STAFF REPORT
Meeting Date:
April 14, 2026
CONSENT
CALENDAR
15 SUBJECT: WORKPLAN TO EVALUATE JOINING THE ORANGE COUNTY POWER
AUTHORITY (ENVIRONMENTAL SUSTAINABILITY COMMITTEE)
RECOMMENDATION: It is recommended that the City Council:
1. Direct staff and the Environmental Sustainability Committee (ESC) to implement the proposed work plan and return to the City Council with findings, community input, and a recommendation regarding potential Orange County Power Authority (OCPA) membership at the October enrollment decision timeline.
SUMMARY OF THE MATTER
At the direction of the City Council during its January 27, 2026 study session, and subsequently affirmed by City Council action at its January 10, 2026 meeting, a preliminary work plan has been developed by the Environmental Sustainability Committee (ESC) to evaluate whether membership in the Orange County Power Authority (OCPA) would be in the best interest of the City (Attachment 1) and area ratepayers. The purpose of the work plan is to provide a structured and transparent process through which ESC, with support from City staff, can review relevant financial, operational, governance, legal, and community considerations before returning to City Council with a recommendation.
The proposed work is intended to support a future City Council policy decision and does not commit the City to joining OCPA. Rather, it establishes a framework for due diligence, community education and outreach, and comparative analysis so that City Council may later consider the issue with a more complete record.
DISCUSSION
Background
Community Choice Energy (CCE) is a model where local governments choose the source of electricity for their community instead of leaving that decision entirely to a traditional utility company. The existing utility, such as Southern California Edison (SCE), still delivers the electricity, maintains the poles and wires, sends the bill, and responds to outages. The main difference is who buys the electricity and how much renewable energy is included in the power mix.
OCPA is Orange County’s local CCE provider. It purchases electricity on behalf of participating cities and offers different energy plan options, including choices with higher renewable energy content. OCPA’s role is to give cities and customers more local control over energy procurement, cleaner energy options, and potentially more stable long term energy planning. It does not replace the utility’s role in transmission, infrastructure, or outage response.
Timeline
Attachment 2
20 Workplan to Evaluate Joining the Orange County Power Authority (Environmental Sustainability Committee)
April 14, 2026
The enrollment process begins with the City Council adopting a resolution declaring its intent to join OCPA.
That action is taken in October of each year. The ESC has developed a workplan to conduct due diligence and community outreach working back from that October meeting date. A five phase workplan is included as Attachment 1. Additionally a streamlined task oriented workplan is included as Attachment 2. These plans are subject to change as the process unfolds, but what is proposed will be the general process followed.
The table below summarizes the timing and objectives of each phase.
Phase Name Objective
Phase 1
(March-April) Authorization and Framework Secure City Council direction and establish the evaluation framework.
Phase 2
(April – June)
Data Collection, Baseline
Analysis, and Community
Outreach
Build the factual record, begin comparative analysis,
and engage the community early in the process.
Phase 3
(Jul – Aug) Due Diligence and Validation Validate assumptions, fill information gaps, and assess legal, operational, and governance issues.
Phase 4
(Sep)
Synthesis and Draft
Recommendation
Bring together the technical analysis, risk
assessment, and community input into a clear
recommendation.
Phase 5
(Oct) Council Review and Direction Present the completed assessment and recommendation for City Council consideration.
Fiscal and Staffing Considerations
There is no direct cost to the City to authorize OCPA to conduct a preliminary evaluation of the City’s energy profile and potential service options. However, staff anticipates that a meaningful review of potential participation in OCPA would require a substantial legal and administrative analysis beyond the City’s current internal capacity.
Specifically, staff expects that the City Attorney’s Office would need to conduct extensive legal research and review to evaluate the governance structure, financial obligations, risk exposure, withdrawal provisions, regulatory considerations, and other potential liabilities associated with enrollment in a CCE program. At this time, we do not believe that the City has sufficient internal capacity to complete that level of evaluation with existing staff resources.
As a result, the City Attorney would likely need to retain outside legal counsel with subject matter expertise in CCE and Joint Powers Authority participation to perform this analysis. Staff estimates that this work would carry a cost of approximately $40-50,000, depending on the scope of review and the level of due diligence directed by the City Council (assumes 100-150 hours at $275-$400/hour).
Given current budget and staffing constraints, the City Council would need to consider the broader organizational impact of undertaking this evaluation. The City is currently operating with limited staff and operational resources, and moving forward with a formal assessment is likely to require the reprioritization or reprogramming of existing funds and staff time. If directed to proceed, the City Council would need to 21 Workplan to Evaluate Joining the Orange County Power Authority (Environmental Sustainability Committee)
April 14, 2026
determine whether sufficient resources should be reassigned from other operational priorities to support this effort.
FINANCIAL ANALYSIS
Outside legal review is estimated to cost approximately $40,000 to $50,000, exclusive of any additional staff time or internal oversight required to manage that work.
This cost is not currently included in the adopted budget and would need to be considered as part of the City’s Fiscal Year 2026-27 budget process, alongside other competing priorities.
ENVIRONMENTAL ANALYSIS
The recommended action is not a project under the California Environmental Quality Act (CEQA) pursuant to State CEQA Guidelines Section 15378 because it consists only of the City Council’s review and consideration of a proposed workplan and does not authorize any physical activity, development, or other action that could result in a direct or reasonably foreseeable indirect change to the environment. In the alternative, the action is also exempt from CEQA pursuant to State CEQA Guidelines Section 15061(b)(3), the common sense exemption, because it can be seen with certainty that there is no possibility the recommended action would have a significant effect on the environment.
ATTACHMENTS
1. ESC Proposed Work Plan for OCPA
2. Task List Version
Submitted By:
. Approved: .
Jeremy Frimond, Assistant City
Manager
Dave Kiff, City Manager
Report Prepared By: Coordinated With:
Jeremy Frimond, Assistant City Manager, City
Manager's Office
22
Proposed Work Plan for Environmental Sustainability Committee Review of Orange County Power Authority Membership
RECOMMENDATION
Receive the proposed work plan from the Environmental Sustainability Committee for evaluation of potential membership in the Orange County Power Authority and provide direction on whether the Committee and City staff should proceed with the assessment and return to City Council with findings and a recommendation.
SUMMARY OF THE MATTER
At the direction of the City Council, a preliminary work plan has been developed by the Environmental Sustainability Committee to evaluate whether membership in the Orange County Power Authority (OCPA) would be in the best interest of the City. The purpose of the work plan is to provide a structured and transparent process through which ESC, with support from City staff, can review relevant financial, operational, governance, legal, and community considerations before returning to City Council with a recommendation.
The proposed work is intended to support a future City Council policy decision and does not commit the City to joining OCPA. Rather, it establishes a framework for due diligence, community education and outreach, and comparative analysis so that City Council may later consider the issue with a more complete record.
The proposed work plan is organized into five phases, as summarized below.
PROPOSED WORK PLAN
Phase 1: Authorization and Evaluation Framework
March 2026
The first phase would consist of City Council review of the proposed work plan and direction on whether ESC and City staff should proceed.
If authorized to proceed, ESC and staff would establish the framework that will guide the assessment, including the primary evaluation criteria to be used in developing a future recommendation. Those criteria are anticipated to include:
• Potential customer rate impacts
• Rate stability and long term cost considerations
• Renewable energy and sustainability benefits
• Governance structure and local control
Attachment 1
23
• Financial, legal, and operational risks
• Community interest and alignment with City priorities Phase 1 Deliverable:
City Council direction on whether to proceed and confirmation of the evaluation framework.
Phase 2: Preliminary Analysis, Data Collection, and Community Outreach April through June 2026
If authorized to proceed, ESC and staff would begin collecting and organizing information necessary to evaluate OCPA membership.
This phase would include requesting relevant customer load data through OCPA coordination with the applicable investor owned utilities, including Southern California Edison and, if applicable, San Diego Gas & Electric. ESC and staff would also work to develop a preliminary bill impact analysis to better understand potential customer cost implications.
In addition, ESC and staff would revisit the City’s prior 2023 questionnaire used to evaluate Joint Powers Authority participation and refine that framework as appropriate for this review. Questions that can be answered through publicly available information, online materials, adopted documents, financial records, and agency publications would be completed during this phase.
Community outreach would also occur during this phase so that public education and feedback may inform the review while it is still underway. Outreach efforts may include informational materials, public discussion at ESC meetings, stakeholder engagement, and opportunities for residents and businesses to provide feedback.
Phase 2 Deliverables:
• Preliminary bill impact and customer analysis
• Updated evaluation questionnaire
• Community outreach summary and public input log
Phase 3: Due Diligence and Agency / Internal Review
July through August 2026
24
The third phase would focus on validating information, filling gaps in the record, and addressing legal, operational, and governance questions that require direct agency or internal review.
ESC and staff would seek to schedule discussions with OCPA leadership, including Joe Mosca and/or Tiffany Law, in order to obtain responses to questions requiring clarification, direct confirmation, or technical explanation.
During this same phase, ESC and staff would also confer with the City Attorney and City Manager to evaluate legal, contractual, governance, and implementation considerations associated with potential membership.
The work completed during this phase would inform the City’s understanding of issues such as governance structure, financial oversight, membership obligations, operational implications, and risk exposure.
Phase 3 Deliverable:
Governance, legal, and risk assessment memorandum.
Phase 4: Draft Findings and Recommendation
September 2026
Following completion of the analysis and outreach process, ESC and staff would consolidate the information developed in the prior phases and evaluate OCPA against the approved criteria.
This phase would result in preparation of draft findings and a recommendation to City Council regarding whether the City should further consider membership in OCPA. If warranted, the recommendation may also identify conditions, safeguards, or additional follow up actions that should be considered in connection with any future Council direction.
Phase 4 Deliverable:
Draft ESC recommendation and supporting analysis.
Phase 5: City Council Workshop / Presentation of Findings October 2026
25
The final phase would consist of ESC presentation of its findings and recommendation to City Council at a future public meeting or workshop.
The presentation would summarize the results of the review, including financial and customer considerations, governance and legal issues, identified risks and opportunities, and the nature of community feedback received during the process.
At that time, City Council would have the opportunity to consider whether to provide further direction regarding potential OCPA membership.
Phase 5 Deliverable:
Presentation of ESC findings and recommendation to City Council. 26
ESC Workplan for OCPA Assessment (Task Item Version)
Phase 1: Authorization and Framework (March)
Objective: Secure City Council direction and establish the evaluation framework.
Tasks
• Present the proposed scope, timeline, and workplan to City Council • Request authorization to proceed with the assessment of Orange County Power Authority • Establish evaluation criteria to guide ESC and staff analysis, including:
o Cost competitiveness
o Rate stability
o Renewable energy and sustainability value
o Governance and local control
o Financial and legal risk
o Community benefit and alignment with City values
• Confirm the roles of the Environmental Sustainability Committee and City staff in carrying out the work
Deliverable
• City Council approved workplan and evaluation criteria Phase 2: Data Collection, Baseline Analysis, and Community Outreach (April – June) Objective: Build the factual record, begin comparative analysis, and engage the community early in the process.
Tasks
• Ask OCPA to coordinate with Southern California Edison and San Diego Gas & Electric, as applicable, to obtain load data
• Work with OCPA and City staff to develop a preliminary bill impact analysis for residential and commercial customers
• Revisit and refine the City’s 2023 questionnaire used to evaluate potential Joint Powers Authorities
• Complete those portions of the questionnaire that can be answered through publicly available information and online research
• Develop and implement a community outreach plan to:
o Educate the public on what OCPA is and what membership would mean o Provide neutral background information on options and tradeoffs o Solicit public input from residents, businesses, and stakeholders • Gather and organize public feedback for later incorporation into the analysis Deliverables
• Preliminary financial and customer impact analysis
• Updated evaluation questionnaire
Attachment 2
27
• Community outreach summary and input log
Phase 3: Due Diligence and Validation (July – August)
Objective: Validate assumptions, fill information gaps, and assess legal, operational, and governance issues.
Tasks
• Schedule and conduct interviews with:
o Joe Mosca
o Tiffany Law
• Obtain answers to questions requiring direct agency response or verification • Schedule and conduct internal discussions with:
o City Attorney
o City Manager
• Evaluate:
o Governance structure
o JPA membership terms
o Financial oversight and transparency
o Potential legal and operational risks
• Assess reliability of assumptions used in the preliminary bill and risk analyses Deliverable
• Governance, legal, and risk assessment memorandum
Phase 4: Synthesis and Draft Recommendation (September) Objective: Bring together the technical analysis, risk assessment, and community input into a clear recommendation.
Tasks
• Consolidate findings from:
o Financial analysis
o Questionnaire responses
o Governance and legal review
o Community outreach
• Evaluate OCPA against the Council approved criteria
• Develop a draft recommendation on whether the City should join OCPA • If appropriate, identify conditions, safeguards, or follow up steps that should accompany any recommendation
Deliverable
• Draft ESC recommendation report to City Council
Phase 5: Council Review and Direction (October)
28
Objective: Present the completed assessment and recommendation for City Council consideration.
Tasks
• Present ESC findings and recommendation to City Council • Summarize:
o Financial impacts
o Risks and opportunities
o Governance considerations
o Community feedback
o Overall recommendation
• Request Council direction on whether to proceed with or decline OCPA membership consideration
Deliverable
• City Council presentation and requested direction
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