1 Andrea Pizano
From: Eric Veium <[email protected]>
Sent: Monday, April 7, 2025 1:24 PM
To: Andrea Pizano
Cc: Louise Auerhahn; Tim Frank; Leslie Austin
Subject: Public Comment – SVCE Board Meeting, Item 3 (April 9, 2025) Attachments: SVCE April 9 2025 Board Meeting _Item 3 PPA Project Selection Policy_ CCA W&EJ Alliance Public Comment Letter.pdf
ATTENTION: This message is from an external user. Confidential information such as social security, credit card bank routing, wire transfer and other personally identifiable information should not be transmitted to this user.
For questions, please contact the SVCE IT Department.
Hello Clerk Pizano,
I am writing on behalf of the CCA Workforce & Environmental Justice Alliance regarding Agenda Item 3 for the Silicon Valley Clean Energy Board Meeting on April 9, 2025.
Please find attached our comment letter addressing the proposed PPA Project Selection Policy. We respectfully request that this letter be shared with the SCVE Board of Directors.
Thank you,
~Eric Veium
Co-Director
CCA Workforce & Environmental Justice Alliance
SLOEarthFest 2025 - April 26th
SLOEarthFest.org
Eric Veium, MPP
he | him (why do pronouns matter?)
Board Chair
Home Energy Advising Service Director
Co-Director, CCA Workforce & EJ Alliance
805.835.3669
[email protected]
www.sloclimatecoalition.org
Schedule a Meeting with Me
Learn More About Me
CT&,W!FEST
2 Connect with SLO Climate Coalition
Climate Pulse | Instagram | Facebook | X
To find our DEI Vision Statement & Land Acknowledgment visit our About Us page.
April 7, 2025
Chair Tyson and Honorable Directors
Silicon Valley Clean Energy
333 W. El Camino Real, Ste 330
Sunnyvale, CA 94087
Re: ITEM 3: Adopt SVCE’s Power Purchase Agreement Project Selection Policy Dear Chair Tyson and Honorable Directors,
We begin with sincere appreciation for Monica Padilla, Bena Chang, Kris Van Vactor, Britta Bradshaw and other supportive staff who have been instrumental in the collaborative effort that has delivered SVCE’s PPA Project Selection Policy for your consideration. We are still requesting a few small refinements, requiring your direction, that we believe deliver greater value for SVCE, its customers, and the communities it serves. We are confident that the remaining issues can be resolved and see an opportunity for joint celebration of what we think is a proud moment for SVCE. We are looking forward to our continued collaboration. 1 CCA Workforce
& EJ Alliance
^jsierraclub
Vgiin uie san francisco bay
Coalition
the
climate
center
LOCAL
CLEAN
ENERGY
ALLIANCE
WORKING
PARTNERSHIPS
USA 10BOP NETWORK
fOR susiflNflBurr
CLIMATE
EMERGENCY
COALITION
JOBS TO
MOVE AMERICA
PUBLIC GOODS FOR THE MOSTPUBLIC GOOD CCCJN
Diversity Coalition
San LiusO>i« Coi vn
CAUSE
ISCalifornia Alliance
for Community Energy
www.cacommunityenergy,org
^CRITICAL \ IMPACT CONSULTING
5301a Cru*
Community
Environmental
Council
ROMERO
INSTITUTE
extinct!
SF BAY AREA
350 Conejo
San Fernando Valley
♦35CBayArea
ACTION
Citizens’ Climate Lobby
Santa Cruz Chapter
Terra Advocati
for a sustainable planet
environteers
Outstanding Issues in the Proposed Policy
We strongly support the labor, workforce, environmental, and community provisions included in the current proposed policy. To help ensure project success in cases where a project has not yet reached the permitting or entitlements phase, we recommend two additions:
1) Consider environmental impacts for earlier stage projects.
The proposed policy recommends prioritizing projects “Where the developer and local land use authority have established an enforceable development agreement which, in part, sets forth measures to mitigate impacts to sensitive habitats or environmentally sensitive areas.” However, when RFP/RFO responses are being evaluated, not all projects may yet be at this stage. We suggest adding language similar to the following:
“Or for projects that are in earlier stages of the development process, where the developer has adequately assessed likely impacts and addressed potential mitigants to sensitive habitat or environmentally sensitive areas, as for instance by committing to compliance with applicable Habitat Conservation Plans.”
2) Assess community engagement for earlier stage projects.
Similarly, the proposed policy recommends prioritizing projects that “Commit to meaningful engagement with local communities throughout the entitlement and construction processes”, but does not address the pre-entitlement phase. We suggest adding language similar to the following:
“Demonstrate commitment in their offer plans to meaningful engagement with local communities throughout the pre-entitlement, entitlement and construction processes” A Risk-Reduction, Cost-Saving, and Market-Smart Strategy The policy is preference-based – not mandates. This simple framework articulates SVCE’s preferences for what great projects look like alongside financial and technical considerations, at the very beginning of the procurement process. This clarity attracts stronger, more thoughtful proposals from developers, helps avoid costly oversights such as environmental conflicts or community opposition, and produces higher overall value aligned with the agency’s commitments and long-term goals. This is not just a ‘values’ exercise—it’s a strategic approach to procurement that reduces risks to SVCE, its customers, and the clean energy industry as a whole. Peer CCAs, including Sonoma Clean Power, Ava Community Energy, CCCE, and Clean Power SF have adopted similar standards. Clean Power Alliance—the largest CCA in the State—has included similar preferences in its RFOs for years - demonstrating that this policy is practical and achievable.
This approach is an important response to challenges facing the clean energy industry. There are a growing number of examples of projects that have been delayed, denied, or otherwise failed due to avoidable issues that might have been identified and addressed during project selection. In fact, according to a recent study by LBNL, surveying clean energy project developers, after interconnection, community opposition due to misalignment with or lack of 2 community, economic, and local workforce benefits is the second leading cause of costly project delays, litigation, or denial.
At its core, this policy provides SVCE with a flexible, transparent structure that:
● Avoids delays and cost overruns by prompting early attention to labor, permitting, and community expectations.
● Reduces costs for both SVCE and developers by identifying and addressing opportunities and risks early in the process while minimizing time-consuming negotiation and project revisions or other delays later on.
● Protects long-term value by avoiding misaligned or poorly scoped projects that carry delivery, financial, or reputational risks.
● Strengthens the competitive field by encouraging developers to align with SVCE’s goals, as other leading CCAs have successfully done.
Through clear, upfront guidance to developers regarding best practices promoted by SVCE and other CCA industry leaders, SVCE can elicit more projects that align with its preferences while retaining full discretion and flexibility for the staff and board to accommodate projects needed to meet technical requirements.
Clarifying What This Policy Does and Doesn't Do
● It is not a mandate. The policy signals preferences—not hard rules. SVCE retains full discretion to pursue any project necessary to meet technical, financial, or regulatory requirements.
● It builds on existing public standards. Cities and counties in SVCE’s territory already require prevailing wage and apprenticeship on small public works projects. These practices are well-established.
We urge the Board to adopt this policy framework as a market-smart and risk-conscious strategy to improve project quality, reduce risks, and protect SVCE’s fiscal and community priorities. Thank you for your continued leadership in building a clean energy future that works for everyone.
Sincerely,
Eric Veium, Tim Frank, & Leslie Austin
Co-Directors, CCA Workforce & Environmental Justice Alliance Louise Auerhahn
Director of Economic and Workforce Policy, Working Partnerships USA 3 SOUTH BAY
April 8, 2025
COUNCIL
Jean Cohen, EXECUTIVE OFFICER
EXECUTIVE BOARD
Dear Chair Tyson and Honorable Directors,
Sincerely,
TRUSTEES
opeiu#29afl-cio/clg
Re: April 9, 2025, Board Item 3: Adopt SVCE’s Power Purchase Agreement Project Selection Policy
Stanley Young
IFPTE Local 21
On behalf of the South Bay AFL-CIO Labor Council, I thank the Silicon Valley Clean Energy leadership for your work on the PPA Project Selection Policy, and urge the board to approve the proposed policy.
Silicon Valley Clean Energy’s Power Purchase Agreements support billions of dollars worth of energy production and storage projects, creating large-scale impacts on workers and communities where the projects are located. Done right, these can be hugely positive impacts, creating good family-supporting jobs generating clean, renewable energy and building career pipelines for community members. However, there is also the danger of a “low-road” approach to project development which can lead to worker exploitation and damage to nearby communities.
By creating a preference for projects that meet strong labor, workforce, community, and environmental standards, the PPA Selection Policy will enable SVCE to send a signal to project developers. We strongly support the focus on high-road projects built with standards that will ensure availability of a skilled workforce, effective project delivery, and high quality of work needed for reliable operations over the long term.
We further support the additions proposed by the Workforce and Environmental Justice Alliance in their public comment letter, which would help ensure that the policy includes a framework to adequately assess early-stage projects. We ask the Board to include those two suggested additions.
Jean Cohen
Executive Officer
South Bay Labor Council
Chair Tyson and Honorable Directors
Silicon Valley Clean Energy
333 W. El Camino Real, Ste 330
Sunnyvale, CA 94087
Danny Mangan
Sprinkler Fitters Local 483
Malinda Markowitz
CNA/NNOC
Jerry May
IAFF Local 230
Eric Mussynski
UA Local 393
Patty Picard
CSEA Chapter 350
Bob Prola
OGEA
Robert Sandoval
Teamsters Local 350
Raj Singh
ATU Local 265
Nydia Smith
AFSCME Local 1587
Enrique Arguello
LiUNA! Local 270
David Bini
Building Trades Council
Kathy Jasper
AFT Local 6157
Samuel Kehinde
SEIU USWW
Tony Alexander
APRI
Paul Fong
AFT Local 6157
Dominic Torreano
SMW Local 104
John Tucker
AFSCME District Council 57
Bill Wallace
IBEW Local 1245
2302 ZANKER ROAD SAN JOSE, CA 95131 P 408 606.2060 F 408 703.2020 www. southbaylabor.org
Riko Mendez, PRESIDENT
SEIU Local 521
Maria Noel Fernandez, 1ST VICE PRESIDENT
IAM& AW Local 1101
Will Smith, 2ND VICE PRESIDENT
IBEW Local 332
Troy Jones, RECORDING SECT.
UFCW Local 5
Dolores Morales, SERGEANT-AT-ARMS
CEMA
Enrique Fernandez, TREASURER
UNITE HERE! Local 19