AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER AGENDA
Regular Meeting of the Board of Directors of
San Diego Community Power (Community Power)
Thursday, June 26, 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 you provide your name and city of residence for the record. Commenters are requested to address their comments to the Board of Directors as a whole through the Chair. Comments may be provided in one of the following manners:
1. Providing oral comments during 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 you have anything that you wish to 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
WELCOME
CALL TO ORDER
ROLL CALL
CLOSED SESSION
1. PUBLIC EMPLOYEE(S) PERFORMANCE EVALUATION(S) 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): Law Firm of Best, Best & Krieger LLP Unrepresented employee(s): Chief Executive Officer and General Counsel CALL TO ORDER – OPEN SESSION
ROLL CALL
REPORT ON CLOSED SESSION
PLEDGE OF ALLEGIANCE
LAND ACKNOWLEDGEMENT
2 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER
SPECIAL PRESENTATIONS AND INTRODUCTIONS
• Proclamation recognizing outgoing Community Advisory Committee member Gary Jahns
• 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 May 22, 2025, Meeting Minutes
2. Receive and File Treasurer’s Report for Period Ending April 30, 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 Marketing, Public Relations, and Local Government Affairs
7. Receive and File Community Advisory Committee Monthly Report
8. Receive and File Update on Regulatory and Legislative Affairs 3 AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER
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.
9. Approve Community Advisory Committee Member for City of Chula Vista Recommendation: Approve appointment of Alonso Gonzalez to the Community Advisory Committee for the City of Chula Vista.
10. Consider Amendments to Executive Employment Agreements a. Approve Amended and Restated Employment Agreement for Chief Executive Officer
Recommendation: Approve Amended and Restated Chief Executive Officer Employment Agreement.
b. Approve First Amendment to Employment Agreement for General Counsel Recommendation: Approve First Amendment to General Counsel Employment Agreement.
11. Tariffs, Tax Credits and Executive Orders: New-Build Market Outlook Update Recommendation: Receive and file the Community Power staff status report on federal policy and budget as it relates to clean energy procurement.
12. Public Hearing - AB 2561 - Status of vacancies, recruitment and retention efforts Recommendation: Hold a public hearing, receive comments, and accept report on the status of Community Power employee vacancy rates and recruitment and retention efforts.
13. Approve the FY 2025-2026 Operating Budget, the FY 2025-2026 Capital Budget, and the FY 2026-2030 Capital Investment Plan
Recommendation: Adopt Resolution No. 2025-06, approving the FY 2025-2026 Operating Budget, the FY 2025-2026 Capital Budget, and the FY 2026-2030 Capital Investment Plan.
14. Approve Update to San Diego Community Power’s Energy Risk Management Policy: California Carbon Allowance and Carbon Offset Transactions and Obligations
Recommendation: Adopt Resolution No. 2025-05 approving Addendum 2 to San Diego Community Power’s Energy Risk Management Policy: California Carbon Allowance and Carbon Offset Transactions and Obligations, to allow the CEO to approve procurement of California Carbon Allowance (CCA) and Carbon Offset (CO) to meet San Diego Community Power compliance obligations under California’s Cap-and-Trade Program.
AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER
15. Adoption of Resolution No. 2025-07, Authorizing Execution of an Energy Prepayment Transaction, Related Documents, and ‘Form of’ Documents Subject to Maximum Issuance Amount, Limitation on Fees, and Minimum Required Savings
Recommendation: Adopt Resolution No. 2025-07, approving parameters under which an energy prepayment transaction can be completed; authorizing and approving documents or “form of” documents supporting the prepay transaction; and directing California Community Choice Financing Authority (CCCFA) to make payments to service providers for issuance costs from prepay bond proceeds.
16. Approve Amended and Restated Energy Storage Service Agreement with Yellow Pine Solar III, LLC
Recommendation: Approve the proposed Amended and Restated Renewable Energy Storage Service Agreement with Yellow Pine Solar III, LLC to move the capacity between project sites, reduce the fixed capacity price, and make additional minor amendments, and authorize the Chief Executive Officer to execute the agreement.
17. Approve Energy Storage Service Agreement for the North Johnson Energy Center Recommendation: Approve the proposed 15-year Energy Storage Service Agreement with North Johnson Energy Center, LLC for a 50 MW/200 MWh, 4-hour battery energy storage facility and authorize the Chief Executive Officer to execute the agreement.
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.
ADJOURNMENT
The San Diego Community Power Board of Directors will adjourn to a regular meeting scheduled on Thursday, August 28, 2025, at 5 pm.
AGENDA – BOARD OF DIRECTORS – SAN DIEGO COMMUNITY POWER 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. 6 MEETING MINUTES – BOARD OF DIRECTORS – COMMUNITY POWER – MAY 22, 2025
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
May 22, 2025
______________________________________________________________________
WELCOME
CALL TO ORDER
Chair Aguirre called the Community Power Board of Directors regular meeting to order at 5 p.m.
ROLL CALL
PRESENT: Chair Aguirre, City of Imperial Beach; Director Elo-Rivera, City of San Diego (arrived at 5:02 p.m.); Director Inzunza, City of Chula Vista; Director San Antonio, City of Encinitas; Director Suzuki, City of La Mesa; and Director Yamane, City of National City
ABSENT: Vice Chair Lawson-Remer, County of San Diego
Staff Present: Chief Executive Officer Burns; General Counsel Tyagi; Director of Finance Manglicmot; Finance Manager Alfaro; Senior Financial Analyst Do; Financial Analysts Mercedes and Bateman; Director of Power Contracts Key; Director of Origination Torres; Clerk of the Board Hernandez; and Assistant Clerk of the Board Vences
PLEDGE OF ALLEGIANCE
Chair Aguirre led the Pledge of Allegiance.
SPECIAL PRESENTATIONS AND INTRODUCTIONS
• Introduction of New Community Power Staff
Chair Aguirre welcomed new employee Krystal Carranza, Procurement Analyst, to introduce herself.
7 MEETING MINUTES – BOARD OF DIRECTORS – COMMUNITY POWER – MAY 22, 2025
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 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
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 There were no public comments on Consent Item Nos. 1-9.
Motioned by Director Inzunza and seconded by Director Yamane to approve Consent Calendar Item Nos. 1 through 9. The motion carried 6/0 as follows:
AYES: Chair Aguirre, Directors Elo-Rivera, Inzunza, San Antonio, Suzuki, and Yamane
NOES: None
ABSTAINED: None
ABSENT: Vice Chair Lawson-Remer
8 MEETING MINUTES – BOARD OF DIRECTORS – COMMUNITY POWER – MAY 22, 2025
REGULAR AGENDA
10. Community Advisory Committee Report
Community Advisory Committee (CAC) Chair Vasilakis provided a quarterly report on CAC’s activities.
There were no public comments on Item No. 10.
Board members expressed appreciation to Mr. Vasilakis for his continued work and efforts on the CAC.
After Board member discussion and comments, the CAC quarterly report was received and filed.
11. Presentation of Draft of FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan Mr. Manglicmot presented an overview of the draft FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan.
Jake Marshall, Operations Manager at Greentech Renewables San Diego, provided a public comment.
After Board member questions, discussion and comments, the draft FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan was received and filed.
12. Approve Amended and Restated Renewable Power Purchase Agreement with Pelicans Jaw Solar, LLC
Mr. Key presented the proposed Amended and Restated Renewable Power Purchase Agreement with Pelicans Jaw Solar, LLC.
There were no public comments on Item No. 12.
After Board member questions, discussion and comments, motioned by Chair Aguirre and seconded by Director Yamane to 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.
The motioned carried 6/0 as follows:
AYES: Chair Aguirre, Directors Elo-Rivera, Inzunza, San Antonio, Suzuki, and Yamane
9 MEETING MINUTES – BOARD OF DIRECTORS – COMMUNITY POWER – MAY 22, 2025 NOES: None
ABSTAINED: None
ABSENT: Vice Chair Lawson-Remer
13. Approve Amended and Restated Power Purchase Agreement with Noble Solar, LLC
Mr. Key presented the proposed Amended and Restated Power Purchase Agreement with Noble Solar, LLC.
There were no public comments on Item No. 13.
After Board member questions, discussion and comments, motioned by Director Yamane and seconded by Director Suzuki to 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. The motioned carried 6/0 as follows:
AYES: Chair Aguirre, Directors Elo-Rivera, Inzunza, San Antonio, Suzuki, and Yamane
NOES: None
ABSTAINED: None
ABSENT: Vice Chair Lawson-Remer
14. Approve EEI Master Agreement, Confirmation and Collateral Annex with Clean Power Alliance of Southern California
Ms. Torres presented the proposed EEI Master Agreement, Confirmation and Collateral Annex with Clean Power Alliance of Southern California.
There were no public comments on No. 14.
After Board member questions, discussion and comments, motioned by Chair Aguirre and seconded by Director Inzunza to 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. The motioned carried 6/0 as follows:
AYES: Chair Aguirre, Directors Elo-Rivera, Inzunza, San Antonio, Suzuki, and Yamane
NOES: None
10 MEETING MINUTES – BOARD OF DIRECTORS – COMMUNITY POWER – MAY 22, 2025 ABSTAINED: None
ABSENT: Vice Chair Lawson-Remer
CHIEF EXECUTIVE OFFICER REPORT
Ms. Burns reported on Community Power’s recent activities and events.
DIRECTOR COMMENTS
There were no Director comments.
CLOSED SESSION:
There were no public comments on Closed Session Item Nos. 1 and 2.
The Board recessed into Closed Session at 6:29 p.m. to hear item Nos. 1 and 2.
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
The Board reconvened in Open Session with a quorum present at 7:49 p.m.
PRESENT: Chair Aguirre, City of Imperial Beach; Director Elo-Rivera, City of San Diego; Director Inzunza, City of Chula Vista; Director San Antonio, City of Encinitas; Director Suzuki, City of La Mesa; and Director Yamane, City of National City
ABSENT: Vice Chair Lawson-Remer, County of San Diego
Staff Present: General Counsel Tyagi; BBK Counsel de Sousa; Clerk of the Board Hernandez; and Assistant Clerk of the Board Vences
11 MEETING MINUTES – BOARD OF DIRECTORS – COMMUNITY POWER – MAY 22, 2025 REPORT ON CLOSED SESSION:
Legal Counsel de Sousa reported that the Closed Session commenced at 7:35 p.m. and there were no reportable actions.
ADJOURNMENT
Community Power Board meeting adjourned at 7:49 p.m. to the next regular meeting scheduled for Thursday, June 26, 2025, at 5 p.m.
_____________________________
Maricela Hernandez, MMC, CPMC
Clerk of the Board
12 SAN DIEGO COMMUNITY POWER
Staff Report – Item 2
____________________________________________________________________________________ TO: Board of Directors
FROM: Eric W. Washington, Chief Financial Officer/Treasurer VIA: Karin Burns, Chief Executive Officer
SUBJECT: Treasurer’s Report for Period Ending April 30, 2025 DATE: June 26, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and File Treasurer’s Report for Period Ending April 30, 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 ten-month period ended April 30, 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.
13 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 April 30, 2025: $1,033.0 million in net operating revenues were reported compared to $1,033.6 million budgeted for the period. $1,009.4 million in total expenses were reported (including $968.7 million in energy costs) compared to $1,034.1 million budgeted for the period (including $972.5 million budgeted for energy costs). After expenses, Community Power’s change in net position of $23.6 million was reported year-to-date for FY 2024-25. The following is a summary of the actual results compared to the amended FY 2024-25 Operating Budget.
Table 1: Budget Comparison Versus Actual Result
• Net operating revenues finished $0.6 million (or 0.1 percentage points) under the budget and was largely in line with expectations. Customers also received the California Climate Credit in April 2025 which partially offset customer arrearages. • Operating expenses finished $24.7 million (or 2.0 percentage points) under the budget due to the sale of certain renewable resources, a reclassification of CAISO settlement fees from January 2025, and unhedged energy at higher prices than budgeted.
YTD FY25 as of
4/30/25 (10 months)
FY25 YTD Budget
Amended
Budget Variance
($) Budget (%)
Net Operating Revenues $ 1,032,972,314 $ 1,033,560,599 $ (588,285) 99.9% Total Expenses $ 1,009,359,387 $ 1,034,085,870 $ (24,726,483) 98% Change in Net Position $ 23,612,927 $ (525,271) $ 24,138,198 Budget Comparison
14 Figure 1: Budget Comparison versus Actual Results
For the ten-month period ending April 30, 2025, Community Power contributed $23,612,928 to its net position compared to the expected deficit of ($525,271) per the FY 2024-25 Operating Budget. Total Community Power reserves at the end of the period were $322,766,955 based on cash and cash equivalents – unrestricted, and total available liquidity (including lines of credit) was $535,266,955. Community Power has a total FY 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 April 31, 2025, the market value of the portfolio was $61.5 million compared to the $61.4 million market value as of March 31, 2025. The rise in market value is reflective of accrued interest during the month. The following is a snapshot of overall characteristics of the portfolio.
$(200,000,000)
$-
$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 4/30/25 (10 months) FY25 YTD Budget Amended 15 Contract Execution between $50,000 and $125,000
There were no contracts in May that were executed between $50,000 and $125,000. 16 Metrics
Figure 2: Participation Rates as of 6/1/2025
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.
17 • 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 June 1, 2025. The $2 million decline in arrearages was attributed to the receipt of the California Climate Credit in April 2025 which partially offset customer arrearages.
Figure 3: State of Community Power Arrearages as of 6/1/2025 Figure 4: State of Community Power Arrearages Residential vs Commercial as of 6/1/2025 FISCAL IMPACT:
N/A
COMMITTEE REVIEW:
This item was presented at the Finance and Risk Management Committee on June 12, 2025. The Committee received and filed the report.
18 ATTACHMENTS:
A: 2025 Year-to-Date Period Ended April 30, 2025, Financial Statements. 19 ITEM 2
ATTACHMENT A
20 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 April 30, 2025, and the related statement of revenues, expenses, and changes in net position, and the statement of cash flows for the ten 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
June 4, 2025
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com 21 Current assets
Cash and cash equivalents - unrestricted 322,766,955$
Cash and cash equivalents - restricted 14,105,819
Accounts receivable, net of allowance 85,306,096
Accrued revenue 41,175,142
Prepaid expenses 7,207,103
Other receivables 10,284,546
Deposits 10,167,029
Investments 2,808,767
Total current assets 493,821,457
Noncurrent assets
Cash and cash equivalents - restricted 647,000
Investments 57,969,963
Capital assets, net of depreciation and amortization 1,509,937 Total noncurrent assets 60,126,900
Total assets 553,948,357
Current liabilities
Accrued cost of electricity 117,999,609
Accounts payable 3,524,236
Other accrued liabilities 1,975,488
State surcharges payable 175,048
Deposits - energy suppliers 3,263,000
Lease liability 804,984
Advances from grantors 13,605,819
Total current liabilities 141,348,184
Noncurrent liabilities
Lease liability 746,779
Deposits - energy suppliers 4,410,450
Total noncurrent liabilities 5,157,229
Total liabilities 146,505,413
Restricted for security collateral 14,752,819
Unrestricted 392,690,125
Total net position $ 407,442,944
NET POSITION
SAN DIEGO COMMUNITY POWER
STATEMENT OF NET POSITION
As of April 30, 2025
ASSETS
LIABILITIES
See accountants' compilation report. 2
22 OPERATING REVENUES
Electricity sales, net $ 1,031,704,056
Grant revenue 1,277,998
Other income 1,268,258
Total operating revenues 1,034,250,312
OPERATING EXPENSES
Cost of electricity 968,694,635
Contract services 16,239,471
Staff compensation 13,833,929
Other operating expenses 13,619,317
Depreciation and amortization 533,960
Total operating expenses 1,012,921,312
Operating income 21,329,000
NON-OPERATING REVENUES (EXPENSES)
Investment income 11,164,558
Interest expense (432,996)
Nonoperating revenues (expenses), net 10,731,562
CHANGE IN NET POSITION 32,060,562
Net position at beginning of year 375,382,382
Net position at end of year $ 407,442,944
SAN DIEGO COMMUNITY POWER
STATEMENT OF REVENUES, EXPENSES
AND CHANGES IN NET POSITION
Ten Months Ended April 30, 2025
See accountants' compilation report. 3
23 CASH FLOWS FROM OPERATING ACTIVITIES
Receipts from customers $ 1,087,655,899
Receipts from grantors 14,883,817
Receipts of supplier security deposits 15,187,455
Other operating receipts 1,246,064
Payments to suppliers for electricity (983,518,699)
Payments for other goods and services (30,326,203)
Payments for deposits and collateral (1,974,371)
Payments for staff compensation (13,839,179)
Payments of state surcharges (2,411,387)
Net cash provided by operating activities 86,903,396
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 (540,492)
Net cash used by capital and related financing activities (540,492)
CASH FLOWS FROM INVESTING ACTIVITIES
Investment income received 9,818,815
Proceeds from investment sales and maturities of investments 642,757 Purchase of investments (60,352,851)
Net cash provided (used) by investing activities (49,891,279) Net change in cash and cash equivalents 36,077,664
Cash and cash equivalents at beginning of year 301,442,110 Cash and cash equivalents at end of year $ 337,519,774
Reconciliation to the Statement of Net Position
Cash and cash equivalents (unrestricted) $ 322,766,955
Restricted cash - current 14,105,819
Restricted cash - noncurrent 647,000
Cash and cash equivalents $ 337,519,774
NONCASH INVESTING ACTIVITIES
Unrealized appreciation and timing differences in investment income $ 1,345,743
NONCASH CAPITAL AND RELATED
FINANCING ACTIVITIES
Acquisition of lease asset $ 1,284,053
SAN DIEGO COMMUNITY POWER
STATEMENT OF CASH FLOWS
Ten Months Ended April 30, 2025
See accountants' compilation report. 4
24 Operating income $ 21,329,000
Adjustments to reconcile operating income to net
cash provided by operating activities
Depreciation and amortization expense 533,960
(Increase) decrease in:
Accounts receivable, net 18,206,069
Accrued revenue 35,688,281
Prepaid expenses 27,811,297
Other receivables (4,118,581)
Deposits 1,995,170
Increase (decrease) in:
Accrued cost of electricity (30,116,707)
Accounts payable (1,483,641)
Advances from grantors 13,605,819
Other accrued liabilities 812,173
State surcharges payable (353,894)
Deposits - energy suppliers 2,994,450
Net cash provided by operating activities $ 86,903,396
SAN DIEGO COMMUNITY POWER
STATEMENT OF CASH FLOWS (continued)
Ten Months Ended April 30, 2025
RECONCILIATION OF OPERATING INCOME TO NET
CASH PROVIDED BY OPERATING ACTIVITIES
See accountants' compilation report.
25 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 ten months ended April 30, 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
June 4, 2025
1101 Fifth Avenue, Suite 200 San Rafael, CA 94901 415 459 1249 mahercpa.com 26 Amended
Budget Actual
Amended
Budget Variance
(Under) Over
Actual/
Amended
Budget %
Amended
Budget
Amended
Budget
Remaining
REVENUES AND OTHER SOURCES
Gross Ratepayer Revenues 1,051,970,075 1,050,080,464$ (1,889,611) 100% 1,243,010,863 $ 192,930,399 Less: Uncollectible Customer Accounts (18,409,476) (18,376,408) 33,068 100% (21,752,690) (3,376,282) Other Income 1,268,258 - 1,268,258 na (1,268,258) - Total Revenues and Other Sources 1,033,560,599 1,032,972,314 (588,285) 1,221,258,173 188,285,859
OPERATING EXPENSES
Cost of Energy 972,511,996 968,694,635 (3,817,361) 100% 1,116,836,549 148,141,914 Professional Services and Consultants 20,288,630 15,323,700 (4,964,930) 76% 24,346,342 9,022,642Personnel Costs 15,473,240 12,965,257 (2,507,984) 84% 18,567,895 5,602,639 Marketing and Outreach 2,482,173 1,496,972 (985,201) 60% 2,978,593 1,481,621 General & Administrative 4,091,468 2,360,508 (1,730,960) 58% 4,909,761 2,549,253 Total Operating Expenses 1,014,847,507 1,000,841,071 (14,006,436) 1,167,639,140 166,798,070 Operating Income (Loss) 18,713,092 32,131,243 13,418,151 53,619,033 21,487,790
NON-OPERATING REVENUES (EXPENSES)
Investment Income 11,164,558 - 11,164,558 na (11,164,558) - Interest and Related Expenses (1,063,333) (1,507,844) (444,511) 142% (1,276,000) 231,844 Transfer to Capital Investment Program (18,175,030) (18,175,030) 100% (18,175,030) - - Total Non-Operating Revenues (Expenses) (19,238,363) (8,518,316) 10,720,047 (19,451,030) (10,932,714) NET CHANGE $ (525,271) $ 23,612,928 $ 24,138,199 $ 34,168,003 $ 10,555,075
SAN DIEGO COMMUNITY POWER
BUDGETARY COMPARISON SCHEDULE
Ten Months Ended April 30, 2025
OPERATING FUND
Year-to-Date Annual
See accountants' compilation report.
27 SAN DIEGO COMMUNITY POWER
Staff Report – Item 3
____________________________________________________________________________________ TO: Board of Directors
FROM: Colin Santulli, Senior Director of Programs
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Update on Programs
DATE: June 26, 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: The Commercial Application Assistance Pilot has now concluded, and a final pilot summary report was compiled by TRC for staff. Through the pilot, 20 key accounts were engaged, with over three million kWh per year of potential savings identified. The pilot identified over $12M in program funding for customers although it was not possible to ascertain how much was actually received due to application timelines and awards not aligning with the Pilot timelines.
Next Steps: Program staff is working with the Accounts Team to assess the need for a continued program offering and evaluate changes to the pilot structure to scale into a full program.
28 Efficient Refrigeration Pilot Project
Status: Staff began outreach for the Efficient Refrigeration Pilot in March 2025. Eligible corner stores, small businesses, and nonprofits in low-income and low-food-access areas within Community Power’s service territory can receive up to two energy-efficient refrigerators and/or freezers and an American Society of Heating, Refrigerating, and Air-Conditioning Engineers (“ASHRAE”) Level 1 energy audit at no cost to the participant.
The pilot aims to serve a total of 24 participants. To date, Staff have been conducting targeted outreach for the pilot primarily by engaging member agency staff, elected officials, and community organizations. As of June 6, 2025, 14 participants have been enrolled in the pilot.
Next Steps: Staff will continue to conduct outreach and enroll participants in the pilot until grant funds are expended.
Residential Programs
California Energy Commission (“CEC”) Equitable Building Decarbonization Direct Install (“EBD DI”) Program
Status: At the April 2024 Board of Directors meeting, the Board adopted Resolution No. 025-03 that authorized Staff to execute a Memorandum of Understanding (“MOU”) between Community Power and Los Angeles County (“LA County”), the Program Administrator for the EBD DI Program. The MOU was fully executed at the end of May 2025 by LA County.
At the April 2025 Board meeting, the Board requested clarification on tenant protections and displacement-related requirements. The program guidelines require that Program Administrators (i.e., LA County) design projects to avoid displacement. LA County has clarified that, due to budget constraints, projects where resident displacement is unavoidable will not be prioritized. The EBD DI program lacks dedicated funding to cover displacement-related costs. Before any project begins, residents and property owners will be presented with an assessment and plan that describes the benefits of specific measures and any potential impacts from the work, including potential displacement, so they can adjust measures and make an informed decision about continuing with participation.
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 DI program, anticipated summer 2025.
29 Flexible Load Programs
Smart Home Flex Pilot Project
Staff continue to work with Virtual Peaker to prepare to initiate Smart Flex Events this summer. Staff are creating a strategy for calling events that best utilize the smart thermostats to bring value to Community Power and pilot participants. Staff anticipate most events to be called in the late summer months of August and September since that is when Community Power typically sees the highest prices for energy and resource adequacy.
Staff are planning to add heat pump water heaters to the Smart Home Flex pilot later this calendar year. Staff are targeting water heaters incentivized through the TECH Clean CA program, which are equipped with thermostatic mixing valves allowing Community Power to safely heat water up to 140 degrees. This will avoid heating water during Smart Home Flex events while ensuring customers continue to receive hot water when they need it.
Next Steps: Staff are continuing to work with Virtual Peaker and the Power Services team to prepare for the Smart Flex Events this summer and add electric heat pump water heaters with built-in smart capabilities.
EV Flex Connect Pilot Project
Status: Staff launched EV Flex Connect in February 2025 and continue to work with its implementation partner to increase participant enrollment. On May 15, 2025, Staff was notified that it received an award for its proposal to California Energy Commission (“CEC”) Grant Funding Opportunity 24-302 — Enabling Electric Vehicles as Distributed Energy Resources. The awarded project will use data from EV Flex Connect together with distribution data from SDG&E to analyze and quantify the value of V1G strategies. Staff will work with external partners, including SDG&E, Optiwatt, and the U.S. Department of Energy’s Pacific Northwest National Laboratory, to execute this project.
Next Steps: Staff will continue to work with its implementation partner on increasing participant enrollment and begin planning activities for the awarded CEC grant.
Solar and Energy Storage Programs
Disadvantaged Communities–Single-Family Affordable Solar Homes (“DAC-SASH”) Readiness Pilot Project Status: GRID Alternatives (“GRID”) has been working to process DAC-SASH applications and complete roof repair work by the pilot deadline. While GRID has identified potential projects, projects have dropped out due to building code issues that are too difficult or expensive to correct, electrical usage too low to meet DAC-SASH minimum system requirements, and/or lack of responsiveness/loss of contact. This has led Staff to extend pilot deadline to June 30, 2025, to ensure that as many homes as possible receive the benefits of the pilot and DAC-SASH program.
30 Next Steps: Once the pilot is complete, GRID will work on a final pilot report identifying successes, challenges, and opportunities. Staff anticipate bringing a full update on the pilot to the Board this summer 2025.
Net Energy Metering (“NEM”) and Net Billing Tariff (“NBT”) Status and Next Steps: Please refer to Item 2 of the December 2023 Board staff report for the most recent update on this program.
Solar Battery Savings (“SBS”) Program
Status: Staff continue to work on the development of the Residential Solar Battery Savings (SBS) Program. Building on the success of the SBS Pilot launched in 2024, staff are making improvements to the program design with a goal of launching the SBS Program in late Q3 2025. Staff held two informational sessions with solar and storage contractors in late May to receive feedback on program design changes under consideration. Over 30 contractors attend the in-person and virtual feedback sessions.
Next Steps: Staff continue to finalize program documentation and other pre-launch activities (e.g., improving the program’s web-based contractor portal to improve program efficiency, developing marketing collateral to provide consistent program messaging to contractors and participants.)
Solar Advantage Program
Status: Please refer to Item 3 of the May 2025 Board staff report for the most recent update on this program.
Next Steps: Staff anticipates filing an additional extension request due to continued negotiations for one of the bids received from the first Request for Offer (“RFO”). Staff anticipates bringing this PPA to the Board of Directors meeting for review and approval in Q3 2025.
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, questions were due on May 15, 2025, and responses to questions were posted on Community Power’s solicitation webpage on May 22, 2025.
Next Steps: Staff will finalize contract negotiations with vendors selected from the Phase 1 solicitation. Staff anticipate contracts to be signed by the end of July 2025 in accordance with Resolution No. 2025-01 adopted by the Board on January 23, 2025, authorizing the 31 Chief Executive Officer to ‘negotiate and execute contracts with third parties to implement the agreement or use of [SDREN] funds.’ Contracts are expected to be executed with selected vendors with amounts not exceeding the budgets stated in the solicitations, which are $800,000 for administrative, regulatory, and reporting support; $5,556,916 for the Codes and Standards Program; $5,556,916 for the Energy Pathways Program; and $9,030,024 for the Workforce Training and Capacity Building Program. SDREN funds are authorized by the California Public Utilities Commission and are disbursed to San Diego Community Power in accordance with the San Diego Regional Energy Network Energy Efficiency Programs and Budget Agreement for Years 2024-2027 executed between Community Power and SDG&E (under Resolution No. 2025-01).
Additionally, the Phase 3 solicitation is planned to close on June 26, 2025. Staff anticipate awarding contracts for Phase 2 solicitations in Q3 CY 2025, and the Phase 3 solicitation in Q4 CY 2025.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
32 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: June 26, 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 thirteen people strong. The Power Services team has one open position currently for a Chief Commercial Officer, and is excited to continue stable, prudent growth through 2025.
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 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 33 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 have over two dozen long-term contracts executed for energy, renewable energy credits and/or capacity from renewable and storage projects.
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 second 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 34 the Board in January. 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 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 remained steady due to relatively mild weather and high renewable power supply. Summer forecasts indicate higher chances of above normal temperatures throughout the West, with slightly lower chances in coastal locations. No supply shortfalls are expected, but markets remain sensitive to extreme weather events and unexpected supply shortages.
FISCAL IMPACT:
N/A
ATTACHMENTS:
N/A
35 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: June 26, 2025
____________________________________________________________________________________ RECOMMENDATION:
Receive and file an update on various customer operations’ initiatives.
BACKGROUND:
Staff will provide regular updates to the Board of Directors 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 May 19, 2025, Community Power is serving a cumulative total count of 957,504 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 2 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. 36 B) Customer Participation Tracking
The below charts summarize customer elections into San Diego Community Power’s four (4) available service levels:
37 38
39 40
41 42
43 D) Contact Center Metrics
As anticipated, call volumes have continued to decrease as a result of the temperate weather and lower winter electricity rates.
The chart below summarizes contact made by customers into the Contact Center broken down by month:
44 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.
As of this latest reporting month, Community Power has 9 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
45 SAN DIEGO COMMUNITY POWER
Staff Report – Item 6
____________________________________________________________________________________ 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: June 26, 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
46 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 47 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
48 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: Community Advisory Committee Monthly Report
DATE: June 26, 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 on the regular agenda and monthly reports on the consent agenda. The next quarterly update is expected to take place at the September 25, 2025 Board meeting.
ANALYSIS AND DISCUSSION:
During the June 12, 2025, regular CAC meeting:
• Vice-Chair Emerson (City of National City) 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 held elections for its Fiscal Year 2025-2026 Officers. The results were as follows:
o Chair: David Harris (La Mesa)
49 o Vice-Chair: Luis Montero-Adams (City of San Diego) o Secretary: Ross Pike (Unincorporated San Diego County) • Members received a joint presentation from the Regulatory and Legislative Affairs and Power Services teams on Tariffs, Tax Credits and Executive Orders: New-Build Market Outlook. Members relayed concern around the uncertainty regarding federal tax credits and tariffs and encouraged staff to advocate for alternate ways to incentivize developers, such as expediting permitting processes. • The CAC also discussed the Draft Fiscal Year 2025-2026 Operating and Capital Budgets, as well as the Fiscal Year 2026-2030 Capital Improvement Plan.
Members asked questions on reserve target timelines, the qualifications of the consultant providing Community Power’s enterprise-wide data platform, the Solar Battery Savings program and its implementation, as well as earned media opportunities.
• The Vice-Chair shared as an announcement the departure of Member Jahns from the CAC, who is ending his last term, and will be formally recognized at the Board of Directors at their next regular meeting. The CAC will observe a July meeting recess. No Board of Directors items were recommended.
As of June 12, 2025, the CAC has one vacancy representing the City of Chula Vista, with an appointment for the Board of Directors’ consideration expected to be heard during the June 26, 2025 regular meeting. Come July 2025, the CAC also has an expected vacancy for the City of Encinitas.
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
50 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: June 26, 2025
______________________________________________________________________ RECOMMENDATION:
Receive and file the update on regulatory and legislative affairs.
BACKGROUND:
Staff provides regular updates to the Board of Directors regarding Community Power’s regulatory and legislative engagement. Please see Item No. 11 for the update on federal policy matters.
ANALYSIS AND DISCUSSION:
A) Regulatory Updates
Power Charge Indifference Adjustment
On May 23, 2025, the California Public Utilities Commission (CPUC) issued a Proposed Decision in Track 1 of the Power Charge Indifference Adjustment (PCIA) proceeding. The Track 1 Proposed Decision adopts several methodological changes to the Resource Adequacy (RA) Market Price Benchmark (MPB), which is part of the calculation for determining the market value of the investor-owned utility’s (IOU) – such as San Diego Gas and Electric (SDG&E) – portfolio of resources that it procured on behalf of customers who departed to another provider, such as Community Power. Specifically, the Proposed Decision addresses five proposals from CPUC Energy Division staff, as outlined in a staff proposal released in February 2025. Community Power’s trade association, the California Community Choice Association (CalCCA), took positions on each of the staff proposals in previous comments and briefs; for additional background, see the April 2025 regulatory update to the Board of Directors on page 49 and the May 2025 regulatory update to the Board of Directors on page 46. The table below outlines the five CPUC staff proposals, 51 CalCCA’s position on each proposal, and what the CPUC is ultimately proposing to adopt in the Proposed Decision.
CPUC Staff Proposal CalCCA Position CPUC Proposed Decision Include all transactions
available for given delivery
year for all system, flex,
and local RA forecast and
final adders
Reject: Inclusion in the RA
MPB of all transactions
deliverable, rather than
transacted, in a year does
not reflect current market
value as required by the
RA MPB Framework
Adopts Modified: RA MPB
based upon three-years’
transaction data for the
forecast calculation and
four-years’ transaction data
for the final calculation
Exclude affiliate
transactions from the
calculation of the MPB
Support: Risk of price
manipulation and distorting
the accuracy of the RA
MPB
Adopts
Exclude swap and sleeve
transactions from the MPB
Support: To the extent the
CPUC can identify such
transactions in an objective
and transparent manner
Adopts Modified: Swap
transactions shall be
excluded and utilize a
single transaction within a
sleeve transaction
Consider using monthly
values for the MPBs
Support: More accurately
reflects seasonal prices
Deferred: Beyond the
scope of Track 1
Consider using one value
for all MPBs, including
system, local and flexible
Support: Maximizes the
overall transaction sample
size
Adopts
The Proposed Decision proposes to apply the changes outlined above to the calculation of the 2025 Final and 2026 Forecast RA MPB. Opening comments on the Proposed Decision are due June 12, 2025, reply comments are due June 17, 2025, and the earliest the CPUC can vote on a Final Decision is June 26, 2025.
Community Choice Aggregator (CCA) Customer Access to Self-Generation Incentive Program (SGIP) Funding
Community Power submitted a formal letter to the CPUC urging immediate action to resolve inequities preventing low-income CCA customers from accessing Self-Generation Incentive Program (SGIP) Residential Storage and Solar Equity (RSSE) funds.
Community Power, in coordination with CCAs across the state, have engaged with the CPUC in good faith to resolve this issue for over a year with no resolution, meanwhile the RSSE program funding was released on June 2, while current program rules provide no practical pathway for CCA customers to be eligible for funding. The SGIP program requires enrollment in a “Qualified Demand Response” program, but none currently exists for CCA customers. Currently, the only approved “Qualified Demand Response” (DR) program in San Diego is limited to bundled customers, leaving 70% of the region’s residents, including SDCP customer, unable to participate unless they opt out of CCA service and face higher costs. SDCP has a pending advice letter seeking approval of its 52 Solar Battery Savings program, which meets the stated goals of the SGIP program and would provide immediate access to SGIP incentives.
Integrated Resource Planning
On April 29, 2025, the CPUC issued a Ruling requesting comment on the Reliable and Clean Power Procurement Program (RCPPP) 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 held a workshop to present the Staff Proposal and answer parties’ questions on May 16. The CPUC granted a request to extend the comment deadline, which is now July 15, and reply comments are due August 5, 2025.
Resource Adequacy
On May 22, 2025, the CPUC issued a Proposed Decision in the Resource Adequacy (RA) proceeding adopting Local Capacity Requirements for 2026-2028, Flexible Capacity Requirements for 2026, refinements to the RA program, and closing the proceeding. The Proposed Decision establishes RA needs as well as addresses the proposals submitted by more than 20 parties in March 2025, including:
• Adopts Local Capacity Requirements for the San Diego/Imperial Valley Region to be 2,631 MW in 2026, 2,800 MW in 2027, and 2,968 MW in 2028. 53 • Adopts an 18 percent planning reserve margin (PRM), with an extension of the effective PRM target of 1,260-2,300 MW for June-October (translates to 3-5.5%), for 2026 and 2027.
• Does not adopt hourly load transactions, as proposed by CalCCA, instead authorizes Energy Division to prepare a report on whether transactability issues exist in 2nd Quarter (Q2) 2026.
• Finds CalCCA’s proposal to count co-located energy-only resources as RA resources is not adequately developed.
• Adopts proposal that if an LSE that cures its deficiency with a new resource coming online before the T-1 deadline, the LSE will not be assessed penalties. • Agrees it is reasonable to extend the off-peak import counting rule, as the rule may help with affordability issues with off-peak imports that are lower cost than a 24 x 7 product.
• Modifies the load migration update process as follows: an LSE is permitted one load migration update in mid-February to cover June to December load migration.
Other than the one load migration update, an LSE’s load forecast is locked in for the January-May timeframe and the June-December timeframe for each RA compliance year.
Opening comments on the Proposed Decision are due June 11 and reply comments are due June 16, 2025.
Green Access Proceeding
On May 8, 2025, the CPUC issued Draft Resolution E-5367 adopting an updated methodology for the cost containment cap for the Disadvantaged Communities Green Tariff (DAC-GT) program. Community Power administers the DAC-GT program for its service area (regionally referred to as the Solar Advantage program), which provides 100 percent clean energy at a 20 percent total bill discount to residential customers who reside in disadvantaged communities as defined by the California Environmental Protection Agency’s CalEnviroScreen tool. The program utilizes state funding sources to pay above market costs for power purchase agreements for local, renewable energy projects that meet program requirements, but those costs are limited by a cost containment cap.
Draft Resolution E-5367 largely adopts the updated cost containment cap methodology proposed by the Joint IOUs, which differs from what was proposed by the Joint CCAs, including Community Power, as outlined in the table below. 54 The Joint CCAs filed comments (Attachment A) on Draft Resolution E-5367, highlighting the shortcomings of the proposal and offering improvements to make the cost containment cap more reflective of current market conditions and enable a successful program.
Provider of Last Resort
On May 28, 2025, the CPUC issued a Ruling providing parties the opportunity to comment on the CPUC guidance necessary to establish a procedural pathway to review applications for Provider of Last Resort (POLR) status.
Based on the record, it is unknown whether any non-investor-owned utility (IOU) entity will seek to apply to serve as POLR in place of the existing IOU POLR for all the IOU’s customers within a geographic subset of one or more of the IOU’s current territory. Given these uncertainties, this ruling seeks party comment on (1) the Commission’s authority over a non-IOU POLR; and (2) a potential procedural path to consider any future applications for POLR status.
The Ruling outlines a potential procedural pathway in which the Commission issues a decision that provides a framework for its regulatory authority over a non-IOU POLR and the services it provides. Such a decision would close the instant proceeding and direct any non-IOU entity that seeks POLR status to first file and serve a Petition for Rulemaking (PFR) at least 12 months before filing an application to assume POLR responsibilities.
Upon receipt of a PFR, the Commission would resume its consideration of the threshold questions and topic areas identified in the Scoping Memo.
Opening Comments are due by June 13, and Reply Comments are due by June 20, 2025.
55 SDG&E Energy Resource Recovery Account (ERRA) Forecast The purpose of the ERRA Forecast proceeding is to review the forecasted costs that SDG&E will incur to procure energy resources (fuel for power plants, purchased power, and GHG Costs & Allowance Revenues) in the coming year. Based on these forecasts, the CPUC approves rates that allow utilities to recover these costs from customers.
SDG&E 2026 ERRA Forecast Case
On May 15, 2025, SDG&E filed its Application for approval of its 2026 Electric Procurement Revenue Requirement (ERRA), electric sales, and GHG-related forecasts.
Additionally, SDG&E requests approval for its proposed 2026 GHG Allowance Return rates, vintage Power Charge Indifference Adjustment (PCIA) rates, and Modified Cost Allocation Mechanism (MCAM) rates. SDG&E anticipates filing its October Update on October 14, 2025.
SDG&E requests a total 2026 forecasted revenue requirement of $270.5 million, an increase of $148.2 million from current rates. The proposed rate changes, based on the ERRA revenue requirement and electric sales forecast, would result in a 10.6% increase in the total bundled system average rate, or an additional 3.6 per kWh. Without the Residential and Small Business Semi-Annual California Climate Credit, the rate would rise by 9%, or 3.2 cents per kWh. For unbundled customers, SDG&E's system average delivery with PCIA rates would increase by 8%, or 1.4 cents per kWh, and by 5.1%, or 1 cent per kWh without the Residential and Small Business Semi-Annual CCC.
In terms of customer impact for customers using 400 kWh per month, a typical bundled non-CARE residential customer using 400 kWh per month may experience an increase of 14.8% ($23). A typical bundled CARE residential customer’s bill may increase by 18.3% ($16). For unbundled customers, a non-CARE residential bill would rise by 12.2% ($10), and a CARE customer’s bill would increase by 18.0% ($8).
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 2024 ERRA Compliance Case
San Diego Gas & Electric filed its 2024 Energy Resource Recovery Account Compliance application with the California Public Utilities Commission. The filing requests Commission verification that all procurement-related activities, including contract administration fuel procurement and least cost dispatch were conducted in compliance with applicable CPUC decisions and statutory requirements throughout the calendar year 56 2024. SDG&E is not requesting any rate changes as part of this application. The utility is seeking approval of recorded entries in a range of balancing and memorandum accounts.
The application also provides a summary of public safety power shutoff events during 2024 and their associated customer impacts, though no disallowances are proposed in this filing. Responses and protests to the application are due July 2.
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 were filed on May 9. SDG&E’s reply brief argues that the CPUC should be authorized to recover the costs of the Green Tariff program from all customers via the Public Purpose Program Rate. The Joint CCAs reply brief urges the CPUC to reject SDG&E’s request to recover its outstanding Green Tariff undercollections through the Public Purpose Program rate component from all customers and instead determine a path forward for disposition of these balances that maintains customer indifference. To the extent the Commission determines that SDG&E’s outstanding Green Tariff-related undercollections are recoverable, the Commission should require SDG&E to recover those amounts from former program participants. A Proposed Decision is expected in the third quarter of 2025.
Energy Efficiency
General Energy Efficiency Proceeding (R.25-04-010): Order Instituting Rulemaking On April 24, 2025, the CPUC approved a new Order Instituting Rulemaking (OIR) for Oversight of Energy Efficiency Portfolios, Policies, Programs, and Evaluation. On May 19, 2025, San Diego Community Power on behalf of San Diego Regional Energy Network (SDREN) participated in Joint REN opening comments on the OIR. Additional details on the preliminary scope of the proceeding and the Joint REN opening comments can be found in Item 8 of the May 2025 Community Power Board of Directors agenda packet.
On May 29, 2025, San Diego Community Power, on behalf of SDREN, submitted reply comments on the OIR. SDREN urged the Commission to prioritize reforms that improve energy efficiency (EE) portfolio performance and cost-effectiveness before considering SDG&E's request to withdraw from energy efficiency administration. The filing supports proposals from stakeholders such as the California Technical Forum (CalTF), Small 57 Business Utility Advocates (SBUA), and California Energy and Demand Management Council (CEDMC) to streamline EE rules, enhance evaluation processes, consider non-energy benefits, and integrate demand-side management strategies. SDREN opposed Public Advocates Office’s proposals to impose new cost-effectiveness thresholds on RENs, citing their equity-focused mandate, and RENs’ unique customer base. SDREN also supported the Labor Coalition’s recommendation to add workforce concerns to the proceeding scope, and the Center for Accessible Technology’s recommendation to expand the CPUC’s definition of hard-to-reach customers to include individuals with disabilities.
A prehearing conference will be held on June 17, 2025. At this conference, parties will have an opportunity to provide additional input on the scope and schedule for the proceeding. Thereafter, the CPUC will issue a scoping ruling that will indicate the final scope and schedule.
General Energy Efficiency Proceeding (R. 25-04-010): Potential and Goals Study On May 1, 2025, the CPUC issued a Ruling inviting comment on the Draft Potential and Goals Study (Draft Study) for 2026 and beyond—a study that informs electricity and natural gas efficiency savings targets for the IOUs. San Diego Community Power, on behalf of SDREN, filed opening comments which are summarized in Item 8 of the May 2025 Board of Directors agenda packet.
On May 30, 2025, SDG&E submitted reply comments on the Draft Study. SDG&E urged the Commission to disregard comments from SDREN, BayREN, and 3C-REN, asserting that their critiques of SDG&E’s proposed withdrawal from energy efficiency administration were procedurally inappropriate in the context of the P&G Study. SDG&E further disputed claims that its proposed $300 million budget reduction would not necessarily reduce customer rates. SDG&E also opposed recommendations to adopt savings goals based on aggressive electrification assumptions, instead recommending the Commission adopt savings goals based on a more conservative electrification forecast and only accounting for savings from measures that pass cost-effectiveness screens.
SDG&E Application to Withdraw from Regional Energy Efficiency Program Administration (A. 25-04-014)
On April 25, 2025, SDG&E submitted an application to the CPUC requesting approval to revise its 2024–2031 Energy Efficiency (EE) Business Plan. The proposal is summarized in Item 8 of the May 2025 Community Power Board of Directors agenda packet.
Responses and protests to the application were due on May 29, 2025. A protest indicates a party opposes the relief requested in an application, whereas a response does not.
Community Power on behalf of SDREN, the Public Advocates Office, and the Small Business Utility Advocates filed protests. Southern California Edison filed a response.
Community Power filed a protest jointly with other RENs and the City of San Diego (joint parties’ protest, Attachment F). The protest urges the Commission to defer consideration 58 of SDG&E’s request until foundational legal and policy questions - such as whether IOU withdrawal is permissible under current law - are resolved in the new EE proceeding. The joint parties’ protest argues that SDG&E’s application lacks sufficient factual support, understates portfolio benefits, and overstates cost savings. They further note that many issues raised in the application, including cost-effectiveness challenges and program overlap, are already slated for evaluation in the EE proceeding. The protest emphasizes the importance of maintaining equitable and comprehensive EE service coverage and urges the Commission to ensure any withdrawal process is deliberate, transparent, and aligned with state energy and climate goals.
SDG&E filed its reply to the joint parties’ protest on June 9, 2025. SDG&E reasserted that its proposal is narrow in scope, procedurally appropriate as a stand-alone application, and necessary to improve ratepayer affordability. The filing disputes claims that the proposal should be delayed until the EE proceeding resolves broader policy questions, arguing that such deferral would be inefficient. SDG&E further contends that continued access to statewide EE programs and its retained regional Codes and Standards program will ensure sufficient service coverage for all customers, including those outside the SDREN footprint. The utility maintains that its portfolio underperforms relative to cost, and statute allows flexibility in achieving their CPUC-established savings targets. SDG&E urges the Commission to disregard protests and proceed with timely action on its application.
The CPUC is expected to decide on SDG&E’s request for an expedited application by May 16, 2025.
B) State Legislative Activities Update
Community Power Seeks Amendment to Customer Billing Legislation, Which Has Failed to Advance
AB 1295 (Patterson) would have created a new process at the CPUC to potentially make changes to customer billing. It is supported by San Diego Gas & Electric. Community Power shares the author’s goal of providing clear, understandable, and accurate bills to customers. However, AB 1295 (Patterson) does not consider the role of CCAs in the customer billing experience, and the legislation also fails to take a comprehensive approach to all portions of customer bills. To that end, Community Power submitted an oppose unless amended position letter recommending:
1. An amendment to ensure that CCAs are explicitly consulted and involved in the development and implementation processes envisioned by the bill.
2. An amendment to ensure all relevant billing details are considered, including fees and delivery charges.
3. An amendment that seeks to better balance cost-effective bill delivery methods that meet diverse customer needs.
59 Soon after Community Power issued its position letter (Attachment B), the bill was held by the Assembly Committee on Appropriations on their suspense file on May 23, meaning it will not move forward this year.
Community Power Supported Legislation Passes Key Legislative Hurdle June 6 marked the House of Origin deadline in the Legislature, meaning bills introduced in the Senate or the Assembly must have passed their respective legislative chamber to be eligible for further consideration in the legislative process. It generally marks the half way point of the legislative year, which is scheduled to end on September 12. The following Community Power supported bills advanced past the House of Origin deadline:
• AB 259 (Rubio) would extend alternative teleconferencing procedures under the Brown Act through 2030.
• AB 915 (Petrie-Norris): This would have advanced a conversation about the Clean Energy Reliability Investment Plan (CERIP), which could provide funding for distributed assets. Although Community Power supported the April 22 version of the bill, amendments on May 23 removed the language relevant to Community Power. As a result, Community Power no longer has a support position on the bill. • SB 302 (Padilla): This would conform state tax law to federal tax law with respect to transferable tax credits under the Inflation Reduction Act, potentially saving 1%- 6% on project costs. It is sponsored by American Clean Power, the Solar Energy Industries Association, and the Large-Scale Solar Association. • SB 330 (Padilla): This would address ratepayer affordability issues by establishing a pilot project to publicly finance certain electrical transmission facilities. It is sponsored by The Utility Reform Network and Net Zero California. • SB 540 (Becker): This would facilitate the California Independent System Operator’s ability to operate and participate in a West-wide energy market that will deliver affordability, reliability, and greenhouse gas emission reduction benefits. It is sponsored by the Coalition of California Utility Employees, the State Association of Electrical Workers, the Environmental Defense Fund, and the Natural Resources Defense Council. It is also supported by the California Community Choice Association, among others. While the bill was approved by the Senate, it was approved with language that may no longer comport with the vision of an independently governed regional energy market capable of facilitating transactions with load-serving entities located in other states. Without an independent market governance structure, the potential regional market envisioned by SB 540 would not attract participants from other states, such as Washington and Oregon.
Community Power continues to support the bill and is part of a coalition urging the Assembly to modify some of the bill’s challenging provisions. The coalition letter is included as an attachment.
• SB 710 (Blakespear): This would eliminate the sunset date on a law that allows rooftop solar and battery storage systems to be excluded from a property tax reassessment. It is sponsored by the California Solar & Storage Association. 60 SB 239 (Arreguin) would modernize teleconferencing protocols for subsidiary bodies, like the Community Advisory Committee. It is sponsored by the League of California Cities and California State Association of Counties, among others. It did not advance past the House of Origin deadline. Instead, the contents of the bill were amended into SB 707 (Durazo), which is a larger Brown Act reform bill. Community Power is reviewing the legislation.
Legislative positions and associated letters of support or opposition are kept up-to-date on this Community Power webpage: https://sdcommunitypower.org/legislative-priorities/ Several Battery Safety Bills Continue to Advance in the Legislative Process The Legislature is advancing the following two bills to establish new safety standards for battery energy storage. Each bill advanced passed the House of Origin deadline:
• 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 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.
• AB 615 (Davies): This would require that an entity that uses the statewide permitting process for a battery project has an emergency response and action plan and must ensure the project meets NFPA 855.
• 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.
• 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.
The following bills are not advancing this year in the legislative process:
• 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. It was never set for a hearing by the Assembly Committee on Utilities & Energy.
• 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 never set for a hearing in the Assembly Committee on Utilities & Energy.
• AB 588 (Patel): This would create a working group to recommend potential solutions to enhance building safety with respect to lithium batteries. It was held by the Assembly Appropriations Committee on their suspense file. 61 Update on the State Budget
The Governor recently released his updated May Revise budget proposal. Notably, the Governor now expects the state to have a $12 billion deficit this year, an issue he proposes to solve through fund shifts, use of reserves, and cuts. As part of his updated budget proposal, the Governor also released a proposal to rename the state’s Cap & Trade Program to Cap & Invest, and to extend its statutory authority from 2030 through 2045. The Governor notes that extending the program would result in $60 billion through 2045 for the California Climate Credit, the biannual credit that is applied to electricity and natural gas bills.
The May Revise includes reductions for certain energy programs. Most notably, the May Revise eliminates the January budget proposal to provide $180 million to the CEC’s Distributed Electricity Backup Assets (DEBA) program, a funding proposal that Community Power supports. DEBA can help support distributed energy resources, like batteries. That program was slated to be funded from Cap & Trade revenues and with extension of the program now officially being considered, the Governor and Legislature are likely to hold off on approving new expenditures until an extension of the program is agreed to. Community Power, along with other CCAs, issued a letter – the third this year – urging inclusion of DEBA funding in the final budget agreement. The letter is included as an attachment (Attachment D).
On June 9, the Legislature announced they had reached an agreement on the budget framework. The Legislature’s budget agreement agrees with the Governor’s May Revise proposal to slash DEBA funding. It is likely the Legislature and Governor will take additional budget actions in August, so there may be further opportunity to advocate for DEBA funding.
Advancing Solutions to Ensure CCA Low-Income Customers Are Eligible for Battery Incentives
The 2023 State Budget provided $280 million for the Self-Generation Incentive Program (SGIP) at the CPUC. The program has historically been ratepayer funded. It provides rebates to customers for batteries based on kilowatt hour installed. The budget appropriation from the State was intended to benefit low-income customers, which are defined as those live in a single-family home with a household income at or below 80 percent Area Median Income or at least 80 percent of the apartment building residents have incomes at or below 60 percent Area Median Income.
To be eligible for an incentive, a low-income customer must enroll in a qualified demand response program. Community Power filed to qualify the Solar Battery Savings program under the CPUC rules. However, the CPUC rejected the filing arguing the program does not meet their narrow definition of a demand response program. The CPUC is also not approving filings from other CCAs. As a result, low-income Community Power customers – and customers for all CCAs – cannot apply for an SGIP battery incentive. In fact, there isn’t a workable qualified demand response program throughout all of San Diego. SDG&E 62 offers a rate under SGIP rules, but Community Power customers would have to unenroll from CCA service and be placed on a volatile six-month transitional rate, before being eligible to enroll in the SGIP qualified rate, which is only open to bundled customers.
Community Power partnered with other CCAs to advise the Legislature about the CPUC’s rules that block CCA customer participation. As a result, a group of 18 legislators sent a letter to the CPUC urging them to qualify CCA programs for SGIP. Among those that signed the letter are four legislators from San Diego, the Chair of the Senate Committee on Budget and Fiscal Review, and the Chair of the Senate Committee on Energy, Utilities, and Communications. The letter is included as an attachment (Attachment E).
Additionally, the Legislature Budget agreement includes trailer bill language – a change to statute that would accompany the budget bill – to affirmatively qualify CCA programs under the SGIP program. It remains to be seen if this budget trailer bill will be passed and signed into law.
C) Federal Activities Update
For an update on federal matters, please refer to the staff report for Item No. 12, titled “Tariffs, Tax Credits and Executive Orders: New-Build Market Outlook Update.” FISCAL IMPACT:
N/A
ATTACHMENTS:
A: Joint CCA Comments on Draft Cost Cap Resolution
B: AB 1295 (Patterson) Letter
C: SB 540 (Becker) Coalition Letter
D: DEBA Support Letter
E: Legislative Letter re SGIP
F: Joint Parties’ Protest to SDG&E Application to Withdraw G: Letter to ED Regarding Self-Generation Incentive Program (SGIP) 63 ITEM 8
ATTACHMENT A
64 Braun Blaising & Wynne, P.C.
Attorneys at Law
2600 Capitol Ave, Suite 400, Sacramento, California 95816 Telephone: (916) 326-5812 ◆ www.braunlegal.com
May 28, 2025
Via Electronic Mail
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Via E-Mail: [email protected]
Re: Joint Community Choice Aggregators’ Comments on Draft Resolution E-5367 Dear Energy Division Tariff Unit:
Pursuant to Rule 14.5 of the Rules of Practice and Procedure of the California Public Utilities Commission (“CPUC” or “Commission”) and the notice accompanying Draft Resolution E-5367, Ava Community Energy, Clean Power Alliance of Southern California, the City and County of San Francisco, acting by and through its Public Utilities Commission, Lancaster Choice Energy, Marin Clean Energy, Peninsula Clean Energy Authority, Pico Rivera Innovative Municipal Energy, San Diego Community Power, San Jacinto Power, and San José Clean Energy (collectively, the “Joint Community Choice Aggregators” or “Joint CCAs”) submit these comments on Draft Resolution E-5367, Approving with Modifications Pacific Gas & Electric Company’s and Southern California Edison Company’s DAC-GT Cost Containment Cap Proposal Update, to be considered at the June 12, 2025 Commission meeting (“Draft Resolution”).
The Draft Resolution, as written, inhibits the ability of program administrators (“PAs”) to successfully procure under the Disadvantaged Communities Green Tariff (“DAC-GT”) program.
The proposed cost containment framework is built on unsupported assumptions, employs a multiplier that is inadequate under current and foreseeable market conditions, and neglects to establish a process to timely resolve the proposal’s likely failures. If adopted without significant revision, the Resolution will render the DAC-GT program unworkable for many PAs, particularly Community Choice Aggregator (“CCA”) PAs, and will undermine the Commission’s statutory objective of expanding clean energy access in disadvantaged communities (“DACs”). These comments identify material, factual, and technical errors in the Draft Resolution and propose targeted corrections to ensure the program can be successfully implemented across all service territories. The Joint CCAs offer necessary revisions in these comments that balance the success of future DAC-GT solicitations, the advancement of economic and environmental benefits for low-income customers in DACs, and customer affordability more broadly.
65 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
BACKGROUND
On May 30, 2024, the Commission adopted Decision (“D.”) 24-05-065, which ordered Pacific Gas and Electric Company (“PG&E”) and Southern California Edison Company (“SCE”) (collectively, the “Joint IOUs”) to work with participating CCAs to develop a proposal for updating the cost containment cap applicable to the DAC-GT program.1 The Commission further ordered PG&E and SCE to submit a Tier 2 Advice Letter proposing an updated methodology for the cost containment cap that reflects the option for pairing storage. 2 The DAC-GT program, initially authorized by D.18-06-027 and implemented via Resolution E-4999, provides eligible residential customers in DACs with 100 percent renewable electricity at a 20 percent bill discount. To limit non-participating ratepayer subsidization, Resolution E-4999 also established a numeric cost containment cap threshold. The cost containment cap was originally set at 200 percent of the highest executed contract price in either the most recent Renewable Auction Mechanism’s (“RAM”) as-available peaking category, or the previous Green Tariff, whichever was higher.3
Pursuant to D.24-05-065, the Joint IOUs filed Joint Advice Letter SCE 5362-E and PG&E 7363-E on August 28, 2024, outlining a proposed methodology for updating the DAC-GT cost containment cap. The Joint IOUs held two meetings with the Joint CCAs, on July 18 and July 24, 2024, and corresponded via email to facilitate development of the proposal. The Joint IOUs’ proposal identified two components of the updated cost containment cap methodology: (1) a Confidential Benchmark Value Reference Price (“CBVRP”), calculated as the average price of historical executed Power Purchase Agreements (“PPAs”) for similar technologies and contract types over a defined time period, and (2) a DAC Percentage Multiplier (“Multiplier”), intended to account for cost differences specific to DAC-GT projects. Under this structure, the final cost containment cap is equal to the product of the CBVRP and the Multiplier.4 While the Joint IOUs and Joint CCAs generally agreed that there should be two cost containment cap elements, they proposed different implementation details, including the appropriate Multiplier and whether CBVRPs should be unique to each PA or uniform across the state. In turn, the Joint IOUs filed public and confidential versions of the advice letter. The public version provided a general outline of the proposed methodology and implementation details. Confidential Appendices A and B contain the Joint IOUs’ characterization of the Joint CCAs’ proposal and the Joint IOUs’ confidential critiques, respectively. San Diego Gas &
1 D.24-05-065, Decision Modifying Green Access Program Tariffs and Adopting a Community Renewable Energy Program, issued June 7, 2024, at p.133. 2 Id. at p. 171 (Ordering Paragraph (“OP”) 4).
3 Commission Resolution E-4999, Pursuant to Decision 18-06-027, Approving with Modification, Tariffs to Implement the Disadvantaged Communities Green Tariff and Community Solar Green Tariff Programs, at p. 66 (OP 1.dd).
4 Joint Advice Letter SCE AL 5362-E and PG&E AL 7363-E, Cost Containment Cap Proposal Update for Disadvantaged Communities Green Tariff Pursuant to Decision 24-05-065, Submitted August 28, 2024, at p. 3.
66 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
Electric Company (“SDG&E”) did not submit a corresponding advice letter due to its Commission-authorized termination of its DAC-GT program, reflecting its uniquely small, bundled service customer base.
On September 17, 2024, the Joint CCAs, the Coalition for Community Solar Access (“CCSA”), the Public Advocates Office at the California Public Utilities Commission (“Cal Advocates”), and the Solar Energy Industries Association (“SEIA”) submitted protests to the Joint Advice Letter. The Joint IOUs replied to the protests and submitted a Joint Supplemental Advice Letter with expanded justification for confidentiality designations and an updated summary of the Joint CCAs’ proposals.
5 Within their Joint Supplemental Advice Letter, the Joint IOUs also argued that the PAs should perform their own CBVRP analyses and submit them to independent evaluators for review.
The Joint CCAs submitted a protest to the Joint Supplemental Advice Letter on November 26, 2024, providing additional justifications regarding the confidentiality of the Joint IOUs’ filings, the inadequacy of the proposed Multiplier, and the failure to provide a meaningful statewide methodology for calculating the CBVRP. On December 5, 2024, the Joint IOUs filed their reply defending their confidentiality designations, rejecting the proposed 175 percent Multiplier, and maintaining that PA-specific CBVRPs better reflect locational and contractual variation.
On May 8, 2025, the Commission issued Draft Resolution E-5367 which proposes to adopt the Joint IOUs’ Advice Letter with modifications. As set forth below, the Joint CCAs submit these comments to identify material, factual, and technical errors in the Draft Resolution’s support of the Joint IOUs’ cost containment cap proposal. As detailed in the sections that follow, the proposed cost containment framework is unworkable due to its reliance on insufficient and non-comparable executed contract data, an inadequately low multiplier, and the absence of a contingency process to address foreseeable procurement failures. Adoption of the Draft Resolution in its current form would result in an outcome that is neither just nor reasonable and is inconsistent with the applicable Commission standards.
COMMENTS
I. The Proposed CBVRP Methodology is Unworkable
The Draft Resolution’s proposed cost containment cap framework is structurally unsound and fails to address the realities of DAC-GT implementation. First, it relies on a methodology that presumes all PAs, including CCAs, have access to a sufficient pool of executed, comparable PPAs. This assumption is not supported by the record and does not reflect the reality of CCA DAC-GT procurement. Second, the Draft Resolution defines “comparable” contracts too narrowly, focusing on resource and contract type while omitting critical cost drivers like project
5 Joint Advice Letter SCE 5362-E-A and PG&E 7363-E-A, Supplement to 5362-E et al., Cost Containment Cap Proposal Update for Disadvantaged Communities Green Tariff Pursuant to Decision 24-05-065, Submitted November 6, 2024.
67 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
size. Third, the fallback option of allowing CCAs to adopt IOU-developed CBVRPs is not a reasonable substitute. IOU procurement portfolios often differ significantly in size and scope, leading to distorted cost containment caps that CCAs cannot reasonably procure under. Finally, the framework fails to incorporate a viable offramp for situations where a bid fails to produce adequate solicitations. To correct this, the Commission should authorize the use of a neutral third-party entity to pool anonymized contract data from multiple PAs to generate regionally appropriate CBVRPs. Without these changes, the adopted cost containment cap will not reflect actual market conditions or program constraints, and the DAC-GT program will be unworkable for many PAs.
a. The Draft Resolution Incorrectly Assumes that All Program Administrators Have Sufficient Executed PPAs to Calculate an Effective CBVRP The Draft Resolution proposes a CBVRP methodology that requires each PA to calculate its CBVRP by surveying its executed contracts and “pooling prices from a comparable set of competitively solicited power purchase agreements... the entity executed....” 6 The PPAs are to be
drawn from a pool of contracts (1) for similar resources, (2) for similar contract types, and (3) that have been executed within the last five years.7 These CBVRPs are then to be reviewed by an Independent Evaluator for reasonableness.8
The proposed CBVRP methodology rests on a factual error in presuming that all DAC-GT PAs have, or each IOU has, a sufficient set of executed, comparable competitively solicited PPAs that satisfy the Draft Resolution’s criteria. Many of the Joint CCAs do not have a sufficient history of executed contracts from which to survey to set their own CBVRP that meets the requirements and standards proposed in OP 2, or which reflect current market prices and developer costs.
9 As a result, the CCAs with few or no executed DAC-GT PPAs may need to rely on surveying executed contracts that do not reflect DAC-GT market conditions or developer costs to calculate their CBVRP.10
While CCAs have the option to survey non-DAC-GT PPAs, these contracts are often for larger-scale projects and may result in a cost containment cap that does not account for costs associated with developing projects that meet DAC-GT requirements. Alternatively, CCAs may need to use the CBVRP set by their respective IOU as proposed in the Draft Resolution. 11 6 Draft Commission Resolution E-5367. Pursuant to Decision 24-05-065, Approving with Modifications Pacific Gas & Electric Company’s and Southern California Edison Company’s DAC-GT Cost Containment Cap Proposal Update, May 8, 2025, at p. 18 (OP 2). 7 Id. at p. 13.
8 Ibid.
9 D.24-05-065, at p. 162 (Findings of Fact 78).
10While Community Solar Green Tarriff (“CSGT”) projects should be considered comparable and similar, only one CCA continues to offer a CSGT program. In turn, for purposes of these comments, “DAC-GT PPAs” will encompass executed CSGT PPAs.
11 Draft Resolution E-5367, at p. 13.
68 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
However, the IOU may also have limited or no history of comparable executed contracts. The Joint CCAs address the proposal for CCAs to leverage the CBVRP set by the IOU for their service territory later in these comments.
In surveying CCA-executed non-DAC-GT PPAs, CCAs will likely need to review contracts that ultimately skew towards resources that exceed the maximum DAC-GT system size of 20 megawatts (“MW”). On a per MW basis, non-DAC-GT PPAs that exceed 20 MW tend to result in lower contract prices than DAC-GT PPAs, at least due to economies of scale. Surveying those PPAs will result in a cost containment cap that is undervalued for the DAC-GT program, which would not reflect market conditions or developer costs since DAC-GT PPAs historically have resulted in projects that do not exceed 3MW.
12 b. The Draft Resolution’s Definition of “Comparable” PPAs Is Technically Incomplete and Risks Skewing Cost Containment Caps
The Draft Resolution defines “comparable” PPAs based on similar resource type, similar contract type, and whether the contract has been executed within the last five years, but fails to incorporate project size as a critical metric.13 DAC-GT projects must be sized between 500 kW and 20 MW and interconnected at the circuit, load or substation level. To date, projects executed through the DAC-GT program have not exceeded 10MW, and when excluding PG&E, have not exceeded 3MW.
14 These specifications result in pricing structures that differ significantly from large, utility-scale projects. The Draft Resolution errs in including executed contracts for projects significantly larger than the DAC-GT program size cap in the CBVRP calculation, as they will further skew the CBVRP downward, making the cost containment cap unworkable for a successful program. As such, the Joint CCAs urge the Commission to expand the guidance on what constitutes a “comparable” project to projects sized between 500 kW and 20 MW to ensure objectivity and consistency in the reasonableness review. c. IOU CBVRPs Do Not Function as a Reasonable Proxy for CCAs with Insufficient Data
To accommodate CCAs with insufficient comparable contract history, the Draft Resolution allows CCA PAs to adopt the CBVRP set by the IOU for the relevant service territory.15 This proposed system presents a significant technical error: IOU-calculated CBVRPs
12 See R.14-07-002, Order Instituting Rulemaking to Develop a Successor to Existing Net Energy Metering Tariffs Pursuant to Public Utilities Code Section 2827.1, and to Address Other Issues Related to Net Energy Metering, DAC-GT PA’s First Quarter 2025 DAC-GT Quarterly Reports submitted by April 30, 2025.
13 Draft Resolution E-5367, at p. 13.
14 D.18-06-027, Alternate Decision Adopting Alternatives to Promote Solar Distributed Generation in Disadvantaged Communities, issued June 22, 2018, at p. 103 (OP 11) and see p. 51. 15 Draft Resolution E-5367 at p. 18 (OP 2).
69 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
are not reasonably comparable or applicable for most CCAs due to differences in program size, procurement scale, and resource expectations. For example, five CCA PAs have a remaining DAC-GT capacity allocation under 4MW, significantly limiting the size of eligible projects and making their programs structurally different from the IOUs.16 Further, it is unclear whether each of the IOUs will have sufficient comparable executed PPAs when excluding non-DAC-GT PPAs for projects that exceed 20MW that would otherwise skew the CBVRP downward. Even within those bounds, available IOU data may not represent the range of project sizes eligible under the DAC-GT program and result in a CBVRP that effectively excludes projects that more accurately represent bids expected to be received through the program based on the history of the DAC-GT program to date. As such, a determination of whether the data pool of IOU PPAs is sufficient should consider whether there is a reasonable representation of project sizes. Moreover, for CCAs using the CBVRP set by the IOU, it is critical that the CCA PA be provided the opportunity to review the IOU’s methodology and be able to comment and/or protest if necessary.
d. The Commission Should Direct a Neutral Third Party to Pool Comparable PPA Data for Regional or LSE-Specific CBVRPs
For CCAs without sufficient historical data, and where IOU CBVRPs are not appropriate, the Commission should select and authorize a neutral third-party entity to pool anonymized pricing data from a comparable set of competitively solicited PPAs executed by participating DAC-GT PAs that satisfy the CBVRP categorical requirements. The third party would then develop a CBVRP for individual CCA PAs as needed based on comparable projects within a given geographic proximity.
As an example, the third-party entity could pool executed PPA data for a CCA PA based on a regional geographic boundary or once a sufficient number of data points, as determined by the third party, is reached. This approach would mitigate the risks of data insufficiency or data that is not representative of expected project bids and ensure that cost containment caps reflect actual market trends and comparable project characteristics. This third-party structure would improve consistency, transparency, and efficiency while respecting the confidentiality of underlying contracts. Moreover, utilizing a single third-party entity for all CCA PAs using this approach would be a more prudent use of ratepayer funds as opposed to each PA contracting with a third party.
II. The 120% Multiplier is Likely Too Low to Receive Viable Project Bids and Should be Increased to 140%
In addition to the issues associated with the CBVRP, the Draft Resolution’s proposed 120% Multiplier does not adequately account for actual market conditions and above-market costs beyond project siting. The Draft Resolution supports the 120% Multiplier primarily on the basis that expanding the DAC-GT siting eligibility to include locations within five miles of a DAC “should reduce developers’ costs.”
17 While some limited cost savings may result from this
16 D. 24-05-065, at pp. 138-139.
17 Draft Resolution E-5367, at p. 14.
70 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
geographic expansion, the Draft Resolution treats siting as the sole or primary driver of project costs for distributed projects of this scale. This reasoning ignores a wide array of other factors that materially affect project costs and does not justify an 80% reduction in the Multiplier.
Notably, the Draft Resolution fails to consider external economic pressures that are likely to increase project costs in the near term, such as the impacts of impending tariffs and the potential termination or reduction of the Investment Tax Credit (“ITC”). The ITC is a longstanding federal tax credit incentive for solar development, in place since 2006 and scheduled to step down to 0% by 2036.18 Since 2006, the ITC has had, and continues to have, a significant impact on reducing the costs of solar development and driving the growth of solar.
Currently, Congress is considering repealing or reforming the ITC, with proposals ranging from accelerating the existing ITC phaseout schedule to terminating the ITC in the near-term. The uncertainty of the future of the ITC in addition to the uncertainties of potential tariffs on the solar market could result in significant increases in costs. These potential near-term cost impacts have not been taken into consideration in the Draft Resolution. By dismissing these material economic pressures and focusing narrowly on siting costs, the Draft Resolution risks understating the multiplier required to attract viable project bids.
The Draft Resolution also errs in referencing the bid price cap adopted for the Enhanced Community Renewables (“ECR”) program as a justification for selecting the 120% Multiplier. 19 The 120% Multiplier was adopted for unrestricted ECR projects, which lacked the size, location, and participant restrictions applicable to DAC-GT projects. In contrast, the ECR Environmental Justice (“EJ”) Reservation category, which shares many of the characteristics of the DAC-GT program, including restrictions on siting and customer eligibility criteria, was authorized with a 200% multiplier.20 The Draft Resolution fails to explain why the more analogous ECR EJ category is not the appropriate point of comparison.21
Finally, D.24-05-065 discontinued future procurement under ECR due to the program’s shortcomings. This limited participation and ultimate discontinuance underscores that a 120% cap was not effective for projects serving disadvantaged communities and should not be used as a benchmark for the DAC-GT program, which is designed to benefit those very communities.
In the Draft Resolution, the Commission declined to set the multiplier at 175%, citing concerns that such a level may not reflect current market conditions and could negatively impact
18 See U.S. Department of Energy, Office of Energy Efficiency & Renewable Energy, Federal Solar Tax Credits for Businesses, February 2024.
19 Draft Resolution E-5367, at p. 15.
20 D.15-01-051, Decision Approving Green Tariff Shared Renewables Program for San Digo Gas & Electric Company, Pacific Gas and Electric Company, and Southern California Edison Company Pursuant to Senate Bill 43, Issued February 2, 2015, at p. 10. 21 See D.15-01-051, at pp. 4-5. Capacity for the ECR EJ category was reserved for facilities no larger than 1 MW “located in areas previously identified by the California Environmental Protection Agency... as the most impacted and disadvantaged communities... as the most impacted and disadvantaged communities.” 71 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
non-participant affordability by increasing the overall DAC-GT program subsidy.22 Unfortunately, the proposed 120% Multiplier in the Draft Resolution does not reflect market conditions particularly for investments in or near DACs, and will likely not result in viable project bids. The proposed Multiplier also does not account for the foreseeable near-term market changes mentioned above. This is particularly concerning considering PA’s CBVRPs under the methodology proposed in the Draft Resolution are likely to underestimate DAC-GT market conditions and developer costs as previously discussed.
The Joint CCAs recommend the Commission adopt a reasonable increase in the Multiplier to 140%. A 140% Multiplier would improve the likelihood of successful bids by equipping PAs to better navigate the challenges with the proposed cost containment cap methodology and accommodate potential rapid and near-term market changes while mitigating the Commission’s concerns around a higher cost containment cap as raised in the Draft Resolution.
a. The Final Resolution Must Include a Built-In Contingency Process As discussed above, the Draft Resolution’s proposed adoption of the Joint IOU’s CBVRP and implementation of a 120% Multiplier will likely result in cost containment caps that are too low to support viable DAC-GT project development. As such, it is critical that the Final Resolution include a contingency process to address the possible scenario where a PA receives zero conforming bids at or below the cost containment cap that also meet all program requirements as established by the Commission. PAs must have access to a well-defined procedural pathway to update the cost containment cap in the instance that it proves to be infeasible.
To address this, the Joint CCAs recommend that the Commission incorporate in the Final Resolution a contingency option for each PA to propose and justify an adjustment to their cost containment cap multiplier via an Advice Letter submittal when zero conforming bids are received (1) at or below the cost containment cap and (2) otherwise meet all program requirements as established by the Commission. The PA's proposed adjusted cost containment cap multiplier must be substantiated by a PA's solicitation results and must not exceed 175% of the CBVRP. In the PA’s Advice Letter filing, subject to confidential protection of market sensitive data, the PA would summarize the results of their solicitation, including the number of bids received, the percentage of bids that exceeded the cost containment cap, and if the bids would have fulfilled program requirements. Pending the Commission’s review of the PA’s Advice Letter submittal, the PA may adjust the multiplier for its cost containment cap. This process would preserve Commission oversight while providing necessary flexibility for PAs to adapt to evolving market conditions, including the aforementioned ITC and tariffs.
22 Draft Resolution E-5347, at p. 13.
72 Joint CCAs’ Comments on Draft Resolution E-5367
May 28, 2025
CONCLUSION
The Joint CCAs thank the Commission for its consideration of these comments.
Respectfully,
/s/ Jessica Melms
Jessica Melms
Braun Blaising & Wynne, P.C.
2600 Capitol Ave, Suite 400
Sacramento, CA 95816
(916) 326-5812
[email protected]
On behalf of the Joint Community Choice Aggregators
cc (via e-mail): Connor Flanigan, SCE ([email protected]) Adam Smith, SCE ([email protected])
Sidney Bob Dietz II, PG&E ([email protected])
Service List: A.22-05-022, R.14-07-002
73 ITEM 8
ATTACHMENT B
74 SD Community Power and CEA are Community Choice Aggregators (CCAs) serving nearly 70% of the electric load throughout San Diego County, both with a goal of providing 100% renewable energy by 2035 at competitive rates. 1 May 12, 2025
The Honorable Buffy Wicks
Chair, Assembly Committee on Appropriations
1021 O Street, Suite 8220
Sacramento, CA 95814
RE: Oppose Unless Amended - AB 1295 (Patterson) Public utilities: bills and notices:
consolidation and transparency (Amended as of 4/22/2025) Dear Assemblymember Wicks,
We write this letter on behalf of San Diego Community Power (SD Community Power) and Clean Energy Alliance (CEA) to express our oppose-unless-amended position on AB 1295 (Patterson) related to customer billing for energy. We’ve had productive conversations with the author’s office and expect them to continue. SDCP shares the author’s goal of providing clear, understandable, and accurate bills to our customers. As outlined below, we suggest a few clarifying amendments to better ensure AB 1295 (Patterson) effectively enhances the billing experience for all customers, including those served by community choice aggregators (CCAs) like SD Community Power and CEA.
We suggest an amendment to ensure that CCAs are explicitly consulted and involved in the development and implementation processes outlined in AB 1295 (Patterson). Currently, AB 1295 (Patterson) allows the California Public Utilities Commission to seek and consider input from utilities and other relevant stakeholders to inform its evaluation. It does not, however, specify that CCAs must be included in this consultation process. Under law, CCA generation charges are assessed through a consolidated bill issued by the Investor Owned Utility (IOU) that provides delivery services. As organizations founded and governed by the community, we welcome the opportunity to have direct input on changes to customer billing.
We also seek a clarifying amendment to ensure that all relevant billing details are taken into consideration. This includes fees and delivery charges collected on the consolidated bill. A comprehensive approach will provide customers with a truly transparent view of their total energy costs. Finally, we believe it is important to balance the need for cost-effective billing delivery with ensuring accessibility for all customers. We suggest an amendment that acknowledges this balance, allowing for various delivery methods that meet diverse customer needs while remaining fiscally responsible.
We want to emphasize that SD Community Power and CEA have been actively engaged in discussions with the author’s staff regarding these proposed amendments. We are optimistic that with these amendments, AB 1295 (Patterson) can enhance billing transparency and improve the customer experience across California. Our draft amendments are attached. 75 2
If you have any questions, please contact Amy Costa at [email protected].
Sincerely,
Patrick Welch
Associate Director of Legislative Affairs
SD Community Power
Greg Wade
Chief Executive Officer
CEA
Cc: The Honorable Joe Patterson, 5th Assembly District
ATTACHMENT
76 3
77 ITEM 8
ATTACHMENT C
78 Coalition alert: SB540 – SUPPORT (June 3, 2025)
79 Coalition alert: SB540 – SUPPORT (June 3, 2025)
VOTE YES on SB 540 (Becker and Stern)
Regional energy market negotiations must continue
SB 540 reforms governance of regional energy markets run by CAISO to encourage utilities from around the West to join. Those reforms are urgently needed to prevent California from becoming isolated as more and more trading partners commit instead to a competing market run out of Arkansas. While recent amendments work against that purpose, the respective organizations above all agree on one thing: SB 540 must move forward, because we can’t afford to wait any longer. Passing SB 540 off the floor sends a critical signal that California remains committed to getting this done.
Vote YES to move SB 540 off the floor to:
● Lower costs and increase reliability by solidifying partnerships. California relies on its neighbors for about 30% of its electricity, and even more in times of stress. Having reliable trading partners means more places to buy and sell clean energy at lower costs.
Losing those partners would result in greater risk of blackouts, higher energy costs, and prolong our reliance on dirty forms of energy.
● Enable California to meet its clean energy goals the fastest, cheapest way possible. Meeting this challenge by 2045 requires a 400% increase in clean energy supplies to power our homes, vehicles, and businesses. While California generates more clean energy than ever, it has never wasted more. In 2024, California curtailed 3.4 million megawatt hours (MWh) of utility-scale wind and solar energy, a 29% increase from 2023. This is wasted potential and dollars that will only grow if we are not a part of an energy market where we can sell our excess energy supplies. ● Give this diverse and committed coalition time to get the policy right. While many of the stakeholders reflected in this coalition have serious concerns with the current bill language, we are committed to continue working on the policy to strike a balance that provides for reasonable legislative oversight without undermining the core tenet of independent governance. The stakes of doing nothing are simply too high.
VOTE YES on SB 540 to KEEP CRUCIAL NEGOTIATIONS GOING
80 ITEM 8
ATTACHMENT D
81 May 29, 2025
The Honorable Jesse Gabriel
Chair, Assembly Budget Committee
1021 O St, Room 8230
Sacramento, CA 95814
The Honorable Scott Wiener
Chair, Senate Budget & Fiscal Review Committee
1021 O St, Room 8620
Sacramento, CA 95814
Subject: Fund the California Energy Commission’s (CEC) Distributed Electricity Backup Assets (DEBA) Program
Dear Assemblymember Gabriel and Senator Wiener,
We are writing to express our support for funding the Distributed Electricity Backup Assets (DEBA) program as part of budget negotiations. The DEBA program was previously included in the Governor’s Budget. The program was intended to receive $200 million dollars in 2025-26 and $180 million dollars in 2026-27. However, the current May Revision proposal eliminates funding for the DEBA program, which we deem critical for achieving both ratepayer affordability and California’s goals for a cleaner energy future.
Investments in DEBA are more important than ever due to rising electricity costs and the increasing threat of extreme weather events. According to the CPUC’s Public Advocates Office, bundled electricity rates have increased between 82% to 110% in the last decade, placing a growing burden on households. At the same time, climate change is causing more frequent and intense weather events that can strain our power grid.
DEBA can help address these challenges by supporting the acquisition of additional clean customer resources that can be enrolled in virtual power plants (VPPs). California’s Community Choice Aggregators are at the forefront of building VPPs, which rely on aggregated customer resources – like batteries and thermostats – that are critical to achieving the state’s clean energy goals, reducing costs for ratepayers, supporting grid reliability & resilience, and advancing environmental justice through accessible clean energy. By enabling customers to participate in automated dispatch, VPPs can collectively provide capacity through demand reduction at peak hours when energy is most expensive, thereby benefiting all customers. 82 Joint CCA Support for DEBA Funding (May 29, 2025) – Page2 Investing in DEBA is an investment in a more reliable and affordable energy future for all Californians, which is well-aligned with the goals of the Cap-and-Invest Program. We respectfully urge that it be included as part of the final budget agreement and the Cap-and-Invest spending plan. If you have any questions, please contact Amy Costa, at [email protected].
Sincerely,
Patrick Welch
Associate Director of Legislative Affairs
San Diego Community Power
Marc Hershman
Director of Government Affairs
Peninsula Clean Energy
Vincent Wiraatmadja
Senior Legislative Manager
MCE
Greg Wade
Chief Executive Officer
Clean Energy Alliance
Mitch Sears
Chief Executive Officer
Valley Clean Energy
Bena Chang
Director of Government & Legislative Affairs
Silicon Valley Clean Energy
Scott Green
Senior Government Affairs Manager
San Jose Clean Energy
CC: Senator Benjamin Allen, Chair, Budget subcommittee 2 Assemblymember Steve Bennett, Chair, Budget subcommittee 4 Joe Stephenshaw, Department of Finance
Chase Hopkins, Office of Assembly Speaker Robert Rivas
Kip Lipper, Office of Senate pro Tempore Mike McGuire
83 ITEM 8
ATTACHMENT E
84 May 30, 2025
Alice Busching Reynolds, President
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re: Self-Generation Incentive Program and Harm to Community Choice Aggregators Customers
Dear President Reynolds:
We write to request that the CPUC immediately review and approve the submitted CCA demand-response program advice letters for SGIP.
The 2023 Budget Act provided $280 million for the program, and we are dismayed that, more than two years later, the CPUC has yet to approve allocation of the funds to communities throughout California. Now more than ever, at a time when ratepayers are facing increased costs and the status of other climate funds are uncertain, we expect state agencies to move with alacrity in getting funds out the door in an expedient, efficient, and equitable manner.
The Self-Generating Incentive Program (SGIP) is an essential program that provides financial rebates for energy storage systems and other distributed energy resources (DERs), that are vital to meet California’s increasingly complex reliability, distribution and transmission, climate, and affordability needs.1 Originally launched in 2001, SGIP is designed to serve residential and non-residential customers statewide. 1 Public Utilities Code section 379.6.
85 President Reynolds
May 30, 2025
2 In 2018, the Legislature passed SB 700 (Wiener, Chapter 839, Statutes of 2018) which extended the SGIP program for five years through 2025. SB 700 continued savings for ratepayers across the state, from the installation of more than 2,000 MW of storage capacity in order to meet the state’s increasing energy, replacing fossil fuels, and further enabling the deployment of variable renewable energy sources. The Legislature explicitly directed the CPUC to offer the program to all ratepayers, “The commission shall ensure that distributed generation resources are made available in the program for all ratepayers.”2
All California ratepayers pay into the SGIP program,
3 and the Legislature intended all
Californians to be eligible to benefit from the program.4 Unfortunately, the program’s current implementation, especially as it relates to the 2023 Budget Act allocation, unfairly prevents many from participating. Specifically, the current implementation of SGIP impermissibly denies the nearly 1/3 of Californians served by CCAs access to the SGIP rebates that they help fund.5 We are concerned to hear from our constituents that, in addition to denying CCA customers beneficial rebate access, the current implementation of SGIP also unjustifiably imposes cost increases on CCA customers in an increasingly challenging energy affordability crisis.6 The CPUC must act immediately to allow pathways for CCA customers to access SGIP and prevent further financial harm to current and former CCA customers. The Commission has the authority under current law and the responsibility to update its implementation of the “qualified demand response program” enrollment requirements.7
Qualified Demand Response Program Enrollment Requirement To better support SGIP’s programmatic goals, the Legislature directed the Commission to consider requiring SGIP participants to enroll in a, “demand response program or a peak load reduction program offered through the customer’s load-serving entity[.]”8 The law does not require participation in demand response programs, but rather that the CPUC must consider
2 Senate Bill 700 (2018), section (i).
3 Funding sources include ratepayer funds, greenhouse gas reduction funds and in some cases general funds appropriated by the Legislature.
4 Assembly Bill 209 (2022), Section 25, “It is the further intent of the Legislature that the commission, in future proceedings, provide for an equitable distribution of the costs and benefits of the program.” 5 CalCCA, California Aggregator, 2024, p. 4, available at: https://cal-cca.org/wp-content/uploads/2024/01/California-Aggregator-Winter-2024-Newsletter.pdf?utm_source=chatgpt.com (“CCAs are procuring energy resources for over 14 million customers in California, about one-third of the state’s population.”).
6 CPUC, 2024 Senate Bill 695 Report, pp. 1-3 available at: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/office-of-governmental-affairs-division/reports/2024/2024-sb-695-report.pdf. 7 CPUC, Decision (D.)24-03-071, pp. 3, 75-76.
8 Public Utilities Code section 379.10 (b).
86 President Reynolds
May 30, 2025
3 participation in demand response programs or in peak load reduction programs. The Legislature appropriated $280 million in greenhouse gas reduction funds, and extended the collection of ratepayer funds for the program.9
Subsequently, the Commission issued two key decisions to disburse funds and update implementation of the SGIP program. In Decision (D.) 23-12-005 the CPUC created a definition of a “qualified demand response program” and outlined an advice letter process to add programs.
In D.24-03-071 three months later, the Commission revised its previous decision and added a new list of qualified demand response programs exclusively for SGIP.10 In addition to creating confusion and unnecessary complexity for customers and program administrators, the latter decision only qualifies a handful of investor-owned utility (IOU) programs. These programs are unavailable to residential CCA customers. No CCA customer may self-enroll in any of these qualified demand response programs in order to access SGIP.11 Consequently, no CCA customer has accessed SGIP rebates since the implementation of this decision statewide. We are disheartened to learn that despite significant CCA, developer, and customer engagement12 with the Commission on this issue, no solution has been offered to CCA customers.
Harms to CCA Customers
Due to the CPUC’s implementation of SGIP qualified demand response program requirements, CCA residential customers, unlike IOU customers, cannot access their share of the $280M in SGIP incentives approved by the Legislature in the 2023-24 budget when they become available on May 20th. This is in spite of the fact that CCA residential customers pay into the program.
The CPUC’s implementation of SGIP qualified demand response program requirements harm CCA customers in several ways. Many CCA customers, after being directed by SGIP project developers or interpreting vague program rules themselves, opted out of CCA service in order to access SGIP. Customers who opt out of CCA service are placed on a 6 month transitional rate that is extremely volatile and prohibits enrollment in IOU administered SGIP qualified demand response programs.13 Several of these customers experienced higher energy bills and lost access
9 Assembly Bill 209 (2022); Assembly Bill 102 (2023); CARB, California Climate Investments, available at: https://ww2.arb.ca.gov/our-work/programs/californiaclimate-investments/about. 10 D.24-03-071, Appendix E.
11 Pacific Gas & Electric filed an advice letter to update its CBP program so unbundled customers may enroll and access SGIP. The Commission has failed to issue a timely disposition on the advice letter.
PG&E AL 7548-E (December 2024).
12 CCAs raised this issue with the Commission several times in written submissions, meetings, and by providing supplemental information on numerous occasions. Multiple CCAs have also submitted their own programs to be added to the qualified demand response programs list for SGIP and none have received an approval disposition as of this date.
13 IOU generation rates are presently higher than many CCA generation rates. 87 President Reynolds
May 30, 2025
4 to CCA bill discounts and other beneficial programs. Customers have been charged as much as 4 times their previous energy bills. Many of these customers were unaware they would be unable to enroll in a qualified demand response program for 6 months and are now at risk of missing the opportunity to enroll in the program before SGIP sunsets in 2026. Customers who find themselves stuck in this situation are not permitted to return to CCA service for a full year. As a result, customers are now experiencing significantly higher bills, unable to access SGIP, and unable to choose their preferred load-serving entity. Low-income customers, who are able to stack SGIP rebates with other programs such as the Transformative Climate Communities funds, are particularly hit hard by these delays which in turn further frustrates the implementation of other climate funds.
The Solution
We are concerned to hear that the CPUC’s actions and implementation of these funds is resulting in inequitable outcomes and raising costs for CCA customers. This is not our intent. We request that Energy Division staff efficiently and effectively review CCA demand response program advice letters no later than 30 days following their protest period. 14 Thank you for your consideration of our concerns and your attention to this important matter.
Please feel free to reach out to me with any questions, or if your staff have questions, please do not hesitate to contact Radhika Gawde in my office at [email protected] or 916-651- 4011.
Sincerely,
Scott Wiener
Senator, 11th District
Monique Limon Aisha Wahab
Senator, 21st District Senator, 10th District
14 Equivalent to 50 days following the submission of an advice letter. 88 President Reynolds
May 30, 2025
5 Jesse Arreguín Ben Allen
Senator, 7th District Senator, 24th District
Stephen Padilla Jerry McNerney
Senator, 18th District Senator, 5th District
Jacqui Irwin Rhodesia Ransom
Assembly Member, 42nd District Assembly Member, 13th District John Harabedian Tasha Boerner
Assembly Member, 41st District Assembly Member, 77th District Darshana Patel Steve Bennett
Assembly Member, 41st District Assembly Member, 38th District
Chris Ward Josh Becker
Assembly Member, 78th District Senator, 13th District
89 President Reynolds
May 30, 2025
6 Diane Papan Damon Connolly
Assembly Member, 21st District Assembly Member, 12th District Buffy Wicks
Assembly Member, 14th District
CC:
Leuwam Tesfai, Director, Energy Division, CPUC
Matt Baker, Commissioner, CPUC
Karen Douglas, Commissioner, CPUC
Darcie L. Houck, Commissioner, CPUC
John Reynolds, Commissioner, CPUC
90 ITEM 8
ATTACHMENT F
91 BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Application of San Diego Gas & Electric Company
(U 902 M) to Revise its 2024-2031 Energy
Efficiency Rolling Portfolio Business Plan
A.25-04-014
PROTEST OF SAN DIEGO REGIONAL ENERGY NETWORK, BAY AREA
REGIONAL ENERGY NETWORK, TRI-COUNTY REGIONAL ENERGY NETWORK,
INLAND REGIONAL ENERGY NETWORK, NORTHERN RURAL ENERGY
NETWORK, AND THE CITY OF SAN DIEGO TO THE APPLICATION OF SAN
DIEGO GAS & ELECTRIC COMPANY
Elizabeth M. Kelly
LAW OFFICE OF ELIZABETH KELLY
P.O. Box 225037
San Francisco, CA 94122
Telephone: (415) 535-9998
Email: [email protected]
Counsel for:
ASSOCIATION OF BAY AREA GOVERNMENTS,
for the Bay Area Regional Energy
Network (BayREN) program
COUNTY OF VENTURA, for the Tri-County
Regional Energy Network (3C-REN)
program
Alissa Greenwald
Jacob Schlesinger
Keyes & Fox LLP
1580 Lincoln Street, Suite 1105
Denver, CO 80203
Telephone: (913) 302-5567
E-mail: [email protected]
[email protected]
Counsel for San Diego Community Power, for
the San Diego Regional Energy Network
(SDREN)
Patricia Terry
Senior Portfolio Manager
Redwood Coast Energy Authority
633 Third St
Eureka, CA 95501
Telephone: (707) 269-1700
E-mail: [email protected]
Representative for the Northern Rural Energy
Network (NREN)
Casey Dailey
Director of Energy & Environmental
Programs
Western Riverside Council of Governments
3390 University Ave., #200
Riverside, California 92501
Telephone: (951) 405-6720
E-mail: [email protected]
Administrative Lead Agency for the Inland
Regional Energy Network (I-REN), ID #246
92 May 29, 2025
William Smith
Deputy City Attorney
Office of the San Diego City Attorney
1200 Third Avenue, Suite 1100
San Diego, California 92101 Telephone: (619) 533-6449
E-mail: [email protected]
Representative for the City of San Diego
93 Joint Parties’ Protest of SDG&E Application i
SUBJECT MATTER INDEX
I. JOINT PARTIES’ INTERESTS ............................................................................................ 2 A. SDREN’s Interests .............................................................................................................. 3 B. City of San Diego’s Interests .............................................................................................. 5 C. BayREN, I-REN, 3C-REN, and NREN’s Interests ............................................................ 6 II. GROUNDS FOR PROTEST ................................................................................................. 9 A. SDG&E’s Application Implicates Broad Issues of Law and Policy That Should be Examined in the New EE OIR. ........................................................................................... 9
1. It is Not Clear Whether California Law Allows SDG&E to Withdraw from Energy Efficiency Program Administration. .............................................................................. 9
2. SDG&E’s Withdrawal as an EE PA Will Impact Larger Issues Associated with Procurement Planning, Statewide EE Goals, and Customer Rates. ............................. 11 B. Much of SDG&E’s Application Overlaps with Topics Already Slated for Consideration in the EE OIR. ................................................................................................................... 12 C. SDG&E’s Application Lacks Sufficient Factual Support and Rests on Several Key Mischaracterizations. ........................................................................................................ 15
1. SDG&E Mischaracterizes the Extent of the Cost Savings Associated with its Application and Improperly Speculates as to SDREN Impacts on Savings. ............... 16
2. SDG&E’s Application Asserts That Certain Programs Overlap with SDREN But Does Not Detail Mitigation Measures in Place. .................................................................... 18
3. SDG&E’s Application Does Not Provide Additional Information Needed to Properly Evaluate its Request. .................................................................................................... 19 III. CATEGORIZATION OF PROCEEDING, ISSUES TO BE CONSIDERED, NEED FOR HEARINGS, AND PROPOSED PROCEDURAL SCHEDULE ........................................ 20 A. Categorization ................................................................................................................... 20 B. Need For Hearings ............................................................................................................ 20 C. Issues to be Considered ..................................................................................................... 20 D. Schedule ............................................................................................................................ 21 IV. COMMUNICATIONS AND SERVICE ............................................................................. 22 V. CONCLUSION .................................................................................................................... 24 94 Joint Parties’ Protest of SDG&E Application ii
TABLE OF AUTHORITIES
Statutes
Cal. Pub. Res. Code § 25305 ........................................................................................................ 12 Cal. Pub. Res. Code § 25310 ........................................................................................................ 12 Cal. Pub. Util. Code § 399.15 ....................................................................................................... 11 Cal. Pub. Util. Code § 451 ............................................................................................................ 12 Cal. Pub. Util. Code § 454.5 ........................................................................................................... 9 Cal. Pub. Util. Code § 454.55 ....................................................................................................... 10 Commission Decisions
D.07-10-032 .................................................................................................................................. 10 D.07-12-052 .................................................................................................................................. 10 D.08-09-040 .................................................................................................................................. 10 D.08-10-037 .................................................................................................................................. 14 D.12-01-033 .................................................................................................................................. 10 D.12-11-015 .................................................................................................................................... 4 D.15-10-028 .................................................................................................................................. 14 D.18-05-041 .................................................................................................................................. 18 D.19-12-021 .......................................................................................................................... 4, 5, 18 D.20-11-013 .................................................................................................................................... 8 D.21-05-031 .................................................................................................................................. 10 D.21-09-037 .................................................................................................................................. 16 D.23-06-055 .................................................................................................................................. 10 D.24-08-003 .................................................................................................................................... 3 Commission Rules of Practice and Procedure
Rule 2.6 ........................................................................................................................................... 1 95 Joint Parties’ Protest of SDG&E Application iii
SUMMARY OF RECOMMENDATIONS
The Joint Parties respectfully requests that the Commission1 evaluate the broad questions of law and policy embedded in SDG&E’s request to cease administering regional energy efficiency programming in a rulemaking venue in which all IOU and non-IOU PAs are respondents. Should the resolution of threshold questions confirm SDG&E could be permitted to withdraw under the current statutory framework, the Commission should order SDG&E to resubmit its Application with additional detail provided. The Commission should evaluate the Application on a non-expedited basis to allow for the time and processes needed to determine whether, under SDG&E’s proposal, there will remain sufficient EE programming coverage in SDG&E’s territory. 1 All acronyms and defined terms used in the Summary of Recommendations are defined in the body of this Protest.
96 Joint Parties’ Protest of SDG&E Application 1
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Application of San Diego Gas & Electric Company
(U 902 M) to Revise its 2024-2031 Energy
Efficiency Rolling Portfolio Business Plan
A.25-04-014
PROTEST OF SAN DIEGO REGIONAL ENERGY NETWORK, BAY AREA
REGIONAL ENERGY NETWORK, TRI-COUNTY REGIONAL ENERGY NETWORK,
INLAND REGIONAL ENERGY NETWORK, NORTHERN RURAL ENERGY
NETWORK, AND THE CITY OF SAN DIEGO TO THE APPLICATION OF SAN
DIEGO GAS & ELECTRIC COMPANY
In accordance with Rule 2.6 of the Rules of Practice and Procedure of the California Public Utilities Commission (“Commission”), San Diego Community Power (“SDCP”) on behalf of the San Diego Regional Energy Network (“SDREN”); the Association of Bay Area Governments on behalf of the Bay Area Regional Network (“BayREN”) program; the County of Ventura on behalf of the Tri-County Regional Energy Network (“3C-REN”) program; Western Riverside Council of Governments (“WRCOG”) on behalf of the Inland Regional Energy Network (“I-REN”); Redwood Coast Energy Authority (“RCEA”) on behalf of the Northern Rural Energy Network (“NREN”); and the City of San Diego (together, the “Joint Parties”)2 hereby submit this protest to
the Application of San Diego Gas & Electric Company (U 902 M) to Revise its 2024-2031 Energy Efficiency Rolling Portfolio Business Plan (“Application”).3 In accordance with Rule 2.6 and the noticing of this Application on the Commission’s Daily Calendar on April 29, 2025, this Protest is timely filed.
Through its Application, San Diego Gas & Electric Company (“SDG&E”) seeks Commission approval to discontinue regional energy efficiency (“EE”) program administration, 2 Each of the Joint Parties respectfully requests individual party status. 3 Application (“A.”) 25-04-014, Application of San Diego Gas & Electric Company (U 902 M) to Revise its 2024-2031 Energy Efficiency Rolling Portfolio Business Plan (Apr. 25, 2025). 97 Joint Parties’ Protest of SDG&E Application 2
except for its Codes and Standards (“C&S”) program. While the Application presents a unique opportunity to re-envision the Commission’s market-rate EE portfolio administrative model and how to more effectively meet the state’s climate and energy goals, it also presents significant questions of law and policy that the Commission has not previously addressed. Most notably, there is no precedent to guide the Commission’s evaluation as to whether an investor-owned utility (“IOU”) can withdraw from EE portfolio administration, or what an IOU portfolio administrator (“PA”) must demonstrate in such an application. Likewise, granting SDG&E’s request will have novel implications on its existing obligations under its Commission-approved procurement plan.
The Commission must first consider the threshold legal questions and broad policy implications that the Application raises before it can fully consider the SDG&E Application and any potential alternatives to the proposal. Evaluation and resolution of these issues will impact all IOU EE PAs, as well as the regional energy networks (“RENs”) in their service territories. As such, the Joint Parties respectfully request that the Commission refrain from taking up SDG&E’s Application until it can resolve these broader questions in the recently opened EE Rulemaking proceeding4 (“EE OIR”) in which all PAs are named respondents.
I. JOINT PARTIES’ INTERESTS
The least expensive kWh is the one that is never used. This is an important underpinning of the loading order that was established in 2007 as a result of the passage of Assembly Bill (“AB”) 57 and serves as the cornerstone of the state’s climate and energy goals. This is just one of several factors that have contributed to California’s national leadership in the EE space. 4 Rulemaking (“R.”) 25-04-010.
98 Joint Parties’ Protest of SDG&E Application 3
California has scored #1 in the American Council for an Energy-Efficient Economy’s (“ACEEE”) State Energy Efficiency Scorecard seven times,5 including 2025, since the report’s inception in 2007. Various sub-categories contribute to the overall ranking, including “utility and public benefits programs and policies.” In this subcategory, California was also #1 in the nation.
The 2025 Scorecard states, “[Energy efficiency] benefits have been most pronounced where states and utilities have invested in energy efficiency as a resource by factoring efficiency as an integral part of utility energy resource planning and decision making in much the same way as resources such as power plants, wind turbines, and solar panels. In particular, states that have adopted an energy efficiency resource standard (EERS), establishing tangible multiyear utility savings goals, have been most successful in delivering the vast majority of utility-sector savings nationwide.” California has embraced both practices.
In reaching this level of national leadership in the EE space, the California legislature and the Commission have invested significant time and resources into formulating the deep-rooted policies that have spurred EE growth in the state. Due to the broad reach of these policies, major shifts in the EE landscape will necessarily impact many of the entities working to effectuate the Commission’s EE goals.
A. SDREN’s Interests
Authorized by the Commission in Decision 24-08-003,6 SDREN is a collaboration between SDCP7 and the County of San Diego, created to be a driving force for communities in the region 5 American Council for an Energy-Efficient Economy, 2007-2010, 2020-2022, 2025 State Energy Efficiency Scorecards. Accessible at: aceee.org. 6
See generally, Decision (“D.”) 24-08-003 (Aug. 1, 2024). 7 SDCP is a Community Choice Aggregator (“CCA”) serving the cities of Chula Vista, Encinitas, Imperial Beach, La Mesa, National City, and San Diego, as well as the unincorporated areas of San Diego County that receive SDG&E transmission and distribution service. SDCP is a load serving entity (“LSE”), and its customers are categorized as unbundled customers. 99 Joint Parties’ Protest of SDG&E Application 4
to adopt clean, reliable energy through community-driven solutions that contribute to local and state energy efficiency and climate goals. SDREN’s portfolio of ten programs is designed to complement SDG&E’s offerings and will start launching in late 2025. These programs span public, residential, commercial, and cross-cutting sectors.8 At a fundamental level, SDREN’s priority is programming that best meets the needs of San Diegans across the region’s 18 incorporated cities, 47 school districts, 18 recognized Tribal communities, and unincorporated areas. In keeping with its core values, SDREN will integrate a collaborative and purposeful investment in the region's underserved and hard-to-reach communities to contribute to an equitable transition to a clean energy economy.
SDG&E’s Application directly impacts these interests through its argument that in its absence, SDREN and statewide programs will provide adequate coverage for SDG&E’s service territory. Indeed, as noted in subsequent sections, SDREN’s footprint does not align completely with SDG&E’s service area. Aside from the question of geographical coverage, it is possible that relying on a REN to provide coverage intended to be provided by IOUs is inconsistent with the Commission’s stated purpose of REN programs. The Commission authorized the first two RENs as pilots in 2012,9
and subsequently recognized that local governments are well positioned to fill gaps in service left by IOU PA, elect-to-administer PA, and apply-to-administer PA portfolios.10 SDG&E’s assertion must also be considered within the context of Commission-established criteria that local governments must meet to qualify as a REN. These criteria reflect the intended purpose of RENs and define the unique role they play in the market-rate EE landscape:
8 R.13-11-005, Motion of San Diego Community Power on Behalf of the San Diego Regional Energy Network for Approval of Energy Efficiency Portfolio Application, Exhibit 1, p. 3 (Jan. 5, 2024). 9 D.12-11-015, p. 2 (Nov. 15, 2012). 10 D.19-12-021, p. 18 (Dec. 12, 2019). 100
Joint Parties’ Protest of SDG&E Application 5
1) “Activities that utilities or CCA program administrators cannot or do not intend to undertake;
2) Pilot activities where there is no current utility or CCA program offering, and where there is potential for scalability to a broader geographic reach, if successful. 3) Activities serving hard-to-reach markets (HTR), whether or not there is another utility or CCA program that may overlap.11”
Importantly, these criteria were not developed within the context of an IOU ceasing to serve as a PA. In fact, the Commission has explained that “[T]he criteria above were designed to allow the REN programs to operate as supplemental to and in conjunction with the existing utility energy efficiency portfolios.”12 Additionally, cost-effectiveness requirements inadvertently made it difficult for IOU PAs to serve hard-to-reach communities. RENs are intended to fill gaps, which inherently assumes other PA types are also serving the region.13 Notwithstanding, SDREN’s ultimate priority is best serving San Diegans and maximizing affordability. SDREN is open to exploring pathways that promote innovative, nimble, and effective adoption of technology and services. While RENs are neither authorized nor intended to “take on,” “adopt,” or “absorb” programs administered by another PA, if the Commission ultimately determines it is legally permissible to grant SDG&E’s request, SDREN would theoretically need to issue a market assessment to re-assess the region’s needs and design new programs to appropriately meet those needs. However, the Commission must first address the important threshold questions identified herein before any such assessment can be made.
B. City of San Diego’s Interests
The City of San Diego is one of the largest users of electricity and distribution resources in SDG&E’s territory, with approximately 3,500 electric accounts across every rate class and a 11 Id. at 32.
12 Id. at 5.
13 Id. at 37.
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wide variety of service schedules. The City values EE as a solution to help achieve its ambitious decarbonization goals. The City and its constituents have benefitted from SDG&E’s EE programming over the years, and the City’s ultimate interest is ensuring continuity of programming for municipal operations and its constituents. The City was a party to the original Rulemaking, R.13-11-005, that ultimately led to the creation of SDREN and is excited for the launch of new SDREN programs to complement the SDG&E portfolio. The City supports a deliberate and transparent process to ensure there are no unintended and inadvertently deleterious consequences that could arise as a result of SDG&E’s Application to withdraw from EE administration starting in 2026. Local programs tailored to regional needs remain critical to achieving the City’s Climate Action Plan targets, reducing utility burdens on customers, and advancing decarbonization efforts across the built environment.
C. BayREN, I-REN, 3C-REN, and NREN’s Interests
NREN’s service territory encompasses a broad and predominantly rural expanse that includes Alpine, Amador, Butte, Calaveras, El Dorado, Humboldt, Lake, Lassen, Mariposa, Mendocino, Nevada, Placer, Plumas, Sierra, Sutter, Tuolumne, and Yuba counties—areas that lie within Pacific Gas and Electric Company’s (“PG&E”) service area. These communities are home to a majority of hard-to-reach, underserved, low-income, and tribal populations. In alignment with the Commission’s longstanding recognition of the unique role of RENs, NREN was established to fill gaps where existing program administrators—due to scale, geography, or cost-effectiveness constraints—have historically been unable to deliver services. The NREN portfolio provides a comprehensive suite of EE services across the residential, commercial, and public sectors, including education and outreach, technical assistance, project incentives, financing, workforce development, and codes and standards support. These offerings are specifically tailored to meet the distinct needs of the region’s underserved populations. NREN is concerned about the 102
Joint Parties’ Protest of SDG&E Application 7
Application’s impact on relationships between IOUs and RENs in delivering EE programs and does not support any redefinition of the REN role in the absence of IOUs operating regional EE programs.
BayREN serves customers in the nine-county Bay Area region, a region that serves nearly 8 million residents, incorporates urban, suburban and rural populations and operates solely within PG&E’s service area. BayREN administers regional, equity-based and equity focused programs within the resource acquisition and market support segments as well as one statewide program.
BayREN’s programs include, among others, its C&S program—improving C&S compliance at the local government level and supporting local governments in implementing reach codes—and its award-winning multifamily program which serves a notoriously hard-to-reach sector. 3C-REN serves customers in the Counties of San Luis Obispo, Santa Barbara, and Ventura; 3C-REN’s customers receive utility service from PG&E, Southern California Edison Company (“SCE”), and Southern California Gas Company (“SoCalGas”). 3C-REN serves regional needs that were previously not met given the overlapping service territories of the IOUs in its region.
I-REN serves customers in the counties of Riverside and San Bernardino (together, the Inland Empire)—a vast territory that includes large rural areas with underserved, low income, and tribal populations. The I-REN EE portfolio includes interrelated programs serving local public agencies through technical assistance, public facility upgrade incentives, codes and standards compliance support, and workforce initiatives to provide job opportunities that build capacity at local agencies to undertake EE planning and retrofit projects. I-REN also offers training opportunities to building professionals to increase understanding of code-compliant EE equipment installation, and workforce development efforts to encourage high-road EE career awareness in a region that does not have sufficient trained workforce to meet local needs. Across all these efforts, 103
Joint Parties’ Protest of SDG&E Application 8
I-REN coordinates with the IOUs in its territory and views them as partners, referring customers to their programs to help meet customer needs, as well as partnering with them to offer energy code compliance trainings and EE workforce development events.
Together, the Joint Parties have an interest in this proceeding due to the statewide implications this Application would have: its monetary and non-monetary impacts on ratepayers; its impact on climate change and the environment; and its impact on the health of the energy efficiency ecosystem in California. California has established goals for carbon neutrality, renewable energy, heat pump installation, and others, but to achieve those goals, it’s necessary to have boots on the ground. That includes a trained workforce (including through the Commission’s Market Support programs); programs and incentives to ensure the appliances that save money and energy actually are installed (Resource Acquisition programs); a focus on opportunities to increase the health and safety of ratepayers, particularly California’s most vulnerable populations, including by reducing indoor air temperature and improving indoor air quality (Equity programs); and local governments that must work to support successful implementation of – and compliance with – the state’s codes and standards, air district zero emission compliance standards, and local government reach codes. As communities are growing, Californians in underserved, disadvantaged, and hard-to-reach regions need more support from EE PAs. An abrupt unraveling of one element of the EE ecosystem, as proposed by the Application, will have impacts on other IOUs in considering doing the same, as well as others in the ecosystem. An IOU’s departure does not change state and local goals, nor can the Commission assume that “the market” will somehow step in to ensure equity or solutions to the climate crisis.
Finally, it is important to consider factors contributing to SDG&E’s Application that may influence other IOUs to take similar actions. For example, in Decision 20-11-013, the Commission 104
Joint Parties’ Protest of SDG&E Application 9
put a moratorium on IOU shareholder incentives for EE performance. This is just one of many changes in the portfolio framework that may be a contributing factor to SDG&E’s decision to propose withdrawal and could serve as motivation to the other IOU PAs. This is not mentioned in the SDG&E Application, which instead justifies its proposal to withdraw based on cost-effectiveness trends, which are discussed in subsequent sections.
II. GROUNDS FOR PROTEST
A. SDG&E’s Application Implicates Broad Issues of Law and Policy That Should Be Examined in the New EE OIR.
The legal, policy, and operational issues inherent within SDG&E’s Application will not just impact SDREN, but all EE PAs more broadly. Indeed, the Application introduces questions that could fundamentally change the rules and roles the Commission has assigned to IOU and non-IOU PAs over the years. The broad applicability of these questions and the impact their resolution will have on other PAs across California underscores the need to address these issues in a non-expedited proceeding in which all IOU and non-IOU PAs are respondents. As many of the topics raised in SDG&E’s Application are already slated for consideration in the EE OIR, the Commission should refrain from evaluating the merits of SDG&E’s specific proposal until it can resolve the broader threshold issues in the EE OIR.
1. It is Not Clear Whether California Law Allows SDG&E to Withdraw from Energy Efficiency Program Administration.
SDG&E’s request to withdraw as a regional PA would set in motion a major shift that requires additional scrutiny of IOU obligations under California law and Commission policy. For instance, California Public Utilities Code § 454.5(b)(9)(C)(i)14 requires an IOU’s approved 14 All subsequent statutory references are to the California Public Utilities Code, unless indicated otherwise.
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Joint Parties’ Protest of SDG&E Application 10
procurement plan to demonstrate that it will first meet unmet resource needs through all available EE and demand response resources that are cost effective, reliable, and feasible. This requirement was subsequently implemented through Commission decisions establishing a “loading order” for resource procurement.15 In addition, Section 454.55(a)(1) requires the Commission, along with the California Energy Commission, to identify all potentially achievable cost-effective electricity efficiency savings and establish efficiency targets for the IOUs to achieve. This process is accomplished through the Potential and Goals Study (“P&G Study”) process.16 Consistent with these requirements, D.07-10-032 required the IOUs to create long-term EE strategic plans17 which were adopted in D.08-09-040 and included SDG&E as a PA.18 In D.21-05- 031, the Commission revised the EE Portfolio Application process and ordered all EE PAs to file applications by February of 2022 to cover a four-year program portfolio beginning in 2024 and eight-year business plan extending to 2031.19 In D.23-06-055, the Commission reaffirmed SDG&E’s role as a PA and approved SDG&E’s 2024-2027 Portfolio Plan and its 2024 – 2031 Business Plan.
20 To date, there is no precedent indicating whether or how an IOU PA could withdraw from administrator status. Resolution of these questions will require thorough Commission evaluation of whether an IOU can comply with the statutory requirement to first meet unmet resource needs with cost-effective, reliable, and feasible EE resources, as well as the Commission’s loading order and SDG&E’s approved procurement plan. These issues implicate all IOU PAs, warranting more 15 See, e.g., D.07-12-052, p. 12 (Dec. 20, 2007). Note that the loading order is an ongoing obligation (see D.12-01-033).
16 The current 2025 P&G Study process is currently underway in R.25-04-010. 17 D.07-10-032, p. 2, Ordering Paragraphs (“OPs”) 1 and 4 (Oct. 18, 2007). 18 D.08-09-040, OPs 1 and 2 (Sept. 18, 2008).
19 D.21-05-031, OP 5 (May 20, 2021).
20 D.23-06-055, OP 1.
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Joint Parties’ Protest of SDG&E Application 11
thorough consideration in a proceeding in which all PAs will be participating – as opposed to a separate Application proceeding where parties would need to move for party status in order to provide input. This would risk an insular treatment of the issues raised in the Application, despite the Application raising questions of statewide impact and import.
2. SDG&E’s Withdrawal as an EE PA Will Impact Larger Issues Associated with Procurement Planning, Statewide EE Goals, and Customer Rates.
Beyond the threshold question of whether SDG&E can withdraw as an EE PA, its Application raises issues of broad applicability associated with Commission and legislative mandates. For example, Section 399.15 governs the Renewables Portfolio Standard (“RPS”).
Failure to achieve the EE targets established by the Commission’s Potential and Goals Study would allow load to grow unchecked, increasing the absolute amount of renewable energy required to meet the RPS – even if the percentage target remains unchanged. This scenario risks exposing IOUs and all LSEs to RPS compliance penalties.
Moreover, as statewide load growth continues, even modest EE savings remain essential to alleviating grid constraints, reducing Resource Adequacy requirements, and enhancing system reliability.21 Recognizing these contributions is consistent with the Legislature’s direction under Senate Bills 10022 and 35023 and Assembly Bill 3232,24 which collectively identify EE as a core pillar of the state’s long-term decarbonization and reliability strategies. 21 Frick, N.M., Carvallo, J.P., and Schwartz, L., Quantifying grid reliability and resilience impacts of energy efficiency: Examples and Opportunities, LBNL Technical Brief, December 2021. 22 Increases RPS mandate to 60% by 2030 and requires renewable and zero carbon resources to supply 100% of retail sales. Energy efficiency is important as a measure to mitigate the need for fossil fuels to supplement renewables as California’s load increases
23 Requires a doubling of energy efficiency by 2030.
24 Directs the CEC to “assess the potential…to reduce the emissions of greenhouse gases in…residential and commercial building stock by at least 40% below 1990 levels by January 1, 2030.” 107
Joint Parties’ Protest of SDG&E Application 12
California’s adopted energy planning framework, as codified in Public Resources Code Sections 25310 and 25305, also recognizes EE savings and the California Energy Demand (“CED”) forecast as foundational inputs for evaluating future system needs. These elements are central to ensuring resource planning efforts remain aligned with the state’s climate, reliability, and affordability objectives.
Finally, the Commission should review SDG&E’s Application in a manner consistent with longstanding precedent interpreting utility obligations under Section 451, which requires just and reasonable rates—necessarily including cost-effective EE—and adequate service for customers, taking into consideration their health, safety and comfort. Any change in administrative roles must preserve, rather than diminish, the statutory responsibility of utilities to provide safe, reliable, and just and reasonable service. Consideration of these obligations—particularly as they relate to the role of EE in the state’s preferred loading order—should proceed transparently and be integrated into the broader issues currently scoped into the EE OIR. Resolving these issues in isolation through a stand-alone application risks generating outcomes that are incomplete or misaligned with established Commission frameworks.
B. Much of SDG&E’s Application Overlaps with Topics Already Slated for Consideration in the EE OIR.
Many of the issues raised in SDG&E’s Application are substantively similar to those scoped into the EE OIR. In particular, the Commission’s Order Instituting Rulemaking (“OIR”) indicates that the Commission will evaluate cost-effectiveness policy, deliberation of program and portfolio interactions between various administrator types, energy efficiency potential and goals, changes to statewide program implementation and policy, and more.25 Opening comments filed on 25 R.25-04-010, Order Instituting Rulemaking, pp. 3-8 (Apr. 29, 2025). 108
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the OIR indicate strong interest from parties to conduct a deeper evaluation of cost-effectiveness policy and approaches that will improve the portfolio’s efficacy.26 SDG&E’s Application gives rise to systemic issues of cost-effectiveness – which is currently narrowly defined by the Commission27 – common to other IOU PA portfolios. This is affirmed by the recent State Audit28 that identified a generally decreasing cost-effectiveness trend amongst IOU EE programs.29 The State Audit highlights areas for improvement with regard to Commission oversight and highlights previous evaluations that provided guidance to IOUs on increasing the cost-effectiveness of their portfolios.30 Notably, the State Audit is of particular importance within the context of the new EE OIR, which specifically references the State Audit in defining the scope of the planned cost-effectiveness discussion therein.31 SDG&E’s assertion that its regional programs should be eliminated due to poor cost-effectiveness fails to acknowledge that the underlying challenges are not unique to SDG&E, but rather symptomatic of broader issues affecting all IOU portfolios. To reiterate, the State Audit indicates that poor cost-effectiveness is a general trend within each IOU’s portfolio–and among a small number of programs sampled-that warrants remediation and directs the Commission to address these shortfalls.32 This trend is ostensibly a function of market maturity; as ‘low-hanging fruit’ is exhausted, remaining opportunities for savings are more expensive to capture. The 26 R.25-04-010, Opening Comments of The Utility Reform Network, p. 3 (May 19, 2025); R.25-04- 010, Opening Comments of SoCalREN, pp. 2-3 (May 19, 2025). 27 For a discussion of this issue, see, R. 22-11-013, Comments of BayREN and 3C-REN on Avoided Cost Calculator Guiding Principles (May 12, 2025).
28 California State Auditor Report 2023-127, issued March 2025. 29 A.25-04-014, Prepared Direct Testimony of Hollie Bierman, pp. HB-3 – HB-5 (Apr. 2025). 30 California State Auditor, “The California Public Utilities Commission – Without Improving its Oversight, the Benefits of Energy Efficiency Programs May Not be Worth Their Cost to Ratepayers, pp. 25-34 (Mar. 2025). Available at: https://www.auditor.ca.gov/wp-content/uploads/2025/03/2023-127- Report.pdf.
31 Order Instituting Rulemaking at 5.
32 At page 14 and 20 of California State Auditor Report 2023-127, issued March 2025. 109
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Commission acknowledged this dynamic as early as 2008,33 reiterated it in 201534 and again in 2021.35 In opening comments on the OIR, several parties urge the Commission to prioritize cost-effectiveness policy specifically.
Further analysis of cost-effectiveness scores is also warranted across all IOUs’ energy efficiency portfolios because the Audit draws conclusions based on a time period inclusive of the COVID years when PAs faced extraordinary challenges in delivering in-person services, therefore limiting their ability to achieve energy savings. SDREN recommends normalizing audit data to account for these pandemic-related impacts, including any lingering spillover effects that may have continued to affect portfolio performance. Additionally, data from 2017–2019 poses challenges due to inflated savings from the Upstream Lighting Program, the analytic limitations of both pre-2020 and pandemic-era data underscore the need for closer scrutiny and broader deliberation in the EE proceeding.
Accordingly, the Joint RENs’36 EE OIR opening comments recommended adding systemic cost-effectiveness (among other issues) to the scope of the rulemaking:
“Systemic Cost-Effectiveness Evaluation
• How the Commission should address system-wide portfolio cost-effectiveness challenges, including those identified in the 2025 State Audit, before acting on utility specific administrative proposals;
33 D.08-10-037, p. 84 and FOF 3
34 D.15-10-028, p. 2.
35 Guidehouse, 2021 Energy Efficiency Top-Down Potential Prototype Analysis, prepared for the California Public Utilities Commission, p. 76 (Jan. 18, 2022). Accessible at: https://www.cpuc.ca.gov/- /media/cpuc-website/divisions/energy-division/documents/energy-efficiency/cpuc-top-down-potential-final-2022-1-18.pdf. 36 The Joint RENs include BayREN, 3C-REN, Central California Rural Regional Energy Network, NREN, I-REN, and SDREN.
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• How reforming the EE administrative model itself could improve portfolio performance, cost-effectiveness, and customer outcomes.”37 In summary, cost-effectiveness issues are not unique to SDG&E and should not be treated separately from the Commission’s deliberations on cost-effectiveness in the rulemaking. Given these broadly applicable and outstanding issues, it is prudent to consider remediation interventions and other ways to improve cost-effectiveness prior to resolving a specific IOU’s request to withdraw due to poor portfolio cost-effectiveness.38
Finally, in addition to cost-effectiveness, parties have called for broader reforms to enhance administrative efficiency and strengthen portfolio performance, both of which are essential to achieving meaningful cost containment. These EE-specific trends and potential solutions merit deeper examination in the EE OIR, where all PAs are respondents, and the Commission is positioned to undertake comprehensive reform.
C. SDG&E’s Application Lacks Sufficient Factual Support and Rests on Several Key Mischaracterizations.
Beyond implicating issues of broader applicability that are more appropriately addressed in the EE OIR, the Commission should not grant the Application as it lacks necessary details and relies upon several material mischaracterizations. If the Commission determines through the EE OIR that it is legally permissible for an IOU to withdraw from administering EE programs, then the Commission should also utilize that proceeding to determine the specific details that must be included in such an application. Thereafter, the Commission should require SDG&E to resubmit its Application according to that guidance.
37 Joint Regional Energy Network Comments on Order Instituting Rulemaking at 5-6. 38 See Bierman Direct at HB-3 – HB-5.
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Joint Parties’ Protest of SDG&E Application 16
1. SDG&E Mischaracterizes the Extent of the Cost Savings Associated with its Application and Improperly Speculates as to SDREN Impacts on Savings.
SDG&E argues throughout its Application and supporting testimony that closing its regional EE programs will yield approximately $300 million in savings for ratepayers over a six-year period (2026-2031).39 This claim is misleading in several respects, including the fact that some portion of these costs may be required to support programs designed to maintain continuity of service and ongoing delivery of EE offerings should SDG&E be allowed to withdraw.
To that end, the Application appears to define savings as a simple subtraction of program budgets, without accounting for the value of the foregone Total System Benefits (“TSB”), which are the long-run avoided costs that EE programs deliver. TSB is designed to more holistically capture the benefits of EE—like reduced grid strain, and greenhouse gas emissions reductions.
Decision 21-09-037 established TSB as the primary metric by which to quantify portfolio benefits; therefore, it is important for the Commission to temper SDG&E’s claimed savings with TSB data, considering the losses in monetized benefits that the Application will implicate.40 In short, TSB must be considered because it provides stakeholders and decisionmakers a sense of scale, impact, and benefits at the macroscale – information that is not apparent with cost-effectiveness scores alone. Similarly, the Application does not account for the avoided costs (e.g., transmission and distribution, generation, etc.) that will no longer be avoided if SDG&E’s portfolio ceases to exist.
Ultimately, SDG&E’s asserted savings only materialize if it’s assumed that there are currently zero benefits to the grid and ratepayers from its EE program expenditures.
It is important to note that any program currently achieving more than a 1.0 Total Resource Cost (“TRC”) ratio that is eliminated will result in additional costs to ratepayers, and any program 39 Application at 9.
40 A.25-04-014, Prepared Direct Testimony of Hollie Bierman, Table HB-3 on p. HB-10 (Apr. 2025). 112
Joint Parties’ Protest of SDG&E Application 17
achieving less than a 1.0 TRC will only result in partial savings based on how near or far it is from the 1.0 ratio. Thus, even if TRC is used as the primary measure of cost-effectiveness, which is not the intention according to the Commission’s Standard Practice Manual,41 the actual customer savings from eliminating EE programs would be just a fraction of $300 million. Any program achieving a TRC greater than 1.0 that is eliminated will result in net cost increases to ratepayers, and even sub-1.0 programs may deliver critical non-energy benefits (e.g., local economic development, reduced energy burden, health, safety, and resilience) not captured by the TRC.
Additionally, the TRC only accounts for utility avoided costs, not the benefits and costs of the customer.42 SDG&E's portfolio generates monetized TSB, and its Application demonstrates that the proposed withdrawal would leave behind unaccounted benefits.43 The systemic concerns described in prior sections are driven, at least in part, by methodological constraints in current cost-effectiveness tools like the TRC test and the Avoided Cost Calculator (“ACC”) itself – constraints which help explain why SDG&E’s estimated cost savings are inaccurate. The ACC fails to account for localized costs and non-energy benefits, especially in underserved communities, leading to skewed assessments of portfolio value.44 The ACC also omits key avoided costs like methane leakage, particulate pollution, and those borne by ratepayers, all of which are real but uncounted benefits of demand-side investments.45,46 As such, 41 See Standard Practice Manual, p. 6.
42 R.22-11-013, Comments of Association of Bay Area Governments and County of Ventura on Administrative Law Judge Ruling, pp. 24-25.
43 Bierman Direct at HB-10, Table HB-3.
44 R. 22-11-013, Comments of BayREN and 3C-REN on Avoided Cost Calculator Guiding Principles (May 12, 2025).
45 Id.
46 Energy efficiency further yields significant benefit to the ratepayers, reflected in ongoing Commission and statewide discussions regarding non-energy impacts (NEIs) and non-energy benefits (NEBs) as well as in Draft Resolution E-5351 reflecting key metrics and indicators of EE programs. 113
Joint Parties’ Protest of SDG&E Application 18
SDG&E’s cited TRC-based cost-effectiveness results are the product of an outdated framework under review,47 not a failure specific to any single IOU.
Finally, SDG&E’s suggestion that new SDREN programs could offset its program closures is speculative and conflicts with D.19-12-021, which clarifies that RENs are intended to operate as supplemental to, not substitutes for, IOU portfolios. All things considered, any claims of ratepayer savings associated with the potential exit of an IOU from program administration warrant rigorous scrutiny.
2. SDG&E’s Application Asserts That Certain Programs Overlap with SDREN But Does Not Detail Mitigation Measures in Place.
SDG&E’s Application indicates its intention to sunset programs that overlap with SDREN offerings and cost customers more than the value they provide.48 However, SDG&E’s claim that programs are redundant lacks detailed discussion, evidentiary support, and important context.
The Commission requires EE PAs with overlapping service areas to submit a joint cooperation memorandum (“JCM”) to coordinate program activities.49 Specifically, the Commission stated:50
“We will require the PAs (RENs, IOUs, and CCAs) to develop a joint cooperation memo to demonstrate how they will avoid or minimize duplication for programs that address a common sector (e.g., residential or commercial) but pursue different activities, pilots that are intended to test new or different delivery models for scalability, and/or programs that otherwise exhibit a high likelihood of overlap or duplication and are not targeted at hard-to-reach customers. For such programs, each PA must explicitly identify and discuss how its activities are complementary and not duplicative of other PAs’ planned activities.”
47 TRC is currently used as the primary measure of cost-effectiveness, which is not the intention according to the Commission’s Standard Practice Manual. 48 See Bierman Direct at HB-9.
49 D.18-05-041, pp. 97, 122, FOF 55, COL 47 (June 5, 2018). 50 Id. at 97.
114
Joint Parties’ Protest of SDG&E Application 19
Accordingly, the 2024-2025 JCM between SDREN and SDG&E was submitted on November 5, 2024, and illustrates how this collaboration will occur and ensure customers are routed to the programs and services that will best meet their needs. Additionally, provided SDREN’s programs will not be launching until the end of 2025, there is not ample evidence to demonstrate implemented programs have been redundant. Absent further justification, SDG&E’s claim is unsubstantiated.
Finally, the Commission should recognize that SDREN’s service area is not coterminous with SDG&E’s. While SDG&E’s current EE portfolio extends into southern Orange County, this portion of its service territory falls outside SDREN’s authorized footprint. If SDG&E is permitted to withdraw, these customers risk being left without sufficient access to EE programs – an outcome that underscores the importance of thoughtfully planning for continued service coverage across the entire territory.
3. SDG&E’s Application Does Not Provide Additional Information Needed to Properly Evaluate its Request.
SDG&E’s Application is notably lacking an impact analysis and discussion of remediation efforts. Impact analyses are crucial for the Commission to understand the Application’s effect on job losses, local workforce opportunities, and other equity implications resulting from program closures. In addition to the previously described threshold legal and policy issues, it is important that the Commission consider remediation measures for underperforming IOU portfolios to maximize statewide energy savings and GHG reductions. These missing details are material to the issues raised in the Application and as such, the absence of this information further indicates that the Application cannot yet be decided. If the Commission finds through the EE rulemaking that it is acceptable for an IOU PA to withdraw from administering regional EE programs, then it should 115
Joint Parties’ Protest of SDG&E Application 20
also provide detailed guidance to IOU PAs that wish to withdraw on what must be included in such an application.
III. CATEGORIZATION OF PROCEEDING, ISSUES TO BE CONSIDERED, NEED
FOR HEARINGS, AND PROPOSED PROCEDURAL SCHEDULE
A. Categorization
The Joint Parties agree with the categorization of this proceeding as ratesetting.51 B. Need For Hearings
As discussed above, the Joint Parties recommend that the Commission migrate the consideration of threshold issues from this Application into the EE OIR for further consideration.
Subject to that recommendation, the Joint Parties anticipate that hearings may be necessary to further develop the record on the important issues of facts raised in this Application.
C. Issues to be Considered
SDG&E proposes as the sole issue to be considered: “The primary issue to be considered is whether SDG&E is authorized to close its regional programs, yielding approximately $300 million in savings for ratepayers over a six-year period.” In addition to removing the contested factual assertion contained therein, the Joint Parties offer the following recommendations:
1) The Joint RENs recommend R.25-04-010 as the forum in which threshold legal and policy questions be addressed. If the Commission does not elect to address those issues in the Rulemaking, those issues should be scoped here.
2) If the Commission determines that SDG&E may withdraw, in whole or in part, from its role as regional program administrator, the Commission should scope whether the process and timeline of the proposed reduction in services to ratepayers is adequate. 51 Application at 8.
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Joint Parties’ Protest of SDG&E Application 21
3) Finally, consistent with the Commission’s Environmental and Social Justice Action Plan (“ESJ” Action Plan), the Joint Parties strongly encourage the Commission to include ESJ impacts in the scope of the proceeding.
D. Schedule
It is imperative that the Commission decline SDG&E’s request for expedited treatment.
The Application raises novel questions of law and policy that necessitate additional time for the Commission and parties to thoroughly evaluate. As the Commission will be considering issues material to the resolution of this Application in the EE rulemaking, prudence, efficiency and consistency require that those issues be resolved prior to considering SDG&E’s related request.
Accordingly, the Joint Parties respectfully request that the Commission integrate the schedule as proposed below into the EE rulemaking schedule.52 This schedule ensures sufficient time and opportunity for the EE OIR to resolve related issues included in the preliminary track, which in turn should result in more efficient deliberation starting in 2026 of outstanding issues associated with the SDG&E Application.
Event Proposed Date
ALJ Ruling Seeking Input on Outstanding IOU Withdrawal Key Policy/Legal Issues
Late Q1 2026
Opening Comments Filed and Served Q2 2026
Reply Comments Filed and Served Q2 2026
ALJ Ruling with Staff Proposal for Party Comment Late Q2 2026 Opening Comments Q3 2026
Reply Comments Q3 2026
Proposed Decision Late Q3 2026
Final Decision Q4 2026
52 This is the same schedule proposed in the Joint REN opening comments on the OIR at 26-28. 117
Joint Parties’ Protest of SDG&E Application 22
If the Commission adopts an alternate schedule, the Joint Parties request that – to the extent practicable – the Commission stagger the deadlines for the present Application, the EE OIR including the foundational questions referenced above, and the filing and response deadlines of the forthcoming Portfolio Administrator Applications (due February 15, 2026).
IV. COMMUNICATIONS AND SERVICE
Each of the Joint Parties respectfully requests to be listed as individual parties, consents to “email only” service, and requests that the following individuals be added to the service list for A.25-04-014:
Party Representatives
Please list the following as the party representative for SDREN:
Alissa Greenwald
Keyes & Fox LLP
1580 Lincoln St, Suite 1105
Denver, CO 80203
Telephone: (913) 302-5567
E-mail: [email protected]
Please list the following as party representative for BayREN and 3C-REN:
Elizabeth M. Kelly
LAW OFFICE OF ELIZABETH KELLY
P.O. Box 225037
San Francisco, CA 94122
Telephone: (415) 535-9998
Email: [email protected]
Counsel for:
ASSOCIATION OF BAY AREA GOVERNMENTS, for the
Bay Area Regional Energy Network (BayREN)
program
COUNTY OF VENTURA, for the Tri-County Regional
Energy Network (3C-REN) program
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Joint Parties’ Protest of SDG&E Application 23
Please list the following as party representative for I-REN:
Casey Dailey
Director of Energy & Environmental Programs
Western Riverside Council of Governments
3390 University Ave., #200
Riverside, California 92501
Telephone: (951) 405-6720
E-mail: [email protected]
Please list the following as party representative for the City of San Diego:
William Smith
Deputy City Attorney
Office of the San Diego City Attorney
1200 Third Avenue, Suite 1100
San Diego, California 92101
Telephone: (619) 533-6449
E-mail: [email protected]
Please list the following as party representative for NREN:
Patricia Terry
Senior Portfolio Manager
Redwood Coast Energy Authority
633 Third St
Eureka, CA 95501
Telephone: (707) 269-1700
E-mail: [email protected]
Information-Only
Please include the SDREN representatives listed below on the information-only service list for this proceeding:
Aisha Cervantes-Cissna
Senior Policy Manager
San Diego Community Power
P.O. Box 12716
San Diego, CA 92101
Telephone: (619) 732-4629
E-mail: [email protected]
Jacob Schlesinger
Partner
Keyes & Fox LLP
1580 Lincoln St., Suite 1105
Denver, CO, 80203
Telephone: (970) 531-2525
E-mail: [email protected]
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Joint Parties’ Protest of SDG&E Application 24
Laura Fernandez
Senior Director of Regulatory and Legislative
Affairs
San Diego Community Power
P.O. Box 12716
San Diego, CA 92101
Telephone: (619) 657-0406
E-mail: [email protected]
Sheena Tran
Associate Director of Programs
San Diego Community Power
P.O. Box 12716
San Diego, CA 92101
Telephone: (619) 732-6266
E-mail: [email protected]
V. CONCLUSION
For the foregoing reasons, the Joint Parties respectfully request that the Commission first address the broader legal and policy questions raised by this Application in proceeding R.25-04- 010, prior to taking up the merits of SDG&E’s specific request. The Joint Parties look forward to working collaboratively with the Commission and SDG&E to address the unique questions posed by this Application in the EE OIR. Following the resolution of the threshold issues described herein, the Joint Parties look forward to resolving this Application in a manner that best serves all customers in San Diego County.
Respectfully submitted,
/s/ Alissa Greenwald
Alissa Greenwald
Jacob Schlesinger
Keyes & Fox LLP
1580 Lincoln Street, Suite 1105
Denver, CO 80203
Telephone: (913) 302-5567
E-mail: [email protected]
[email protected]
On behalf of San Diego Community Power
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Joint Parties’ Protest of SDG&E Application 25
/s/ Elizabeth M. Kelly
Elizabeth M. Kelly
LAW OFFICE OF ELIZABETH KELLY
P.O. Box 225037
San Francisco, CA 94122
Telephone: (415) 535-9998
Email: [email protected]
Counsel for:
ASSOCIATION OF BAY AREA GOVERNMENTS, for the Bay
Area Regional Energy Network (BayREN) program
COUNTY OF VENTURA, for the Tri-County Regional
Energy Network (3C-REN) program
/s/ Casey Dailey
Casey Dailey
Director of Energy & Environmental Programs
Western Riverside Council of Governments
3390 University Ave., #200
Riverside, California 92501
Telephone: (951) 405-6720
E-mail: [email protected]
Administrative Lead Agency for
Inland Regional Energy Network (I-REN), ID #246
/s/ Patricia Terry
Patricia Terry
Senior Portfolio Manager
Redwood Coast Energy Authority
633 Third St
Eureka, CA 95501
Telephone: (707) 269-1700
E-mail: [email protected]
Representative for NREN
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Joint Parties’ Protest of SDG&E Application 26
/s/ William Smith
William Smith
Deputy City Attorney
Office of the San Diego City Attorney
1200 Third Avenue, Suite 1100
San Diego, California 92101
Telephone: (619) 533-6449
E-mail: [email protected]
Representative for City of San Diego
May 29, 2025
122
ITEM 8
ATTACHMENT G
123
PO BOX 12716
San Diego, CA 92112
sdcommunitypower.org
June 17, 2025
San Diego Community Power
PO BOX 12716
San Diego, CA 92112
VIA ELECTRONIC MAIL
Ms. Leuwam Tesfai
Deputy Executive Director
Energy and Climate Policy
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Ms. Candace J. Morey
Interim Director
Office of Distributed Energy Resources, Natural Gas and Retail Rates California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re: Community Choice Aggregator (CCA) Customer Access to Self-Generation Incentive Program (SGIP) Funding
Dear Ms. Tesfai and Ms. Morey:
This letter is to respectfully request the California Public Utilities Commission (CPUC) take swift action to reduce barriers for low-income community choice aggregator (CCA) residential customers seeking to access limited Self-Generation Incentive Program (SGIP) funds. San Diego Community Power (SDCP) has a pending advice letter (Center for Sustainable Energy Advice Letter 165-E) requesting approval of its Solar Battery Savings program as a Qualified Demand Response (DR) program. This program has been successfully deployed and has proven to increase individual customer resiliency, reduce the electric grid’s net peak demand, lower electric ratepayer costs, and decrease emissions of greenhouse gas and localized air pollution. These outcomes align with the CPUC’s stated intent for the SGIP. If approved, SDCP’s Solar Battery Savings program would provide an immediate and equitable pathway for low-income SDCP customers to access SGIP Residential Storage and Solar Equity (RSSE) program incentives in a timely manner.
1. There is Currently No Pathway for a CCA Customer in San Diego to Participate in SGIP
124
Last month the Commission launched the SGIP RSSE, a “statewide initiative” intending to “help California’s low-income utility customers.”1 The RSSE program is time- and budget-limited, and delaying access to a class of customers for months or years essentially prevents that class from accessing the funding. The legislature did not provide funding for RSSE only to benefit bundled customers of Investor-Owned Utilities (IOUs).2
But as is true for many low-income CCA residential customers around the state, SDCP’s residential customers cannot access the recently-opened RSSE program. To receive funding from the RSSE budget, the Commission is requiring low-income customers to enroll in a “Qualified Demand Response” program.3 However, no “Qualified Demand Response” program is currently available to SDCP residential customers.
a. The Only “Qualified Demand Response” Program in San Diego Is Only Open to Bundled Customers
There is currently only one “Qualified Demand Response” program in San Diego: San Diego Gas & Electric (SDG&E) EV-TOU-5-P. SDG&E EV-TOU-5-P is a “critical peak pricing” rate that is only open to bundled customers. Accordingly, bundled customers are currently the only customers able to access SGIP incentives. The Commission has left 70% of the customers in San Diego County (those served by the two CCAs) unable to access SGIP incentives unless they opt out of the CCA.
b. The Road Blocks Facing CCA Customers Who Seek Access to the SGIP Program SDCP has been made aware of instances where contractors are encouraging customers to opt out of CCA service in order to be eligible for the SGIP incentive. But even if one of these contractors convinced a San Diego electricity customer to leave SDCP today, that customer still would not be eligible to enroll in the only currently available “Qualified Demand Response” program for six months. They would be required to spend that time using Transitional Bundled Service—a six-month service that is extremely volatile and prohibits enrollment in IOU-administered SGIP Qualified Demand Response programs.
So, that hypothetical customer would not only remain without access to payment under the SGIP, but they would also be subject to a more unpredictable commodity product.
As such, forcing customers back into bundled service is not only anti-competitive, but it also undermines the purpose of SGIP’s RSSE budget: helping California’s low-income 1 California Public Utilities Commission, “$280 Million Program to Expand Battery Storage and Solar Access for Low-Income Households” (May 29, 2025), available at: https://www.cpuc.ca.gov/news-and-updates/all-news/$280-million-program-to-expand-battery-storage-and-solar-access-for-low-income-households. 2 See Senate Bill 700 (2018), section (i) (“The commission shall ensure that distributed generation resources are made available in the program for all ratepayers.”). 3 It is also worth noting that the governing statute does not obligate the Commission to require customer participation in such a program, but rather the statute requires the CPUC to consider requiring customers to participate in a demand response or peak load reduction program. Public Utilities Code 379.10(b). 125
customers. Once customers are enrolled in a standard SDG&E tariff six months after they opt to leave SDCP, they will be subject to higher ongoing commodity costs. SDG&E’s rates are 5% and 3% higher than SDCP’s PowerBase generation rate and PowerOn rate, respectively. They would spend at least a year with those rates, as customers must wait 12 months before returning to CCA service.
The bottom line is, under the status quo, low-income customers are being encouraged to leave a lower cost option for their electricity service, in order to possibly be eligible for an SGIP incentive in six months, assuming the funding does not run out. c. The Pending Capacity Bidding Program Advice Letter Is Also not a Practical Solution SDG&E has a pending Advice Letter 4569-E to implement a residential Capacity Bidding Program (CBP) that would meet SGIP’s “Qualified Demand Response” program requirements and theoretically be available to CCA customers (once approved). As proposed, that program is also not a solution for CCA customers considering whether to reserve funds this year.
Under the proposed program rules, SDCP understands that individual residential customers must rely on third-party aggregators to participate in the CBP and cannot personally enroll in them. But based on SDCP’s engagement with industry stakeholders, there is currently not an aggregator implementing residential Capacity Bidding programs.
If the pending advice letter is approved and a hypothetical aggregator stepped forward to offer the program, it is still the case that no such program would be available for many months because that aggregator would need to undertake program development work before offering it to residential customers. Therefore, even if approved, SDG&E’s CBP does not remove the barrier facing San Diego CCA customers seeking SGIP incentives. d. It Is Unreasonable to Delay Incentives for Low-Income Customers Under the RSSE Program
Per the program handbook rules, customers cannot get their SGIP incentive paid until after enrollment in a Qualified Demand Response program. In practical terms, this means that developers are unlikely to serve low-income CCA customers who are considering transitioning to an IOU to take advantage of the RSSE program. Such customers cannot afford upfront payment of the system until the rebate is paid, and developers are unlikely to be able serve these customers if there is regulatory uncertainty regarding the incentive payment.
2. SDCP’s Solar Battery Savings Program Is a Viable and Proven DR Solution That Dispatches Resources on a Daily Basis
SDCP also has a pending advice letter, Center for Sustainable Energy Advice Letter 165-E requesting approval of its Solar Battery Savings program as a Qualified DR program for SGIP 126
purposes. Approving the Solar Battery Savings program will immediately allow SDCP customers to access SGIP funding and support California's policy goals.
The program aggregates participants’ batteries and dispatches them on a daily basis, reducing SDCP’s Resource Adequacy obligation (and is therefore counted by the California Energy Commission as a “load modifying resource”). The program can also respond to grid events through active dispatches triggered by CAISO day-ahead pricing. SDCP launched the Solar Battery Savings Pilot4 in 2024, which is active and has already demonstrated peak demand reductions, enhanced resiliency benefits, and reduced ratepayer costs. The pilot was featured as a case study in the U.S. Department of Energy’s Pathways to Commercial Liftoff: Virtual Power Plants Report on January 10, 2025.
As is further noted in Center for Sustainable Energy Advice Letter 165-E, SDCP plans to launch an updated version of the program in 2025 that builds on the foundational program design of the pilot and adds active demand response events, which are tied to CAISO market pricing signals.
Importantly, unlike SDG&E’s critical peak pricing rate5 or proposed Residential Capacity Bidding Program6
—which offers a small number of annual or monthly “events” during which participating customers can reduce load to receive compensation—SDCP’s Solar Battery Savings program is a daily load-shifting program that can support California’s reliability goals on a routine basis. In fact, a maximum of 18 Reduce Your Use events can be triggered per calendar year under EV-TOU-5-P, the critical peak pricing program that is only available to bundled customers. The CBP, which will be open to CCA customers if an aggregator eventually steps up to offer it (and once the CPUC approves the pending advice letter), similarly can only be utilized up to six days per month, and the program only runs for six months out of the year.
3. Given that the Residential Clean Energy Credit Will Likely Sunset in 2025, It is Imperative That the Commission Take Swift Action to Preserve Equity and Legislative Intent SDCP therefore respectfully requests the Commission approve its pending advice letter or otherwise take swift action to ensure SGIP RSSE funding does not flow solely to bundled customers. The status quo is misaligned with the intent of the Legislature, which allocated substantial SGIP funding for low-income customers statewide7 and not solely to customers of the IOUs.
Even setting aside the limited RSSE program budget, time is of the essence. As the Commission is aware, the Residential Clean Energy Credit (RCEC) provides a 30% credit to support the installation of residential solar and storage systems. The version of the One Big Beautiful Bill Act approved by the House of Representatives would sunset the RCEC at the end of 2025. 8 This tax
credit plus an SGIP incentive can cover the entire cost of a solar and battery system for a low-4 The Solar Battery Savings pilot resulted in over 1,600 projects, providing an expected 7.2 MW of peak load reduction daily during on-peak periods for up to 10 years. 5 EV-TOU-5-P provides a maximum of eighteen Reduce Your Use events per calendar year. 6 Capacity Bidding Program provides a maximum of six events per month ranging from two to four hours. 7 See supra note 2.
8 One Big Beautiful Bill Act, H.R. 1 (119th Cong.), Sec. 112006 (engrossed in House of Representatives, May 22, 2025), available at https://www.congress.gov/bill/119th-congress/house-bill/1/text. 127
income customer. The longer the Commission delays approval of advice letters to add qualified DR programs to the SGIP program, the fewer low-income Californians will be able to take advantage of the existing tax credit, before the likely sunset at the end of 2025.
Under the current status quo, regardless of whether they meet the other requirements, the Commission’s delay is effectively blocking 70% of San Diegans from the ability to install a solar and battery system for potentially no cost. Even if all customers opted out of their CCA today, they would not be eligible to enroll in a qualified DR program until mid-December, approximately two weeks until the threatened sunset of the existing 30% tax credit. The Commission must act swiftly to remedy this inequity. SDCP appreciates the continued dialogue with Energy Division and Commission Staff regarding the SGIP and looks forward to the Commission’s expeditious resolution of the concerns described in this letter.
Sincerely,
Karin L. Burns
Chief Executive Officer, San Diego Community Power
128
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
Xiomalys Crespo, Senior Community Engagement Manager
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Approval of Community Advisory Committee Member for City of Chula Vista
DATE: June 26, 2025
____________________________________________________________________________________ RECOMMENDATION:
Approve the appointment of Alonso Gonzalez to the Community Advisory Committee (CAC) for the City of Chula Vista.
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 the Authority. The Community Advisory Committee is advisory only, and shall not have decision-making authority, nor receive any delegation of authority from the Board of Directors. Each Party may nominate a committee member(s) and the Board shall determine the final selection of committee members, who should represent a diverse cross-section of interests, skills sets, and geographic regions.
ANALYSIS AND DISCUSSION:
At both the March 2024 CAC and Board of Directors meetings, staff announced a CAC vacancy for the City of Chula Vista. Since, staff has promoted this and other vacancies through Community Power’s social media channels and the CAC, as well as directly engaging with staff, advocacy organizations, and the general public during networking and tabling events in all of our member agencies. Staff worked with Director Inzunza to 129
review the three applications received and advance the nomination process for Alonso Gonzalez.
If approved by the Board with a simple majority vote, staff will work with the representative to conduct their oath of office and onboarding prior to the next CAC meeting on August 14, 2025. Staff will also update Attachment A: CAC Roster and Seat Assignments, which is publicly available through Community Power’s website, to include the new representative.
As of the time this report was drafted, there is one expected CAC vacancy for the City of Encinitas, once Member Gary Jahns is termed out in June 2025.
FISCAL IMPACT:
N/A
ATTACHMENTS:
A: CAC Roster and Seat Assignments
130
ITEM 9
ATTACHMENT A
131
Community Advisory Committee Roster
Member Agency Name Appointed
Current
Term
Term
Ends
San Diego
Luis Montero-Adams August 2024 First 2025
Matthew Vasilakis (Chair) April 2020 Second 2026
Chula Vista
Anthony Sclafani July 2022 First 2025
Vacant - - -
La Mesa
Shaun Sumner March 2025 First 2025
David Harris April 2020 Second 2026
Encinitas
Gary L. Jahns April 2020 Second 2025
Tara Hammond April 2020 Second 2026
Imperial Beach
Kenneth Hoyt May 2024 First 2025
Ilian Sandoval November 2023 First 2026
County of San
Diego
(unincorporated)
Peter Andersen February 2022 First 2025
Ross Pike January 2025 First 2027
National City
Aida Castañeda (Secretary) February 2022 First 2025
Lawrence Emerson
(Vice-Chair) February 2022 Second 2026
Terms end at the end of every June. Members are subject to two, three-year consecutive terms.
They are also subject to CAC Policies and Procedures. Odd seats are displayed in blue. 132
SAN DIEGO COMMUNITY POWER
Staff Report – Item 10a
______________________________________________________________________ TO: Board of Directors
FROM: Nicholaus Norvell, Special Legal Counsel
SUBJECT: Approve Amended and Restated Chief Executive Officer Employment Agreement
DATE: June 26, 2025
______________________________________________________________________ RECOMMENDATION:
Approve Amended and Restated Chief Executive Officer Employment Agreement.
BACKGROUND:
On April 18, 2022, San Diego Community Power (“Community Power”) entered into a Chief Executive Officer Employment Agreement (“Agreement”) with Chief Executive Officer (“CEO”) Karin Burns. The Agreement provides the CEO with salary and benefits as described in the Agreement, including standard benefits received by all other Community Power employees, which may include health insurance, retirement, vacation, cost of living adjustments, etc.
On October 27, 2022, the parties entered into a First Amendment to the Agreement that extended the term, revised the notice provision as to termination of the Agreement without cause, and extended the relocation expense reimbursement time period. On June 22, 2023, the parties entered into a Second Amendment to the Agreement to provide an annual merit increase. On August 22, 2024, the parties entered into a Third Amendment to the Agreement to provide an annual merit increase and a market adjustment.
ANALYSIS AND DISCUSSION:
Pursuant to the terms of the Agreement, the CEO is to be evaluated by the Board of Directors annually. As part of the CEO’s performance evaluation, the Board may consider a merit increase or other adjustments in salary based on performance and market conditions.
During this item, the Board will consider approving an Amended and Restated version of the Agreement that incorporates prior amendments and makes additional changes to the Agreement as negotiated and agreed by the parties. Final terms of the Amended and Restated Agreement will be verbally announced and voted on as part of this agenda item. 133
Alternatively, if the Amended and Restated Agreement is fully finalized prior to the meeting, copies will be made available as an update to the agenda packet and/or provided to the Board and public at the meeting. Any increase in salary would be effective on July 1, 2025, or other such time as approved by the Board.
FISCAL IMPACT:
There is no impact to the current budget for Fiscal Year 2025-26 as CEO salary and benefits were anticipated to be incurred during this fiscal year.
ATTACHMENTS:
A: Amended and Restated Chief Executive Officer Employment Agreement 134
ITEM 10A
ATTACHMENT A
1 AMENDED AND RESTATED CHIEF EXECUTIVE OFFICER EMPLOYMENT
AGREEMENT
This AMENDED AND RESTATED CHIEF EXECUTIVE OFFICER EMPLOYMENT AGREEMENT (“Agreement”) is made by and between SAN DIEGO COMMUNITY POWER, a California joint powers authority (“SDCP”), and KARIN BURNS, an individual (“Executive”) as of ___________, 2025 (“Effective Date”). SDCP and Executive are sometimes individually referred to herein as the “Party” and collectively as the “Parties.”
RECITALS
A. SDCP and Executive are Parties to that certain Chief Executive Officer Employment Agreement dated April 18, 2022 (the “Prior Agreement”), pursuant to which Executive has been employed as SDCP’s Chief Executive Officer (“CEO”);
B. Pursuant to the Prior Agreement, Executive serves as the Chief Executive Officer to SDCP and is required to perform the functions and duties specified by SDCP’s Board of Directors and as provided by any such other resolutions of the Board, applicable laws, rules, regulations, orders, directives, policies, or procedures in effect or adopted by SDCP.
C. SDCP and Executive entered into a First Amendment to the Prior Agreement dated October 27, 2022 (“First Amendment”);
D. SDCP and Executive entered into a Second Amendment to the Prior Agreement dated June 22, 2023 (“Second Amendment”);
E. SDCP and Executive entered into a Third Amendment to the Prior Agreement dated August 22, 2024 (“Third Amendment”);
F. The Board wishes to continue to employee Executive as CEO, and Executive wishes to continue such employment, subject to the terms and conditions set forth in this Agreement; G. This Agreement supersedes and replaces the Prior Agreement, First Amendment, Second Amendment, and Third Amendment between the Parties; NOW, THEREFORE, in consideration of such continuing employment and other good and valuable consideration, the Parties agree as follows:
AGREEMENT
SECTION 1. DUTIES OF EXECUTIVE. Executive shall have the powers of the CEO position and perform the functions and duties specified by SDCP’s Board and as provided by any such other resolutions of the Board, applicable laws, rules, regulations, orders, directives, policies, or procedures now in effect or hereafter adopted by SDCP. a. Full Energy and Skill. Executive shall faithfully, diligently, and to the best of Executive's abilities, perform all duties that may be required under this Agreement.
Executive agrees that Executive has a duty of loyalty and a general fiduciary duty 2 to SDCP. Executive shall devote the whole of Executive's working time, skill, experience, knowledge, ability, labor, energy, attention, and best effort exclusively to SDCP's business and affairs.
b. No Conflict. Executive shall not engage in any employment, activity, consulting service, or other enterprise, for compensation or otherwise, which is actually or potentially in conflict with, inimical to, or which interferes with the performance of Executive's duties. Nothing herein shall prevent Executive from participating in charitable, civic, educational, professional, or community affairs or from serving on the board of directors or advisory boards of private companies, subject to SDCP’s Board approval and provided such activities do not materially interfere with the performance of her duties hereunder or create a potential conflict with SDCP or the appearance thereof. If at any time service on any board of directors or advisory board would, in the good faith judgment of the Board, conflict with the Executive’s fiduciary duty to SDCP or create any appearance thereof, then Executive shall as soon as reasonably practicable considering any fiduciary duty to the other entity, resign from such other board of directors or advisory board after written notice of the conflict is receive from the Board.
c. Hours of Work. Executive is an exempt employee but is expected to engage in those hours of work that are necessary to fulfill the obligations of the CEO position.
Executive does not have set hours of work as Executive is expected to be available at all times. It is recognized that Executive must devote a great deal of time to the business of SDCP outside of SDCP's customary office hours, and to that end Executive's schedule of work each day and week may vary in accordance with the work required to be performed and in accordance with any specific direction provided by the Board.
SECTION 2. EFFECTIVE PERIOD. Executive shall serve at the will and pleasure of the Board of Directors.
a. At Will Employment. Executive understands and agrees that employment under this Agreement is “at-will” meaning that either Executive or the Board may terminate Executive’s employment at any time, with or without cause, subject only to the provision set forth below in Section 3.
b. No Property Interest. Executive understands and agrees that Executive has no constitutionally-protected property or other interest in Executive's employment as CEO. Executive understands and agrees that Executive works at the will and pleasure of SDCP’s Board, and that Executive may be terminated, or asked to resign, at any time, with or without cause, by a majority vote of its members.
SECTION 3. TERMINATION.
a. By SDCP—Not “For Cause”.
At any time, SDCP may terminate Executive’s employment without Cause 3 (“For Cause” is defined in Section 3(b) below) by providing Executive written notice of termination. In the event Executive is terminated without Cause, Executive shall be entitled to an amount equal to Executive’s base salary for six (6) months conditioned upon Executive’s execution of a settlement agreement (i) waiving any and all claims Executive may have against SDCP and/or its officers or directors; (ii) including a release of all known or unknown claims related to or arising out of Executive’s employment with SDCP, including the termination of said employment; (iii) a Civil Code section 1542 waiver; and (iv) any other provisions, clauses, terms and/or conditions, deemed appropriate by the Board at the time of the termination of Executive’s employment, under the facts and circumstances of such termination.
In order for Executive to be eligible for the severance payment, the release agreement must be finalized no later than twenty-one (21) days after the effective date of Executive’s termination or the date upon which the release agreement is presented to Executive, whichever is later. Thereafter, all of SDCP’s obligations under this Agreement shall cease. SDCP may dismiss Executive as provided in this Section 3 notwithstanding anything to the contrary contained in or arising from any statements, policies, or practices of SDCP relating to the employment, discipline, or termination of its employees.
b. By SDCP—”For Cause”.
At any time, and without prior notice, SDCP may terminate Executive for Cause.
SDCP shall payExecutive all compensation then due and owing; thereafter, all of SDCP’s obligations under this Agreement shall cease. Termination shall be “For Cause” if Executive: (i) acts in bad faith and to the detriment of SDCP; (ii) willfully and unequivocally refuses or fails to act in accordance with any specific direction or order of SDCP’s Board, unless such direction is fraudulent or in violation of a law, statute, ordinance, or regulation; (iii) exhibitsin regard to his or her employment gross unfitness or chronic unavailability for service, unsatisfactory performance, misconduct, dishonesty, habitual neglect, or incompetence; (iv) is convicted of a crime involving dishonesty, breach of trust, or physical or emotional harm to any person resulting in incarceration; (v) commits or is accused of committing an act involving moral turpitude under federal, state, or local law (regardless of whether or not such act involving moral turpitude is a misdemeanor or felony); and/or (vi) breaches any material term of this Agreement.
c. Statutory Requirements.
In compliance with Government Code section 53243, to the extent SDCP provides: (i) paid leave to Executive pending an investigation; (ii) funds for the legal criminal defense of the Executive; and/or (iii) a cash settlement to Executive related to the termination of Executive pursuant to Section 3(b) of this Agreement, Executive shall fully reimburse SDCP for any and all amounts paid by SDCP which fall within any such categories in the event that Executive is convicted of a crime involving the abuse of their office or position.
4 d. By Executive.
In the event that Executive desires to terminate this Agreement during such time as SDCP desiresfor Executive to continue in the capacity of CEO, then Executive agrees to provide SDCP with at least forty-five (45) days’ written notice of said termination.
SECTION 4. COMPENSATION AND PERFORMANCE REVIEWS.
a. Executive shall receive a three and one-half percent (3.5%) merit increase to her current base annual salary, bringing Executive’s total base salary to Four Hundred Eighty Six Thousand Seven Hundred Seventy Two Dollars and Eighty Two Cents ($486,772.82) effective as of July 1, 2025, payable on a pro-rata basis in accordance with SDCP’s payroll practices and less all applicable payroll taxes and withholdings.
b. SDCP shall perform a performance review of Executive at least annually. The Board or a committee of the Board of Directors shall additionally review the base compensation, bonuses, and benefits provided to Executive under this Agreement and may, in their sole discretion, adjust the same.
SECTION 5. OTHER BENEFITS. Executive shall be entitled to participate in SDCP’s benefits adopted by SDCP on the same basis as other executives of SDCP. a. Automobile. Executive shall receive a gross monthly vehicle allowance of Five Hundred Dollars and No Cents ($500.00) per month. The Parties intend for this taxable allowance to be in lieu of reimbursement on an itemized basis for mileage, gas, maintenance of a vehicle, etc. Executive shall not be separately reimbursed for mileage incurred in connection with the execution of her duties. b. Technology Allowance. Executive shall receive either an SDCP-owned cell phone and (accompanying SDCP-paid plan) or a $100 monthly taxable technology allowance to use towards her personal discretionary technological purchases and expenses in furtherance of employment (e.g., cellular phone, tablet, data plan, laptop computer). The Parties intend this allowance to cover all technology-related costs that Executive incurs in the course and scope of her employment with SDCP. If Executive’s actual business use exceeds her allowance, she may contact Human Resources and request payment in a higher amount to correspond with actual business use supported by receipts.
c. Vacation Leave. Executive shall accrue an additional forty (40) hours of vacation leave annually (i.e., an additional 1.67 hours semi-monthly) consistent with SDCP’s Vacation Leave accrual schedule established for full-time, regular employees of SDCP. Executive shall be subject to all other terms and conditions of SDCP’s Vacation Leave policy to the same extent as other executives of SDCP. d. Other Benefits. Subject to the provisions of this Section 5, Executive shall be entitled to participate in benefits, including health care coverage and premium 5 payments, retirement plans and/or 401(k) plans, and to receive sick leave, vacation accrual, and any and all other benefits to the same extent and as other executives of SDCP.
SECTION 6. INDEMNIFICATION. SDCP shall indemnify and defend Executive in accordance with the California Government Claims Act. Unless otherwise specifically required by law, SDCP’s Board shall determine, in its sole discretion, whether to file an appeal if a final judgment is adverse to Executive or whether to compromise and settle any such claim orsuit against Executive, as well as the amount of any settlement or judgment rendered thereon. SDCP shall also pay for the cost of any fidelity or other bonds required by law for the position of CEO.
SECTION 7. OTHER TERMS AND CONDITIONS OF EMPLOYMENT. SDCP shall make and implement any other terms and conditions of employment related to the performance of Executive which may be reflected in SDCP policies and procedures applicable to employees in general and to other executives of SDCP specifically, provided such terms and conditions are not inconsistent with the provisions of this Agreement or by law.
SECTION 8. NOTICES. Notices given under this Agreement shall be in writing and shall be served personally or sent by Federal Express or some equivalent private overnight delivery service. Notices shall be deemed received at the earlier of actual receipt or two (2) days following transmission to an overnight carrier.
To SDCP: Attn: Chair of the Board of Directors
San Diego Community Power
P.O. Box 12716
San Diego, CA 92112-3716
With a copy to:
Veera Tyagi
SDCP General Counsel
P.O. Box 12716
San Diego, CA 92112-3716
To Executive: Karin Burns
At the address on file with SDCP’s
Human Resources Department
SECTION9. INTEGRATION.This Agreement isintended to be the final, complete, and exclusive statement of the terms of Executive's employment by SDCP. This Agreement supersedes all other prior and contemporaneous agreements and statements, whether written or oral, express or implied, pertaining in any manner to the employment of Executive, and it may not be contradicted by evidence of any prior or contemporaneous statements or agreements. To the extent that the practices, policies, or procedures of SDCP, now or in the future, apply to Executive and are inconsistent with the terms of this Agreement, the provisions of this Agreement shall control. 6 SECTION 10. AMENDMENTS; WAIVERS. This Agreement may not be amended except by an instrument in writing,signed by each of the Parties. No failure to exercise and no delay in exercising any right, remedy, or power under this Agreementshall operate as a waiver thereof, nor shall any single or partial exercise of any right, remedy, or power under this Agreement preclude any other or further exercise thereof, or the exercise of any other right, remedy, or power provided herein or by law or in equity.
SECTION 11. ASSIGNMENT; SUCCESSORS AND ASSIGNS. Executive agrees that he or she will not assign, sell, transfer, delegate, or otherwise dispose of, whether voluntarily or involuntarily, or by operation of law, any rights or obligations under this Agreement. Any such purported assignment, transfer, or delegation shall be null and void. Nothing in this Agreement shall prevent the consolidation of SDCP with, or its merger into, any other entity, or the sale by SDCP of all or substantially all of its assets, or the otherwise lawful assignment by SDCP of any rights or obligations under this Agreement. Subject to the foregoing, this Agreement shall be binding upon and shall inure to the benefit of the Parties and their respective heirs, legal representatives,successors, and permitted assigns, and shall not benefit any person or entity other than those specifically enumerated in this Agreement.
SECTION 12. SEVERABILITY. If any provision of this Agreement, or its application to any person, place, or circumstance, is held by an arbitrator or a court of competent jurisdiction to be invalid, unenforceable, or void, such provision shall be enforced to the greatest extent permitted by law, and the remainder of this Agreement and such provision as applied to other persons, places, and circumstances shall remain in full force and effect.
SECTION 13. ATTORNEY’S FEES. In any legal action, arbitration, or other proceeding brought to enforce or interpret the terms of this Agreement, the prevailing party shall be entitled to recover reasonable attorneys' fees and costs.
SECTION 14. GOVERNING LAW AND VENUE. This Agreement shall be governed by and construed in accordance with the laws of the State of California. The Parties agree that venue for any dispute shall be in San Diego County Superior Court.
SECTION 15. INTERPRETATION. This Agreement shall be construed as a whole, according to its fair meaning, and not in favor of or against any party. By way of example and not in limitation, this Agreement shall not be construed in favor of the party receiving a benefit nor against the party responsible for any particular language in this Agreement. Captions are used for reference purposes only and should be ignored in the interpretation of the Agreement.
SECTION 16. REPRESENTATION BY COUNSEL. The Parties acknowledge and agree that they were, or had the opportunity to be, represented individually by legal counsel with respect to the matters that are the subject of this Agreement and that they are fully advised with respect to their respective rights and obligations resulting from signing this Agreement.
SECTION 17. COUNTERPARTS AND ELECTRONIC SIGNATURES. This Agreement may be executed in triplicate counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument. The Parties agree that this Agreement may be executed and delivered by electronic signatures and that the signatures appearing 7 on this Agreement are the same as handwritten signaturesforthe purposes of validity, enforceability, and admissibility.
IN WITNESS WHEREOF, SDCP and Executive have executed this Amended and Restated Chief Executive Officer Employment Agreement on the date written above:
SAN DIEGO COMMUNITY POWER
By:
Paloma Aguirre
Chair, SDCP Board of Directors
APPROVED AS TO FORM:
By:
SDCP Special Counsel
EXECUTIVE
By:
Karin L. Burns, Chief Executive Officer
ATTEST:
By: ______________________________
Maricela Hernandez
SDCP Clerk of the Board
SAN DIEGO COMMUNITY POWER
Staff Report – Item 10b
______________________________________________________________________ TO: Board of Directors
FROM: Nicholaus Norvell, Special Legal Counsel
SUBJECT: Approve First Amendment to General Counsel Employment Agreement
DATE: June 26, 2025
______________________________________________________________________ RECOMMENDATION:
Approve First Amendment to General Counsel Employment Agreement BACKGROUND:
On December 14, 2023, San Diego Community Power (“Community Power”) approved a General Counsel Employment Agreement (“Agreement”) with General Counsel Veera Tyagi. The Agreement provides the General Counsel with salary and benefits as described in the Agreement, including standard benefits received by all other Community Power employees, which may include health insurance, retirement, vacation, cost of living adjustments, etc.
ANALYSIS AND DISCUSSION:
Pursuant to the terms of the Agreement, the General Counsel is to be evaluated by the Board of Directors annually. As part of the General Counsel’s performance evaluation, the Board may consider a merit increase or other adjustments in salary based on performance and market conditions.
During this item, the Board will consider approving a First Amendment to the Agreement that provides for a merit increase or other salary adjustment and makes additional changes to the Agreement as negotiated and agreed by the parties. Final terms of the First Amendment will be verbally announced and voted on as part of this agenda item.
Alternatively, if the First Amendment is fully finalized prior to the meeting, copies will be made available as an update to the agenda packet and/or provided to the Board and public at the meeting. Any increase in salary would be effective on July 1, 2025, or other such time as approved by the Board.
135
FISCAL IMPACT:
There is no impact to the current budget for Fiscal Year 2025-2026 as General Counsel salary and benefits were anticipated to be incurred during this fiscal year.
ATTACHMENTS:
A: First Amendment to General Counsel Employment Agreement 136
ITEM 10B
ATTACHMENT A
FIRST AMENDMENT TO
GENERAL COUNSEL EMPLOYMENT AGREEMENT BETWEEN
SAN DIEGO COMMUNITY POWER AND VEERA TYAGI
THIS FIRST AMENDMENT (“First Amendment”) is entered into effective as of ____________________ (“Amendment Effective Date”), by and between the SAN DIEGO COMMUNITY POWER, a California joint powers authority (“SDCP”) and VEERA TYAGI (“Executive”). SDCP and Executive are sometimes individually referred to herein as the “Party” and collectively as the “Parties.”
RECITALS
A. The Parties entered into a General Counsel Employment Agreement dated February 1, 2024 (“Agreement”).
B. Pursuant to the Agreement, Executive serves as the General Counsel to SDCP and is required to perform the functions and duties specified by SDCP’s Board of Directors and as provided by any such other resolutions of the Board, applicable laws, rules, regulations, orders, directives, policies, or procedures in effect or adopted by SDCP.
C. The Parties desire to execute this First Amendment as of the Amendment Effective Date.
AGREEMENT
NOW, THEREFORE, for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged and agreed, the Parties agree to the following terms and conditions:
1. Amendment 1 to the Agreement. The Parties hereby agree to amend the Agreement as follows:
a. Section 1(a). Section 1(a) of the Agreement is amended to correct “appliable law” to “applicable law.”
b. Section 2. EFFECTIVE PERIOD. Section 2 of the Agreement is amended to state the following: “Executive is appointed as General Counsel beginning on the Effective Date of the General Counsel Employment Agreement and shall serve at the will and pleasure of the Board. Executive’s employment with SDCP may be terminated by either Party in accordance with Section 3 of the General Counsel Employment Agreement.”
c. Section 3(a). Section 3(a) of the Agreement is amended to delete “as” and insert “‘For Cause’ is” in the parenthetical clause referring to the definition of “For Cause” and is further amended to correct “Executive execution” to “Executive’s execution.” The second paragraph regarding Government Code section 53260 is also deleted.
d. Section 3(b). Section 3(b) is amended to insert the following language at the end of the clause set forth in (ii) and immediately before (iii): “, unless such direction is fraudulent or in violation of a law, statute, ordinance, or regulation, or violates a rule of professional conduct”.
e. Section 4(a). Section 4(a) of the Agreement is amended to provide Executive with a four percent (4%) merit increase in salary, and a fifty thousand dollar ($50,000) market adjustment, bringing Executive’s total base salary to Four Hundred Eight Thousand Two Hundred Forty-One Dollars and Sixty Cents ($408,241.60), effective as of July 1, 2025, payable on a pro-rata basis in accordance with SDCP’s payroll practices and less all applicable payroll taxes and withholdings. f. Section 5(b). Section 5(b) of the Agreement is amended to delete “his or” where it appears in the section and to add the following sentence at the end of the section:
“If Executive’s actual business use exceeds her allowance, she may contact Human Resources and request payment in a higher amount to correspond with actual business use supported by receipts.”
g. Section 7. Section 7 is amended to state as follows: “SDCP shall make and implement any other terms and conditions of employment related to the performance of Executive which may be reflected in SDCP policies and procedures applicable to employees in general and to other executives of SDCP specifically, provided such terms and conditions are not inconsistent with the provisions of this Agreement or by law.”
h. Section 8. Section 8 of the Agreement is amended to replace B. Allison Borkenheim at Littler Mendelson and instead send a copy of any notice to Christina Snider, Partner; Quarles & Brady, LLP; 101 W. Broadway, Suite 1500; San Diego, CA 92101.
2. Capitalized Terms. Any capitalized terms not defined herein shall have the meanings set forth in the Agreement.
3. Counterparts. This Amendment may be executed in two or more counterparts, each of which shall be deemed an original, but all of which together shall constitute but one and the same instrument.
4. Full Force. Except as expressly set forth herein, the Agreement shall remain unmodified and in full force and effect.
SIGNATURES ON FOLLOWING PAGE(S)
IN WITNESS WHEREOF, the Parties have executed this First Amendment to the General Counsel Employment Agreement between San Diego Community Power and Veera Tyagi as of the date first set forth above.
SAN DIEGO COMMUNITY POWER
_______________________________
Paloma Aguirre
Chair, SDCP Board of Directors
VEERA TYAGI
_______________________________
Veera Tyagi, General Counsel
APPROVED AS TO FORM:
_________________________________
Special Labor Counsel
ATTEST:
______________________________
Maricela Hernandez
SDCP Clerk of the Board
SAN DIEGO COMMUNITY POWER
Staff Report – Item 11
______________________________________________________________________ TO: Board of Directors
FROM: Patrick Welch, Associate Director of Legislative Affairs Andrea Torres, Director of Origination
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Tariffs, Tax Credits and Executive Orders: New-Build Market Outlook Update
DATE: June 26, 2025
______________________________________________________________________ RECOMMENDATION:
Receive and file the Community Power status report on federal policy and budget as it relates to clean energy procurement.
BACKGROUND:
This staff report is a summary of the latest status – as of June 16 – on federal policy and budgeting matters that have the potential to impact Community Power’s current and future electricity procurement portfolio.
STAFF ANALYSIS:
I. Tariffs
The U.S. imposed tariffs on Chinese goods of between 25%-50% during the prior Trump Administration and during the Biden Administration. Since January, the current Administration has signaled a wide range of tariffs to be imposed on goods from various nations and those tariff levels have changed numerous times in the interim. The tariff percentages applied to China reached their peak earlier in April at 145% and at one point reached 3,521% on solar equipment from Cambodia. Since then, as of May 12, China and the U.S. have agreed to a 90-day pause in their trade war at an average of 30% tariff on Chinese goods into the U.S. and a 10% tariff on U.S. goods into China, noting that other Southeast Asian countries that are a significant source of PV and battery material supply have been among the hardest hit, facing between 32% and 49% tariffs on goods into the U.S.
137
II. Tax Credits
Congress is expected to send the President budget reconciliation legislation that would extend the 2017 Tax Cuts and Jobs Act. Congress will need to make corresponding budget cuts to pay for the Tax Act extension. One means of creating savings is to reduce or eliminate federal energy tax credits that support the transition to clean energy. Current law, as enacted by the Inflation Reduction Act of 2022, provides a 30% tax credit for utility scale clean energy projects. There are two routes to obtain the credit: either through the Production Tax Credit (PTC), which is based on the electrical output of a clean energy project, or the Investment Tax Credit (ITC), which is based on the total investment value of a project. Current law also creates consumer-level tax credits. The Residential Clean Energy Credit (RCEC) provides a 30% credit to support the installation of residential solar and storage systems, and the Home Energy Efficiency Investment Credit (HEEIC) provides a dollar-capped credit ($3,200) for home energy efficiency and electrification improvements.
House of Representatives Approves Legislation to Phase Out Energy Tax Credits The One Big Beautiful Bill Act (H.R. 1) is the budget reconciliation legislation of the majority party in the House of Representatives. The over 1,000-page bill was approved by the House on May 22. With respect to clean energy tax credit issues, it would do the following:
• Eliminate the New Clean Vehicle Tax Credit ($7,500). The 30% residential solar and storage tax credit (RCEC) and the $3,200 home energy efficiency and electrification upgrade tax credit (HEEIC) would sunset at the end of 2025. Solar companies would also be barred from claiming a tax credit for lease agreements for rooftop solar.
• Phase out the ITC and the PTC for all utility-scale technologies by December 31, 2028. Projects would have to either start construction within 60 days of the bill’s enactment or be placed into service by December 31, 2028, to qualify. • Impose restrictive foreign entities of concern (FEOC) conditions on projects seeking ITC and PTC benefits in such a manner that energy facilities could not receive any material assistance from foreign controlled or influenced entities, including the component parts of facilities. This largely means that any energy project with any parts from China, or a company with ties to China, would not be eligible. This would go into effect on December 31, 2025. • Transferability of tax credits would still be allowed, but only during the narrow window for when projects are eligible for the credits, making it harder for smaller companies to gain access to capital.
• The bill retains a tax credit until 2031 for nuclear power production, advanced manufacturing for certain components, clean fuels, and geothermal heat property.
H.R. 1 also allows fossil fuel companies to pay a higher permitting fee to benefit from faster project permitting. Finally, it would rescind unobligated funds from various federal energy programs. Community Power is not the recipient of any such funding so the reversion of unobligated funds should not have a programmatic impact. The legislation would rescind unobligated funding from the following programs:
138
• State based energy efficiency training grants
• Department of Energy Loans program
• Tribal Energy Loan Guarantee
• Transmission Facility Financing and Interstate Electricity Transmission Lines • Interregional and Offshore Wind Planning
Senate Finance Committee Releases Different Approach to Clean Energy Tax Credit Phase Out
On June 16, the Senate Finance Committee released their approach to budget reconciliation. Staff is still assessing the proposal and understanding all the details, but upon initial review it appears to do the following with respect to clean energy tax credits:
• Eliminate – 180 days after enactment – the $7,500 New Clean Vehicle Tax Credit, the 30% residential solar and storage tax credit (RCEC), and the $3,200 home energy efficiency and electrification upgrade tax credit (HEEIC). Solar companies would also be barred from claiming a tax credit for lease agreements for rooftop solar.
• Phase out the ITC and PTC for solar and wind only. Specifically, the proposal would limit the credits to 60% of their value for wind and solar facilities that begin construction in 2026 and 20% of the credit value for wind and solar facilities that begin construction in 2027. There would be no credit in years thereafter. • The credits for other clean energy technologies, such as geothermal and energy storage, could be claimed through 2033, then 75% in 2034, 50% in 2035, and 0% in 2036.
• While the Senate Finance proposal maintains the start of construction standard and would phase down the credits for wind and solar facilities only, it appears to apply complex new FEOC restrictions to all clean energy technologies.
Specifically, to be eligible for the ITC or PTC, any eligible clean energy facility that begins construction after December 31, 2025, could not receive material assistance from a prohibited foreign entity. Likewise, the taxpayer could not be a prohibited foreign entity. Material assistance appears to be defined to mean a certain cost ratio of components that come from a prohibited foreign entity in a project. There are different ratios for different technologies. For example, solar energy components from prohibited foreign entities like China could not have a ratio of more than 50% in 2026, 40% in 2027, 30% in 2028, 20% in 2029, and 15% in 2029. There appears to be safe harbor language for contracts entered into before June 16, 2025, and placed into service before January 1, 2030; these projects could be excluded from the material assistance provisions.
Like H.R. 1, the Senate proposal also modifies a tax credit for nuclear power and restricts a tax credit for clean hydrogen. The Senate version would create a new America First Energy Policy that would extend and modify a clean fuel production tax credit and would make changes to tax applicable to hydrogen storage and carbon capture, among other things.
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The intended goal is for the House and Senate to agree to budget reconciliation legislation such as H.R. 1 or the Senate Finance Committee proposal by July 4. It is a fluid situation, and much could change in the interim.
Several Congressmembers Introduce Alternative Energy Tax Credit Proposals On May 9, a group of majority party members of the House of Representatives introduced the Certainty for Our Energy Future Act (HR 3291) as an alternative approach to changing the ITC and PTC. Specifically, the legislation would end the ITC and PTC for solar and wind only by 2031. It would maintain the tax credits into the 2030s for other technologies, like energy storage and geothermal. The legislation would also maintain the start of construction standard for ITC eligibility, includes safe harbor language for existing projects, and would impose less restrictive foreign sourcing restrictions. It has been referred to the House Ways & Means Committee for a hearing.
Another bill introduced by four members of the majority party – The Ending Intermittent Subsidies Act (HR 2838) would phase out the ITC and PTC for wind and solar, and impose a placed in-service standard. It has been referred to the House Ways & Means Committee.
Table 1. Summary of Federal Proposals on Utility Scale Project Tax Credits Current
Law
Certainty for Our
Energy Future Act
(HR 3291)
Ending Intermittent
Energy Subsidies
Act (HR 2838)
One Big
Beautiful Bill
Act (HR 1)
Senate Finance
Committee
Sponsor N/A Reps. Garbarino
(NY-2), Valadao
(CA-22), Newhouse
(WA-4), & Amodei
(NV-2)
Reps. Goldan (TX-12), Palmer (AL-6),
Weber (TX-14), &
Fluger (TX-11)
Rep. Arrington
(Tx-19)
Senate Finance
Committee
Status 30% tax
credit for
clean
energy
projects
based either
on a
project’s
total
investment
or the
electricity
produced
Referred to the
House Ways &
Means Committee
Referred to the
House Ways &
Means Committee
Passed the
House on May
22 on a 215-214
vote
Published June 16
Preference Preferred Second preference Third preference Least preferred Under review Tax Credit
Sunset
2032 or
when the
electric
sector GHG
emission fall
25% below
2022 levels,
whichever is
Wind and solar
credits end
December 31,
2030. There is a
safe harbor
provision for
projects for projects
that have, or will
Wind and solar
credits only are
phased out:
• 80% credit value
in 2026
• 60% 2027
• 40% 2028
Can’t claim tax
credit for any
technology if:
• Construction
begins 60
days after the
date of
enactment
Wind and solar will
be phased out:
• 60% credit
value in 2026
• 20% in 2027
• 0% in 2028 and
thereafter
140
later,
followed by
the following
phase out:
• 75% of
credit
value
following
second
year
• 50% third
year
• 0% fourth
year
soon, start
construction based
on current IRS
guidance.
• 20% 2029
• 0% 2030
or
• The project is
placed into
service after
Dec 31, 2028
All other clean
energy
technologies
would be phased
out:
• 75% in 2034
• 50% in 2035
0% in 2036 and
thereafter
Tax
Attachment
Point
Start of
construction
Start of
construction
Placed into service
for ITC and year of
production for PTC
Both Start of
construction
Foreign Entity
of Concern
(FEOC)
Restrictions
A FEOC is
China, Russia,
Iran, and North
Korea
None Modest restrictions
would be imposed
6 months after the
Treasury
Department issues
guidance.
Specifically, a
taxpayer could not
be a disqualified
company that is
created under the
laws of, or
controlled by, a
FEOC.
None Significant
restrictions
would be
imposed 1 year
after enactment.
Generally, the
taxpayer of a
project could not
receive “material
assistance” –
including
component parts
– from a FEOC.
A taxpayer could
also not be
deemed to be
influenced or
controlled by
any FEOC.
Significant
restrictions would
be imposed
beginning
December 31,
2025 for any
facility, not just
wind and solar.
Generally, a
taxpayer could not
receive material
assistance from a
prohibited foreign
entity.
Transferability Allowed Allowed Allowed Allowed Cannot transfer to specified foreign
entities
Domestic
Content &
Energy
Community
adders
10% Maintained Maintained Maintained Maintained
III. Energy Project Development on Public Lands
Executive actions have caused the Bureau of Land Management (BLM) to pause permitting for renewable energy projects
The Unleashing American Energy Executive Order (EO) revoked an EO from 2021 called the Tackling the Climate Crisis at Home and Abroad (EO #14008). The BLM was relying on the 2021 EO to prioritize the permitting of renewable energy – like solar – on federal lands. By revoking the prior EO, and by uplifting the development of fossil fuels, in 141
particular, the new EO deprioritizes the development of renewable energy and energy storage on federal land. Concurrently, the Department of Interior, which oversees BLM, issued a 60 day pause authorizing any renewable energy projects. Community Power has learned that the permitting pause – for solar at least – is no longer in effect and projects are still being approved. However, BLM may not be approving the projects at an expeditious rate given the Administration’s priority permitting focus on traditional energy projects. As a potential positive sign, the BLM recently announced approval of a solar project in Arizona. Community Power has a power purchase agreement (PPA) for a large solar PV and battery project largely sited on BLM land.
IV. Potential Impacts to Community Power’s Long-Term Renewable Energy Portfolio
Community Power staff are closely monitoring any potential effects of the aforementioned actions on Community Power’s existing portfolio of long-term contracts under development as well as projects in Community Power’s negotiation pipeline.
With respect to tariffs, Community Power notes that it is challenging for both buyers and sellers of renewable energy to assess the market impacts of tariffs until trade discussions settle. However, staff is in regular contact with counterparties to understand any impacts on project economics or the potential for delays to construction due to challenges with securing supply with minimal tariff risks. Fortunately, two-thirds of the forecasted renewable MWhs under contract, but not yet operational are in the later stages of development, having secured construction financing, onshored key equipment and/or commenced construction, effectively mitigating the risk of new tariffs. For those projects that are in earlier stages of development, staff will continue to work closely with developers to track any risks to project viability. For new contracting opportunities, staff are prioritizing projects that are better positioned to mitigate tariff exposure due to developer-specific procurement and project financing strategies.
With respect to the proposed modifications to existing clean energy tax credits, the final outcome is unclear, as there are several steps left in the Congressional process. The House of Representatives passed H.R. 1 as described in Section II of this report and the Senate Finance Committee has published their preferred approach. The Senate is aiming to adopt their version of a budget reconciliation bill by July 4, though that is an uncertain deadline. If the Senate approves a modified version of HR 1 – or a different legislative vehicle entirely – then the House will need to vote on the bill again. Similar to the assessment of tariff impacts, approximately two-thirds of the forecasted renewable energy volume under development in our contracted portfolio is from either projects under construction or those having met the construction start safe harbor provisions (i.e. meeting a 5% threshold of capital investment delivered or stored). Those projects are not anticipated to be affected by modifications to the rules on tax credit eligibility, whether under H.R. 1 or the bill proposed by the Senate Finance Committee.
With respect to our contracted energy storage projects, the Senate’s version of the bill appears to explicitly allow energy storage assets to capture the full ITC with the initial reduction not occurring until 2034 and be safe harbored from the FEOC restrictions if the project had a contract before June 16 of this year. However, the Senate’s FEOC 142
restrictions would likely have a material impact to the eligibility of the ITC for those projects not having a contract at this time. Staff is investigating to what extent the FEOC composition ratio thresholds (e.g. 50% in 2026) under the Senate’s version can be met with currently anticipated supply chains for battery energy storage and other technologies.
Regardless of technology, it is too soon to draw conclusions on the likely impacts to project costs and viability under any new tax credit for any resource that has not met the proposed safe harbor requirements . With several more weeks to go in the Congressional process, it is probable that the final budget reconciliation bill may be altered further, as the situation and dynamics evolve.
Finally, regarding the permitting pause on BLM land, in May the Board approved an amendment for Community Power’s PPA with Primergy’s Purple Sage project, a 400 MW solar and storage project sited largely on BLM land. The amendment extends the guaranteed commercial operation date by a year into 2028 in exchange for other adjustments to terms to increase the project’s value to Community Power’s ratepayers.
In the meantime, staff will continue to monitor the progress made on project permitting and development and will see if the recently approved PV project in Arizona signals good news for permitting approvals for Purple Sage.
Staff have conducted a project-by-project scenario analyses of Community Power’s developing portfolio to stress test for project delays or potential project failure and have concluded that Community Power remains on track meet its clean energy target of 100% by 2035 as well as the interim target of 75% by 2027. Staff will provide additional updates on Community Power’s pathway to 100% clean energy to the Board and the CAC in Q4 2025.
FISCAL IMPACT:
N/A
COMMITTEE REVIEW:
This item was presented at the June 12, 2025, Community Advisory and Finance Risk Management Committee meetings. The Committees received and filed the update.
ATTACHMENTS:
N/A
143
SAN DIEGO COMMUNITY POWER
Staff Report – Item 12
____________________________________________________________________________________ TO: Board of Directors
FROM: Chandra Pugh, Senior Director of People Operations and Administration
VIA: Karin Burns, Chief Executive Officer
SUBJECT: AB 2561 – Status of Vacancies, Recruitment and Retention Efforts DATE: June 26, 2025
______________________________________________________________________ RECOMMENDATION:
Recommend the Board hold a public hearing, receive comments, and accept report on the status of Community Power employee vacancy rates and recruitment and retention efforts.
BACKGROUND:
Assembly Bill (AB) 2561 (McKinnor) amended the Myers-Milias-Brown Act (MMBA) to add Government Code Section 3502.3, which created a new obligation for public agencies to present the status of vacancies and recruitment and retention efforts. The public hearing must be held at least once per fiscal year prior to adopting an annual budget. During the hearing, the public agency shall identify any necessary changes to policies, procedures, and recruitment activities that may lead to obstacles in the hiring process. The law also allows recognized employee organizations, which Community Power does not have, an opportunity to present at the public hearing. The new law took effect on January 1, 2025, and applies to all public agencies.
ANALYSIS AND DISCUSSION:
Status of Job Vacancies
For the Fiscal Year 2024-2025, thirty-one vacancies have been filled, three are currently open, and three were not filled, as shown in Table 1 below. The three current vacancies are: Chief Commercial Officer, Community Outreach Representative (Part-Time) and Senior Origination Associate. For the three positions that were not filled, the hiring managers determined at the time that other operational needs took priority over filling those positions.
144
Community Power did encounter difficulties in filling the Rates Analyst and Origination Manager positions. Due to the specification of these roles, the candidates that applied did not meet the role requirements which resulted in a limited qualified applicant selection for the positions. Human Resources (HR) recommended that both positions be reposted with either a lower or higher salary grade. The Origination Manager position was reposted as a Senior Origination Associate and is in the process of being filled. For the Rates Analyst position, the position was reposted as a Senior Rates Analyst and the candidate has been selected and is in the final hiring stage.
Table 1
Recruitment and Retention Efforts
The recruitment process includes three interview stages including a virtual and two in-person panel interviews. At the end of the recruitment process for a position, HR deploys a candidate engagement survey to provide feedback regarding the recruitment process.
As shown in Table 2 below, the feedback from candidates regarding the recruitment process has been positive.
There has been very little employee turnover at Community Power this past fiscal year.
Of the 31 vacancies, 27 were new positions. Community Power’s retention efforts include 145
offering competitive wages, 10% of base pay employer contribution to employee Money Purchase Plan retirement account, generous vacation and sick time, 11 paid holidays including a winter break, and a professional development stipend. Because Community Power has been highly successful in filling vacant positions this past fiscal year and retaining its employees, no changes are being recommended to its recruitment process and retention efforts.
Table 2
FISCAL IMPACT:
N/A
COMMITTEE REVIEW:
This item was presented to the Finance Risk Management Committee on June 12, 2025.
The Committee members unanimously recommended the Board hold a public hearing on this matter.
ATTACHMENTS:
N/A
146
SAN DIEGO COMMUNITY POWER
Staff Report – Item 13
TO: Board of Directors
FROM: Dr. Eric Washington, Chief Financial Officer
VIA: Karin Burns, Chief Executive Officer
SUBJECT: Recommend Board Approval of Resolution No. 2025-06, adopting the FY 2025-2026 Operating Budget, FY 2025-2026 Capital Budget, and FY 2026-2030 Capital Investment Plan
DATE: June 26, 2025
RECOMMENDATION:
Recommend Board Approval of Resolution No. 2025-06, adopting the FY 2025-2026 Operating Budget, the FY 2025-2026 Capital Budget, and the 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. 147
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.
Table 2. Community Power Budget History
Operating Budget Net Revenues Total Expenses Net Position FY 2020-21 Amendment $ 26,286,909 $ 34,135,000 $ (7,848,091) FY 2021-22 Amendment $ 378,053,506 $ 342,177,063 $ 35,876,443 FY 2022-23 Amendment $ 929,791,929 $ 772,078,709 $ 157,713,220 FY 2023-24 Amendment $ 1,304,274,067 $ 1,070,891,284 $ 233,382,783 FY 2024-25 Amendment $ 1,221,258,172 $ 1,187,090,169 $ 34,168,003 FY 2025-26 Proposed $ 1,199,619,794 $ 1,035,006,277 $ 164,613,302 ANALYSIS AND DISCUSSION:
The proposed FY 2025-2026 operating budget includes net operating revenue of $1,199,619,579 and total expenses of $1,035,006,277, resulting in net position of $164,613,302.
The proposed FY 2025-2026 capital budget includes revenue and expenses of $54,545,636 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 $344.3 million in investments. The first year of the FY 2026-2030 CIP comprises the FY 2025-2026 capital budget. Additionally, $11.2 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. 148
• 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 with adjustments of 3.8% for Cost of Living1 increases and up to 5% for potential merit increases, as authorized under the Board-approved Total Compensation Policy, 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 Plan (CIP)
In FY 2025-2026 Community Power is continuing its Capital Investment Plan (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 1 The SDCP Total Compensation Policy, adopted March 23, 2023, bases the Cost of Living (COLA) from the San Diego Consumer Price Index for all Urban consumers calculated on a rolling 12-month basis from the Bureau of Labor Statistics in January of the calendar year in which the COLA increase will take effect. 149
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 2025-2026 budget results in a net position of $164,613,302.
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 2025-2026 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 Plan (Transfer Out) 4.7 18.2 22.2
Total Expenses 1,071.0 1,187.1 1,035.0
Net Position 233.3 34.2 164.6
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 Budget
FY25 FY26 FY27 FY28 FY29 FY30 Total
External Funding
Regional Energy Network -
31.9 59.5
51.4 42.0
43.7 228.6
DAC-GT
(0.1)
0.6 0.5
0.5 0.5
0.5 2.4
150
CDFA
0.7 -
-
-
-
-
0.7 Equitable Building
Decarbonization
1.4 -
-
-
-
-
1.4 Subtotal
2.0 32.5
60.0 51.9
42.5 44.2
233.0
Internal Funding
Energy Efficiency
0.0 -
-
-
-
-
0.0 Solar Battery Savings
3.2 18.8
11.1 10.4
8.3 8.5
60.3 Pilot Programs
2.5 -
-
-
-
-
2.5 Grants
0.2 1.3
-
-
-
-
1.5 DER
0.0 -
-
-
-
-
0.0 Flexible Load
0.3 0.3
0.6 0.6
0.8 0.7
3.3 IT Projects
2.5 1.5
-
-
-
-
4.0 Community Education -
0.0 -
-
-
-
0.0 App Assistance
0.3 -
-
-
-
-
0.3 Program Evaluation -
0.3 -
-
-
-
0.3 Other CIP -
-
7.4 8.7
11.2 11.7
39.1 Subtotal
9.2 22.2
19.1 19.7
20.3 20.9
111.3
CIP Expense Total
11.2 54.7
79.1 71.6
62.8 65.1
344.3
Amounts displayed in millions, $
The proposed budget now includes an adjustment to our Capital Investment Plan (CIP) funds. We've shifted some of the remaining budget allotment from in-house personnel to professional services, which we expect will lead to long-term savings on personnel costs.
We've also updated the carryforward funds. These revisions make the proposed budget more current.
151
Table 5. Community Power FY 2025-2026 CIP Draft vs Proposed Amounts displayed in millions, $
Draft CIP
FY26
Proposed
CIP
FY26
FY26 Draft
vs.
Proposed
External Funding
Regional Energy Network 228.7 228.6 0.1
DAC-GT 2.7 2.4 0.3
CDFA 0.5 0.7 (0.2)
Equitable Building Decarbonization 1.5 1.4 0.1
Other 0.9 - 0.9
Subtotal 234.3 233.0 1.3
Internal Funding
Energy Efficiency - 0.0 (0.0)
Solar Battery Savings 59.8 60.3 (0.5)
Pilot Programs 1.7 2.5 (0.8)
Grants 1.5 1.5 (0.0)
DER 0.1 0.0 0.1
Flexible Load 3.1 3.3 (0.2)
IT Projects 3.5 4.0 (0.5)
Community Education - 0.0 (0.0)
App Assistance 0.1 0.3 (0.2)
Program Evaluation 0.3 0.3 0.1
Other CIP 0.2 39.1 (38.9)
Subtotal 70.3 111.3 (41.0)
CIP Expense Total 304.6 344.3 (39.7)
152
Table 6. Community Power FY 2025-2026 Budget Draft vs Proposed FISCAL IMPACT:
The proposed FY 2025-2026 budget is expected to result in a net position of $164.6 million, with resulting total cash reserves of $572.0 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 $22.2 million into the agency’s Capital Investment Plan. 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.
COMMITTEE REVIEW:
This item was presented at the Finance and Risk Management Committee on June 12, 2025. The Committee recommended advancing this item to the Board for approval.
Category Draft Budget FY26 Proposed Budget FY26 FY26 Draft vs Proposed Difference
Revenue
Gross Ratepayer Revenues $ 1,220,986,849 $ 1,220,986,849 $ - (Less 1.75%* Uncollectible ) $ (21,367,270) $ (21,367,270) $ - Total $ 1,199,619,579 $ 1,199,619,579 $ -
Expenditures
Cost of Energy $ 956,690,816 $ 956,690,816 $ -
General and Administration $ 5,841,527 $ 5,841,527 $ -
Marketing and Outreach $ 2,647,481 $ 2,647,481 $ -
Personnel Costs $ 21,115,541 $ 21,115,541 $ -
Professional Services and Consultants $ 24,647,755 $ 24,647,755 $ - Programs $ - $ - $ -
Total $ 1,010,943,119 $ 1,010,943,119 $ -
Debt Service $ 1,892,558 $ 1,892,558 $ -
CIP $ 21,353,333 $ 22,170,600 $ 817,267
Net Position $ 165,430,569 $ 164,613,302 $ (817,267)
153
ATTACHMENTS:
A: Draft FY 2025-2026 Operating Budget Book (Jun 12 redlined) B: Draft FY 2026-2030 Capital Investment Plan (Jun 12 redlined) C: A Resolution of the Board of Directors of San Diego Community Power Adopting the Fiscal Year 2025-2026 Operating Budget (Exhibit A), the Fiscal Year 2025- 2026 Capital Budget, and the Fiscal Year 2026-2030 Capital Investment Plan (Exhibit B)
154
ITEM 13
ATTACHMENT A
155
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Contents i
FISCAL YEAR
2025
2026
SAN DIEGO COMMUNITY POWER
Resolution 2025-XX Draft Revised June 12, 2025
Fiscal Year 2025–2026
Operating Budget
156
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
157
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 Affairs45
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
158
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
159
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Contents v List of Tables
TABLE 1. OPERATING BUDGET OVERVIEW* 27
TABLE 2. OPERATING REVENUE BY BUDGET LEVEL 2* 29
TABLE 3. OPERATING EXPENSES BY BUDGET LEVEL 2* 30
TABLE 4. OPERATING EXPENSES BY DEPARTMENT 30
TABLE 5. PERSONNEL BY DEPARTMENT 31
TABLE 6. FY 2025–2026 CAPITAL BUDGET OVERVIEW* 32
TABLE 6.1. FY 2026–2030 CIP PROGRAMS AND PROJECTS 33
TABLE 7. OPERATIONS POSITIONS 40
TABLE 8: POWER SERVICES POSITIONS 41
TABLE 9. FINANCE POSITIONS 42
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
160
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 161
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
162
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.
163
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Overview of San Diego Community Power 4 v
Overview of
San Diego
Community
Power
01 164
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 165
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.
166
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Serviced Communities 7 v
Serviced
Communities
02 167
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.
168
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
169
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.
170
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
171
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 12 v
Budget
Process
03 172
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 173
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.
174
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 175
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.
176
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
177
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
178
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Process 19 FIGURES 15, 16 & 17. COMMUNITY OUTREACH AND EDUCATION
179
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Guidelines 20 v
Budget
Guidelines
04 180
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
181
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
182
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
183
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.
184
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 185
Budget Guidelines 25
v
Budget
Overview
05 186
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 22.2 Total Expenses 1,071.0 1,143.9 1,034.2 1,035.0
Net Position 233.3 34.0 165.4 164.6
TABLE 1. OPERATING BUDGET OVERVIEW*
*Amounts displayed in millions of dollars
187
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 188
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 29 FY 2024 $1,304,274,067
$1,221,258,172
$1,199,619,579
$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
$1,242,354,119$1,199,619,579
189
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 22.2 Total Expenses 1,071.7 1,147.1 1,034.2 1,035.0
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
190
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 87.0 86.0 94.0
1 14 FTEs were approved but not hired in FY24 and need to be reapproved in FY25. 191
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 2026–2030 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 2026–2030 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 $54.7 million and the FY 2025–2029 2026–2030 CIP
total $304.3 $344.3 million. Additionally, $10.3 $11.2 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 9.2 - 21.4 22.2
Regional Energy Network[2] 0.3 - 31.8 31.9 31.8 -
DAC-GT 0.5 (0.1) 0.3 0.6 0.3 -
CDFA 0.5 0.7 - -
Equitable Building Decarbonization 1.5 1.4 - -
Other - - 0.9 -
CIP Revenue 10.3 11.2 32.1 32.5 54.4 22.2
*Amounts displayed in millions of dollars
[1] The carry forward amount represents actual financial data through March 31, 2025, updated April 30, 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, and funded programs will be available across SDG&E service territory.
192
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 33 [1] The carry forward amount represents actual financial data through March 31, 2025, updated April 30, 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 , it is reflected in this table as anticipated spending by fiscal year.
TABLE 6.1. 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]
2.1 1.8 2.1 0.3 - 31.8 31.9 59.5 51.4 42.0 43.7 228.7
228.6
DAC-GT 0.9 0.4 1.0 0.5 (0.1) 0.3 0.6 0.5 0.5 0.5 0.5 2.7 2.4 CDFA 0.7 0.2 - 0.5 0.7 - - - - - 0.5 0.7
Equitable Building
Decarbonization
1.5 0.1 1.5 1.4 - - - - - 0.5 1.4
Other - - - 0.9 - - - - - 0.9 -
Subtotal 5.2 2.4 3.2 2.8 2.0 33.0 32.5 60.0 51.9 42.5 44.2 234.4 233.0
Internal Funding
Solar Battery
Savings
10.6 7.9 7.4 2.7 3.2 18.8 11.1 10.4 8.3 8.5 59.860.3
Energy Efficiency 0.3 0.3 0.0 - - - - - 0.0
Pilot Programs 3.0 1.3 0.5 1.7 2.5 - - - - - 1.7 2.5
Grants 0.8 0.3 0.6 0.7 0.2 0.8 1.3 - - - - 1.5
DER 0.1 0.0 0.1 0.1 0.0 - - - - - 0.1 0.0
Flexible Load 0.6 0.5 0.3 0.2 0.3 0.3 0.6 0.6 0.8 0.7 3.1 3.3 IT Projects 2.6 0.6 0.1 2.0 2.5 1.5 - - - - 3.5 4.0
Community
Education
0.1 0.0 0.1 0.0 - 0.0 - - - - 0.0
Program Evaluation - - - 0.3 - - - - 0.3
Application
Assistance
0.3 - 0.3 - - - - - 0.3
Other - - - 0.2 - 7.4 8.7 11.2 11.7 0.2 39.1
Subtotal 15.4 18.4 11.1 9.2 7.5 9.2 21.4 22.2 11.7 19.1 11.0 19.7 9.1 20.3 9.2 20.9 69.9 111.3
CIP Expense Total 20.6 23.6 13.5 12.5 10.3 11.2 54.454.7 71.7 79.1 62.9 71.6 51.6 62.8 53.4 65.1 304.3 344.3
193
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Overview 34 About the CIP
The Community Power Fiscal Year 2025–2029 2026–2030
Capital Improvement Investment Plan (CIP) includes 21
projects that will receive funding in the five-year period, totaling $304.3 $344.3 million
in investments across Community Power member
jurisdictions. San Diego County. More detail can be found within the companion FY 2025–2029 FY 2026–2030
Capital Improvement Investment 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 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
the project has occurred. As design requirements, budgets 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 $344.3M
$304.3M
21 Across Community Power
member jurisdictions
Across San Diego County
Capital Investment Plan (CIP)
194
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 195
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
NET POSITION
$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. 196
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 164.6 166.0
FY28
264.3
FY29
313.0
FY30
344.1
1,035.0
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.
165.4 1034.2
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 1,035.0 967.0 926.4 931.1 957.9
Annual Reserve (Net Position) 165.4 164.6 166.0 264.3 313.0 344.1 Cumulative Net Position 574.9 574.1 741.0 740.1 1,005.3 1,004.4 1,318.3 1,317.5 1,662.40 1,661.6 180-Day Expense 510.0 510.4 486.8 467.3 470.1 483.8
Projected Excess Reserves 64.9 63.7 254.1 253.3 538.0 537.1 848.2 847.4 1,178.6 1,177.7 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.
197
v
Budget by
Department
06 198
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 199
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 5.0 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
200
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
201
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 9.0 *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
202
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 8.0 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
203
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 9.0 12.0
Department Organizational Structure
FIGURE 36. IT AND DATA ANALYTICS ORGANIZATIONAL STRUCTURE 204
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
205
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 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
(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 12.0 *14.0
*5.0 6.0 positions will be externally funded in FY26
*Positions authorized in FY26
206
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
207
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
208
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
209
v
Budget
by Level 2
and Level 3
07 210
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 1,243.0 1,233.4 1,221.0 (Less 4.5% 1.75% Uncollectible Customer
Accounts)
(61.5) (55.5) (21.8) (55.5) (21.4)
Net Operating Revenues 1,304.3 1,177.9 1,221.3 1,177.9 1,199.6 TABLE 17. OPERATING REVENUE BY BUDGET LEVEL 2 AND LEVEL 3* *Amounts displayed in millions of dollars
211
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
212
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
213
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
214
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
215
v
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Financing
08 216
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
217
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 218
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Financial
Policies
09 219
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.
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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.
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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.
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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.
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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 226
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 227
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.
236
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.
237
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
238
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.
239
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.
240
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. 241
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).
242
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.
243
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. 244
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. 245
v
Glossary
of Terms
10 246
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, 247
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
248
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 249
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.
250
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).
251
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.
252
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.
253
v
Budget
Resolution
11 254
SAN DIEGO COMMUNITY POWER OPERATIONAL BUDGET FY 2025–2026 Budget Resolution 95 Budget Resolution Pending
255
v
Acknowledgments
12 256
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
257
ITEM 13
ATTACHMENT B
258
SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Contents i Resolution 2025-XX Draft Revised June 12, 2025 Fiscal Years 2026–2030
SAN DIEGO COMMUNITY POWER
Capital Investment Plan (CIP)
FISCAL YEAR
2026
2030
259
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
260
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 3. COMMUNITY NEEDS ASSESSMENT 19
TABLE 4. ENERGY AWARENESS AND EDUCATION PROJECTS 23
TABLE 5. APPLICATION ASSISTANCE PROJECTS 24
TABLE 6. DISADVANTAGED COMMUNITIES GREEN TARIFF PROJECTS 25 TABLE 7. PILOT PROGRAMS PROJECTS 26
TABLE 8. GRANT PROGRAMS PROJECTS 27
TABLE 9. BUILDING ELECTRIFICATION HEAT PUMP TECHNOLOGY PROJECTS 28 TABLE 10. PLANNING & STUDIES PROJECTS 29
TABLE 11. DISTRIBUTED ENERGY RESOURCES: ENERGY STORAGE SYSTEMS PROJECTS 30 TABLE 12. DISTRIBUTED ENERGY RESOURCES: DEMAND RESPONSE PROJECTS 31 TABLE 13. ENERGY EFFICIENCY PROJECTS 32
TABLE 14. TRANSPORTATION ELECTRIFICATION: INFRASTRUCTURE PROJECTS 33 TABLE 15. TRANSPORTATION ELECTRIFICATION: LIGHT-DUTY VEHICLES PROJECTS 34 TABLE 16. TRANSPORTATION ELECTRIFICATION: MEDIUM- AND HEAVY-DUTY VEHICLES PROJECTS 35 TABLE 17. INFORMATION TECHNOLOGY UPGRADES PROJECTS 36
TABLE 18. COMMUNITY POWER FUNDING GUIDE 40
261
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 FY25–26 262
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
263
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.
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Capital
Investment
Plan Overview
01 265
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 9.2 - 21.4 22.2
Regional Energy Network [2] 0.3 - 31.8 31.9 31.8 -
DAC-GT 0.5 (0.1) 0.3 0.6 0.3 -
CDFA 0.5 0.7 - -
Equitable Building Decarbonization 1.5 1.4 - -
Other - - 0.9 -
CIP Revenue 10.3 11.2 32.1 32.5 54.4 22.2
*Amounts displayed in millions of dollars
[1] The Carry Forward amount represents actual financial data through March 31, 2025, updated April 30, 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 and funded programs will be available across SDG&E service territory
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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]
2.1 1.8 2.1 0.3 - 31.8 31.9 59.5 51.4 42.0 43.7 228.7
228.6
DAC-GT 0.9 0.4 1.0 0.5 (0.1) 0.3 0.6 0.5 0.5 0.5 0.5 2.7 2.4 CDFA 0.7 0.2 - 0.5 0.7 - - - - - 0.5 0.7
Equitable Building
Decarbonization
1.5 0.1 1.5 1.4 - - - - - 0.5 1.4
Other - - - 0.9 - - - - - 0.9 -
Subtotal 5.2 2.4 3.2 2.8 2.0 33.0 32.5 60.0 51.9 42.5 44.2 234.4 233.0
Internal Funding
Solar Battery
Savings
10.6 7.9 7.4 2.7 3.2 18.8 11.1 10.4 8.3 8.5 59.860.3
Energy Efficiency 0.3 0.3 0.0 - - - - - 0.0
Pilot Programs 3.0 1.3 0.5 1.7 2.5 - - - - - 1.7 2.5
Grants 0.8 0.3 0.6 0.7 0.2 0.8 1.3 - - - - 1.5
DER 0.1 0.0 0.1 0.1 0.0 - - - - - 0.1 0.0
Flexible Load 0.6 0.5 0.3 0.2 0.3 0.3 0.6 0.6 0.8 0.7 3.1 3.3 IT Projects 2.6 0.6 0.1 2.0 2.5 1.5 - - - - 3.5 4.0
Community
Education
0.1 0.0 0.1 0.0 - 0.0 - - - - 0.0
Program Evaluation - - - 0.3 - - - - 0.3
Application
Assistance
0.3 - 0.3 - - - - - 0.3
Other - - - 0.2 - 7.4 8.7 11.2 11.7 0.2 39.1
Subtotal 15.4 18.4 11.1 9.2 7.5 9.2 21.4 22.2 11.7 19.1 11.0 19.7 9.1 20.3 9.2 20.9 69.9 111.3 CIP Expense Total 20.6 23.6 13.5 12.5 10.3 11.2 54.454.7 71.7 79.1 62.9 71.6 51.6 62.8 53.4 65.1 304.3 344.3 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. [1] The carry forward amount reviews actual financial data through March 31, 2025, updated April 30, 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, 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.
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SAN DIEGO COMMUNITY POWER CAPITAL INVESTMENT PLAN FY 2026–2030 Overview of San Diego Community Power 7 v
Overview of
San Diego
Community
Power
02 268
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
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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.
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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.
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Capital
Investment
Plan
03 272
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 Investment Plan (CIP) includes 21 projects
that will receive funding in the five-year period, totaling $304.3 $344.3 million in investments across Community
Power member jurisdictions San Diego County. 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 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
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 $344.3
$304.3
21 Across Community Power
member jurisdictions San Diego County
Capital Investment Plan (CIP)
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Strategic
Planning
04 274
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.