The issues associated with SDG&E’s application will be addressed solely within A.25-04-014.” See R.25- 04-010, Assigned Commissioner’s Scoping Memo and Ruling, p. 9 (Jul. 23, 2025). 9 See, e.g., A.25-04-014, Prepared Direct Testimony of Hollie Bierman, p. HB-2:11-13 (Apr. 2025). 10 See id. at HB-4:15-26.
11 See id. at HB-2:13-15, HB-5:12-13.
12 See, e.g., Application at 6-7.
13 For a discussion of several relevant statewide and Commission goals, see Section II.A.1. 329
5 1 to customers, and relies upon insufficient data to conclude that regional EE is not cost-2 effective. 3 It is imperative that the Commission consider the shortcomings in SDG&E’s 4 analysis for several reasons. First, the Commission must weigh the actual cost savings that 5 discontinuance of regional EE will have against the value of lost benefits. This analysis is 6 necessary to determine remaining needs and appropriate next steps for the region in 7 meeting the Commission’s affordability, decarbonization, reliability, and equity goals. 8 When evaluating all data available, it is clear that total discontinuation of regional EE is 9 neither a just and reasonable nor effective solution for addressing affordability challenges. 10 Rather, the information available indicates there is significant remaining 11 opportunity and need for cost-effective and beneficial regional EE programs within 12 SDG&E’s territory, particularly when integrating innovative solutions. Regardless of 13 SDG&E’s status as a regional PA, the Commission should continue to foster these 14 opportunities. Thus, should the Commission permit SDG&E to withdraw from regional EE 15 portfolio administration, it should be ready to authorize funding up to at least the current 16 level as other PAs step in to fill SDG&E’s role. The following discussion in Section II of 17 this testimony addresses Scoping Questions 7, 17, 18, 19, 20, 21, and 23. 18 A. Total Discontinuation of Regional EE is Not an Appropriate or Effective 19 Solution to Address Affordability Challenges.
20 1. Energy Efficiency Remains a Key Aspect of Achieving the 21 Commission’s Affordability, Equity, Reliability, and Climate Goals. 22 At the outset, it is important to properly contextualize the role of EE as it relates to 23 ongoing affordability concerns. When evaluating the last ten years of data for the region, 24 it is apparent that EE is not a key driver of rate increases. Between 2014 and 2024, 25 SDG&E’s revenue requirements specific to EE decreased by 117%, as compared to its 330
6 1 revenue requirements associated with other customer programs, which increased by 204%, as well as its distribution revenue requirements, which increased by 115%.14 2 3 Irrespective of whether SDG&E continues to administer a regional portfolio, it is 4 also important to recognize the key role that EE continues to play in delivering 5 affordability, reliability, and equity benefits to the region, as well as in meeting the state’s 6 aggressive decarbonization goals. EE has been the state’s priority resource since 2003, 7 when the Commission, the California Energy Commission (“CEC”), and the Consumer 8 Power and Conservation Financing Authority came together to develop the first Energy Action Plan (“EAP I”).15 9 EAP I established a “loading order” related to electric resource procurement.16 10 The loading order, which was reiterated in subsequent EAP updates, 11 provides that “…the state, in meeting its energy needs, would invest first in energy 12 efficiency and demand-side resources, followed by renewable resources and only then in 14 See California Public Utilities Commission, Assembly Bill 67 Reports for Years 2014-2024, Demand-Side Management and Customer Programs (comparing IOUs’ EE revenue requirements with those of other programs, such as the Self-Generation Incentive Program (“SGIP”), Electric Program Investment Charge (“EPIC”), California Alternative Rates for Energy (“CARE”), Energy Savings Assistance (“ESA”), and other Public Purpose Program (“PPP”) programs). Accessible at:
https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/reports-on-utility-costs.
The Commission has recently reaffirmed the value of EE in the July 2025 Report to the Legislature on Demand-Side Management (“DSM”) Programs, which stated “DSM-related expenditures constitute less than 5 percent of utility revenue requirements, demonstrating a highly effective return on investment through lowered overall system energy costs.”
15 See California Public Utilities Commission and California Energy Commission, Energy Action Plan 2008 Update, p. 1 (Feb. 2008) (explaining the history of the Energy Action Plan and noting that the Consumer Power and Conservation Financing Authority is now defunct). Accessible at:
https://www.cpuc.ca.gov/-/media/cpuc-website/files/uploadedfiles/cpuc_public_website/content/utilities_and_industries/energy_- _electricity_and_natural_gas/2008-energy-action-plan-update.pdf. 16 California Public Utilities Commission, California Energy Commission, and California Power Authority, Energy Action Plan I, p. 4 (May 8, 2003). Accessible at: https://www.cpuc.ca.gov/- /media/cpucwebsite/files/uploadedfiles/cpuc_public_website/content/utilities_and_industries/energy_- _electricity_and_natural_gas/2003-energy-action-plan.pdf. 331
7 clean conventional electricity supply.”17 1 In 2005, the California Legislature amended 2 Section 454.5 of the Public Utilities Code to codify the “first in the loading order” status for EE and demand reduction resources.18 3
4 The EAP was developed within the context of growing energy consumption and peak load demand.19 5 The broad policy goal behind the EAP (and the loading order) was to 6 ensure “that adequate, reliable, and reasonably priced electrical power and natural gas 7 supplies are achieved and provided through policies, strategies, and actions that are cost-effective and environmentally sound for California’s consumers and taxpayers.”20 8 In 9 prioritizing EE as the “first-in-the-loading order” resource, these agencies reasoned that, 10 “[b]y definition, energy efficiency is a zero-emissions strategy, and also a least-cost strategy.”21 11 This is consistent with the widely accepted principle that the least expensive 12 kWh is the one that is never used. These agencies further concluded that EE is the most 13 important tool in achieving greenhouse gas (“GHG”) emissions reductions, and that 14 aggressive and innovative EE strategies are necessary to achieve statewide decarbonization goals.22 15 The Commission has recently reaffirmed the value of EE in the July 2025 Report 16 (to legislature) on Demand-Side Management (“DSM”) Programs, which stated “DSM-17 related expenditures constitute less than 5 percent of utility revenue requirements, 17 See California Public Utilities Commission and California Energy Commission, Energy Action Plan II, p. 1 (Oct. 2005). Accessible at: https://docs.cpuc.ca.gov/published/Report/51604.htm; see also EAP 2008 Update at 1 (emphasis added).
18 2005 Cal. Senate Bill (“SB”) 1037 (enacted Sept. 29, 2005). 19 EAP I at 4.
20 California Public Utilities Commission, Energy Action Plan Legislative Report, p. 1. Accessible at: https://docs.cpuc.ca.gov/word_pdf/REPORT/33091.pdf. 21 EAP 2008 Update at 6.
22 Id.
332
8 1 demonstrating a highly effective return on investment through lowered overall system energy costs.”23 2
3 While much has changed within the California energy sector since the EAP was 4 last updated in 2008, the core principles and policy rationales for prioritizing EE continue 5 to apply. The state is currently facing large increases in projected energy demand, driven, in part, by electrification efforts and emerging, energy-intensive industries. 6 24 A Lawrence 7 Berkeley National Laboratory (“LBNL”) Report published in 2024 concluded that when compared to electricity generation, EE programs still stand out as a least-cost resource.25 8 9 Based on findings from a national survey, the LBNL Report demonstrated that 10 approximately 80% of energy savings and demand reductions cost less than $0.035/kWh and $150/kW, which is less than the lowest levelized generation costs.26 11 In other words, 12 EE is still a least-cost strategy to meet growing demand, as EE resources remain less 13 expensive than building additional generation to serve demand. 14 Moreover, EE remains a key strategy in reaching the state’s aggressive 15 decarbonization goals. For example, Senate Bill (“SB”) 100 (2018) calls for statewide 16 carbon neutrality by 2045. The California Air Resources Board (“CARB”) 2022 Scoping 17 Plan identified building decarbonization, defined as “energy efficiency, use of low- and 23 California Public Utilities Commission, Report on Demand-Side Management Programs Pursuant to PUC Section 913.5: 2021-2023 Results, p. 4 (Jul. 2025). Accessible at: https://www.cpuc.ca.gov/- /media/cpuc-website/divisions/office-of-governmental-affairs-division/reports/2025/report-on-demandside-management-programs-pursuant-to-puc-section-9135.pdf. 24 See, e.g., California Energy Commission, Adopted 2024 Integrated Energy Policy Report Update, pp. 19-23 (Oct. 9, 2025). Accessible at: https://www.energy.ca.gov/publications/2024/2024-integrated-energy-policy-report-update. 25 Lawrence Berkeley National Laboratory, Consumer Benefits of Clean Energy: Energy Efficiency, pp. 4-5 (Dec. 2024). Accessible at: https://eta-publications.lbl.gov/sites/default/files/2024- 12/ee_consumer_benefit_final.docx.pdf.
26 Id. at 5, Figures 3 and 4.
333
9 1 zero-carbon electricity, demand flexibility, energy storage, use of very low- or no-GWP 2 refrigerants and refrigerant emission leak reduction, and eliminating fuel combustion by 3 electrifying appliances and equipment, among other actions,” as a key means by which the state can achieve SB 100 goals.27 4 The 2022 Scoping Plan makes clear that much more work 5 is needed to achieve carbon neutrality by 2045, emphasizing the need for “[m]arket-6 enabling actions such as incentives, affordable energy rates, education, and flexible 7 demand programs lay the foundation to prepare consumers, building developers, appliance manufacturers, and contractors for an equitable transition to building decarbonization.”28 8 9 Recent CEC analysis similarly highlighted the ongoing importance of EE in meeting the 10 SB 350 (2016) target of doubling statewide energy efficiency savings in electricity and natural gas end uses by 2030.29 11 In particular, the CEC noted that “[a]chieving energy 12 efficiency doubling by 2030 while reducing GHG emissions from buildings requires the 13 continued success of traditional efficiency programs, as well as new efforts to electrify end uses.”30 14
15 Beyond its critical role in facilitating aggressive decarbonization, EE continues to 16 more broadly support system reliability. A 2021 LBNL Technical Brief analyzed the 17 specific grid reliability and resiliency benefits associated with EE, ultimately concluding 27 California Air Resources Board 2022 Scoping Plan, Appendix F, p. 1 (Nov. 2022). Accessible at:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents. 28 Id. at Appendix F, p. 49.
29 See California Energy Commission, Draft California Building Energy Action Plan, p. 137 (Dec. 19, 2025).
30 Id.
334
10 1 that EE delivers these benefits to the bulk power system and the distribution system, while simultaneously enhancing demand-side management strategies.31 2 3 Finally, the clean and least-cost nature of EE reinforces its position as a key 4 resource in carrying out the Commission’s affordability, equity, and decarbonization goals. 5 In particular, the Commission’s Environmental and Social Justice Action (“ESJ”) Plan 6 emphasizes the need to increase investment in clean energy resources to benefit ESJ communities, especially to improve local air quality and public health.32 7 Moreover, failure 8 to prioritize available and cost-effective EE as a key resource may lead to more costly 9 generation investments, only exacerbating affordability challenges. 10 In sum, EE remains the key, least-cost, zero-emissions resource to help mitigate the 11 need for more costly generation investments and to simultaneously bolster the state’s 12 progress towards decarbonization goals. Regardless of any conclusions the Commission 13 reaches as to the performance of SDG&E’s portfolio in serving these important purposes, 14 it should continue to contextualize EE as the priority resource in the San Diego region and 15 to ensure that if SDG&E is relieved of its responsibility to administer regional EE 16 programming, there are other pathways to acquire EE resources. 31 Frick, N.M., Carvallo, J.P., and Schwartz, L., Quantifying grid reliability and resilience impacts of energy efficiency: Examples and Opportunities, Lawrence Berkeley National Laboratory Technical Brief, p. 2 (December 2021) (“LBNL Technical Brief”). Accessible at:
https://emp.lbl.gov/publications/quantifying-grid-reliability-and. 32 California Public Utilities Commission, Environmental and Social Justice Action Plan, Version
2.0, p. 5 (Apr. 7, 2022).
335
11 1 2. When Evaluated with Proper Context, the Benefits of Regional EE Still 2 Outweigh the Costs.
3 i. SDG&E’s calculation of cost savings to customers is artificially 4 inflated.
5 SDG&E’s Application represents its withdrawal from regional portfolio 6 administration as a simple and direct $300 million in savings to customers over a six-year period.33 7 However, this characterization is fundamentally flawed due to three key factors:
8 1) the Application’s savings calculations assume another PA will not step in to provide 9 continuity of service in the event of SDG&E’s exit; 2) the Application assumes that absent 10 withdrawal, SDG&E would spend its full $300 million portfolio budget; and 3) the 11 Application assumes ratepayers receive no value for the programs that would be closed. 12 Put more simply, it is incorrect to accept SDG&E’s implicit assumption that the reduction 13 of its regional portfolio budget will translate into a dollar-for-dollar ratepayer savings. 14 First, SDG&E’s savings calculation assumes that the entirety of its $300 million 15 budget would no longer be collected from customers. However, this assumption fails to 16 account for commensurate PA expansion in the San Diego region. As discussed below, the 17 programmatic gaps left by SDG&E’s withdrawal would necessitate new or existing PA 18 expansion to continue to deliver total system benefit (“TSB”) and ensure equitable access 19 to EE is preserved in the region. Alternative PA expansion (and related budgets) would 20 necessarily reduce the dollar amount to be removed from Public Purpose Program (“PPP”) 21 collections.
22 Second, SDG&E’s estimated $300 million in savings is based on SDG&E’s approved 2026-2031 Business Plan budgets from D.23-06-055.34 23 This calculation does not 33 Application at 2.
34 Id. at 5, Table 2; SDG&E’s budget is derived from SDG&E’s Advice Letter 4203-E for years 2026- 2027. For 2028-2031, SDG&E utilized the budget approved in D.23-06-055. 336
12 1 recognize the fact that SDGE’s actual EE expenditures are less than originally forecasted, 2 and its 2024-2027 portfolio forecast has been revised as reflected in its recently filed Mid Cycle True Up Advice Letter (“MCAL”).35 3 In fact, SDG&E’s recent MCAL indicates 23% 4 lower spend in 2024 than estimated in its last True Up Advice Letter (“TUAL”) and 5 includes 2026 and 2027 budgets that are 8% less than what was included in SDG&E’s Application and over 10% less than their 4-year approved budget cap.36 6 This historical 7 trend indicates that SDG&E’s future EE expenditures may very well continue to be less 8 than its full authorized budget, and that calculating hypothetical ratepayer savings based 9 on the full portfolio budget overinflates the actual dollar impact that SDG&E’s withdrawal 10 would have on customers.
11 Finally, SDG&E’s estimate of total savings erroneously assumes that none of its 12 current regional EE programs deliver any economic benefit to ratepayers. This is 13 inconsistent with the findings set forth in the Commission’s recent DSM Report to Legislature,37 14 and cannot be accepted as a factual claim. To contextualize SDG&E’s 15 omission of these benefits, it is helpful to evaluate SDG&E’s Total Resource Cost (“TRC”) 16 data for its Resource Acquisition (“RA”) segment. The TRC is the Commission’s primary metric of EE cost effectiveness.38 17 The TRC nets total program costs to the utility and 35 See San Diego Gas & Electric Company Advice Letter (“AL”) 4747-E, Energy Efficiency Mid Cycle True Up Advice Letter Pursuant to D.21-05-031 (Nov. 4, 2025). 36 See id. at 6, Table 2.3a, line 11; San Diego Gas & Electric Company AL 4302-E, Energy Efficiency True Up Advice Letter Pursuant to D.21-05-031, Appendix 3, Table 2.3, line 11 (Oct. 16, 2023); D.23-06- 055 at OP 5 (approving SDG&E’s 4-year budget cap).
37 See generally, Report to the Legislature on DSM Programs: 2021-2023 Results. 38 See Energy Efficiency Policy Manual (Version 6), Section IV: Cost-Effectiveness (Apr. 2020).
Accessible at: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/energy-efficiency/eepolicymanualrevised-march-20-2020-b.pdf. 337
13 participants against benefits in the form of avoided supply-side investments.39 1 Generally, 2 a TRC ratio of 1.0 or greater indicates that the benefits, as defined in the TRC test, outweigh the costs and the program is therefore cost-effective.40 3 The majority of SDG&E’s regional EE portfolio falls under the RA segment.41 4 5 SDG&E’s prior reporting indicates that its RA segment meets or almost meets a 1.0 TRC ratio,42 6 with its most recent MCAL forecasting an RA segment TRC ratio of 1.12 for 2024- 2027.43 7 Based on these TRC values, SDG&E’s regional EE programs have a demonstrable 8 economic benefit for customers.
9 Because these quantifiable benefits exist, it is misleading to characterize savings to 10 customers based solely on the dollar reduction in SDG&E’s EE expenditures. A more 11 accurate depiction of savings in the event of SDG&E withdrawal would be the pro rata 12 portion of the budgets between the actual TRC performance and the 1.0 TRC goal. For 13 example, SDG&E spent $38,332,496 on regional programs (not including C&S) in 2024, which achieved an overall 0.80 TRC ratio.44 14 Thus, no more than two-tenths of SDG&E’s 15 budget ($7,687,438) should be construed as potential ratepayer “savings” if these programs 39 Id.; see also California Standard Practice Manual, p. 18 (Oct. 2001). Accessible at:
https://www.cpuc.ca.gov/-/media/cpuc-website/files/uploadedfiles/cpuc_public_website/content/utilities_and_industries/energy_- _electricity_and_natural_gas/cpuc-standard-practice-manual.pdf. 40 See, e.g., D.21-05-031, pp. 21-22 (May 26, 2021); see also California Standard Practice Manual at 18 (stating that “[t]he benefits calculated in the Total Resource Cost Test are the avoided supply costs, the reduction in transmission, distribution, generation, and capacity costs valued at marginal cost for the periods when there is a load reduction”).
41 AL 4747-E at 6.
42 R.25-04-010, San Diego Gas & Electric Company (U 902 M) Energy Efficiency Programs Annual Report 2024 Results, Supporting Document “SDGE_2024_Annual Report Narratives and Spreadsheets_2024_SDGE_EE_Annual_Report_Tables_Final.xlsx,” Tab ‘T-4 Segment Summary’ (Jun. 30, 2025).
43 AL 4747-E at 7.
44 Note that this example assumes that there are no other ratepayer benefits or value (including non-energy or equity benefits) that the program delivers, other than those included within TRC. 338
14 1 were discontinued. This is because these programs delivered 80% of the quantifiable 2 benefits when netted against costs. Despite achieving a TRC below 1.0, customers received 3 significant value from these programs that would be lost if the programs were closed. 4 ii. SDG&E’s Application fails to account for lost Total System 5 Benefit.
6 SDG&E’s Application further does not adequately discuss the parallel loss of TSB 7 that will occur if it withdraws, which is important context alongside the potential ratepayer 8 savings in the form of budget reductions. TSB is the metric by which the Commission sets 9 EE goals, and is “an expression, in dollar terms, of the lifecycle energy, capacity, and GHG benefits, expressed on an annual basis.”45 10 Whereas failure to consider lost TRC benefits 11 understates lost value to customers, failure to consider lost TSB understates general lost 12 benefits to the system.
13 In its most recent EE Business Plan Application, SDG&E forecasted approximately $300 million in TSB over the 2024-2027 period.46 14 SDG&E’s recent MCAL confirmed, 15 based on actual 2024 data, updated 2025 goals, and updated 2026-2027 projections, a forecasted TSB value of nearly $280 million.47 16 The Commission’s updated 2025 Potential 17 and Goals further indicated opportunity for growth in SDG&E’s delivered TSB, adopting a goal of approximately $365 million for the 2032-2035 period.48 18 In sum, there is 19 substantial system value associated with SDG&E’s EE portfolio. If SDG&E withdraws 45 D.21-05-031 at 9. Note that TSB is essentially equivalent to the numerator of the TRC ratio. 46 See D.23-06-055, p. 96, Table 10 (Jul. 3, 2023). 47 AL 4747-E at 7. 48 D.25-08-034, p. 21, Table 5 (Sept. 5, 2025).
339
15 1 and its regional programs are not replaced, then these forecasted TSB values and adopted goals represent the lost opportunity cost associated with abandonment of regional EE.49 2 3 It is important to consider the reduction in TSB that would occur as a result of 4 SDG&E’s withdrawal as compared to the dollar reduction in SDG&E’s EE budget to more 5 fully contextualize the dollar savings-to-lost benefit scenario. With its request for a budget 6 reduction of approximately $300 million, SDG&E simultaneously projects a reduction in TSB of $286 million.50 7 SDG&E’s updated TSB forecast, based on the request set forth in 8 its Application, is reflected in the table below.
Graphic 1: Snapshot of SDG&E’s Updated TSB Forecast51 9 10 Without consideration of this substantial lost TSB value, SDG&E’s estimated 11 ratepayer savings fail to capture the complete picture of impacts to the region. 49 See, e.g., AL 4747-E at 7 (explaining that SDG&E is forecasting to achieve 112% of its TSB goal for 2024-2027). 50 Bierman Direct at HB-10, Table 3 (compare the sum of SDG&E’s old TSB forecast, $557,871,710, minus the sum of SDG&E’s new TSB forecast, $271,629,303). 51 Id. at HB-10. 340
16 1 iii. SDG&E’s Application does not account for lost non-energy 2 benefits.
3 Beyond the more straightforward TRC and TSB benefits, SDG&E’s savings 4 estimate also omits any analysis of lost non-energy benefits (“NEBs”). NEBs may include 5 benefits such as cleaner air and a healthier workforce, which are harder to quantify but nonetheless provide substantial value to customers.52 6 Along similar lines, SDG&E’s 7 representation of savings does not account for lost ratepayer value associated with Market Support and Equity programs, which are not evaluated on a TRC basis.53 8 Equity and 9 Market Support programs are instead evaluated based on specific metrics and indicators, 10 for which IOUs, and all PAs, must quantify and calculate benefits based on Commission-approved methodologies.54 11 12 Finally, SDG&E argues that its request to withdraw will result in bill reductions, as 13 it will be collecting approximately $300 million less through PPP rates to support its portfolio.55 14 However, this representation may not be accurate for program participants. 15 For example, a project may achieve a lifetime impact of $1,000 in TSB, but the customer 16 achieves $2,500 in lifetime bill savings. These customer bill savings are not captured in 17 TSB. In other words, program beneficiaries realize far greater bill savings and system 52 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, p. 3 (Mar. 2025). Accessible at: https://www.auditor.ca.gov/wp-content/uploads/2025/03/2023-127- Report.pdf. Note that efforts are currently underway to develop a methodology for quantifying and valuing 11 NEB categories: the benefit of bill savings, increased comfort, better health at the participant level, increased job access, economic development, better health at the societal level, increased jobs, reduced shut-offs, increased property value, increased productivity, and enhanced community resilience and adaptation to climate change. See Illume Advising, LLC & Industrial Economics, Inc., Market Rate Equity Segment Non-Energy Benefits Research Plan (Prepared for SoCalGas), p. 2, Table 1 (Jul. 1, 2025).
Accessible at:
https://pda.energydataweb.com/api/view/4183/CA%20Market%20Rate%20Equity%20Segment%20NEB s%20Study%20Research%20Plan%20v20250701_clean.pdf.
53 See D.21-05-031 at 22-24. 54 Resolution E-5351, pp. 9-10, Appendix B (Jun. 12, 2025). 55 Application at 4-6.
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17 1 benefits than the potential bill reductions as a result of decreased PPP rates. SDREN and 2 CEA have neither the detailed and comprehensive participation data by customer class nor 3 the participant bill savings data to offer a technical analysis of SDG&E’s purported bill 4 savings, but nonetheless offer SDG&E’s lack of consideration for participant bill impacts 5 to participating customers as another factor for the Commission’s evaluation. 6 To accurately portray the savings associated with SDG&E’s withdrawal, SDG&E 7 would need to quantify the total TRC, TSB, NEBs (to the extent possible), and Market 8 Support and Equity benefits that its regional portfolio currently provides. Those benefits 9 would then be applied as an offset to the straight dollar reduction figure associated with 10 discontinuing SDG&E’s portfolio.
11 Without providing a comprehensive analysis of cost savings netted against lost 12 benefits, it is important to note that the lost benefits not currently considered in SDG&E’s 13 analysis are substantial. For example, SDG&E’s 2024 Annual Report projected a total 14 estimated first-year bill savings for 2024 amount to $95.5 million across all customer 15 segments, and estimated lifecycle bill savings of $1.2 billion. These bill savings projections 16 are reflected in Graphic 2 below.
Graphic 2: Snapshot of Net Savings Presented in SDG&E’s 2024 Annual Report56 17 56 SDG&E 2024 Annual Report Tables and Spreadsheets at Tab T-5, Bill Impacts. 342
18 1 In a similar vein, SDG&E provided estimated bill savings associated with its 2 portfolio in its 2024-2031 Business Plan Portfolio Application Excel Sheets. Specifically, 3 SDG&E estimated a total of $893 million in total average annual bill savings between 4 2026-2031 and $11.2 billion in total average lifecycle bill savings. SDG&E’s estimated 5 bill savings as presented in its previous Business Plan Application are reflected in Graphic 6 3 below.
7 Graphic 3: Snapshot of Average Annual Bill Savings in SDG&E’s Business Plan Application57 8
9 B. There are Remaining Opportunities for Cost-Effective and Innovative EE in 10 the San Diego Region.
11 1. Known Limitations in the TRC Evaluation Methodology Misrepresent 12 Program Benefits.
13 The Commission’s recently adopted Potential and Goals Study, finds growing 14 economic and market adoption scenarios for cost-effective EE in the San Diego service area through 2037.58 15 Beyond this assessment, there exists even further opportunity for 57 A.22-03-005, Application of San Diego Gas & Electric Company (U 902-M_ to Adopt 2024-2031 Energy Efficiency Rolling Portfolio Business Plan Pursuant to D.21-05-031, Attachment A (Revised), Tab 1, Bill Payer Impacts - IOU Only (Mar. 4, 2022). Accessible at: https://www.sdge.com/node/22336. 58 See generally, Guidehouse, 2025 PG Study Viewer. Accessible at:
https://public.tableau.com/app/profile/cpuc.pg.study.2025/viz/2025CPUCPGResultsViewer06- 09Release/LandingPage.
343
19 1 innovative EE. In considering the feasibility of cost-effective EE in SDG&E’s service 2 territory, it is important to note that known limitations in the TRC as the primary cost-3 effectiveness metric bias current cost-effectiveness analyses towards portfolio 4 underperformance.
5 As mentioned above, the TRC nets total program costs to the utility and participants 6 against benefits in the form of avoided supply-side investments. The Avoided Cost 7 Calculator (“ACC”) utilizes a Commission-approved modeling scenario to determine the values used to calculate TRC benefits.59 8 The current ACC considers avoided generation 9 capacity, energy, ancillary services, GHG emissions, high global warming potential gases, transmission and distribution capacity, and natural gas infrastructure.60 10 The ACC (and 11 resulting TRC cost-benefit analysis) does not include NEBs and other harder-to-quantify participant or system benefits.61 12
13 In its 2024 Report, the California State Auditor specifically noted this shortcoming 14 in the Commission’s cost-effectiveness framework, finding that inclusion of all costs, but 15 only a portion of the benefits, associated with EE programs skews the TRC analysis 16 towards lower values. The State Auditor concluded that “[t]he absence of participant 17 benefits in the CPUC’s TRC calculation also produces lower TRC values for certain 18 programs that provide efficiency benefits directly to program participants, such as programs that install equipment in ratepayer homes.”62 19 The State Auditor noted examples 59 See, e.g., Resolution E-4942, p. 2 (Jul. 12, 2018) (describing the adoption and use of the ACC in EE cost-effectiveness analyses).
60 See Resolution E-5328 (Nov. 7, 2024) (adopting the most recent iteration of the ACC); see also California Public Utilities Commission, 2024 Distributed Energy Resources Avoided Cost Calculator Documentation, p. 1 (Oct. 2, 2024).
61 See 2024 California State Auditor Report at 3.
62 Id.
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20 1 of other states adding up to a 15% adder to the calculated benefits of EE programs to account for NEBs.63 2 This finding is consistent with LBNL analysis, which determined that 3 existing cost-benefit analyses, such as the TRC, do not adequately capture the grid reliability and resilience benefits of EE.64 4 The LBNL Brief provided several technical 5 approaches by which regulators could quantify these benefits for inclusion within cost-6 effectiveness analyses. 7 Finally, the Equity and Market Support segments capture broader ratepayer benefits through different indicators and metrics that are not reflected within the TRC calculation.65 8 9 It is therefore important to consider which customer segments benefit from EE programs, 10 as benefits that accrue to hard-to-reach or underserved customers and communities deliver 11 high-value, equitable outcomes that cannot be ascertained from program TRC alone. 12 The Commission is slated to consider revisions to its current cost-effectiveness policy in the EE OIR,66 13 and any modifications to current policy that account for these 14 benefits are likely to result in significant improvements to EE cost-effectiveness more 15 generally. These identified shortcomings, as well as planned re-evaluation, mean that 16 regional EE cost-effectiveness is currently understated and likely to improve when cost-17 effectiveness policy and calculation methodologies are reformed to fully capture benefits. 18 Absent reform, the systemic issues associated with the current cost-effectiveness 19 framework will materially affect any PA that serves the region. The Commission should 20 exercise caution in reaching any conclusions about the feasibility of cost-effective regional 63 Id. 64 See generally, LBNL Technical Brief: Quantifying Grid Reliability and Resilience Impacts of Energy Efficiency. 65 See generally, Resolution E-5351. 66 R.25-04-010, Order Instituting Rulemaking, p. 6 (Apr. 29, 2025); R.25-04-010, Scoping Ruling at 4, 5.
345
21 1 EE based on SDG&E’s cost-effectiveness assertions, as they are based on a flawed 2 framework that is currently under review.
3 2. Even Utilizing the Current TRC as the Metric for Cost-Effectiveness, 4 Historical Data Indicates Positive Regional EE Program Performance. 5 When evaluating the feasibility of SDG&E’s (or any PA’s) regional EE portfolio, 6 it is important to specify the period over which performance is analyzed (i.e., year-to-year 7 versus by program cycle). Comparative data shows SDG&E’s 2024 performance aligns 8 with that of Southern California Edison Company (“SCE”), and that its 2023 actual TSB 9 delivered as compared to its Potential and Goals target exceeded that of other electric IOUs. 10 Graphics 5 and 6 below, which are derived from the California Energy Efficiency 11 Coordinating Committee (“CAEECC”) 2024 Annual Performance Report Review, 12 illustrate these data points.
346
2 2
Gr a p hic 5: C A E E C C A n al ysis of 2 0 2 4 T S B Pr o gress 6 7 1 Gr a p hic 6: C A E E C C A n al ysis of 2 0 2 4 E E P ortf oli o C ost -Effecti ve ness 6 8 2 6 7 Calif or nia E ner g y Efficie nc y C o or di nati n g C o m mittee ( “C A E E C C ”), A n n u al 2 0 2 4 P ortf oli o Perf or m a nce Re p ort Revie w: P ortf oli o Perf or m a nce Overvie w Prese nte d by E ner gy Divisi o n , p. 2 1 (J ul. 3 0, 2 0 2 5) (all data p ulle d fr o m C E D A R S i n J ul. 2 0 2 5). Accessi ble at:
htt ps:// w w w.caeecc. or g/ _files/ u g d/ 8 4 9f 6 5 _ac 7c 5 6 0 8 4 7 5 b 4 7a 8 8 8 d d b 6 0 1 8 4 8 b d 7 b 7. p df. 6 8 I d. at 2 3.
347
23 1 The historical performance of SDG&E’s regional portfolio weighs heavily against any assertion that opportunities for beneficial EE in the San Diego region are infeasible.69 2 3 Moreover, SDG&E’s Application provides no insights as to its efforts to implement 4 corrective actions beyond seeking termination of programs to remediate more recent 5 portfolio underperformance. Accordingly, the Commission should not consider the limited 6 analysis of program performance set forth in SDG&E’s Application as necessarily 7 indicative of larger trends in the region.
8 3. Innovative Statewide and Regional Programs are Essential to Serve the 9 Region in a Cost-Effective Manner.
10 SDG&E opines throughout its Application that much of its reported portfolio 11 underperformance is due to emerging difficulty in developing cost-effective EE measures.70 12 The Commission has previously acknowledged these challenges, stating:
13 “[d]ue to the success of energy efficiency programs and advancing building 14 codes/appliance standards, cost-effectiveness is becoming much more difficult to 15 achieve…” and, “there is less cost-effective energy efficiency available, at least by the 16 current and long-term definitions of cost-effectiveness, than has been historically available.”71 17 These challenges are not an absolute bar to cost-effective and beneficial EE 18 in the region; rather, they present the need to innovate as new opportunities arise. 19 Regional EE will be a necessary factor in addressing emerging opportunities for 20 energy savings, such as local efficiency needs resulting from electrification of vehicles and 21 the transportation sector, commercial and residential building electrification, accelerated 69 Note that SDG&E also launched several Commercial Sector programs in 2025, which are likely to deliver significant benefits in future years once reaching steady state. See AL 4747-E at 11-12. 70 Bierman Direct at HB-4 – HB-5.
71 D.21-05-031 at 20-21.
348
24 adoption of heat-pump technologies, and advancements in appliance efficiency.72 1 With a 15% projected load growth in the SDG&E service area by 2031,73 2 it is imperative to 3 maintain a dependable portfolio of programs specifically authorized within the SDG&E 4 service area. Regional EE is a key component of the statewide EE portfolio, as it provides 5 increased flexibility and opportunities to leverage local relationships and networks that statewide programs may not.74 6 Broadly speaking, statewide programs are more conducive 7 to generic, one-size-fits-all approaches that are not tailored to the specific needs and 8 efficiency opportunities of the region. Statewide programs also serve an important role, but 9 are most effective when complemented with regional programming. 10 Moreover, the flexibility provided by regional programs may present more feasible 11 opportunities to achieve the harder-to-reach energy savings remaining now that the “low-12 hanging fruit,” or more traditional and conventional avenues for savings, have been captured.75 13 In particular, efforts are underway across the state to develop innovative 14 Integrated Demand-Side Management (“IDSM”) strategies capable of achieving savings 15 that have not yet been tapped. Regional programs are effective in removing or reducing 16 barriers to integrate IDSM with EE for more load flexibility opportunities to better manage 17 load growth. With the acceleration of electrification, each intervention is an opportunity to 18 manage and control new electric load in ways that are beneficial to both customers and the 72 See, e.g., A.24-12-009, Application of Pacific Gas and Electric Company (U 39 M) on Behalf of the California Market Transformation Administrator (U-1339-E) for the Approval of the Initial Tranche of Statewide Energy Efficiency Market Transformation Initiatives (Dec. 20, 2024). 73 California Energy Commission Docket No. 25-IEPR-03, SDG&E CED 2025 Baseline Load Forecast, Form 1.2 (Jan. 2026). Accessible at:
https://efiling.energy.ca.gov/GetDocument.aspx?tn=268179-7&DocumentContentId=105224. 74 See D.01-11-066, pp. 15-16 (Dec. 3, 2001) (describing the benefits of local programs as compared to their statewide counterparts).
75 See D.21-05-031 at 20 (explaining that the success of energy efficiency programs and building codes and standards has made cost-effective energy efficiency more difficult to achieve). 349
25 1 grid. Local customers and the local distribution grid require regional knowledge, data, and 2 interventions that specifically address San Diego’s locational energy management needs. 3 C. Key Takeaways
4 To ground this discussion, SDREN and CEA reiterate that they do not offer these 5 critiques of the representations and conclusions in SDG&E’s Application as opposition to 6 the Application itself. Rather, SDREN and CEA offer these insights to make clear that EE 7 serves an important role in the San Diego region, and that the Commission should not write 8 off the feasibility of regional EE as a wholesale conclusion based on SDG&E’s 9 Application. Instead, the Commission should continue to foster EE at (or above) the level 10 currently maintained, and should pursue policy pathways that enable non-IOU PAs to fill 11 any gaps that are left in the event the Commission authorizes SDG&E to withdraw. 12 III. THE COMMISSION SHOULD FACILITATE OPPORTUNITIES FOR 13 EXISTING AND FUTURE PAS TO HELP SERVE THE REGION.
14 As the Commission considers SDG&E’s request to withdraw from regional 15 portfolio administration, it is simultaneously important to consider the impacts SDG&E’s 16 withdrawal will have on customers and other PAs in the region. An evaluation of regional 17 implications ensures the Commission has a holistic view of the remaining needs post-18 SDG&E withdrawal, and is positioned to quickly implement policy changes necessary to 19 allow other PAs to step in. The following discussion in Section III of this testimony 20 addresses Scoping Questions 8, 9, 10, 11, 12, 15, 16, and 24. 21 A. If Permitted, SDG&E’s Withdrawal Would Leave Significant Programmatic 22 Gaps in the Region.
23 If SDG&E discontinues its regional portfolio and SDREN does not equivalently 24 expand, the entirety of SDG&E’s discontinued portfolio would constitute a programmatic 25 gap. It would also create regional disparities in equitable access to DSM services across 350
26 1 the state as well as energy planning areas. This is because SDREN was designed to fill 2 gaps that were identified based on SDG&E’s existing portfolio, and further because 3 SDREN and SDG&E have coordinated extensively to prevent overlap in programming. 4 Put another way, SDREN does not currently fulfill any part of the role occupied by 5 SDG&E.
6 SDREN’s coordination with SDG&E began early in the development of its 2024- 7 2031 Business Plan Application. Through regular meetings, SDREN sought information 8 necessary to intentionally design offerings that would complement, and not duplicate or overlap, SDG&E’s portfolio.76 9 These efforts included “sector-level meetings with the 10 appropriate SDG&E EE team members to walk through each program and discuss any comparable offerings and initial coordination strategies.”77 11 SDG&E reviewed SDREN’s 12 proposals to prevent duplication and overlap, and the Commission acknowledged these efforts in its authorization of SDREN.78 13 Specifically, the Commission found that SDREN’s 14 proposed portfolio would “provide unique value and contribute meaningfully to efforts to achieve the state’s energy, climate and equity goals.”79 15 Pursuant to the Commission’s guidance,80 16 SDREN and SDG&E subsequently 17 submitted a Joint Cooperation Memorandum (“JCM”) in late 2024, which provided a 18 detailed description of the ongoing processes SDREN and SDG&E jointly employ to 76 See R.13-11-005, Motion for Approval of SDREN at Exhibit 1, p. 17 (describing SDREN’s engagement and coordination with SDG&E). Note that SDREN, now entering its launch stage, has regular sector coordination meetings with SDG&E to ensure complementary offerings. 77 Id. 78 See D.24-08-003 at 10. Note that the Commission permits overlap in narrow instances where programs will seek to ensure that hard-to-reach customers are not left behind (see id. at 11). 79 Id. at 12, Conclusion of Law (“COL”) 1.
80 See D.18-05-041, p. 97 (Jun. 5, 2018); see also, D.24-08-003 at OP 3. 351
27 prevent overlapping or duplicative programs.81 1 Together, these initial and ongoing efforts 2 have effectively mitigated overlap in services. SDG&E has further not specifically 3 identified any areas of alleged overlap in its Application. Accordingly, absent concurrent 4 non-IOU PA expansion, SDG&E’s withdrawal would necessarily leave significant gaps in 5 regional accessibility to EE programming.
6 B. The Commission Should Facilitate Other PAs’ Efforts to Fill Gaps in 7 SDG&E’s Absence.
8 1. SDG&E Withdrawal Will Necessitate Commensurate PA Expansion. 9 Given the gaps described above, SDREN would feel a moral duty to examine 10 portfolio expansion in the event of SDG&E’s withdrawal. SDREN’s priority is ensuring 11 that customers in the San Diego region are not left without valuable regional EE 12 programming, and that the region more broadly is not negatively impacted by a significant 13 decrease in available EE programming should the Commission approve SDG&E’s 14 Application.
15 SDREN may be well positioned to help meet programming gaps in the event of 16 SDG&E’s withdrawal, as the REN criteria includes areas that the IOUs cannot or do not intend to undertake.82 17 Notwithstanding, the Commission cannot and should not require SDREN to take on responsibility for achieving SDG&E’s EE goals 18 83 which cannot be 19 disassociated with the Commission's statutory obligations related to energy efficiency. 20 Further, relying solely upon SDREN to fill SDG&E’s role may not be the only solution; 81 See generally, SDREN and SDG&E 2024 Joint Cooperation Memo. Accessible at:
https://sdcommunitypower.org/wp-content/uploads/2025/02/2024-SDREN-and-SDGE-Joint-Cooperation-Memo.pdf. 82 D.11-12-015, p. 17 (Nov. 15, 2012).
83 See A.25-04-014, Initial Brief of San Diego Community Power on Behalf of the San Diego Regional Energy Network, Clean Energy Alliance, the Bay Area Regional Energy Network, the Tri-County Regional Energy Network, and the Inland Regional Energy Network, pp. 16-19 (Sept. 5, 2025). 352
28 1 there may be a shared role among multiple non-IOU PAs in sustaining the region’s EE efforts and ensuring continuity of service.84 2
3 SDREN and CEA encourage the Commission to explore all potential pathways for 4 filling the gaps if SDG&E is allowed to withdraw. In doing so, the Commission should be 5 prepared to authorize regional EE funding at least up to the current level to support 6 expansion of the PA or PAs that step in to fill this role. Maintaining continuity in the level 7 of funding available ensures, to the greatest degree possible, that PAs are able to effectively 8 take over the entirety of SDG&E’s regional obligations. 9 2. The Commission Should Implement Policy Changes to Enable Other 10 Potential PAs to Step in and Serve the Region.
11 As mission-driven local government entities, CCAs are particularly well-suited to 12 administer EE programming. This is because CCAs share customer bases and data with 13 IOUs, are governed by boards of elected officials who are directly accountable to the 14 members of their community, and have overlapping affordability, sustainability, and equity objectives as those associated with EE programs.85 15 Beyond formation of a REN, CCAs 16 may implement EE programs through the ETA framework set forth in Section 381(e)-(f), 17 or the Apply to Administer (“ATA”) framework set forth in Section 381.1(a). 84 Note that SDREN’s service territory does not include around 8% of SDG&E’s electric customers who reside in South Orange County, however those customers have access to EE programming through statewide programs, and, as applicable, as customers of Southern California Gas Company. 85 See, e.g., Clean Energy Alliance: Background and Mission Statement, accessible at:
https://thecleanenergyalliance.org/background/ (CEA’s mission is to “empower local communities with the choice of sustainable and affordable energy for all customers, accelerating the transition to clean energy and fostering local economic growth, environmental responsibility, inclusivity and community well-being”); San Diego Community Power: Who We Are, accessible at: https://sdcommunitypower.org/about/ (SDCP’s mission is “[t]o provide affordable clean energy and invest in the community to create an equitable and sustainable future for the San Diego region”).
353
29 1 The ETA framework is intended to provide CCAs with a simpler route to administer EE programs than the alternative ATA pathway.86 2 However, the Commission and 3 stakeholders have recently highlighted specific funding challenges associated with the 4 ETA pathway that effectively form a barrier for CCAs seeking to implement ETA 5 programs. CEA recently began exploring the development of a portfolio of EE programs 6 under the ETA framework, but encountered obstacles in obtaining the level of funding 7 required to implement EE programming.
8 The funding for ETA programs is derived from a portion of the IOUs’ collections of EE revenues from the CCA’s customers.87 9 In D.24-04-007, the Commission refined its initial ETA maximum funding calculation as follows:88 10 11 CCA maximum funding = Total electricity energy efficiency nonbypassable 12 charge collections from the CCA’s customers – (total electricity energy 13 efficiency nonbypassable charge collections from the CCA’s customers * 14 % of the applicable IOU portfolio budget that was dedicated to statewide 15 and regional programs in the most recently authorized program cycle). If 16 the percentage of the applicable IOU portfolio budget dedicated to statewide 17 and regional programs in the most recently authorized program cycle 18 exceeds 96 percent, then the percentage shall be fixed at that 96 percent 19 level and will not be allowed to exceed it, for purposes of this formula only. 20 As reflected in the calculation methodology described above, a key input in 21 determining the maximum funding CCAs may request for ETA energy efficiency programs 22 is the “total electricity energy efficiency nonbypassable charge collections from the CCA’s 86 D.14-01-033, p. 21 (Jan. 16, 2014) (explaining that the recently enacted ETA statutory framework “underscores the two distinct options available to a CCA seeking to administer EE funds and highlights the Legislature’s desire to greatly simplify the process by which CCAs can administer EE programs for their own customers”).
87 See Cal. Pub. Util. Code § 381.1(e); see also D.14-01-033 at 22-24 (describing funding collections from CCA customers).
88 D.20-04-007, OP 2 (Apr. 18, 2024).
354
30 customers.”89 1 SDG&E collects the relevant energy efficiency charges from CEA’s customers through the PPP nonbypassable charge (“NBC”).90 2 3 In evaluating the feasibility of an ETA portfolio, CEA utilized the calculation 4 methodology set forth in D.14-01-033, as well as SDG&E’s current EE PPP collections 5 from CEA customers, to determine the maximum possible ETA funding available under 6 the status quo (i.e., with SDG&E continuing to serve as a regional PA). CEA’s calculations 7 revealed that under the Commission’s current ETA funding guidance and SDG&E’s 8 current EE PPP collections, CEA’s maximum ETA funding for the entire three-year 9 program period was $588,230. This figure is based on the 4% budgetary “floor” established 10 in D.20-04-007.
11 This existing challenge will be further exacerbated should SDG&E withdraw from 12 regional EE portfolio administration. Specifically, SDG&E’s Application requests an 13 approximately $300 million reduction in the PPP rates to support its energy efficiency portfolio.91 14 Under the current ETA framework and funding calculation, such a reduction 15 would leave CEA (or any CCA in the San Diego region) with a miniscule fraction of 16 funding from an already small pool of available ETA funds. It is further important to note 17 that the substitution of a non-IOU PA to serve as the primary regional PA will not solve 18 for this problem, as the ETA funding calculation is currently based on the IOUs’ EE 19 portfolio budgets.
20 The Commission recently acknowledged that it is “aware that the budget formula 21 for CCAs that elect to administer energy efficiency programs may need to be modified or 89 See id. 90 See A.25-04-014, Prepared Direct Testimony of Alton Kwok, pp. AK-20 – AK-21 (Apr. 25, 2025). 91 Application at 4.
355
31 refined,”92 and is slated to consider such changes in early 2026.93 1 As the Commission plans 2 to consider modifications to the ETA funding calculation in the EE OIR, SDREN and CEA 3 do not offer specific recommendations as to the appropriate changes in this proceeding. 4 However, when the Commission considers changes to the ETA funding calculation, it 5 should consider the unique circumstances presented by SDG&E’s requested withdrawal. 6 In particular, the Commission may need to develop a San Diego-specific approach to ETA 7 funding, or to tie ETA funding to a factor other than IOU portfolio budgets. Developing a 8 solution that solves for the current ETA funding challenges and also SDG&E’s potential 9 withdrawal will better position CCAs in the San Diego region to step in and serve the 10 region’s EE needs.
11 This concludes our testimony.
92 R.25-04-010 at 4; see also, R.25-04-010, Scoping Ruling at 3. 93 See R.25-04-010, Scoping Ruling at 11-12.
356
ATTACHMENT A
357
energycoalition.org
Professional Experience
Education
Cal State University Dominguez Hills, 1983
Master of Public Administration
University of California Los Angeles, 1980
Master of Arts, Latin American Studies;
Master of Arts, Political Science
University of California Berkeley, 1975
Bachelor of Arts, Sociology
Publications
Author and co-author of articles on solar
electric projects, alternative fuel vehicles,
water and energy efficiency, and urban runoff
management practices.
Awards
• J. Robert Fluor Award, 2002
• Heal the Bay Super-Healer Award, 2004
• American Public Works Association
Achievement Award, 2006
CRAIG PERKINS
President and Executive Director The Energy Coalition Irvine, CA President and Executive Director 2008 - Present
The Energy Coalition has been developing sustainable energy solutions for public agencies, communities, and utilities for over fifty years. Our mission is to change the way that people think about and use energy through the design and implementation of innovative programs and initiatives to reduce energy use and decrease greenhouse gas emissions.
City of Santa Monica Santa Monica, CA
Director of Environment & 1993 - 2008
Public Works Department
Directed operations, maintenance, and capital improvement programs for the City’s water, wastewater, stormwater,
and solid waste utilities; managed the design, engineering, construction, and maintenance of City buildings and
infrastructure; managed environmental protection, resource efficiency, alternative fuels, and renewable energy programs; directed development and implementation of the Sustainable City and Climate Action Plans.
Environmental Programs Manager 1991 - 1993
Developed and managed programs for water and energy
efficiency, pollution prevention, hazardous materials
management, recycling, and stormwater/watershed
management. Proposed and implemented new utility rate
structures to increase customer equity, improve service levels, and fund environmental initiatives. Led the creation of the Santa Monica Sustainable City Plan.
Budget Director; 1983 - 1991
Senior Management Analyst
Oversaw development of the City’s operating and capital improvement budgets, performed fiscal and policy analyses for the City Manager and City Council, managed organization development processes, and led efforts to improve the
efficiency and cost-effectiveness of City operations.
UCLA Latin American Center Los Angeles, CA
Research Associate 1981 - 1983
Conducted research on Latin American policy issues and edited specialized publications for the Latin American Center at the University of California, Los Angeles.
Voluntary & Civic Service
• Mayor’s Appointee, City of Los Angeles Stormwater Bond Oversight Committee
• SCAG Global Land Use and Economics (GLUE) Advisory Council member • Board & Executive Committee member, Heal the Bay
• Board & Executive Committee member, The Bay Foundation • Leadership Council member, Los Angeles Regional Climate Collaborative (LARC)
• Board member & Treasurer, Microgrid Resources Coalition • Advisory Board member, Bay Area RAPID: Regional Climate Accelerator 358
energycoalition.org
Professional Experience
Publications
• Beyond the Audit: Making Energy Efficiency Easy and Enticing by Addresessing Project Procurement
• Driving Energy Efficiency in the Public Sector - A Model for Success Education
University of California Santa Barbara, 2003
Bachelor of Arts, Business Economics
Affiliations
• California Energy Efficiency Coordinating
Committee (CAEECC) - 2025 co-chair
and active participant in the following
working groups and trainings:
◦ Evolving CAEECC Working Group
◦ CAEECC Diversity, Equity, and
Inclusion (DEI) Training
◦ Equity Metrics Working Group
◦ EE Portfolio Filing Process Working
Group
◦ Underserved Working Group
• California Efficiency + Demand
Management Council (CEDMC) - Board
Member
• Association of Women Water Energy
& Environment - Board Member &
Membership Committee Chair
• Switch is On Ambassador
• San Clemente Green Ribbon Panel -
Energy Conservation Chair
LAUREL ROTHSCHILD
Vice President The Energy Coalition Irvine, CA
Vice President Jan. 2019 - Present
• Oversees program operations and implementation for over twenty contracts, totaling over $20 million annually
• Supports business development, partnership and client management, and program management organization-wide
• Effectively leads teams to deliver on all contracts while striving for continued innovations and streamlining of operations for cost-effective delivery
• Facilitate stakeholder conversations and partnerships to advance local engagement
• Initiated initial coordination discussions that led to the formation of SoCalREN Regional Partners efforts and CalREN, a collaboration of statewide RENs; Continues to support facilitation and coordination activities for CalREN
• Lead advisor to support the development of the San Diego Regional Energy Network 2024 - 2031 Portfolio Application and Orange County Power Authority’s Elect to Administer application; both applications engaged in community and stakeholder engagement and robust local support that contributed to program design
Director of Energy Programs Dec. 2016 - Dec. 2018
• Oversaw implementation and management of the Southern California Regional Energy Network Public Agency Program (SoCalREN) • Led SoCalREN program to deliver over 30 million kWh in annual savings in 2017
• Oversaw implementation of eleven contracts totaling approximately $10 million annually
Director of Engagement and Nov. 2010 - Nov. 2016
Education, Program Manager
• Designed and supervised engagement activities for the SoCalREN Public Agency program
• Maintained a 100% realization rate for enrollment
• Organized Advisory Committee activities for the SoCalREN program on behalf of the client
• Established successful coordination of program offerings with the IOUs and other stakeholders for the SoCalREN program
• Managed ongoing coordination and communication among stakeholders • Provided oversight of TEC’s local government partnerships (LGP) and Education portfolios
• Directed the completion and closeout of the Palm Desert Demonstration Project
• Successfully designed, marketed, and co-delivered hands-on ENERGY STAR Portfolio Manager Workshops in partnership with local and federal agencies
• Assisted municipalities with energy management planning for municipal facilities, including benchmarking and climate action planning • Initiated Peer to Peer LGP Implementers group
Project Analyst, Manager, Jan. 2007 - Oct. 2010
Coordinator
• Implemented municipal project tracking system recognized as a best practice among LGPs
• Managed implementation of PEAK Plus Demand Response pilot and supported program evaluation
• Coordinated program activities, including community outreach events, promotion of in-house Direct Install program to residential and small businesses
Certifications
• LEED Accredited Professional in Existing
Buildings: Operations + Maintenance,
GBCI, 2009
• Certified Energy Auditor, Association of
Energy Engineers, 2010
• ENERGY STAR Portfolio Manager Trainer
359
energycoalition.org
Accreditations, Credentials,
and Memberships
• LGSEC - Board of Directors - Board Chair
• IEA - Global Observatory on Peer to Peer
Markets
• United Nations - Building Action Coalition
Member
• CalTF - Policy Advisory Committee
• Building Decarbonization Coalition -
Advisory Board
• Passive House Network - Member
• CAEECC - Member; Market Transformation
Working Group
• CEC – Benchmarking Data Alignment Work
Group
• Linux Foundation Energy - Founding
Member
• LBNL – SEED/BEDES Development TF
• NREL - URBANopt Technical Advisory
Member
• ASHRAE TC7.6 Subcommittee on Data
Exchange
• DOE Asset Score – Data Intake Work Group
• CABEC – Member
Professional Experience
Expertise
An internationally recognized subject matter expert on energy policy, federal energy analysis tools, and data standards. Serves as an in-house and industry-wide resource on how data informs decarbonization policy and on-the-ground market transformation.
Education
California State University, Long Beach
Bachelor of Science in Construction Engineering
Management
University of California, San Diego
Bachelor of Science in Management Science
MARC COSTA,
LEED AP BD+C, CGBP, BOC II,
CPHC, CPHT
Director of Policy & Planning
Open Studio Coalition Apr. 2020 - Present
Co-Founder Irvine, CA
• Co-founded a DBA under The Energy Coalition with partners in Vermont, New York and France to commercialize the DOE’s flagship energy modeling software user interface, OpenStudio
• Conducted strategic planning and business plan development to enhance the user interface, expand product features, rebrand, implement language localization and expand the international user base of 70,000 users in 70 countries
The Energy Coalition Jul. 2017 - Present
Director of Policy and Planning Irvine, CA
• Develops regulatory and policy guidance for California-specific matters related to decarbonization, energy efficiency, demand flexibility, renewables, storage, electric vehicles, solar water heating, GHG reductions, and integrated grid resource planning
• Leads the California Energy Commission Statewide Building Energy Benchmarking Program contract and serves as a technical strategist on data-driven outreach and compliance monitoring
• Serves as a subject matter expert to the Department of Energy, Building Technologies Office, Solar Energy Technology Office, and various national labs on strategic roadmap development, grant funding selection, and commercialization of software and standards related to building energy modeling (BEM), Grid-Interconnected Efficient Buildings (GEBs), Model Predictive Controls (MPCs), and Automated Fault Detection and Diagnosis (AFDD).
• Creates and implements data analysis techniques across the company related to data acquisition, cleansing, analysis, spatial statistics, visualization, and forecasting for energy programs
• Leads the implementation of CEC EPIC grants related to energy master planning and renewable energy system sizing and program design for Disadvantaged Communities and Indoor Air Quality contracts • Represents TEC on various industry groups for policy development and regulatory representation, including CAEECC, NMEC, LGSEC, CalTF, CEDMC, and ASHRAE
• Leads local government projects related to benchmarking and audit ordinance development and implementation, currently for Brisbane, California
• Authors peer-reviewed papers, conference proceedings, and presentations on energy master planning
• Founder of the Linux Foundation Energy group on energy education and open-source energy modeling software
Program Manager Irvine, CA
• Policy Team: Generated, commented, submitted, and filed regulatory and legislative comments in CPUC and CEC Proceedings.
• CEEPMS: Managed overall design and implementation of software that matches building permits and rebates
• CAP: Managed budget and technical input on Energy Atlas Tool, database fields, and metrics for analysis
• Project Delivery Team: Assigned Project Manager to San Bernardino to develop streetlighting and mechanical retrofits
• LGSEC To Code Committee: Contributed comments to regulatory proceedings on data, C&S, and Regulatory Matters
• Benchmarking and Ordinances: Served as a subject matter expert to REN cities on Federal resources on policy and tools
• DOE Grant: OpenEfficiency Initiative: With PSD, NREL, Cadmus, Xcel Energy, and SoCalREN to create and deploy data infrastructure for energy management resources
Publications, Presentations & Awards
• UNEP - Outstanding Service to the Buildings
Action Coalition
• ACEEE - From Loading Order to Loading
Lanes: Rethinking the Energy Transition and
Unlocking Smart Local Energy Markets for
Communities of Concern (2024)
• Sustainable Cities and Nature - Net GHG
emissions and air quality outcomes from
different residential building electrification
pathways within a California disadvantaged
community - 2022
• ACEEE - Using Big Data to Assess Energy
System Transitions in Under-resourced
Communities - 2022 Summer Study
• ACEEE - Next Generation Benchmarking:
Leveraging Benchmarking Ordinances for
Decarbonization Planning, 2020 Summer
Study
• ACEEE - A National Framework for Energy
Audit Ordinances, 2016 Summer Study
• ACEEE - Unlocking the Power of Energy
Consumption and Asset Data for Program
and Policy Design, 2014 Summer Study
360
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking for Oversight of
Energy Efficiency Portfolios, Policies,
Programs, and Evaluation.
Rulemaking 25-04-010
(Filed April 24, 2025)
BAY AREA REGIONAL ENERGY NETWORK, INLAND REGIONAL ENERGY
NETWORK, NORTHERN RURAL ENERGY NETWORK, SAN DIEGO REGIONAL
ENERGY NETWORK, SOUTHERN CALIFORNIA REGIONAL ENERGY NETWORK
AND TRI-COUNTY REGIONAL ENERGY NETWORK
REPLY COMMENTS ON STAFF PROPOSAL
Jane Elias
Director, Energy Programs
Association of Bay Area Governments
375 Beale Street, Suite 700
San Francisco, CA 94105
Tel: (415) 778-4428
E-mail: [email protected]
For the Bay Area Regional Energy Network
(“BayREN”)
Casey Dailey
Director of Energy & Environmental
Programs
Western Riverside Council of Governments
3390 University Ave., Suite 200
Riverside, California 92501
Tel: (951) 405-6720
E-mail: [email protected]
For the Inland Regional Energy Network (“I-REN”)
Aisha Cervantes-Cissna
Senior Policy Manager
San Diego Community Power
P.O. Box 12716
San Diego, CA 92101
Tel: (619) 732-4629
E-mail: [email protected]
For the San Diego Regional Energy Network
(“SDREN”)
Patricia Terry
Senior Portfolio Manager
Redwood Coast Energy Authority
633 Third St
Eureka, CA 95501
Tel: (707) 382-2098
Email: [email protected]
For Northern Rural Energy Network
(“NREN”)
361
Lujuana Medina
Environmental Initiatives Division Manager
County of Los Angeles Office of Energy &
Environmental Service
1100 North Eastern Avenue
Los Angeles, CA 90063-3200
Tel: (323) 393-8537
E-mail: [email protected]
For the Southern California Regional Energy
Network (“SoCalREN”)
January 23, 2026
Alejandra Tellez
Deputy Executive Officer
County Executive Office, County of Ventura
800 S. Victoria Avenue, L#1940
Ventura, CA 93009
Tel: (805) 654-3835
E-mail: [email protected]
For the Tri-County Regional Energy Network
(“3C-REN”)
362
i
TABLE OF CONTENTS
I. EXECUTIVE SUMMARY ................................................................................................... 2 II. REPLIES TO RESPONSES TO QUESTIONS FOR STAKEHOLDERS ........................ 4 A. Equity ............................................................................................................................... 4
1. What other actions should this staff proposal take to encourage electrification among equity customers? ...................................................................................................... 4 a. The Commission Should Refine the PCT and TRC Tests to Account for Non-Energy Benefits and Needs of Equity and HTR Customers. ............................. 5 b. The Commission Should Exclude One-Time Costs of Electrification Enabling Infrastructure from VEA Cost-Effectiveness Tests for the Equity Segment and Equity Customers. .............................................................................................. 6 B. Fuel Substitution Infrastructure Costs .............................................................................. 7
1. What existing data sources should the CPUC use to assess the avoided capital and operating costs of not using a gas measure for the purpose of assessing the Participant Cost for gas and possible VEA measure permutations? ........................................... 7 C. Fuel Substitution Potential Estimated Bill Impacts .......................................................... 8
1. What level of granularity should the CPUC use for including potential bill impacts related to fuel substitution in assessing cost effectiveness for those measures? ....... 8 D. Refrigerant Leakage Detection and Mitigation, and Low-GWP Refrigerant Programs .. 9
1. Are PAs the appropriate implementors of refrigerant leakage detection, reclamation/recycling programs? If not, who is? ...................................................... 9 a. PAs are the Appropriate Implementers of Refrigerant Programs Proposed the Staff Proposal. .................................................................................................... 9 b. The Need for a Pilot Phase for Refrigerant Management Programs Should Be Determined by the Applicable PA. .................................................................. 11
2. How should pilot programs use EE incentives to encourage refrigerant recycling and the use of low-GWP refrigerants be set up? ............................................................ 12
3. Should contractors be offered incentives for documenting refrigerant reclamation, how much should be offered or how should a documentation incentive be determined? ............................................................................................................. 14 E. VEA Cost Effectiveness ................................................................................................. 15
1. Should VEA measures use TRC or PCT for evaluating cost effectiveness? .......... 15
2. Should other cost-effectiveness criteria be considered? ......................................... 16 III. CONCLUSION .................................................................................................................... 18 363
1 BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking for Oversight of
Energy Efficiency Portfolios, Policies,
Programs, and Evaluation.
Rulemaking 25-04-010
(Filed April 24, 2025)
BAY AREA REGIONAL ENERGY NETWORK, INLAND REGIONAL ENERGY
NETWORK, NORTHERN RURAL ENERGY NETWORK, SAN DIEGO REGIONAL
ENERGY NETWORK, SOUTHERN CALIFORNIA REGIONAL ENERGY NETWORK
AND TRI-COUNTY REGIONAL ENERGY NETWORK
REPLY COMMENTS ON STAFF PROPOSAL
Pursuant to the December 1, 2025 Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (“Ruling”) and the December 19, 2025 Email Ruling Granting Extension of Time to File Comments to December 1, 2025 Ruling, the Bay Area Regional Energy Network (“BayREN”),1 Inland Regional Energy Network (“I-REN”),2 Northern Rural Energy Network (“NREN”),3 San Diego Regional Energy Network (“SDREN”),4 Southern California Regional 1 BayREN serves customers in the nine-county Bay Area region, a region that serves over 7.5 million residents and incorporates urban, suburban and rural populations. BayREN delivers its regional programs solely within Pacific Gas and Electric Company’s (“PG&E”) 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 cover the residential, commercial and public sectors as well as codes and standards.
2 I-REN is a coalition of three councils of government – Western Riverside Council of Governments, the Coachella Valley Association of Governments, and the San Bernardino Council of Governments - encompassing Riverside and San Bernardino Counties, and all their respective jurisdictions within the region. These organizations have joined to establish locally administered, designed, and delivered energy efficiency programs in alignment with the Commission’s goals and objectives. 3 The Northern California Rural Regional Energy Network (also known as Northern Rural Energy Network or NREN) is a partnership between the Lake Area Planning Council, the Mendocino Council of Governments, the Redwood Coast Energy Authority, and Sierra Business Council and provides energy efficiency and electrification programs to 17 counties in Northern California and the Sierra Nevada.
NREN’s programs are designed to serve hard-to-reach and underserved rural customers using local resources within the region to achieve California’s energy efficiency and decarbonization goals. 4 SDREN is a program of San Diego Community Power, a Community Choice Aggregator (“CCA”) and the County of San Diego and operates solely within San Diego Gas & Electric’s (“SDG&E”) service area. 364
2 Energy Network (“SoCalREN”)5 and Tri-County Regional Energy Network (“3C-REN”6 and, together, the “Joint RENs”) respectfully submit the following reply comments on the draft Energy Efficiency Natural Gas Incentive Phase-Out Staff Proposal, attached as Attachment 1 to the Ruling (the “Staff Proposal”).
I. EXECUTIVE SUMMARY
As stated in opening comments, the Joint RENs support the policy goal animating the draft Viable Electric Alternative (“VEA”) Staff Proposal to shift ratepayer funding away from gas efficiency measures and focus incentives on California’s electrification goals. The intention behind the proposal is aligned with state law requiring greenhouse gas emission reduction and the state’s recognition of the significant public health benefits of electrification.7 Yet, the Joint RENs share in the concerns raised by numerous parties regarding the challenges of applying the VEA framework set forth in the Staff Proposal in the context of the Equity segment, equity customers and Hard-to-Reach (“HTR”) customers and sites. Further refinement is needed in this regard.
Along with the Joint RENs, numerous parties raised concerns in their opening comments regarding Staff’s proposed adoption of the Participant Cost Test (“PCT”), and, in the alternative, 5 SoCalREN is a CPUC authorized energy efficiency Program Administrator which serves 13 counties across central and southern California. As a regional energy network, SoCalREN provides a wide variety of energy efficiency services to support energy savings for residential, businesses, agriculture, and public agency customers.
6 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 investor-owned utilities (“IOUs”) in its region. 7 Staff Proposal at 3 (citing Assembly Bill 3232 (Stats. 2018, Ch. 373)); Senate Bill 1279 (Muratsuchi, 2022); Sierra Club Opening Comments on Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) at 5 (“Sierra Club Opening Comments”) (citing California Public Utilities Commission (“Commission” or “CPUC”), California Air Resources Board (“CARB”) and California Energy Commission (“CEC”) 2024 Joint Agency Report at 17; CARB Resolution 20-32 (Nov. 19, 2020) at 1-3, available at https://ww2.arb.ca.gov/sites/default/files/barcu/board/res/2020/res20-32.pdf). 365
3 the utilization of the Total Resource Cost (“TRC”) test, as the means of determining cost-effectiveness when identifying whether a Viable Electric Alternative (“VEA”) exists for a gas energy efficiency (“EE”) measure. Many parties advocated for improved incorporation of non-energy benefits (“NEB”) and social costs, and the broader term known as non-energy impacts (“NEI”), into the cost-effectiveness tests.8 SoCalGas stood alone in its opposition to the inclusion of the adverse impacts of indoor air pollution from gas appliances in the VEA cost-effectiveness determination.
Several parties proposed means of addressing the one-time infrastructure and installation costs of electrification enabling or readiness measures that support several future fuel substitution measures within a building, such as service upgrades, panel upgrades, electrical rewiring costs and additional permitting costs. As stated in their opening comments, the Joint RENs strongly recommend excluding these costs from the VEA cost-effectiveness test altogether for the Equity segment and equity customers.
With respect to the refrigerant leakage detection, reclamation and recycling pilots proposed in the Staff Proposal, numerous parties’ opening comments supported the Joint RENs’ position that EE Program Administrators (“PA”) are well-positioned as implementers of such refrigerant 8 Sierra Club Opening Comments at 11-16, 26-30; Opening Comments of Peninsula Clean Energy Authority on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“PCE Opening Comments”) at 4; Central California Rural Regional Energy Network Opening Comments on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“CCR REN Opening Comments”) at 3-4; Opening Comments of Cohen Ventures, Inc. Dba Energy Solutions on Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) on behalf of the TECH Initiative Team (“TECH Initiative Team Opening Comments”) at 7-8.
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4 programs.9 The Joint RENs disagree with and respond to SoCalGas and SDG&E’s opposition to the role of PAs in implementing such pilots, below. Several parties noted that there may not be a need for new refrigerant management pilots in light of existing programs in California. In response, the Joint RENs suggest that a pilot phase may not be needed within some PAs, as existing refrigerant programs are already carrying out refrigerant leakage reduction, recovery, training, responsible disposal. At the same time, some PAs may determine to pilot aspects of refrigerant management based on the status of such programs in their service areas. A refrigerant management pilot phase should not be required, but neither should it be precluded, as determined by the applicable PA.
The Joint RENs replies to other parties’ opening comments are set forth in Section II below, organized in response to the specific questions posed in Section 4 of the Staff Proposal.
II. REPLIES TO RESPONSES TO QUESTIONS FOR STAKEHOLDERS
A. Equity
1. What other actions should this staff proposal take to encourage electrification among equity customers?
The Joint RENs concur with many of the opening comments recognizing the challenges to electrification in the Equity segment and for equity customers, as well as the additional benefits of electrification that particularly flow to disadvantaged communities (“DAC”) that are inadequately quantified in the current cost effectiveness tests. For example, MCE discussed the disproportionate 9 Comments of Southern California Edison Company (U 338-E) on Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“SCE Opening Comments”) at 17-18; Opening Comments of Small Business Utility Advocates on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“SBUA Opening Comments”) at 6-7; Opening Comments of Marin Clean Energy on Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“MCE Opening Comments”) at 7-9; CCR REN Opening Comments at 5-6.
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5 health impacts from natural gas appliances, significantly higher energy burdens, greater barriers to electrification and historic underservice in EE programs faced by equity customers.10 Aligned with and in response to these comments, the Joint RENs reiterate that the Commission should refine both the PCT and the TRC to account for such benefits, exclude the one-time costs of electrification enabling infrastructure from VEA cost effectiveness tests and authorize new incentives to address the specific needs and challenges for the Equity segment and equity and HTR customers. This adjustment is consistent with Section 2.1.4.2 of the Order Instituting Rulemaking in this proceeding, which addresses a “continual improvement” process for cost-effectiveness policies and the application of such policies to energy efficiency portfolios.11 a. The Commission Should Refine the PCT and TRC Tests to Account for Non-Energy Benefits and Needs of Equity and HTR Customers.
As the Joint RENs argued in opening comments, barriers to electrification in equity communities should be taken into account for VEA measure screening, and neither the PCT nor the TRC do so adequately.12 The TECH Initiative Team described several of the co-benefits of electrification and fuel substitution for equity customers, such as extreme heat resilience offered by heat pumps and indoor air quality impacts, that are not fully valued in the PCT.13 The CEC’s Order Instituting Informational Proceeding on Non-energy Benefits and Social Costs (Docket No. 24-OIIP-03) is seeking to more comprehensively assess costs and benefits of distributed energy 10 MCE Opening Comments at 3 (citations omitted).
11 Order Instituting Rulemaking (Apr. 29, 2025) at 6 (“As part of a process of continual improvement of energy efficiency programs, adjustments may be needed to cost-effectiveness policies and their application within energy efficiency portfolios and programs.”).
12 Joint RENs Opening Comments at 4-11, 15-16, 26-32.
13 TECH Initiative Team Opening Comments at 4.
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6 resources and EE, with a focus on equity.14 The CEC’s NEI study in that proceeding will eventually enable the quantification of NEIs in Commission EE cost-effectiveness determinations. In the meantime, the Sierra Club’s recommendation for adders to the PCT or TRC to address NEBs15 would be an administratively-efficient stop-gap measure, which the Joint RENs support. Any such NEB adders should be compatible with PA reporting mechanisms, so that they can be accounted for in the TSB test as well.
b. The Commission Should Exclude One-Time Costs of Electrification Enabling Infrastructure from VEA Cost-Effectiveness Tests for the Equity Segment and Equity Customers.
Numerous parties addressed the issue of electrification-enabling infrastructure upgrade costs in opening comments. The Joint RENs’ opening comments provided examples of such “one-time” costs of electrification, such as service upgrades, panel upgrades, electrical rewiring costs, and additional permitting costs at the building-level that enable numerous present and future electric load.16 The Joint RENs agree with TURN that the Commission should establish additional policies to reduce barriers to electrification for low-income Californians, including up-front costs,17 and also concur in MCE’s comment on the need to support “electrification readiness” measures across portfolios.18
SoCalGas criticized the Staff Proposal’s proposed use of weighted averages to address panel upgrades and electrification-enabling infrastructure costs, arguing that customers with older 14 Joint RENs Opening Comments at 9.
15 Sierra Club Opening Comments at 29; see also CCR REN Opening Comments at 7-8 (recommending an NEB adder to the TRC and TSB).
16 Joint RENs Opening Comments at 10.
17 TURN Opening Comments at 15.
18 MCE Opening Comments at 3-7; 6-7.
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7 homes and low-income customers would be disproportionately impacted.19 Instead, to better address the particular needs of equity customers with respect to electrification readiness, the Joint RENs reiterate our point in opening comments that the one-time electrification enabling infrastructure upgrade costs should be excluded from VEA cost-effectiveness tests for the Equity segment and equity customers.20 CCR REN similarly asserted that “Electric Ready Infrastructure” should be “exempted from accruing to the TRC.”21 The Joint RENs also agree with SDG&E that EE programs should assist customers in avoiding panel upgrades and service upsizing through power-efficient appliances, smart panels and circuit splitters and pausers, but strongly disagree that the costs of such measures should be included in cost-effectiveness calculations for individual measures for VEA screening purposes.22
B. Fuel Substitution Infrastructure Costs
1. What existing data sources should the CPUC use to assess the avoided capital and operating costs of not using a gas measure for the purpose of assessing the Participant Cost for gas and possible VEA measure permutations? The Joint RENs agree with the Sierra Club that the Commission should incorporate the CEC’s electric and gas end-use rate forecasts to assess avoided costs of not using a gas measure into VEA assessment.23 The Joint RENs strongly agree that the significant future increases in gas 19 Southern California Gas Company’s (U 904 G) Comments to Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“SoCalGas Opening Comments”) at 8 (citing Section 3.3 of the Staff Proposal).
20 Joint RENs Opening Comments at 9-11, 15-16.
21 CCR REN Opening Comments at 3.
22 See Opening Comments of San Diego Gas & Electric Company (U 902 M) on Staff Proposal (Jan. 13, 2026) (“SDG&E Opening Comments”) at 4. The Joint RENs are not opposed to including the costs of meter socket adapters in individual measure VEA cost-effectiveness calculations, however. 23 Sierra Club Opening Comments at 24.
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8 (and electric) rates must be considered in these determinations.24 As the Joint RENs pointed out in their opening comments, such steep increases are particularly significant in the context of equity customers facing systematically higher energy burdens and greater exposure to future rate volatility.25
C. Fuel Substitution Potential Estimated Bill Impacts
1. What level of granularity should the CPUC use for including potential bill impacts related to fuel substitution in assessing cost effectiveness for those measures?
The Joint RENs also agree with Sierra Club that the analysis of potential bill impacts relating to fuel substitution should incorporate CEC gas (and electric) rate forecasts.26 In addition, the Joint RENs reiterate their point in opening comments that before the Commission can begin to consider the level of granularity of data to analyze bill impacts of fuel substitution measures, an accurate mechanism for the calculation of such bill impacts is first required.27 RENs currently lack access to the data necessary to such bill impacts, and any data that is provided by IOUs is not done in a timely manner.28 Once all PAs have the capability to estimate bill impacts in the California Energy Data and Reporting System (“CEDARS”) the Commission should then tackle questions of the proper granularity of such data.
24 Joint RENs Opening Comments at 11, Figure 1 (CEC Fossil Gas End-Use Rate Forecast through 2049) and 12, Figure 2 (PG&E Program Year 2024 ESA Annual Report – Energy Price Forecasts through 2048). 25 Id. at 13-14.
26 Sierra Club Opening Comments at 26; see also Opening Comments of Pacific Gas and Electric Company (U 39 M) on Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“PG&E Opening Comments”) at 9 (arguing that Energy Division Staff should provide the underlying analyses and assumptions, including gas rate forecast details, for the PCT). 27 Joint RENs Opening Comments at 17.
28 Id. at 17-18.
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9 D. Refrigerant Leakage Detection and Mitigation, and Low-GWP Refrigerant Programs
1. Are PAs the appropriate implementors of refrigerant leakage detection, reclamation/recycling programs? If not, who is?
a. PAs are the Appropriate Implementers of Refrigerant Programs Proposed the Staff Proposal.
Numerous parties agree with the Joint RENs that PAs are the appropriate implementers of refrigerant leakage detection, reclamation and recycling programs in California. As SCE aptly pointed out, “PAs are well-positioned to implement these efforts given synergies with existing programs that already facilitate equipment exchanges.”29 MCE observed that “PAs of EE programs with low-[Global Warming Potential (“GWP”)] and refrigerant related measures are well positioned to document refrigerant leaks, reclamation and recycling.”30 The Joint RENs disagree with points raised by SDG&E and SoCalGas opposing the role of PAs as implementers of such programs.31
As described in the Joint RENs’ opening comments, several PAs are already implementing refrigerant management programs that are highly relevant to the Staff Proposal’s proposed pilots, and already have significant expertise.32 The Joint RENs described in detail the BayREN Refrigerant Replacement (“BRRR”) Program’s innovative and equity-focused work providing financial and technical assistance to small and HTR businesses, including incentives for 29 SCE Opening Comments at 17; see also SBUA Opening Comments at 6; CCR REN Opening Comments at 5.
30 MCE Opening Comments at 8.
31 See SDG&E Opening Comments at 6-8; SoCalGas Opening Comments at 11. 32 See PG&E Opening Comments at 7-8 (arguing that PAs should implement such pilots if relevant to EE PA programs and PAs can ensure that implementers have the appropriate expertise); Joint RENs Opening Comments at 19-26; MCE Opening Comments at 7-8.
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10 identification and repair of refrigerant leaks, high GWP replacement, gas exchanges and tune-ups.33 BRRR also provides financial support for transportation and recycling/reclamation of refrigerants.34 As the Joint RENs argued:
With BRRR’s experience and existing implementation infrastructure in place, expanding refrigerant management efforts to include enhanced leak detection and increased awareness of the importance of refrigerant recycling is both practical and efficient. This integrated approach would increase public benefits, streamline program deployment, and maximize the overall impact of proactive refrigerant management.35
In fact, SBUA pointed to BayREN’s existing BRRR program for high-GWP refrigerant replacement as helpful and useful.36 Similarly, MCE described how it is incorporating low-GWP refrigerants in its EE portfolio, and its interest in incorporating refrigerant leak, reclamation and recycling measures in its 2028 EE Business Plan application.37 In response to SDG&E’s rationale for opposing this role for PAs, the Joint RENs assert that, for PAs already running refrigerant programs, there would not be “a significant amount of prework”38 and these existing programs could readily be leveraged. SDG&E’s comment that PAs should not administer these pilots because it would be a challenge for the Commission to leverage the Commission’s Refrigerant Avoided Cost Calculator (“RACC”)39 is also inapt: BayREN’s BRRR program is already utilizing the RACC to estimate first-year and lifecycle greenhouse gas (“GHG”) emissions avoided (metric tons of carbon dioxide equivalent or MTCO2e) as a result of 33 Joint RENs Opening Comments at 19-20.
34 Id. at 20.
35 Id. at 22.
36 SBUA Opening Comments at 6.
37 MCE Opening Comments at 7, 8 (citing MCE’s 2024 EE Business Plan and Portfolio Plan Application, Exhibit 2, p. 1-16).
38 Cf. SDG&E Opening Comments at 8.
39 Id.
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11 refrigerant leak repair and components replacement. For modeling purposes, the latest RACC assumes an annual refrigerant leakage rate of approximately 5.3%. BayREN’s BRRR uses this default assumption to estimate annual refrigerant losses from leaks, which are then multiplied by the system’s refrigerant charge and its GWP to calculate lifecycle emissions and associated costs.
As SoCalGas correctly conceded, PAs may be suitable implementors because they “have existing relationships with contractors and installers.”40 The Joint RENs described BayREN BRRR’s relationships with licensed refrigeration contractors, which it leverages to assist small businesses such as corner stores and community kitchens.41 The Joint RENs opening comments also described BayREN BRRR’s assignment of an environmental specialist to each participating business to provide a hands-on approach, its relationships with community organizations, and the ways in which BRRR staff provide education to participating businesses to promote long-term refrigerant management practices.42
In short, PAs, particularly those with existing refrigerant programs, are ideally suited to administer the refrigerant pilots proposed in the Staff Proposal. b. The Need for a Pilot Phase for Refrigerant Management Programs Should Be Determined by the Applicable PA.
A number of parties’ opening comments on the Staff Proposal questioned whether new refrigerant management pilots are needed, in light of such existing REN refrigerant programs.
PAO argued that doing so would be duplicative of existing programs and that, instead, the 40 SoCalGas Opening Comments at 11.
41 Joint RENs Opening Comments at 21.
42 Id.
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12 Commission should incorporate refrigerant training in existing programs that implement EE measures with refrigerants.43
The Joint RENs generally agree with SBUA that each PA has the option to determine whether it would be efficient and effective for it to implement a pilot or carry out the refrigerant management activities in the Staff Proposal through a program.44 The Joint RENs note that, as a general rule, PAs already have the choice as to which programs or pilots to offer. A pilot phase may not be needed within some PAs, as existing refrigerant programs, such as BayREN’s BRRR Program, are already carrying out refrigerant leakage reduction, recovery, training, responsible disposal. At the same time, other PAs may determine to pilot aspects of refrigerant management.
A pilot phase should not be required, but neither should it be precluded, as determined by the applicable PA and their communities’ needs.
2. How should pilot programs use EE incentives to encourage refrigerant recycling and the use of low-GWP refrigerants be set up?
The Joint RENs are aligned with SCE’s support for “leveraging synergies between existing EE programs and refrigerant recycling initiatives.”45 For example, SCE suggests that EE incentives for commercial grocery refrigeration could be increased when reclamation is also implemented.46 In fact, BayREN’s existing BRRR Program already requires at least one EE measure alongside refrigerant management projects (e.g., improved door gaskets and closers, high-efficiency fan 43 Comments of the Public Advocates Office on Administrative Law Judge’s Ruling Providing Notice and Opportunity to Comment on Staff Proposal for Policy on Natural Gas Energy Efficiency Incentives (Jan. 13, 2026) (“PAO Opening Comments”) at 9.
44 See SBUA Opening Comments at 6.
45 SCE Opening Comments at 18.
46 Id.
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13 motors and demand response capabilities).47 BRRR encourages refrigerant recycling by allowing reclamation as an incentive-eligible measure.48 From its experience working directly with businesses, the BRRR Program has observed how incentivizing low- and no-GWP refrigerants has secondary benefits that can “unlock broader efficiency opportunities and maximize the overall value of public investments.”49
But, the Joint RENs disagree with SDG&E and SoCalGas that the Staff Proposal’s proposed refrigerant management pilots should not be ratepayer funded. In response to SoCalGas’s argument that, because contractors are required by law to collect and recycle refrigerants, enforcement, rather than incentives, should be emphasized by the Staff Proposal,50 the Joint RENs highlight that compliance with the law should not be assumed. As an analogue, regional Codes and Standards programs are offered by PAs throughout the state (including SDREN and BayREN).
These regional programs play an important role in closing the compliance gap. As the Joint RENs noted in opening comments, code compliance rates are as low as 10-30%.51 The Joint RENs are not aware of a gap analysis that pertains specifically to contractor compliance with refrigerant recycling; however, it would be prudent for the Commission to conduct a study to determine compliance prior to precluding incentives.
In opening comments, PCE explained its support for additional incentives for deployment of low-GWP measures:
47 Joint RENs Opening Comments at 25.
48 Id. at 23.
49 Id. at 25.
50 SoCalGas Opening Comments at 11.
51 Joint RENs Opening Comments at 27 (citing CEC Docket 24-BDST-05, 2025 Energy Code Compliance Initiatives Staff Workshop 1 Slides (Jan. 27, 2025) at slide 13, available at:
https://efiling.energy.ca.gov/GetDocument.aspx?tn=261312&DocumentContentId=97689). 376
14 Many low-GWP refrigerant measures deliver significant greenhouse gas reduction benefits but may not produce incremental energy or peak demand savings and therefore face structural barriers under existing cost-effectiveness requirements.
Allowing incentives for low-GWP refrigerant measures independent of energy savings, for instance, would complement the refrigerant pilots conceived in the Staff Proposal by addressing refrigerant emissions across the full equipment lifecycle.52
The Joint RENs also discussed compliance barriers faced by small and HTR businesses, such as lack of awareness on the part of decision-makers, costs, engineering requirements and lack of capital.53 “Without generous incentives, typically covering over 70% of project costs, small and hard-to-reach businesses will continue to face knowledge, space, and cost barriers that limit adoption of environmentally friendly refrigerants, even if regulations require them to.”54 In sum, incentives can be a critical component of effective refrigerant management policy to reduce GHG emissions.
3. Should contractors be offered incentives for documenting refrigerant reclamation, how much should be offered or how should a documentation incentive be determined?
In opening comments, parties disagreed with respect to whether incentives should be provided specifically for the documentation of refrigerant reclamations. In reply, the Joint RENs propose that each PA should retain flexibility with respect to pilot or program structure, as it deems appropriate for its specific customer base and program. 52 PCE Opening Comments at 10.
53 Joint RENs Opening Comments at 24-25.
54 Id. at 24.
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15 E. VEA Cost Effectiveness
1. Should VEA measures use TRC or PCT for evaluating cost effectiveness? Numerous parties’ opening comments, including those of the Joint RENs, critiqued both the PCT and TRC for their failure to adequately capture the NEBs of electrification measures, such as reducing indoor air pollution, and supported the inclusion of such benefits in the VEA cost-effectiveness analysis. PCE noted that the TRC imposes structural biases against electrification by imbedding all costs, but not including NEBs.55 The TECH Initiative team described co-benefits such as additional cooling for DAC customers disproportionately residing in hot/dry climates and indoor air quality which are not incorporated into the PCT.56 The Sierra Club also discussed “meaningful” participant benefits not currently accounted for in the PCT, such as indoor air quality and safety benefits associated with fuel substitution.57 SoCalGas alone opposed the inclusion of indoor air quality as part of cost effectiveness assessment.58 The Joint RENs disagree with SDG&E, PG&E and PAO that either the PCT or the TRC should be used without significant further refinement with respect to the Equity segment and HTR customers.59 This further refinement provides an opportunity to test and inform strategies in the scope of this proceeding 55 PCE Opening Comments at 3-4.
56 TECH Initiative Team Comments at 4, 14.
57 Sierra Club Opening Comments at 29.
58 SoCalGas Opening Comments at 22-26.
59 See SDG&E Opening Comments at 5, 10 (supporting TRC); PG&E Opening Comments at 9 (supporting PCT in this context); PAO Opening Comments at 2-3.
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16 with respect to the application of cost-effectiveness to the EE portfolio, and the ability to increase benefits and investment in equity and HTR populations where VEAs can advance affordability.
As some parties noted, the Staff Proposal recommends that the Commission “consider the health benefits for participants of reduced indoor air pollution due to electrifying gas stoves as a part of assessing ratepayer benefit comparison for VEA (Section 3.7) for gas and induction stoves.”60 But the proposal is incomplete and doesn’t sufficiently address such benefits, given the limitations of the PCT (and the TRC).
In response to PG&E’s argument that, while it supports PCT for the VEA determination context, the TRC is the primary test for the Resource Acquisition segment, inclusive of fuel substitution measures, and R.22-11-013 is the primary forum for discussions of cost effectiveness tests for EE portfolios overall,61 the Joint RENs wish to clarify that Total System Benefit (“TSB”) is actually the “North Star” applicable to REN authorizations and evaluation of the Potential and Goals Study. RENs are not subject to the TRC.62
2. Should other cost-effectiveness criteria be considered? Relevant to these equity-related critiques of the Staff Proposal’s use of the PCT (or TRC) to determine cost effectiveness for VEA determination, parties proposed several other criteria to be considered. SBUA suggested the Societal Cost Test (“SCT”), including a social discount rate, be considered for informational purposes to supplement the PCT.63 The Joint RENs agree that the 60 Staff Proposal at 19.
61 PG&E Opening Comments at 9 (citing D.21-05-031 Ordering Paragraph (“OP”) 3). 62 D.21-05-031, Assessment of Energy Efficiency Potential and Goals and Modification of Portfolio Approval and Oversight Process (May 20, 2021) at 21, Conclusion of Law 8, OPs 1, 2; see also R.22-11- 013, Association of Bay Area Governments and County of Ventura Comments on ALJ Ruling (May 12, 2025) at 8-9.
63 SBUA Opening Comments at 7-8.
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17 SCT has value for informational purposes because it is more comprehensive, equitable and inclusive. But, as pointed out in the Joint RENs’ opening comments, the SCT also is still in need of refinements.64
As noted above, the Sierra Club recommended an adder to the PCT to better address NEBs.
The Joint RENs support this approach as an interim step before a more comprehensive means of addressing such benefits and social costs of gas and electrification emerges through the work of the CEC’s Order Instituting Informational Proceeding on Non-energy Benefits and Social Costs (Docket No. 24-OIIP-03).65 It is critical for the Commission to develop an equity-appropriate refinement or companion metric that adequately adjusts for known code-compliance gaps, non-energy barriers, and structural inequities that materially influence customer costs and benefits for the Equity segment, equity customers and HTR customers. By acknowledging the barriers and increased PA effort needed to provide EE programs to equity and HTR customers, and then creating prohibitive policies that reduce access to VEAs would be counterproductive to the objective of serving such populations.
Finally, the Joint RENs agree that, at a very bare minimum, NEIs should be tracked in eTRM.66 Fuel substitution measure packages should be enabled to track such costs and benefits by working with CalTF to create a field in the eTRM for tracking equity and HTR VEAs. The Joint RENs recommend the addition of placeholder fields in the eTRM and CEDARS as outlined in Section 3.4 of the Staff Proposal, and an update to Section 3.8 of the Staff Proposal to direct the eTRM to include a measure permutation field for non-energy impacts.67 64 Joint RENs Opening Comments at 30.
65 Id.
66 See Staff Proposal at 32.
67 Joint RENs Opening Comments at 29.
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18 III. CONCLUSION
The Joint RENs thank the Commission for the opportunity to reply to opening comments on the Staff Proposal. The Joint RENs urge the Commission to revise the Staff Proposal to align with California law and policy supporting and prioritizing decarbonization in disadvantaged communities, and taking into the account the costs and needs of such action in an equitable and inclusive manner. The Joint RENs also strongly support the implementation of refrigerant management by PAs, including RENs.
Respectfully submitted,
/s/ Jane Elias
Jane Elias
Director, Energy Programs
Association of Bay Area Governments
375 Beale Street, Suite 700
San Francisco, CA 94105
Tel: (415) 778-4428
E-mail: [email protected]
For the Bay Area Regional Energy Network
(“BayREN”)
/s/ Casey Dailey
Casey Dailey
Director of Energy & Environmental
Programs
Western Riverside Council of Governments
3390 University Ave., Suite 200
Riverside, California 92501
Office: (951) 405-6720
E-mail: [email protected]
For the Inland Regional Energy Network (“I-REN”)
/s/ Aisha Cervantes-Cissna
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]
For San Diego Regional Energy Network
(“SDREN”)
/s/ Patricia Terry
Patricia Terry
Senior Portfolio Manager
Redwood Coast Energy Authority
633 Third St
Eureka, CA 95501
Tel: (707) 382-2098
Email: [email protected]
For Northern Rural Energy Network
(“NREN”)
381
19 /s/ Lujuana Medina
Lujuana Medina
Environmental Initiatives Division Manager
County of Los Angeles Office of Energy &
Environmental Service
1100 North Eastern Avenue
Los Angeles, CA 90063-3200
Tel: (323) 393-8537
E-mail: [email protected]
For the Southern California Regional Energy
Network (“SoCalREN”)
/s/ Alejandra Tellez
Alejandra Tellez
Deputy Executive Officer
County Executive Office, County of Ventura
800 S. Victoria Avenue, L#1940
Ventura, CA 93009
Tel: (805) 654-3835
E-mail: [email protected]
For the Tri-County Regional Energy Network
(“3C-REN”)
January 23, 2026
382
ITEM 21
ATTACHMENT C
383
January 2026
Electricity bills in California have been rising due to challenging market conditions, outdated policies, and limited flexibility in how energy and capacity are traded. Families and businesses are feeling the impact. Lawmakers and regulators need practical, consumer-focused solutions that bring down costs while maintaining reliability. These two proposals by CalCCA are vehicles for achieving those aims.
1. Improving PCIA Transparency
The Power Charge Indifference Adjustment (PCIA) is a fee designed to ensure customers who leave utility generation service (like a Community Choice Aggregator) pay their fair share of legacy power costs. But over the years of implementing the PCIA, there has been no consistent standard for what data must be made available to the CCAs in California Public Utilities Commission (CPUC) rate proceedings where the PCIA is set.
CalCCA’s Proposal
CalCCA is proposing to bring transparency to the way the PCIA is calculated. Today, CCAs and their customers must pay this charge but often lack access to the data, assumptions, and methods used to set it. This inconsistency creates disputes, inefficiencies, and unexpected rate impacts. More specifically:
• Disclosures vary by utility and by Commission proceeding, resulting in repeated fights between CCAs and the IOUs over data access and increased administrative inefficiencies as the CPUC resolves the issue on a case-by-case basis.
• Utilities make mistakes. For example, PG&E recently identified an accounting error that would have cost CCA customers
$217 million.
• In an ongoing PCIA rulemaking the Commission withheld information on the rate impacts of the proposed change and continues to withhold information even after multiple Public Records Act requests.
Without adequate transparency, CCAs are unable to verify the accuracy of the PCIA charges that their customers must pay and cannot confidently forecast rates – both of which are needed to protect customers from unexpected rate increases. CalCCA proposes amending the Public Utilities Code to require the CPUC and Investor-Owned Utilities (IOUs) to disclose all data used to calculate PCIA costs, including cost inputs, forecasting assumptions, and methodologies. Sensitive information would remain protected through Commission-approved nondisclosure agreements.
Why This Matters
Greater transparency allows CCAs to better forecast costs and shield customers from sudden rate swings. It reduces repeated fights over information, improves regulatory efficiency, and encourages utilities to verify calculations since the underlying data would be open to review. Most of this information already exists, so costs are minimal, while the benefits for rate stability, accountability, and consumer confidence are substantial. This proposal strengthens confidence that customers pay their fair share — and not more. For more on the PCIA go to: https://cal-cca.org/pcia/.
Affordability Solutions
384
January 2026
2. Improving RA Transactability
California’s Resource Adequacy (RA) program ensures there is enough electricity supply to meet customer demand. With the recent transition to the Slice-of-Day (SOD) framework, load-serving entities (LSEs), including CCAs, must show resources sufficient to meet load obligations in each hour rather than monthly. While this aligns resources more precisely with load, under current rules LSEs are restricted to buying or selling RA products for the whole month even though obligations are unique to each hour.
This mismatch means LSEs must purchase more RA than they need to meet their obligations, creating artificial market scarcity and unnecessarily driving up RA demand (and prices). It’s akin to having to buy a crate of oranges when you only need a few slices. These unnecessary costs fall directly on California ratepayers, totaling tens of millions of dollars annually.
CalCCA’s Proposal
CalCCA is proposing reforms that would improve California’s RA trading program by allowing LSEs to transact RA load obligations on an hourly basis to align with the new slice-of-day RA program. Benefits of CalCCA’s RA trading proposal include:
• LSEs with excess resources in one hour could trade with LSEs that are short, reducing the need to purchase additional RA.
• In 2025, hourly trading could have lowered RA costs for consumers by avoiding $105 million in excess RA purchases for summer 2025 and potentially saving an additional $77 million annually. • Trades can be executed bilaterally with existing RA tracking tools, making the system administratively simple while maintaining each LSE’s full responsibility to meet obligations.
These changes make RA more flexible and efficient without requiring new generation infrastructure.
Why This Matters
At a time with rapidly rising costs in the electricity sector, policy makers should provide LSEs maximum flexibility in how they contribute their fair share to keep the overall system reliable. Enabling hourly load obligation trading:
• promotes affordability by reducing artificial RA scarcity • is administratively simple in that LSEs can document bilateral trades using existing RA showing tools with the CPUC
• maintains LSE responsibility by creating a new procurement product rather than offering relief from meeting existing requirements
Today’s RA rules make it difficult for CCAs to allocate resources efficiently, resulting in unnecessary costs and administrative hurdles. By allowing hourly transactions, CCAs can better match supply to local demand, reduce over-procurement, and protect customers from inflated electricity costs. The system becomes more transparent, predictable, and fair. These reforms could save tens of millions of dollars each year while maintaining reliability and supporting California’s clean energy goals. For more on CalCCA’s proposal go to: cal-cca.org/ra-transactability/. 385
ITEM 21
ATTACHMENT D
386
What is CCA?
Through Community Choice Aggregation (CCA), communities can join together to pool (or aggregate) their electricity load in order to purchase clean energy and develop local projects and programs on behalf of their residents and businesses. Aggregators work in partnership with the region’s existing Investor-Owned Utility (IOU), which continues to deliver power and maintain the grid. Some ‘choice’ stats about CCA in California:
CCA: By the Numbers
200+
Cities & counties throughout
California that have made the
choice to implement a
community choice energy
program in their communities
15 milllion+
Electricity customers in
California served by a CCA
program. That’s more than
one-third of the state’s
population
21,000+
Megawatts of new-build solar,
wind, energy storage,
geothermal, and demand
response power purchase
contracts signed by CCAs
48,000
Construction jobs supported
by CCA clean energy power
purchase agreements
25 Operational CCA programs
successfully serving customers
in California
$23 Billion
In green bond prepayment
transactions equating to
savings of around $150
million per year for CCA
customers
$48 Billion+
Committed by CCAs to
build and operate clean
energy resources
Your CalCCA Contact:
Sean MacNeil
Director of Legislative Affairs
[email protected]
27%
Percent of California retail
load served by community
choice energy providers
387
BUTTE
COUNTY
Serving Customers
Implementation Plan Filed
* Not all towns/cities within a county are served by the local CCA program.
Please visit individual agency websites for more detailed service area information. To learn more about CalCCA please visit our website at cal-cca.org.
Considering CCA
TUOLUMNE COUNTY
Chico
Oroville
Los Banos
Stockton
Tracy
Nevada COUNTY
Grass Valley
Paradise
Lathrop
Irivine
Buena Park Fullerton
Fountain Valley
San Joaquin COUNTY
Sonora
sutter
County
Yuba City
Live Oak
Nevada City
Orland
Willows
Glenn County
Cudahy
Lake County
Costa Mesa
Fillmore
Port Hueneme La Cañada Flintride
Lynwood
The California Community Choice
Association’s mission is to support the
development and long-term sustainability
of locally-run CCA electricity providers
throughout California.
Apple Valley Choice Energy
City of Apple Valley
CleanPowerSF
San Francisco County
Ava Community Energy
Unincorporated Alameda County
& 16 cities
King City Community Power
King City
Lancaster Energy
City of Lancaster
MCE
Unincorporated Marin, Napa, Solano,
& Contra Costa Counties & 34 cities
Central Coast Community Energy
Unincorporated Monterey, San Benito, San Luis
Obispo, Santa Barbara, & Santa Cruz Counties
& 30 cities
Peninsula Clean Energy
Unincorporated San Mateo County
& 21 cities
Pico Rivera Innovative Municipal Energy
City of Pico Rivera
Pioneer Community Energy
Unincorporated El Dorado & Placer Counties
& 8 cities
Rancho Mirage Energy Authority
City of Rancho Mirage
Redwood Coast Energy Authority
Unincorporated Humboldt County
and 7 Cities
San Diego Community Power
Unincorporated San Diego County and 6 cities
San Jacinto Power
City of San Jacinto
San José Clean Energy
City of San José
Silicon Valley Clean Energy
Unincorporated Santa Clara County
& 12 cities
Sonoma Clean Power
Unincorporated Sonoma &
Mendocino Counties & 11 cities
Valley Clean Energy
Unicorporated Yolo County &
Cities of Winters, Woodland & Davis
Desert Community Energy
City of Palm Springs
Clean Power Alliance
Unincorporated Ventura
& Los Angeles Counties & 36 cities
Areas of Service:
Pomona Choice Energy
City of Pomona
City of Santa Barbara
Santa Barbara Clean Energy
Orange County Power Authority
3 Cities
Energy for Palmdale’s Independent Choice
City of Palmdale
Clean Energy Alliance
7 cities
COLUSA
County
Williams
Colusa
388
ITEM 21
ATTACHMENT E
389
San Diego Total Cost to Serve 2014-2024 (in Billions)
Supporting an Equitable and
Affordable Clean Energy Transition
Making Better Use of Utility Funds to Deliver Efficiency and Electrification Programs
The San Diego Regional Energy Network (SDREN) makes it simpler for everyone in San Diego County to save energy and realize the benefits of a clean energy economy. Led by San Diego Community Power in partnership with the County of San Diego. SDREN leverages a long-standing funding mechanism already collected from ratepayers statewide for energy efficiency and low-income programs.
The comparison below illustrates the conceptual components of a ratepayer’s electricity expenditure, assuming a rounded $100 spend, and analyzes the structural changes between the 2014 and 2024 billing models.
How are these programs funded?
SDREN is funded through the existing Public Purpose Program Surcharge, enabling broader local access to an existing surcharge on customer bills.
Ratepayer Cost Trends as a Percentage of a Customer Bill 2014 vs. 2024* The San Diego Regional Energy Network is administered by San Diego Community Power and the County of San Diego and funded by California utility ratepayers under the auspices of the California Public Utilities Commission. * Some cost categories may have increased in aggregate, but decreased as a percent of a customer’s total bill.
SDREN.org
Total Generation Distribution Transmission Bonds and Fees Other Customer Programs (including PPP) Energy Efficiency 7 6
5 4
3 2
1 $-
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
2024 75% 114% 66%
21%
203%
2014
$(20) $- $20 $40 $60 $80 $100
Total Generation Distribution Transmission Bonds and Fees Other Customer Programs & Public Purpose Energy Efficiency 116%
decrease in energy
efficiency costs to
the customer
Total Generation Distribution Transmission Bonds and Fees Other Customer Programs (including PPP) Energy Efficiency 7 6
5 4
3 2
1 $-
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
390
IITEM 21
ATTACHMENT F
391
Governance: Local Oversight and Accountability
San Diego Community Power rates, energy procurement and programs are overseen and approved by a Board of Directors consisting of one elected official from each of the seven communities that we serve. The Board is advised by a 14-member Community Advisory Committee, ensuring that the voices of our local communities are represented in the Board’s decision-making process.
Terra Lawson-Remer, Chair
San Diego County
Supervisor
Ditas Yamane,
Vice Chair
City of National City
Councilmember
Michael Inzunza
City of Chula Vista
Councilmember
Marco
San Antonio
City of Encinitas
Councilmember
Jack Fisher
City of
Imperial Beach
Councilmember
Genevieve
Suzuki
City of La Mesa
Councilmember
Sean Elo-Rivera
City of San Diego
Councilmember
SDCommunityPower.org/Legislative-Priorities January 2026 Our mission is to provide affordable, 100% renewable energy by 2035 and invest in the community to create an equitable and sustainable future for the San Diego region. 100% Renewable Energy by 2035
Four competitively priced rate options
designed to meet customer needs
2,000 low-income residents
planned for enrollment in the
Solar Advantage community
solar program by 2027,
receiving a 20% bill discount
14 distributed, locally sited
stand-alone and paired solar
and storage projects, keeping
energy dollars in the region
Two prepayment transactions are saving
customers up to $13 million annually, with
a goal to pursue additional savings of up
to $50 million per year — more than 5%
savings for ratepayers
Community
Impact
allocated to the Solar
Battery Savings program
for home battery systems
of renewable energy and energy
storage capacity procured
3.4 Gigawatts
San Diego Regional Energy Network (SDREN) energy
efficiency programs launching this year provide incentives and workforce development — focused on equity,
community-led solutions and cost reduction
10 union construction jobs created,
supporting the clean energy economy
2,800+
$30M+
awarded through Community
Clean Energy Grants
$2M+
Affordability: Community-Driven Clean Energy
392
Renewable Energy Projects
SDCommunityPower.org/Legislative-Priorities January 2026 California Senate District 18
Want to learn about
Community Power’s
legislative priorities?
Scan this QR code:
76 78
78 56
52 54
67 54
94 78
78 79
79 5 76
5 5
8 8
8 5
15 15
15 805
805
94 94
125
905
125
163
163
COUNTY OF SAN DIEGO
ENCINITAS
SAN DIEGO
LA MESA
NATIONAL CITY CHULA VISTA
IMPERIAL BEACH
Service
Area
963,000+
customers
served
Community Power’s Service Area
130,000+
customers served
178+
Solar Battery Savings
incentives awarded
11+
projects built or
under contract
At a Glance
These projects, typically 3–6 megawatts, help improve local grid reliability and reduce energy costs.
Airway | Brittania | Faivre | Panasonic
Community solar projects, typically under 6 MW, are part of Community Power’s Solar Advantage program, a critical component to our local development goals. The projects are expected to provide bill discounts to over 1,250 low-income residents in the district.
1st Light Chula Vista | Chula Vista Center
Community Power purchases energy from utility-scale renewable energy projects. We prioritize projects in or near the San Diego region that will result in lower transmission and delivery costs, as well as support local job creation.
Utility-Scale
Arrowleaf Solar and Storage | Border Hybrid Energy
Center | Chula Vista Energy Center 2 | Jacumba
Valley Ranch Energy Park | Vikings Energy Farm
Community Solar
Community Battery Projects
393
ITEM 21
ATTACHMENT G
394
Governance: Local Oversight and Accountability
San Diego Community Power rates, energy procurement and programs are overseen and approved by a Board of Directors consisting of one elected official from each of the seven communities that we serve. The Board is advised by a 14-member Community Advisory Committee, ensuring that the voices of our local communities are represented in the Board’s decision-making process.
Terra Lawson-Remer, Chair
San Diego County
Supervisor
Ditas Yamane,
Vice Chair
City of National City
Councilmember
Michael Inzunza
City of Chula Vista
Councilmember
Marco
San Antonio
City of Encinitas
Councilmember
Jack Fisher
City of
Imperial Beach
Councilmember
Genevieve
Suzuki
City of La Mesa
Councilmember
Sean Elo-Rivera
City of San Diego
Councilmember
SDCommunityPower.org/Legislative-Priorities January 2026 Our mission is to provide affordable, 100% renewable energy by 2035 and invest in the community to create an equitable and sustainable future for the San Diego region. 100% Renewable Energy by 2035
Four competitively priced rate options
designed to meet customer needs
2,000 low-income residents
planned for enrollment in the
Solar Advantage community
solar program by 2027,
receiving a 20% bill discount
14 distributed, locally sited
stand-alone and paired solar
and storage projects, keeping
energy dollars in the region
Two prepayment transactions are saving
customers up to $13 million annually,
with a goal to pursue additional savings
of up to $50 million per year — more
than 5% savings for ratepayers
Community
Impact
allocated to the Solar
Battery Savings program
for home battery systems
of renewable energy and energy
storage capacity procured
3.4 Gigawatts
San Diego Regional Energy Network (SDREN) energy
efficiency programs launching this year provide incentives and workforce development — focused on equity,
community-led solutions and cost reduction
10 union construction jobs created,
supporting the clean energy economy
2,800+
$30M+
awarded through Community
Clean Energy Grants
$2M+
Affordability: Community-Driven Clean Energy
395
78,200+
customers served
206+
Solar Battery Savings
incentives awarded
At a Glance
SDCommunityPower.org/Legislative-Priorities January 2026 California Senate District 38
Want to learn about
Community Power’s
legislative priorities?
Scan this QR code:
76 78
78 56
52 54
67 54
94 78
78 79
79 5 76
5 5
8 8
8 5
15 15
15 805
805
94 94
125
905
125
163
163
COUNTY OF SAN DIEGO
ENCINITAS
SAN DIEGO
LA MESA
NATIONAL CITY CHULA VISTA
IMPERIAL BEACH
Service
Area
963,000+
customers
served
Community Power’s Service Area
San Diego Community Power’s CAC includes two community
representatives from each of the seven communities that we serve.
The committee’s role is to advise our Board of Directors, ensuring that the voices of our local communities are represented in the Board’s decision-making process. The CAC meets monthly, and all meetings are open to the public, in person or virtually.
Community Advisory Committee (CAC)
David Harris,
Chair
City of La Mesa
Luis Montero-Adams, Vice-Chair
City of San Diego
Ross Pike,
Secretary
County of San Diego,
Unincorporated
2026 Leadership Positions
396
Glossary
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: AReM is 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. It 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: CAISO is 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: CalCCA is a statewide association, made up of Community Choice Aggregators (CCAs), that represents the interests of California’s community choice electricity providers.
1 397
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: CALSLA is 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: CAM is 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: CARE is a state program for low-income households that provides a 30% discount on monthly energy bills and a 20% discount on natural gas bills. It is funded through a rate surcharge paid by all other utility customers.
CBE – Communities for a Better Environment: CBE is 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, 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 CEC is 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: CEE is 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.
2 398
CLECA – California Large Energy Consumers Association: CLECA is 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: The CPUC is 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: C&I customers are business customers who 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: A Compliance Period is the time period to become Renewables Portfolio Standard (RPS) compliant, set by the California Public Utilities Commission (CPUC).
DA – Direct Access: Direct Access is an option that allows eligible customers to purchase their electricity directly from third-party providers known as Electric Service Providers (ESPs).
DA Cap: The DA Cap is 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: DACC is 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: The DA Lottery is a random drawing by which DA waitlist customers become eligible to enroll in DA service under the currently applicable Direct Access Cap.
DA Waitlist: The DA Waitlist consists of 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: DASR is a request submitted by C&I customers to become direct access eligible.
3 399
Demand: Demand refers to 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 DER is a small-scale physical or virtual asset (e.g., EV charger, smart thermostat, behind-the-meter solar/storage, energy efficiency) that operates locally and is connected to a larger power grid at the distribution level.
Distribution: Distribution refers to 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: DR is 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: Distributed Resource Plans 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: ECR is an IOU (Investor-Owned Utility) 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: Energy Efficiency refers to 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: ELCC is 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).
4 400
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: Energy Storage is 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: An ESA refers to a battery services contract, a capacity contract, demand response contract or similar agreement.
ESP – Energy Service Provider: An Energy Service Provider is an energy entity that provides service to a retail or end-use customer.
EV – Electric Vehicle: An EV is 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) are gases that cause the atmosphere to trap heat radiating from the earth. The most common GHG is carbon dioxide.
GRC – General Rate Case: General Rate Cases are proceedings used to address the costs of operating and maintaining the utility system and the allocation of those costs among customer classes. For California’s three large IOUs, the GRCs are parsed into two phases. Phase I of a GRC determines the total amount the utility is authorized to collect, while Phase II determines the share of the cost each customer class is responsible 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: This is 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.
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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: This is 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: IEPA is 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: An IOU is 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: An Integrated Resource Plan outlines an electric utility’s resource needs in order to meet expected electricity demand long-term. kW – Kilowatt: This is 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: LCE is the CCA that serves the City of Lancaster, California.
LCFS – Low Carbon Fuel Standard: This is 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: This is the amount of Resource Adequacy capacity required to be demonstrated in a specific location or zone.
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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: This is a cost-benefit analysis of distributed resources that incorporates location-specific net benefits to the electric grid.
Load: Load refers to 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: Load-serving Entities 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: MCE was the first CCA in California and began serving customers in 2010.
It serves customers in Contra Costa, Marin, Napa and Solano counties in Northern California.
MEO – Marketing Education and Outreach: This is 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: This is a measure of energy.
NAESCO – National Association of Energy Service Companies: NAESCO is 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: Non-Bypassable Charges are 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: An NDA is a contract by which one or more parties agree not to disclose confidential information that they have shared with each other. 7 403
NEM – Net Energy Metering: NEM is a program in which solar customers receive credit for excess electricity generated by solar panels.
NRDC – Natural Resources Defense Council: NRDC is 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: An OIR is 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: OSC is an order requiring an individual or entity to explain, justify or prove something.
ORA – Office of Ratepayer Advocates: The ORA is an independent consumer advocate within the CPUC, now called the Public Advocates Office.
PA – Program Administrator (for EE Business Plans): IOUs and local government agencies can be authorized to implement CPUC-directed energy efficiency programs.
PCE – Peninsula Clean Energy Authority: PCE is the 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: RPS Portfolio Content Category 1 includes 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: RPS Portfolio Content Category 2 includes 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: RPS Portfolio Content Category 3 includes Unbundled Renewable Energy Certificate (REC).
PCIA or “exit fee” – Power Charge Indifference Adjustment: 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: The PCL is 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). 8 404
PD – Proposed Decision: A PD is 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: PG&E is the IOU that serves 16 million people over a 70,000-square-mile service area in Northern California.
PHC – Prehearing Conference: A PHC is 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 PPA is a contract used to purchase the energy, capacity and attributes from a renewable resource project.
PRP – Priority Review Project: These are 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: The PUC is 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: The PURPA is 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: This is 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. 9 405
RE – Renewable Energy: Renewable energy is 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: This is 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: RPS is 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 Senate Bill is 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.
SBP – Solar Billing Plan: The Solar Billing Plan, also known as the Net Billing Tariff or NEM 3.0, is the new method of compensating customer-sited renewable energy self-generation, intended to promote grid reliability and incentivize solar and battery storage.
SCE – Southern California Edison: SCE is the large IOU that serves the Los Angeles and Orange County area.
SCP – Sonoma Clean Power Authority: SCP is the CCA serving Sonoma County and surrounding areas in Northern California.
SDG&E – San Diego Gas & Electric: SDG&E is the IOU that serves San Diego County and owns the infrastructure that delivers Community Power energy to our customers.
SGIP – Self-Generation Incentive Program: SGIP is 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: This is an electric surcharge intended to penalize consumers for excessive energy use.
SVCE – Silicon Valley Clean Energy: SVCE is the CCA serving the communities in Santa Clara County. 10 406
TCR EPS Protocol – The Climate Registry Electric Power Sector Protocol: This refers to 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: TOU Rates refers to 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: This is 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: TURN is a ratepayer advocacy group charged with ensuring that California IOUs implement just and reasonable rates.
Unbundled RECs: Unbundled RECs are 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 Virtual Power Plant is 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: VAMO is the process for SDG&E to allocate a proportional share of its renewable portfolio to Community Power and other LSEs within the service territory.
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