... R-1 S. WORKFORCE DEVELOPMENT ......................................................................................... S-1 V. FORM OF LIMITED ASSIGNMENT AGREEMENT ……………………………………V-1 247
SECOND AMENDED AND RESTATED RENEWABLE POWER PURCHASE AND
ENERGY STORAGE SERVICE AGREEMENT
This Second Amended and Restated Renewable Power Purchase and Energy Storage Service Agreement (“Agreement”) is entered into as of May ____, 2025 (the “Effective Date”), between Buyer and Seller. Buyer and Seller are sometimes referred to herein individually as a “Party” and jointly as the “Parties.” All capitalized terms used in this Agreement are used with the meanings ascribed to them in Article 1 to this Agreement.
RECITALS
WHEREAS, the Parties entered into that certain Amended and Restated Renewable Power Purchase and Energy Storage Service Agreement, dated as of May 1, 2024, as amended by that certain First Amendment to Amended and Restated Renewable Power Purchase and Energy Storage Service Agreement dated as of December 13, 2024 (as amended, the “First A&R PPA”); and
WHEREAS, the Parties hereby agree to amend, restate, replace and supersede the terms of the First A&R PPA as provided herein; and
WHEREAS, Seller intends to develop, design, permit, construct, own, and operate the Facility; and
WHEREAS, Seller desires to sell, and Buyer desires to purchase, on the terms and conditions set forth in this Agreement, the Product;
NOW THEREFORE, in consideration of the mutual covenants and agreements herein contained, and for other good and valuable consideration, the sufficiency and adequacy of which are hereby acknowledged, the Parties agree to the following:
ARTICLE 1
DEFINITIONS
1.1 Contract Definitions. The following terms, when used herein with initial capitalization, shall have the meanings set forth below:
“Accepted Compliance Costs” has the meaning set forth in Section 3.12(d). “Adjusted Energy Production” has the meaning set forth in Exhibit G. 248
“Affiliate” means, with respect to any Person, each Person that directly or indirectly controls, is controlled by, or is under common control with such designated Person. For purposes of this definition and the definition of “Permitted Transferee”, “control”, “controlled by”, and “under common control with”, as used with respect to any Person, shall mean (a) the direct or indirect right to cast at least fifty percent (50%) of the votes exercisable at an annual general meeting (or its equivalent) of such Person or, if there are no such rights, ownership of at least fifty percent (50%) of the equity or other ownership interest in such Person, or (b) the right to direct the policies or operations of such Person.
“Agreement” has the meaning set forth in the Preamble and includes the Cover Sheet and any Exhibits, schedules and any written supplements hereto. “Alternating Current” or “AC” means alternating current. “Ancillary Services” means all ancillary services, as defined in the CAISO Tariff, that the Facility is capable of providing consistent with the Operating Restrictions, as set forth in Exhibit Q. “Annual Storage Availability” has the meaning set forth in Exhibit P. “Approved Forecast Vendor” means any of (a) the CAISO or (b) any other vendor reasonably acceptable to both Buyer and Seller for the purposes of providing or verifying the forecasts under Section 4.3(d).
“Availability Adjustment” or “AA” has the meaning set forth in Exhibit P. “Availability Adjustment Payment” has the meaning set forth in Exhibit P. “Available Generating Capacity” means the capacity of the Generating Facility, expressed in whole MWs, that is mechanically available to generate Energy. “Bankrupt” means with respect to any entity, such entity that (a) files a petition or otherwise commences, authorizes or acquiesces in the commencement of a proceeding or cause of action under any bankruptcy, insolvency, reorganization or similar Law, (b) has any such petition filed or commenced against it which remains unstayed or undismissed for a period of ninety (90) days, (c) makes an assignment or any general arrangement for the benefit of creditors, (d) otherwise becomes bankrupt or insolvent (however evidenced), (e) has a liquidator, administrator, receiver, trustee, conservator or similar official appointed with respect to it or any substantial portion of its property or assets, or (f) is generally unable to pay its debts as they fall due. “Bid” has the meaning as set forth in the CAISO Tariff. “Business Day” means any day except a Saturday, Sunday, or a Federal Reserve Bank holiday in California. A Business Day begins at 8:00 a.m. and ends at 5:00 p.m. Pacific Prevailing Time (PPT) for the Party sending a Notice, or payment, or performing a specified action. “Buyer” means San Diego Community Power, a California joint powers authority. “Buyer Bid Curtailment” means the occurrence of both of the following:
249
(a) the CAISO provides notice to a Party or the Scheduling Coordinator for the Facility, requiring the Party to deliver less Generating Facility Energy than the full amount of energy forecasted in accordance with Section 4.3 to be produced from the Generating Facility for a period of time;
(b) for the same time period as referenced in (a), the notice referenced in (a) results from the manner in which Buyer or the SC schedules or bids the Generating Facility or Generating Facility Energy, including where Buyer or the SC for the Generating Facility:
(i) did not submit a Self-Schedule or an Energy Supply Bid for the MW subject to the reduction; or
(ii) submitted an Energy Supply Bid and the CAISO notice referenced in (a) is solely a result of CAISO implementing the Energy Supply Bid; or (iii) submitted a Self-Schedule for less than the full amount of Generating Facility Energy forecasted to be generated by or delivered from the Generating Facility.
If the Generating Facility is subject to a Planned Outage, Forced Facility Outage, Force Majeure Event or a Curtailment Period during the same time period as referenced in (a), then the calculation of Deemed Delivered Energy during such period shall not include any Generating Facility Energy that was not generated or stored due to such Planned Outage, Forced Facility Outage, Force Majeure Event or Curtailment Period.
“Buyer Curtailment Order” means (a) the instruction from Buyer to Seller to reduce Generating Facility Energy by the amount, and for the period of time set forth in such instruction, for reasons unrelated to a Planned Outage, Forced Facility Outage, Force Majeure Event or Curtailment Order, or (b) a reduction of Generating Facility Energy pursuant to or as a result of dispatch of the Storage Facility.
“Buyer Curtailment Period” means the period of time, as measured using current Settlement Intervals, during which Seller reduces Generating Facility Energy pursuant to or as a result of (a) Buyer Bid Curtailment, (b) a Buyer Curtailment Order, or (c) Buyer default; provided, that the duration of any Buyer Curtailment Period shall be inclusive of the time required for the Facility to ramp down and ramp up.
“Buyer Dispatched Test” has the meaning in Section 4.9(b). “Buyer’s WREGIS Account” has the meaning set forth in Section 4.10(a). “CAISO” means the California Independent System Operator Corporation. “CAISO Approved Meter” means a CAISO approved revenue quality meter or meters, CAISO approved data processing gateway or remote intelligence gateway, telemetering equipment and data acquisition services sufficient for monitoring, recording and reporting, in real time, all Generating Facility Energy delivered to the Delivery Point or the Storage Facility or all Charging Energy and Discharging Energy delivered to or from the Delivery Point, as applicable. 250
“CAISO Grid” has the same meaning as “CAISO Controlled Grid” as defined in the CAISO Tariff.
“CAISO Operating Order” means the “operating order” defined in Section 37.2.1.1 of the CAISO Tariff.
“CAISO Tariff” means the California Independent System Operator Corporation Agreement and Tariff, Business Practice Manuals (BPMs), and Operating Procedures, including the rules, protocols, procedures and standards attached thereto, as the same may be amended or modified from time-to-time and approved by FERC.
“California Renewables Portfolio Standard” or “RPS” means the renewable energy program and policies established by California State Senate Bills 1038 (2002), 1078 (2002), 107 (2008), X-1 2 (2011), 350 (2015), and 100 (2018) as codified in, inter alia, California Public Utilities Code Sections 399.11 through 399.31 and California Public Resources Code Sections 25740 through 25751, as such provisions are amended or supplemented from time to time. “Capacity Attribute” means any current or future defined characteristic, certificate, tag, credit, or accounting construct associated with the amount of power that the Facility can generate, charge, discharge or deliver to the Delivery Point at a particular moment and that can be purchased and sold under CAISO market rules, including Resource Adequacy Benefits. “Capacity Damages” has the meaning set forth in Section 5(a) of Exhibit B. “CEC” means the California Energy Commission, or any successor agency performing similar statutory functions.
“CEC Certification and Verification” means that the CEC has certified (or, with respect to periods before the date that is one hundred eighty (180) days following the Commercial Operation Date, that the CEC has pre-certified) that the Generating Facility is an Eligible Renewable Energy Resource for purposes of the California Renewables Portfolio Standard. “CEC Precertification” means that the CEC has issued a precertification for the Generating Facility indicating that the planned operations of the Generating Facility would comply with applicable CEC requirements for CEC Certification and Verification. “CEQA” means the California Environmental Quality Act.
“Change of Control” means, except in connection with public market transactions of equity interests or capital stock of Seller’s Ultimate Parent, any circumstance in which Ultimate Parent ceases to own, directly or indirectly through one or more intermediate entities, more than fifty percent (50%) of the outstanding equity interests in Seller; provided that in calculating ownership percentages for all purposes of the foregoing:
(a) any ownership interest in Seller held by Ultimate Parent indirectly through one or more intermediate entities shall not be counted towards Ultimate Parent’s ownership interest in Seller unless Ultimate Parent directly or indirectly owns more than fifty percent (50%) of the outstanding equity interests in each such intermediate entity; and 251
(b) ownership interests in Seller owned directly or indirectly by any Lender (including any tax equity provider) shall be excluded from the total outstanding equity interests in Seller. “Charging Energy” means the Energy delivered to the Storage Facility pursuant to a Charging Notice, as measured at the Storage Facility Metering Point by the Storage Facility Meter, as such meter readings are adjusted by the CAISO for any applicable Electrical Losses and Station Use. All Charging Energy that is not consumed in Electrical Losses or used for Station Use shall be used solely to charge the Storage Facility. Subject to the Operating Restrictions, Charging Energy may be delivered from the CAISO Grid in any Settlement Interval during which the Generating Facility is not producing Generating Facility Energy. “Charging Notice” means the operating instruction, and any subsequent updates, given by Buyer, Buyer’s SC or the CAISO to Seller, directing the Storage Facility to charge at a specific MW rate for a specified period of time or to a specified Stored Energy Level; provided, any such operating instruction shall be in accordance with the Operating Restrictions. For the avoidance of doubt, (i) any instruction to charge the Storage Facility pursuant to a Buyer Dispatched Test shall be considered a Charging Notice, and (ii) any Charging Notice shall not constitute a Buyer Bid Curtailment, Buyer Curtailment Order or Curtailment Order. “COD Certificate” has the meaning set forth in Exhibit B. “Commercial Operation” has the meaning set forth in Exhibit B. “Commercial Operation Date” has the meaning set forth in Exhibit B. “Commercial Operation Delay Damages” or “COD Delay Damages” means an amount equal to (a) the Development Security amount required hereunder, divided by (b)
“Communications Protocols” means certain Operating Restrictions developed by the Parties pursuant to Exhibit Q that involve procedures and protocols regarding communication with respect to the operation of the Storage Facility pursuant to this Agreement. “Compliance Action” has the meaning set forth in Section 3.12(b). “Compliance Expenditure Cap” has the meaning set forth in Section 3.12(b). “Confidential Information” has the meaning set forth in Section 18.1. “Construction Delay Damages” means an amount equal to (a) the Development Security amount required hereunder, divided by (b)
“Construction Start” has the meaning set forth in Exhibit B. “Construction Start Date” has the meaning set forth in Exhibit B. “Contract Capacity” means the sum of the Guaranteed Capacity and the Storage Contract Capacity.
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“Contract Price” has the meaning set forth on the Cover Sheet. To be clear, the Contract Price is each of the Renewable Rate and the Storage Rate. “Contract Term” has the meaning set forth in Section 2.1(a). “Contract Year” means a period of twelve (12) consecutive months. The first Contract Year shall commence on the Commercial Operation Date and each subsequent Contract Year shall commence on the anniversary of the Commercial Operation Date. “Costs” means, with respect to the Non-Defaulting Party, brokerage fees, commissions and other similar third-party transaction costs and expenses reasonably incurred by such Party either in terminating any arrangement pursuant to which it has hedged its obligations or entering into new arrangements which replace the Agreement; and all reasonable attorneys’ fees and expenses incurred by the Non-Defaulting Party in connection with terminating the Agreement. “Cover Sheet” means the cover sheet to this Agreement, which is incorporated into this Agreement.
“CPM Soft Offer Cap” has the meaning set forth in the CAISO Tariff. “CPUC” means the California Public Utilities Commission or any successor agency performing similar statutory functions.
“CPUC System RA Penalty Price” means the RA penalties assessed against load serving entities by the CPUC for RA deficiencies that are not replaced or cured, as established by the CPUC in the Resource Adequacy Rulings and subsequently incorporated into the annual Filing Guide for System, Local and Flexible Resource Adequacy (RA) Compliance Filings that is issued by the CPUC Energy Division, or any replacement or successor documentation established by the CPUC Energy Division to reflect RA penalties that are established by the CPUC and assessed against load serving entities for RA deficiencies.
“Credit Rating” means, with respect to any entity, the rating then assigned to such entity’s unsecured, senior long-term debt obligations (not supported by third party credit enhancements) or if such entity does not have a rating for its senior unsecured long-term debt, then the rating then assigned to such entity as an issuer rating by S&P or Moody’s. If ratings by S&P and Moody’s are not equivalent, the lower rating shall apply.
“Cure Plan” has the meaning set forth in Section 11.1(b)(vi). “Curtailment Cap” has the meaning set forth in Exhibit C, clause (d). “Curtailment Order” means any of the following:
(a) CAISO orders, directs, alerts, or provides notice to a Party, including a CAISO Operating Order, requiring such Party to curtail deliveries of Generating Facility Energy for the following reasons: (i) any System Emergency, or (ii) any warning of an anticipated System Emergency, or warning of an imminent condition or situation, which jeopardizes CAISO’s electric system integrity or the integrity of other systems to which CAISO is connected; 253
(b) a curtailment ordered by the Participating Transmission Owner for reasons including, but not limited to, (i) any situation that affects normal function of the electric system including, but not limited to, any abnormal condition that requires action to prevent circumstances such as equipment damage, loss of load, or abnormal voltage conditions, or (ii) any warning, forecast or anticipation of conditions or situations that jeopardize the Participating Transmission Owner’s electric system integrity or the integrity of other systems to which the Participating Transmission Owner is connected;
(c) a curtailment ordered by CAISO or the Participating Transmission Owner due to scheduled or unscheduled maintenance on the Participating Transmission Owner’s transmission facilities that prevents (i) Buyer from receiving or (ii) Seller from delivering Generating Facility Energy to the Delivery Point; or
(d) a curtailment in accordance with Seller’s obligations under its Interconnection Agreement with the Participating Transmission Owner or distribution operator. “Curtailment Period” means the period of time, as measured using current Settlement Intervals, during which generation from the Facility is reduced pursuant to a Curtailment Order; provided that the Curtailment Period shall be inclusive of the time required for the Facility to ramp down and ramp up.
“Damage Payment”
“Day-Ahead Forecast” has the meaning set forth in Section 4.3(c). “Day-Ahead Market” has the meaning set forth in the CAISO Tariff. “Day-Ahead Schedule” has the meaning set forth in the CAISO Tariff. “Dedicated Interconnection Capacity” means an instantaneous amount of Energy that is permitted to be delivered by the Facility to the Delivery Point under Seller’s Interconnection Agreement, in the amount of MWs as set forth on the Cover Sheet. “Deemed Delivered Energy” means the amount of Generating Facility Energy, expressed in MWh, that the Generating Facility would have produced and delivered to the Storage Facility or the Delivery Point, but that is not produced by the Generating Facility during a Buyer Curtailment Period, which amount shall be calculated using the CAISO VER forecast or an industry-standard methodology agreed to by Buyer and Seller that utilizes meteorological conditions on Site as input for the period of time during such Buyer Curtailment Period, less the amount of Generating Facility Energy delivered to the Storage Facility or the Delivery Point during the Buyer Curtailment Period (or other relevant period); provided that, if the applicable difference is negative, the Deemed Delivered Energy shall be zero (0). For all purposes under this Agreement, including compensation under Exhibit C and the Curtailment Cap, Deemed Delivered Energy shall be reduced in any Settlement Interval by the amount of any Charging Energy that was not able to be delivered to the Storage Facility during such Settlement Interval due to the unexcused unavailability of the Storage Facility.
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“Defaulting Party” has the meaning set forth in Section 11.1(a). “Deficient Month” has the meaning set forth in Section 4.10(e). “Delay Damages” means Construction Delay Damages and COD Delay Damages. “Delivery Point” has the meaning set forth in Exhibit A. “Delivery Term” shall mean the period of Contract Years set forth on the Cover Sheet beginning on the Commercial Operation Date, unless terminated earlier in accordance with the terms and conditions of this Agreement.
“Development Cure Period” has the meaning set forth in Exhibit B. “Development Security” means (i) cash or (ii) a Letter of Credit in the amount set forth for the Development Security on the Cover Sheet.
“Discharging Energy” means all Energy that is delivered from the Storage Facility to the Delivery Point pursuant to a Discharging Notice during any Settlement Interval or Settlement Period, as measured at the Storage Facility Metering Point by the Storage Facility Meter, as such meter readings are adjusted by the CAISO for any applicable Station Use and Electrical Losses to the Delivery Point to the extent such Electrical Losses and Station Use are not already reflected in the Storage Facility Meter measurements.
“Discharging Notice” means the operating instruction, and any subsequent updates, given by Buyer, Buyer’s SC or the CAISO to Seller, directing the Storage Facility to discharge Discharging Energy at a specific MW rate for a specified period of time or to a specified Stored Energy Level; provided, any such operating instruction or updates shall be in accordance with the Operating Restrictions. For the avoidance of doubt, any Discharging Notice shall not constitute a Buyer Bid Curtailment, Buyer Curtailment Order or Curtailment Order, except that any Discharging Notice that results in a reduction in Generating Facility Energy will be deemed a Buyer Curtailment Order for all purposes hereunder. Any instruction to discharge the Storage Facility pursuant to a Buyer Dispatched Test shall be considered a Discharging Notice. “Early Termination Date” has the meaning set forth in Section 11.2(a). “Effective Date” has the meaning set forth in the Preamble. “Efficiency Rate” means the tested round-trip efficiency rate of the Storage Facility, expressed as a percentage, calculated pursuant to a Storage Capacity Test by dividing Energy Out by Energy In.
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“Electrical Losses” means, subject to meeting any applicable CAISO requirements and in accordance with Section 7.1, all transmission or transformation losses (a) between the Generating Facility Metering Point and the Delivery Point associated with delivery of Generating Facility Energy, (b) between the Storage Facility Metering Point and the Delivery Point associated with delivery of Discharging Energy, (c) between the Generating Facility and the Storage Facility Metering Point associated with delivery of Charging Energy. “Eligible Renewable Energy Resource” has the meaning set forth in California Public Utilities Code Section 399.12(e) and California Public Resources Code Section 25741(a), as either code provision is amended or supplemented from time to time. “Energy” means Alternating Current electrical energy measured in MWh. “Energy In” has the meaning set forth in Part II.B of Exhibit O. “Energy Management System” or “EMS” means the Facility’s energy management system.
“Energy Out” has the meaning set forth in Part II.B of Exhibit O. “Energy Supply Bid” has the meaning set forth in the CAISO Tariff. “Event of Default” has the meaning set forth in Section 11.1. “Excess MWh” has the meaning set forth in Exhibit C.
"Expected Commercial Operation Date” means the date set forth on the Cover Sheet. “Expected Energy” means the quantity of Generating Facility Energy that Seller expects to be able to deliver to Buyer during each Contract Year or other time period (assuming no Charging Energy or Discharging Energy during such Contract Year or time period) in the quantity specified on the Cover Sheet, which amount shall be adjusted proportionately to the reduction from Guaranteed Capacity to Installed Generating Capacity pursuant to Section 5(a) of Exhibit B, if applicable, provided, that prior to the Construction Start Date, Seller may update the Expected Energy by providing Notice to Buyer along with a resource evaluation report prepared by an independent engineer, in which case the Expected Energy for the first Contract Year will be automatically revised without further action of the Parties to equal the “P-50” estimate of the Facility’s generation for the first Contract Year as set forth in such report (and the Expected Energy for the remaining Contract Years will be automatically adjusted to reflect 0.50% degradation per Contract Year). Such automatic revision is only allowed without further action of the Parties if the revised expected energy is within ten percent (10%) of the original Expected Energy specified on the Cover Sheet as of the Effective Date.
“Facility” means the Generating Facility and the Storage Facility. “Facility Energy” means the sum of Generating Facility Energy and Discharging Energy during any Settlement Interval or Settlement Period.
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“FERC” means the Federal Energy Regulatory Commission.
“Flexible Capacity” has the meaning set forth in the CAISO Tariff. “Flexible Capacity Category” has the meaning set forth in the CAISO Tariff. “Force Majeure Event” has the meaning set forth in Section 10.1. “Forced Facility Outage” means an unexpected failure of one or more components of the Facility that prevents Seller from generating Energy or making Facility Energy available at the Delivery Point and that is not the result of a Force Majeure Event. “Forecasting Penalty” means for each hour in which Seller does not provide the forecast required in Section 4.3(c) and Buyer incurs a loss or penalty resulting from its scheduling activities in such hour with respect to Generating Facility Energy, the product of (A) the absolute difference (if any) between (i) the expected Energy for such hour (which, for the avoidance of doubt, assumes no Charging Energy or Discharging Energy in such hour) set forth in the Monthly Delivery Forecast, and (ii) the actual Energy produced by the Generating Facility (absent any Charging Energy and Discharging Energy), multiplied by (B) the absolute value of the Real-Time Price in such hour.
“Forward Certificate Transfers” has the meaning set forth in Section 4.10(a). “Future Environmental Attributes” shall mean any and all generation attributes other than Green Attributes or Renewable Energy Incentives under the RPS regulations or under any and all other international, federal, regional, state or other law, rule, regulation, bylaw, treaty or other intergovernmental compact, decision, administrative decision, program (including any voluntary compliance or membership program), competitive market or business method (including all credits, certificates, benefits, and emission measurements, reductions, offsets and allowances related thereto) that are attributable, now, or in the future, to the generation of electrical energy by the Facility. Future Environmental Attributes do not include investment tax credits or production tax credits associated with the construction or operation of the Facility, or other financial incentives in the form of credits, reductions, or allowances associated with the Facility that are applicable to a state or federal income taxation obligation.
“Gains” means, with respect to any Party, an amount equal to the present value of the economic benefit to it, if any (exclusive of Costs), resulting from the termination of this Agreement for the remaining Contract Term, determined in a commercially reasonable manner. Factors used in determining the economic benefit to a Party may include, without limitation, reference to information supplied by one or more third parties, which shall exclude Affiliates of the Non-Defaulting Party, including without limitation, quotations (either firm or indicative) of relevant rates, prices, yields, yield curves, volatilities, spreads or other relevant market data in the relevant markets, comparable transactions, forward price curves based on economic analysis of the relevant markets, settlement prices for comparable transactions at liquid trading hubs (e.g., SP-15), all of 257
which should be calculated for the remaining Contract Term, and include the value of Green Attributes and Capacity Attributes.
“Generating Facility” means the renewable energy electricity generating facility described on the Cover Sheet and in Exhibit A, located at the Site and including mechanical equipment and associated facilities and equipment required to deliver Generating Facility Energy to (i) to the Delivery Point, and (ii) to the Storage Facility as Charging Energy; provided, that the “Generating Facility” does not include the Storage Facility or the Shared Facilities. “Generating Facility Energy” means all Energy that is delivered from the Generating Facility to the Storage Facility or directly to the Delivery Point as measured at the Generating Facility Metering Point by the Generating Facility Meter, as such meter readings are adjusted by the CAISO for Station Use and Electrical Losses to the Delivery Point to the extent such Electrical Losses and Station Use are not already reflected in the Generating Facility Meter measurements. “Generating Facility Meter” means the CAISO Approved Meter, along with a CAISO-approved data processing gateway or remote intelligence gateway, telemetering equipment and data acquisition services sufficient for monitoring, recording and reporting, in real time, the amount of Generating Facility Energy delivered to the Generating Facility Metering Point for the purpose of invoicing in accordance with Section 8.1. The Generating Facility may contain multiple measurement devices that will make up the Generating Facility Meter, and, unless otherwise indicated, references to the Generating Facility Meter shall mean all such measurement devices and the aggregated data of all such measurement devices, taken together. “Generating Facility Metering Point” means the location or locations of the Generating Facility Meter shown on Exhibit R.
“GEP Damages” has the meaning set forth in Section 4.7. “Governmental Authority” means any federal, state, provincial, local or municipal government, any political subdivision thereof or any other governmental, congressional or parliamentary, regulatory, or judicial instrumentality, authority, body, agency, department, bureau, or entity with authority to bind a Party at law, including CAISO; provided, however, that “Governmental Authority” shall not in any event include any Party. “Green Attributes” means any and all credits, benefits, emissions reductions, offsets, and allowances, howsoever entitled, attributable to the generation from the Facility and its displacement of conventional energy generation. Green Attributes include but are not limited to Renewable Energy Credits, as well as: (1) any avoided emissions of pollutants to the air, soil or water such as sulfur oxides (SOx), nitrogen oxides (NOx), carbon monoxide (CO) and other pollutants; (2) any avoided emissions of carbon dioxide (CO2), methane (CH4), nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride and other greenhouse gases (GHGs) that have been determined by the United Nations Intergovernmental Panel on Climate Change, or otherwise by law, to contribute to the actual or potential threat of altering the Earth’s climate by trapping heat in the atmosphere; (3) the reporting rights to these avoided emissions, such as Green Tag Reporting Rights. Green Tags are accumulated on a MWh basis and one Green Tag represents the Green Attributes associated with one (1) MWh of Facility Energy. Green Attributes do not 258
include (i) any energy, capacity, reliability or other power attributes from the Facility, (ii) production tax credits associated with the construction or operation of the Facility and other financial incentives in the form of credits, reductions, or allowances associated with the Facility that are applicable to a state or federal income taxation obligation, (iii) fuel-related subsidies or “tipping fees” that may be paid to Seller to accept certain fuels, or local subsidies received by the generator for the destruction of particular preexisting pollutants or the promotion of local environmental benefits, or (iv) emission reduction credits encumbered or used by the Facility for compliance with local, state, or federal operating or air quality permits. If the Facility is a biomass or landfill gas facility and Seller receives any tradable Green Attributes based on the greenhouse gas reduction benefits or other emission offsets attributed to its fuel usage, it shall provide Buyer with sufficient Green Attributes to ensure that there are zero net emissions associated with the production of electricity from the Facility.
“Green Tag Reporting Rights” means the right of a purchaser of renewable energy to report ownership of accumulated “green tags” in compliance with and to the extent permitted by applicable Law and include, without limitation, rights under Section 1605(b) of the Energy Policy Act of 1992, and any present or future federal, state or local certification program or emissions trading program, including pursuant to the WREGIS Operating Rules. “Guaranteed Capacity” means the amount of generating capacity of the Generating Facility, as measured in MW at the Delivery Point, set forth on the Cover Sheet. “Guaranteed Commercial Operation Date” means the date set forth on the Cover Sheet, as such date may be extended pursuant to Exhibit B.
“Guaranteed Construction Start Date” means the date set forth on the Cover Sheet, as such date may be extended pursuant to Exhibit B.
“Guaranteed Efficiency Rate” means, for each Contract Year, the guaranteed Efficiency Rate of the Storage Facility for such Contract Year, as set forth on the Cover Sheet. “Guaranteed Energy Production” means an amount of Adjusted Energy Production, as measured in MWh, equal to of the total Expected Energy for the applicable Performance Measurement Period.
“Guaranteed RA Amount” means, at any point in time on or after the RA Guarantee Date, the maximum Net Qualifying Capacity (in MWs) for which a storage facility with storage capacity equal to the Installed Battery Capacity with four (4) hour discharge at the Delivery Point, having achieved PCDS to the extent required under the Agreement and performing with operational characteristics equal to those required by the Guaranteed Storage Availability, Guaranteed Efficiency Rate, and the Operating Restrictions, may be counted in any given Showing Month pursuant to the then current Law, including counting conventions set forth in the Resource Adequacy Rulings and the CAISO Tariff applicable to Resource Adequacy Resources. Seller will not be required to obtain or allocate TP Deliverability (as defined in the CAISO Tariff) to the Facility in excess of the Storage Contract Capacity.
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performance test, and as evidenced by a certificate substantially in the form attached as Exhibit I hereto.
“Insurable Force Majeure Event” means any Force Majeure Event which (a) results in direct, physical loss to the Facility, and (b) excludes Force Majeure Events that occur beyond the Delivery Point.
“Interconnection Agreement” means the interconnection agreement(s) entered into by Seller or a Seller Affiliate pursuant to which the Facility will be interconnected with the Transmission System, providing for interconnection capacity available or allocable to the Facility at the Interconnection Point that is no less than the Dedicated Interconnection Capacity, and pursuant to which Seller’s Interconnection Facilities and any other Interconnection Facilities will be constructed, operated and maintained during the Contract Term. “Interconnection Facilities” means the interconnection facilities, control and protective devices and metering facilities required to connect the Facility with the Transmission System in accordance with the Interconnection Agreement.
“Interconnection Point” means the point at which Seller’s Interconnection Facilities interconnect with the Transmission System pursuant to the Interconnection Agreement, which point is identified in Exhibit A.
“Interest Rate” has the meaning set forth in Section 8.2. “Interim Deliverability Status” has the meaning set forth in the CAISO Tariff. “Inter-SC Trade” or “IST” has the meaning set forth in the CAISO Tariff. “Investment Grade Credit Rating” means a Credit Rating of “ITC” means the investment tax credit established pursuant to Section 48 or Section 48E of the United States Internal Revenue Code of 1986.
“Joint Powers Act” means the Joint Exercise of Powers Act of the State of California (Government Code Section 6500 et seq.).
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“Joint Powers Agreement” means that certain Joint Powers Agreement dated October 1, 2019, as amended from time to time, under which Buyer is organized as a Joint Powers Authority in accordance with the Joint Powers Act.
“Law” means any applicable law, statute, rule, regulation, decision, writ, order, decree or judgment, permit or any interpretation thereof, promulgated or issued by a Governmental Authority.
“Lender” means, collectively, any Person (i) providing letters of credit, surety bonds, senior or subordinated construction, interim, back leverage or long-term debt, equity or tax equity financing or refinancing for or in connection with the development, construction, purchase, installation or operation of the Facility, whether that financing or refinancing takes the form of private debt (including back-leverage debt), equity (including tax equity), public debt or any other form (including financing or refinancing provided to a member or other direct or indirect owner of Seller), including any equity or tax equity investor directly or indirectly providing financing or refinancing for the Facility or purchasing equity ownership interests of Seller or its Affiliates, and any trustee or agent or similar representative acting on their behalf, (ii) providing Interest Rate or commodity protection under an agreement hedging or otherwise mitigating the cost of any of the foregoing obligations or (iii) participating in a lease financing (including a sale leaseback or leveraged leasing structure) with respect to the Facility. “Letter(s) of Credit” means one or more irrevocable, standby letters of credit issued by a U.S. commercial bank or a foreign bank with a U.S. branch with such bank having a Credit Rating of at least A- with an outlook designation of “stable” from S&P or A3 with an outlook designation of “stable” from Moody’s, in a form substantially similar to the letter of credit set forth in Exhibit K.
“Licensed Professional Engineer” means an independent, professional engineer selected by Seller and reasonably acceptable to Buyer, licensed in the State of California. “Local RAR” means the local Resource Adequacy Requirements established for load-serving entities by the CAISO pursuant to the CAISO Tariff, the CPUC pursuant to the Resource Adequacy Rulings, or by any other Governmental Authority. “Local RAR” may also be known as local area reliability, local resource adequacy, local resource adequacy procurement requirements, or local capacity requirement in other regulatory proceedings or legislative actions. “Locational Marginal Price” or “LMP” has the meaning set forth in the CAISO Tariff. “Losses” means, with respect to the Non-Defaulting Party, an amount equal to the present value of the economic loss to it, if any (exclusive of Costs), resulting from termination of this Agreement for the remaining Contract Term, determined in a commercially reasonable manner.
Factors used in determining economic loss to a Party may include reference to information supplied by one or more third parties, which shall exclude Affiliates of the Non-Defaulting Party, including quotations (either firm or indicative) of relevant rates, prices, yields, yield curves, volatilities, spreads or other relevant market data in the relevant markets, comparable transactions, forward price curves based on economic analysis of the relevant markets, settlement prices for comparable transactions at liquid trading hubs (e.g., SP-15), all of which should be calculated for 262
the remaining Contract Term and must include the value of Green Attributes, Capacity Attributes, and Renewable Energy Incentives.
“Lost Output” means the amount of Generating Facility Energy expressed in MWh that the Generating Facility would have produced and delivered to the Storage Facility or the Delivery Point, but that is not produced by the Generating Facility during Force Majeure Events, Curtailment Periods, System Emergencies, or Buyer default, which amount shall be calculated using the CAISO VER forecast or an industry-standard methodology agreed to by Buyer and Seller that utilizes meteorological conditions on Site as input for the period of time during such Force Majeure Events, Curtailment Periods, System Emergencies, or Buyer default, less the amount of Generating Facility Energy delivered to the Storage Facility or the Delivery Point during such period of time (or other relevant period); provided that, if the applicable difference is negative, the Lost Output shall be zero (0). For all purposes under this Agreement, Lost Output shall be reduced in any Settlement Interval by the amount of any Charging Energy that was not able to be delivered to the Storage Facility during such Settlement Interval due to the unexcused unavailability of the Storage Facility.
“Master File” has the meaning set forth in the CAISO Tariff. “Maximum Charging Capacity” means the maximum power output level, in MW, at which the Storage Facility can be charged, as specified in Exhibit Q. “Maximum Discharging Capacity” means the maximum power output level, in MW, at which the Storage Facility can be discharged, as specified in Exhibit Q. “Maximum State of Charge” means the maximum State of Charge to which the Storage Facility may be charged, as set forth in Exhibit Q.
“Maximum Stored Energy Level” means the maximum Stored Energy Level the Storage Facility is capable of achieving, expressed in MWh, as set forth in Exhibit Q. “Milestones” means the development activities for significant permitting, interconnection, financing and construction milestones set forth on the Cover Sheet. “Minimum Efficiency Rate” means the percentage specified on the Cover Sheet. “Minimum State of Charge” means the minimum State of Charge to which the Storage Facility may be discharged, as set forth in Exhibit Q.
“Minimum Stored Energy Level” means the minimum Stored Energy Level the Storage Facility is capable of achieving, expressed in MWh, as set forth in Exhibit Q. “Monthly Delivery Forecast” has the meaning set forth in Section 4.3(b). “Moody’s” means Moody’s Investors Service, Inc.
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“MW” means megawatts in Alternating Current, unless expressly stated in terms of direct current.
“MWh” means megawatt-hour measured in Alternating Current, unless expressly stated in terms of direct current.
“Negative LMP” means, in any Settlement Period or Settlement Interval, the Real-Time Market LMP at the Facility’s PNode is less than Zero dollars ($0). “Negative LMP Costs” has the meaning set forth in Exhibit C. “NERC” means the North American Electric Reliability Corporation or any successor entity performing similar functions.
“Net Qualifying Capacity” has the meaning set forth in the CAISO Tariff. “Network Upgrades” has the meaning set forth in the CAISO Tariff. “Non-Defaulting Party” has the meaning set forth in Section 11.2. “Notice” shall, unless otherwise specified in the Agreement, mean written communications by a Party to be delivered by hand delivery, United States mail, overnight courier service, or electronic messaging (e-mail).
“Notice to Proceed” has the meaning set forth in Exhibit B. “Operating Restrictions” means those rules, requirements, and procedures set forth on Exhibit Q.
“Pacific Prevailing Time” means the prevailing standard time or daylight savings time, as applicable, in the Pacific time zone.
“Partial Capacity Deliverability Status” has the meaning set forth in the CAISO Tariff. “Participating Transmission Owner” or “PTO” means an entity that owns, operates and maintains transmission or distribution lines and associated facilities or has entitlements to use certain transmission or distribution lines and associated facilities where the Facility is interconnected. For purposes of this Agreement, the Participating Transmission Owner is set forth in Exhibit A.
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with respect to grid-interconnected, utility-scale generating facilities with integrated storage in the Western United States, or (b) any of the practices, methods and acts which, in light of the facts known at the time the decision was made, could have been expected to accomplish the desired result at a reasonable cost consistent with good business practices, reliability, safety and expedition. Prudent Operating Practice is not intended to be limited to the optimum practice, method or act to the exclusion of all others, but rather to acceptable practices, methods or acts generally accepted in the industry with respect to grid-interconnected, utility-scale generating facilities with integrated storage in the Western United States. Prudent Operating Practice includes compliance with applicable Laws, applicable reliability criteria, and the criteria, rules and standards promulgated in the National Electric Safety Code and the National Electrical Code, as they may be amended or superseded from time to time, including the criteria, rules and standards of any successor organizations.
“PTC” means the production tax credit established pursuant to Section 45 or Section 45Y of the United States Internal Revenue Code of 1986.
“PTC Amount” means the amount, on a dollar per MWh basis, equal to the PTC that Seller would have earned in respect of Generating Facility Energy at the time, grossed up on an after tax basis at the then-highest marginal combined federal and state corporate tax rate, but failed to earn as a result of Buyer Bid Curtailment or Buyer Curtailment Order, which amount will be calculated by reference to the amount of Deemed Delivered Energy in excess of the Curtailment Cap and the portion of the Generating Facility eligible to receive Production Tax Credits at the time of determination.
“RA Compliance Showing” means the (a) Local RAR compliance or advisory showings (or similar or successor showings), (b) RAR compliance or advisory showings (or similar or successor showings), and (c) Flexible RAR compliance or advisory showings (or similar successor showings), in each case, an entity is required to make to the CAISO pursuant to the CAISO Tariff, to the CPUC (and, to the extent authorized by the CPUC, to the CAISO) pursuant to the Resource Adequacy Rulings, or to any Governmental Authority.
“RA Deficiency Amount” means the liquidated damages payment that Seller shall pay to Buyer for an applicable RA Shortfall Month as calculated in accordance with Section 3.8(b). “RA Guarantee Date” means the Commercial Operation Date. “RA Shortfall” has the meaning set forth in Section 3.8(b). “RA Shortfall Month” means, for purposes of calculating an RA Deficiency Amount under Section 3.8(b), any Showing Month, commencing with the Showing Month that contains the RA Guarantee Date, during which there is an RA Shortfall. “Ramp Rate” means the ability of the Storage Facility to change between power output levels, expressed in MWAC/min.
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“Real-Time Forecast” means any Notice of any change to the Available Generating Capacity, Storage Capacity, or hourly expected Energy delivered by or on behalf of Seller pursuant to Section 4.3(d).
“Real-Time Market” has the meaning set forth in the CAISO Tariff. “Real-Time Price” means the Resource-Specific Settlement Interval LMP as defined in the CAISO Tariff. If there is more than one applicable Real-Time Price for the same period of time, Real-Time Price shall mean the price associated with the smallest time interval. “Reliability Network Upgrades” has the meaning set forth in the CAISO Tariff. “Remedial Action Plan” has the meaning set forth in Section 2.4. “Renewable Energy Credit” has the meaning set forth in California Public Utilities Code Section 399.12(h), as may be amended from time to time or as further defined or supplemented by Law.
“Renewable Energy Incentives” means: (a) all federal, state, or local Tax credits or other Tax benefits associated with the construction, ownership, or production or storage of electricity from the Facility (including credits under Sections 38, 45, 46 and 48 of the Internal Revenue Code of 1986, as amended); (b) any federal, state, or local grants, subsidies or other like benefits relating in any way to the Facility; and (c) any other form of incentive relating in any way to the Facility that is not a Green Attribute or a Future Environmental Attribute. “Renewable Rate” has the meaning set forth on the Cover Sheet. “Replacement Energy” means energy produced by an Eligible Renewable Energy Resource other than the Generating Facility, that is provided by Seller to Buyer as a component of Replacement Product, in an amount equal to the amount of Replacement Green Attributes provided by Seller as a component of such Replacement Product.
“Replacement Green Attributes” means Renewable Energy Credits of the same Portfolio Content Category (i.e., PCC1) as the Green Attributes portion of the Product and of the same year of production or a different year as agreed to by the Parties, as the Renewable Energy Credits that would have been generated by the Generating Facility.
“Replacement Product” means (a) Replacement Energy, and (b) Replacement Green Attributes.
“Replacement RA” means Resource Adequacy Benefits, if any, (a) equivalent to those that would have been provided by the Facility with respect to the applicable Showing Month in which a RA Deficiency Amount is expected to be due to Buyer, including, as applicable, Resource Category and Flexible Capacity Category, the same Slice-of-Day (as such term is defined in the Resource Adequacy Rulings) generation profile and related characteristics, and any successor criteria applicable to the Facility, and any Local RAR, unless Buyer consents to accept Replacement RA from another facility that provides non-equivalent Resource Adequacy Benefits, and (b) located within the CAISO balancing authority area. 267
“Resource Adequacy Benefits” means the rights and privileges attached to the Facility that satisfy any entity’s Resource Adequacy Requirements, as those obligations are set forth in any ruling issue by a Governmental Authority, including the Resource Adequacy Rulings, or the CAISO Tariff, and shall include Flexible Capacity, and any local, zonal or otherwise locational attributes associated with the Facility, including any Resource Duration attributes. “Resource Adequacy Requirements” or “RAR” means the resource adequacy requirements applicable to an entity as established by the CAISO pursuant to the CAISO Tariff, by the CPUC pursuant to the Resource Adequacy Rulings, or by any other Governmental Authority.
“Resource Adequacy Resource” has the meaning set forth in the CAISO Tariff. “Resource Adequacy Rulings” means CPUC Decisions 04-01-050, 04-10-035, 05-10-042, 06-04-040, 06-06-064, 06-07-031, 07-06-029, 08-06-031, 09-06-028, 10-06-036, 11-06-022, 12-06-025, 13-06-024, 14-06-050, 15-06-063, 16-06-045, 17-06-027, 18-06-030, 18- 06-031, 19-02-022, 19-06-026, 19-10-021, 20-01-004, 20-03-016, 20-06-002, 20-06-031, 20-06- 028, 20-12-006 and any other existing or subsequent ruling or decision, or any other resource adequacy laws, rules or regulations enacted, adopted or promulgated by the CPUC or the CAISO, however described, as such decisions, rulings, Laws, rules or regulations may be amended or modified from time-to-time throughout the Contract Term. “Resource Category” means the categories for established by the CPUC in the Resource Adequacy Rulings and subsequently incorporated into the annual Filing Guide for System, Local and Flexible Resource Adequacy Compliance Filings that is issued by the CPUC Energy Division, or any replacement or successor documentation established by the CPUC Energy Division. “Resource Duration” means the number of continuous hours of discharge set forth on the Cover Sheet.
“S&P” means the Standard & Poor’s Financial Services, LLC (a subsidiary of The McGraw-Hill Companies, Inc.).
“Schedule” has the meaning set forth in the CAISO Tariff, and “Scheduled” has a corollary meaning.
“Scheduled Energy” means the Charging Energy, Discharging Energy, or Generating Facility Energy, as applicable, that clears under the applicable CAISO market based on the final Day-Ahead Schedule, FMM Schedule (as defined in the CAISO Tariff), or any other financially binding Schedule, market instruction or dispatch for the Facility for a given period of time implemented in accordance with the CAISO Tariff.
“Scheduling Coordinator” or “SC” means an entity certified by the CAISO as qualifying as a Scheduling Coordinator pursuant to the CAISO Tariff for the purposes of undertaking the functions specified in “Responsibilities of a Scheduling Coordinator,” of the CAISO Tariff, as amended from time to time.
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“Security Interest” has the meaning set forth in Section 8.9. “Self-Schedule” has the meaning set forth in the CAISO Tariff. “Seller” has the meaning set forth on the Cover Sheet.
“Seller Initiated Test” has the meaning set forth in Section 4.9(b). “Seller’s WREGIS Account” has the meaning set forth in Section 4.10(a). “Settlement Amount” means the Non-Defaulting Party’s Costs and Losses, on the one hand, netted against its Gains, on the other. If the Non-Defaulting Party’s Costs and Losses exceed its Gains, then the Settlement Amount shall be an amount owing to the Non-Defaulting Party. If the Non-Defaulting Party’s Gains exceed its Costs and Losses, then the Settlement Amount shall be zero dollars ($0). The Settlement Amount does not include consequential, incidental, punitive, exemplary, or indirect or business interruption damages. “Settlement Interval” has the meaning set forth in the CAISO Tariff. “Settlement Period” has the meaning set forth in the CAISO Tariff. “Shared Facilities” means the gen-tie lines, transformers, substations, or other equipment, permits, contract rights, and other assets and property (real or personal), in each case, as necessary to enable delivery of Energy from the Facility (which is excluded from Shared Facilities) to the Interconnection Point, including the Interconnection Agreement itself, that are used in common with third parties or by Seller for electric generation or storage facilities owned by Seller other than the Facility.
“Showing Month” shall be the calendar month of the Delivery Term, commencing with the Showing Month that contains the RA Guarantee Date, that is the subject of the RA Compliance Showing, as set forth in the Resource Adequacy Rulings and outlined in the CAISO Tariff. For illustrative purposes only, pursuant to the CAISO Tariff and Resource Adequacy Rulings in effect as of the Effective Date, the monthly RA Compliance Showing made in June is for the Showing Month of August.
“Site” means the real property on which the Facility is or will be located, as further described in Exhibit A, and as shall be updated by Seller at the time Seller provides an executed Construction Start Date certificate in the form of Exhibit J to Buyer. “Site Control” means that, for the Contract Term, Seller (or, prior to the Delivery Term, its Affiliate): (a) owns or has the option to purchase the Site; (b) is the lessee or has the option to lease the Site; or (c) is the holder of an easement or an option for an easement, right-of-way grant, or similar instrument with respect to the Site.
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“SP-15” means the Existing Zone Generation Trading Hub for Existing Zone region SP15 as set forth in the CAISO Tariff.
“State of Charge” or “SOC” means the ratio of (a) the Stored Energy Level of the Facility to (b) the Storage Capacity multiplied by four (4) hours, expressed as a percentage. “Station Use” means the Energy that is used within the Facility to power certain lights, motors, temperature control systems, control systems and other ancillary electrical loads that are necessary for operation of the Facility (or as otherwise defined by the retail energy provider and CAISO Tariff) except during periods in which the Storage Facility is charging or discharging pursuant to a Charging Notice or Discharging Notice.
“Storage Capacity” means (a) the maximum dependable operating capability of the Storage Facility to discharge Energy that can be sustained for four (4) consecutive hours and (b) any other products that may be developed or evolve from time to time during the Contract Term that the Storage Facility is able to provide as the Facility is configured and subject to the Operating Restrictions and that relate to the maximum dependable operating capability of the Storage Facility to discharge Energy. “Storage Capacity Damages” has the meaning set forth in Exhibit B. “Storage Capacity Test” or “SCT” means any test or retest of the capacity of the Storage Facility and/or Efficiency Rate conducted in accordance with the testing procedures, requirements and protocols set forth in Section 4.9 and Exhibit O.
“Storage Contract Capacity” means the total capacity (in MW) of the Storage Facility initially equal to the amount set forth on the Cover Sheet, as the same may be adjusted from time to time pursuant to Section 5(b) of Exhibit B or Section 4.9 and Exhibit O to reflect the results of the most recently performed Storage Capacity Test.
“Storage Contract Output” means the product of the Storage Contract Capacity multiplied by four (4) hours, represented in MWh, initially equal to the amount set forth on the Cover Sheet, as the same may be adjusted from time to time pursuant to Section 5(b) of Exhibit B or Section 4.9 and Exhibit O to reflect the results of the most recently performed Storage Capacity Test.
“Storage Cure Plan” has the meaning set forth in Section 11.1(b)(vii). “Storage Facility” means the energy storage facility described on the Cover Sheet and in Exhibit A, located at the Site and including the Energy Management System and mechanical equipment and associated facilities and equipment required to deliver Storage Product (but excluding any Shared Facilities), and as such storage facility may be expanded or otherwise modified from time to time in accordance with the terms of this Agreement. “Storage Facility Meter” means a CAISO Approved Meter, along with a CAISO-approved data processing gateway or remote intelligence gateway, telemetering equipment and data acquisition services sufficient for monitoring, recording and reporting, in real time, the amount of Charging Energy delivered to the Storage Facility Metering Point and the amount of 270
Discharging Energy discharged from the Storage Facility at the Storage Facility Metering Points to the Delivery Point for the purpose of invoicing in accordance with Section 8.1. The Facility will contain multiple measurement devices that will make up the Storage Facility Meter, and, unless otherwise indicated, references to the Storage Facility Meter shall mean all such measurement devices and the aggregated data of all such measurement devices, taken together. “Storage Facility Metering Point” means the location or locations of the Storage Facility Meter shown on Exhibit R.
“Storage Payment” has the meaning set forth in Exhibit C. “Storage Product” means (a) Discharging Energy, (b) Capacity Attributes, if any, (c) Storage Capacity, and (d) Ancillary Services (as defined in the CAISO Tariff), if any, in each case arising from or relating to the Storage Facility.
“Storage Rate” has the meaning set forth on the Cover Sheet. “Stored Energy Level” means, at a particular time, the amount of Energy in the Storage Facility available to be discharged as Discharging Energy, expressed in MWh. “Supplementary Storage Capacity Test Protocol” has the meaning set forth in Exhibit O.
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“Supply Plan” has the meaning set forth in the CAISO Tariff. “System Emergency” means any condition that requires, as determined and declared by CAISO or the PTO, automatic or immediate action to (i) prevent or limit harm to or loss of life or property, (ii) prevent loss of transmission facilities or generation supply in the immediate vicinity of the Facility, or (iii) to preserve Transmission System reliability. “Tax” or “Taxes” means all U.S. federal, state and local and any foreign taxes, levies, assessments, surcharges, duties and other fees and charges of any nature imposed by a Governmental Authority, whether currently in effect or adopted during the Contract Term, including ad valorem, excise, franchise, gross receipts, import/export, license, property, sales and use, stamp, transfer, payroll, unemployment, income, and any and all items of withholding, deficiency, penalty, additions, interest or assessment related thereto. “Tax Credits” means the PTC, ITC and any other state, local or federal production tax credit, depreciation benefit, tax deduction or investment tax credit specific to the production of renewable energy or investments in renewable energy facilities. “Terminated Transaction” has the meaning set forth in Section 11.2(a). “Termination Payment” has the meaning set forth in Section 11.3. “Test Energy” means Generating Facility Energy delivered prior “Test Energy Rate” has the meaning set forth in Section 3.6. “Throughput” means, at any point in time during any day, or Contract Year, as applicable, the total cumulative amount of Discharging Energy from the Storage Facility at such point in time during such day, or Contract Year, as applicable (expressed in MWh).
“Transmission Provider” means any entity or entities transmitting or transporting the Facility Energy on behalf of Seller or Buyer to or from the Delivery Point. “Transmission System” means the transmission facilities operated by the CAISO, now or hereafter in existence, which provide energy transmission service downstream from the Delivery Point.
“Ultimate Parent” means SBE US Holdings One, LLC, a Delaware limited liability company.
“Variable Energy Resource” or “VER” has the meaning set forth in the CAISO Tariff. “WREGIS” means the Western Renewable Energy Generation Information System or any successor renewable energy tracking program.
“WREGIS Certificate Deficit” has the meaning set forth in Section 4.10(e). 272
“WREGIS Certificates” has the same meaning as “Certificate” as defined by WREGIS in the WREGIS Operating Rules and are designated as eligible for complying with the California Renewables Portfolio Standard.
“WREGIS Operating Rules” means those operating rules and requirements adopted by WREGIS as of October 2022, as subsequently amended, supplemented or replaced (in whole or in part) from time to time.