^f Outlook
Letter re Agenda item #3 for MSC 8/25/26
From Cynthia Cannady
Date Man 8/24/2026 5:46 PM
To Gao, Beilei <[email protected]>
ffl) 1 attachment (142 KB)
LT MSC 082326 Agenda #3.pdf;
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Please accept this letter submitted by the PASADENA 100 Steering Committee for the meeting tomorrow of the Municipal Services Committee of the City Council, agenda item #3.
Cynthia Cannady
PASADENA 100
August 24, 2026
Dear Councilmembers, City Manager and PWP:
The PASADENA 100 coalition submits these comments on PWP's revised Progress Report to the Optimized Strategic Plan (OSP PR Q2).
The repeated record-breaking heat waves of this summer, the disastrous Baton Canyon fire, and continuing global climate disasters, prove that your unanimous decision in 2023 to pass Clmiate Emergency Resolution 9977 was both courageous and wise. And your subsequent decisions in 2025 to approve the Optimized Strategic Plan (OSP), to support the hourly (carbon free) OSP model, and to prioritize its implementation were ethically and practically sound. Fact-based quarterly progress reports are essential for continued advancement of the City's clean energy goal.
We have orgardzed our comments on the OSP PR Q2 in 3 sections:
A. Improvements over the first submission
B. Comments and suggestions on the critical resource elements of the OSP and how they are dealt with in the OSP PR Q2.
C. Requests related to how the OSP PR Q2 and future quarterly reports handle cost attribution and equity considerations.
A. Improvements over the first submission. We appreciate that PWP has revised the OSP-PR Q2. We note the following improvements:
1. Table 2.7 in Appendix A (p. 30) uses a format that shows the progress in megawatts (MWs) towards the OSP targets.
2. The 5 MW cap on Clean Power Partnership projects has been removed.
3. The commitment to local storage at the Broadway site is clear, and the OSP-PR Q2 provides more information on its status and timely development. 1 B. Comments and suggestions on the critical resource elements of the OSP and how they are dealt with in the OSP PR Q2.
Several of the concerns that were highlighted in our July 28, 2026 letter to the MSC Councilmembers remain and raise serious issues. Because these issues threaten the achievement of our city's carbon free electricity mandate, we must insist that they be addressed with seriousness.
Underlying all these concerns is our obseryation that the climate emergency and Pasadena's response to it are not being addressed with appropriate urgency. This first progress report, which was late, casually announces schedule slips. Further, the multiple references to issues that should have been resolved years or months ago (e.g. the feasibility of solar installation or "review" of Council's decision to pennit 150% overbuild for residential solar) are hard to understand.
We ask that future OSP Progress reports be on time, quarterly, and focused on quantitative progress or specific challenges and how they might be overcome.
1. Imported electricity. Carbon free electricity generated outside of Pasadena remains our largest electric power source and the OSP modeling was based on critical MW targets. a. Although the revised version contains more information about the current RFP than the original draft and identifies the MWs sought in the current RFP (185MW), there is no reference to future RFPs or other means to achieve the OSP target of 325MW. The text refers to the handy Resource Matrix (Table 2.7 in Appendix A) for more information, however, the years 2027, 2028 and 2029 are blank. b. The OSP PR Q2 confuses the issue with references to successful procurements that antedate the OSP and are not part of its modeling, (p. 6) c. The OSP PR Q2 does not explain what resource procurement may be expected from SCPPA, although PWP is on the Board and presumably can have an influence on this or at least gain information about upcoming RFPs.
d. The OSP modeled scenarios based on purchasing geothermal generated electricity that would reduce overall resource needs, so iiiformation on PWP and/or SCPPA procurement plans for geothermal resources would be helpful.
2. Municipal solar. This part of the OSP is important for both resources and resilience. It advances our city from total dependence on imported electricity towards a more balanced system with local resources (aka "distributed generation"). The OSP specifies 20 MW of municipal solar by 2030.
2 a. Unfortunately, the OSP PR Q2 announces a delay in issuing new RFPs for municipal solar, replacing a specific October target with an undetermined, potentially later deadline. No reason for this delay is given. On July 28th, GM Reyes assured residents that RFPs would be issued promptly for the second and third round ofRFPs. The OSP PR Q2 appears to retreat from the assurance. b. Ongoing generalized feasibility fretting causes further delay. The document refers to continuing analysis of the feasibility of solar installation on municipal properties.
Why is basic irdformation still being addressed (e.g. what buildings need new roofs, where trees may reduce efficiency, etc.). When will this be complete? This feasibility assessment is apparently being done m house instead of by the expensive consultancy that was originally planned but changed after public protest. Why did it take 6 months to issue an RFP for solar installation, an established technology, on city properties that have been inventoried for more than a year? c. Further delay is caused by the terms of the RFP for municipal solar that was finally issued in late July. It appears to add non-standard, burdensome and expensive requirements, including that respondents perform their own feasibility study (after the city has done its feasibility study). And respondents must add in storage and EV hook ups, although nothing in the OSP requires on site storage or EV hook ups at municipal sites, which will increase cost. Why is on site storage necessary when the OSP plans for centi-alized storage at Glenarm and Broadway? d. It would be helpful if the OSP PR Q2 addressed reducing cost by doing in-house installation, which has discussed at MS C meetings and is already being tested in a pilot project managed by the Department of Public Works. In-house installations and operations can ensure that existing PWP workers remain employed by being part of the transition to carbon free electricity.
e. There is still no funding commitment to the full 20 MW target, although General Manager Reyes has affirmed the commitinent to develop the full 20 MW by 2030. f. There is a discrepancy between the OSP PR Q2 and the MSC slide presentation, with the former identifying "rate increases" as one way to pay for investment in municipal solar, while this is omitted from the slides. PWP could have funded all the municipal solar investments had they heeded the Council's explicit priorities from the December budget workshop instead of ignoring them. It would be appropriate at this time to provide Council with a proposal for revenue bond, debt or reserve funding.
3. Commercial and institutional solar in Pasadena
4. The OSP PR Q2 identifies specific potential partners but does not identify MW targets, executed agreements, committed capacity, project costs, anticipated dates for negotiation closure.
Residential solar
3 5.
a. Quarterly OSP Updates should include basic data that should be easy to organize actual number of applications, dates submitted, and number of applications approved.
b. The incentives that PWP has developed are excellent, but the word is not yet getting out sufficiently and there is no city-wide campaign that engages city leadership. c. It appears we are behind the OSP's 2026 goal for local non-municipal. What is PWP's strategy to catch up and meet their goal?
d. There is no report on uptake of incentives by low-income property owners. e. What is the sti-ategy for multi-family solar and community solar to help renters and condo-owners? Over the past year, we have encouraged PWP to develop a program that will incent landlords and renters. PWP stated in the OSP that Pasadena's community solar strategy is municipal solar, but as we see from the information above, this is not yet funded and implementation is delayed. This also deviates from the typical understanding of community solar programs and prevents renters from participating in the program. f. We hope that the promised program for low interest loans and/or an on-bill financing program will be implemented promptly.
g. We continue to ask if the operational problems with solar permitting have been resolved, includmg a recent letter to which no reply was given. A reply to an earlier letter stated that another consultancy was being initiated for another software solution, but we don't know if a conti'act was in fact entered. Given that California offers a free solar permitting program to utilities, and that Pasadena was paid to develop its own system in 2024, this ongoing confusion is difficult to understand. h. It was disturbing to see that PWP may again be calling into question the Council's 150% overbuild decision. The OSP PR Q2 raises again an argument that has been offered for more than 3 years now in the STAG and in the TAP, that the distribution system may or may not be able to handle more local solar generation, an argument that is supposed to be assessed in a Caltech collaboration that was mentioned 3 years ago.
However, we imderstand that this potential stidy has not even started. Is there a target date for the Caltech report? There was a reference to a November 2025 Caltech study on the current distribution system. Is this study available? Was this study used to plan the infrastructure upgrades, such as the conversion to 17 kw distribution or the Path 2 upgrade?
Demand Response. The OSP PR Q2 is unclear on the DR element of the OSP, which involves using software, incentives, VPP systems and other tools to optimize efficiency and constrain demand. Historically utilities have resisted this because they "make money" on more electricity being sold, not less. But increasingly it is recognized as essential modem electric power management. We appreciate that PWP plans to roll out its AMI program, but the data on OSP implementation ofDR is unclear. a. The OSP specifies 1 5 MW of DR by 2030. This should be spaced out as follows: .5 in 2026; 1 MW for 2027, 2 MW for 2028, 4.5 MW for 2029, 7 MW for 2030. The Resource Matrix in the OSP PR Q2 should include these incremental/annual goals. 4 b. It appears that we are significantly behind the OSP's 2026 goal for DR. How will PWP plan to catch up? The report does not explain how PWP intends to close that gap or whether other separately tracked programs would materially change the comparison. It appears that no voluntary DR programs have been rolled out. How does PWP plan to achieve the annual DR reductions planned in the OSP? What about DR and battery requirements for joining the VPP?
5 C. Requests related to how the OSP PR Q2 and future quarterly reports handle cost attribution and equity considerations. We have two concerns and specific requests.
1. Cost attribution.
The OSP PR Q2 continues the false narrative that attributes the cost of distribution grid infrastructure investment to the transition to carbon free resources mandated by Climate Emergency Resolution 9977. It is clear that new poles, ti-ansformer, vault renovation and other infrastmcture investments were identified before the passage of Resolution 9977 as part of the PWP plan for updating the local distribution grid. These investments are resource agnostic. Buying poles for electric power lines is simply NOT a cost that can be attributed to the transition to carbon free electric power.
Similarly, demolition and asbestos and other toxic remediation for the Broadway site are apparently now included in the hugely expanded budget estimate for electric power storage. But these costs will be incurred no matter what kind of electricity generation is being used. Even if the site were sold for development unrelated to energy these costs would be incurred by the city or the purchaser.
This same "mistake" arose during the TAP and again at the December budget workshop where PWP submitted documents that falsely estimated the cost of the transition to carbon free electi-ic power as the TOTAL CIP budget for 5 years.
This is misleading to the Council and the public. At this point the continued use of this fallacy makes it appear like a concerted effort to inflate the cost of the transition and blame OSP implementation for rate increases, already a subject of public confusion.
We request that the MSC direct staff to stop making these incorrect cost attributions.
2. The Equity Study
Over the years, the enviroiunental justice community has witiiessed an unfortunate and cynical distortion of the concept of "equity" in the context of the ti-ansition to carbon j&ee electric power. One of the narratives from the playbook of the fossil fuel and investor-owned utility industries is that clean energy is for elites. A related false narrative is that the transition away from fossil fuel resources is the proximate cause of high utility bills, which hurt low-income ratepayers. There is little doubt that the fossil fuel industry has waged a war of disinformation to block climate action: "Just as the tobacco industry manipulated science 6 a.
b.
and public opinion to downplay the dangers of smoking, the fossil fuel industry uses similar tactics to cast doubt on climate change and hinder progress." (The Lancet, 2026).
Given the historic manipulation of the concept of equity, it is important that any study of the impact of the transition to carbon free electricity must be rigorous in avoiding false factual assumptions. Because Pasadena's Climate Emergency Resolution 9977 explicitly embraces rate equity, it is equally important that our city examine the impact of rapidly advancing climate change on our low-income ratepayers.
It is also important that any equity study evaluate and propose real solutions that will result in lower utility bills, not just hand wave about a spurious connection between clean energy and harm to low-income ratepayers. The study should address with specificity: What can Pasadena do to make it easier for low-income ratepayers to afford their electricity bills, whether the electricity is generated by carbon free resources or by burning fossil fuels.
Here are our concerns and questions about the University of Michigan SEAS Equity Project study for Pasadena.
The Project Plan (3 pages) and Update (4 general slides) are very short and non-specific. specific deliverables are identified, only 3 objectives with very general subcategories.
No
The Project Plan states: "equity concerns and potential outcomes must be systematically evaluated to ensure the residents of Pasadena receive equitable access to affordable decarbonized energy." (p.l) However, lack of access to affordable energy is not distinct from lack of access to affordable energy from carbon resources. The problem is poverty: low income and middle-income residents have difficulty paying their bills regardless of the carbon characteristics of the resource. Phrasing the project plan in this way assumes that carbon resource electricity is cheaper than carbon free electricity. Didn't equity concern Pasadena before the enactment in 2023 of Climate Emergency Resolution 9977? c. The unvalidated assumption that carbon free electricity is more expensive than carbon- based electricity is reflected in several statements in the Project Plan:
"potential negative consequences of an energy transition" (p.l); and "how do rate increase proposals driven by transitioning to renewable sources compound on any existing financial burdens?" (p.3, objective 1.3) iC
In fact, the OSP did not include any modeling of the cost of supplying Pasadena's need for electricity with carbon-based fiiels. The largest drivers of increasing electric power cost in Pasadena and throughout the state and country are inflation, supply chain disruptions caused by war and tariffs, deferred infrastmcture investment and, in the case of the investor-owned utilities in California, liability and executive compensation bloat. 7 Renewable energy is the lowest cost electric power resource today. The price of grid scale batteries has dropped precipitously in the last 5 years. A distributed energy resource based system with more local solar and storage is a smart investment in resources that also adds resilience.
d. Is anyone modeling the cost efficiency of continuing to operate the Glenarm facility with all its repair and maintenance costs? Or the cost of upgrading and sourcing from the Magnolia gas plant in Burbank? Will the equity study take that cost reality into account? e. There is no reference in the study documents to analysis of utility bill income graduated discounts to deal with high utility bills. Nor is there an analysis of how Pasadena's puny discount program. (EAUP) could be fortified. It would be helpful if the study could address the response to PASADENA 1 GO'S many requests for more meaningful discounts: that California law prohibits or limits income-based reductions to bills. f. There is no reference in the study documents to analyze whether the aggregation of customer classes in the existing cost of service study produces a systemic bias on the costs of the distribution system that favors large rate payers.
g. The Project Plan identifies the challenges facing renters, and the reality that landlords have little incentive to install solar when their tenants pay the electricity bill but says nothing about the specific programs that can address this. The actual deliverables or "objectives" of the plan include only a very general objective 2.3 that refers to "incentives". A deliverable that specifically addresses how landlords might be incented to install solar and pass on savings would be useful. And what other utilities have done to address this. So would a recommendation for more meaningful income-based bill discounts and an analysis of California as it relates to income-based billing (often cited by utilities as a reason why income-based discounts are not an option).
h. The Project Plan does not address unemployment and underemployment and homelessness in Pasadena. Analysis of the feasibility and impact of workforce development and job opportunities for low-income residents to work in solar installation, storage, public education and other b-ansition areas would be helpful. How have other cities/utilities integrated workforce development with their transition plans? i. There is a cursory reference to impact on small business owners who may not be able to afford solar installation. This ignores the probability that most small business owners in Pasadena do not own their business premises and are tenants/leasees. j. Neither the Project Plan nor the update address the impact of city owned solar installed on municipal property on equity. PWPs position expressed in the OSP has been that municipal solar is our form of community solar.
k. The third objective in the Project Plan is to develop metrics, but the 4 metrics do not seem specific enough to be useful. 3.1 concerns whether PWP is getting the word out to low- income ratepayers. Is that a competence of a University of Michigan graduate student 8 team? We have an entire department in PWP devoted to this. 3.2 and 3.3 appear to be redundant; literally. They both concern what other utilities are doing to measure equity and what "challenges" PWP would have in adopting equity metrics. This is not a metric. Perhaps it is information if useful info about what other utilities are doing can be provided.
1. 3.4 asks what metrics can best capture equity outcomes. It's unclear if this is a question or a deliverable. Will the report propose specific metrics and how will those metrics help address the reality that low-income people have a hard time paying their utility bills, regardless of the carbon characteristics of the resource? m. There is no reference to the DAC, the existing California and Fed. Government metric that identifies disadvantaged communities. The Update slides refer to a "Geospatial and statistical analysis" of ratepayers. Is this redundant with existing information? n. What community groups will be interviewed and how were these selected? Have these interviews been completed? What questions are being asked in this "Semi-Sti^ictured" interview format?
o. When will the preliminary equity study be released for public comment? p. Neither the Project Plan nor the July 2026 Update address the equity concerns of not making a transition to carbon free electric power. It is beyond dispute that those who suffer most from climate change are low-income people. This has been dramatically evidenced by the Baton Canyon fire but is evident daily from the need for air conditioning and shelter from dangerous heat. The Social Cost of Carbon metric should be included in any analysis of equity
9 ^Nt Outlook
MSC Meeting 08.25.2026 Item 3. OSP Update
From
Date Man 8/24/2026 10:40 PM
To Jones, Justin <[email protected]>,· Rick Cole <[email protected]>,· Hampton, Tyron <[email protected]>,· Lyon, Jason <[email protected]> Cc Gao, Beilei <[email protected]>; PublicComment-AutoResponse <[email protected]>
[A] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button (PAB). For more information about the PAB view article "KB001 1474" on the DolT portal.
Dear Members of the Municipal Services Committee,
PWP's revised Progress Report (PR) for the Optimized Strategic Plan (OSP) shows little commitment to achieving the goals of Resolution 9977 or City Council's funding priorities established at the December 2025 workshop.
a. The only committed funding for municipal solar projects comes from the Public Benefit Charge (PBC). As a result, $20 Million of PBC funding will not be available to provide meaningful financial support to low-income residents. A total of $22.5 million remains unfunded for Municipal Solar.
b. PWP estimates the cost of installing solar panels on municipal buildings at $4.5 million per Megawatt. What assumptions were used to calculate this estimated cost? c. The Progress Report Update (p.11) states that PWP will seek grants or alternative financing for solar installations on city properties "in lieu of using ratepayer funds". "Ratepayer funds" consist of the Power Fund and Power Bonds committed for numerous other projects in the FY2027-2031 CIP such as the following:
Power Fund: Priority 11. 2003 Power Plant Upgrades (3280). Gas Turbines 3 & 4 @ $8.1 M
Power Fund: Priority 20. 2016 Power Plant Upgrades (3280). Gas Turbine 5 @ $5.9 M
Power Fund: Priority 21. 1975 Power Plant Upgrades (3182). Gas Turbines 1 & 2 @$1.65M
Power Bond: Priority 23. Fair Oaks Brookside Upgrades (3267) @ $65.961 million Power Bond: Priority 26. Deteriorated Pole Replacement Program (3233) @ $17.0 million
Power Bond: Priority 42. PWP Office Consolidation (3285) @ $32.630 million •
•
d. Core Strategies to Close the Funding Gap (p.12). The items listed are not strategies: #1 Rate Increase (this was threatened by PWP during council discussion of the three rate increases, April 2026, October 2026 and April 2027 for a total of 22.5%). 1a) Base Rates, 1b) Power Cost Adjustment, 1c) Public Benefit Charge. #2 Debt Issuance (e.g. Power Bond); #3 Cash Reserves (e.g. Power Reserve for Working Capital); Public/Private Partnerships (what are examples of such partnerships? Are any being negotiated at this time?); and Grant Funding (what grant applications have been submitted but not funded?). Power cost adjustments applied monthly starting March 2023 resulted in record net income for PWP but the surplus was transferred to the General Fund rather than paying for municipal solar/storage.
e. Language Used Indicates Lack of Commitment to Goals (p.11). All projects are intended to be constructed; ...Intended to support completion by June 2028...by June 2029; and anticipated in FY2030 (this is not the same as "by the end of Calendar Year 2030"). To succeed, a planning and implementation schedule requires more than intention. PWP's choice of words as well as reference to the "2028 Waypoint" suggests that PWP is contemplating a future announcement that they will not meet the goals of the OSP (e.g. do not intend to meet the goals).
f. Newly Announced University of Michigan SEAS Equity Project for City of Pasadena. This study, to be conducted at no-cost by graduate students, introduces a new concern for electric rate equity which was not part of the OSP or the Electric Rate Study.
Unfortunately, the SEAS Equity Project is based on unvalidated assumptions 1) that carbon free electricity is more expensive than carbon- based electricity; and 2) that Pasadena's transition to carbon-free electric power will negatively impact low-income households and Disadvantaged Communities.
The scope of work does not include any onsite fieldwork, essential for understanding local issues. It also assumes that only the Executive Summary will be "Public-Facing"; the interim and final reports and recommendations would be private.
All reports and recommendations by the University of Michigan study team must be public.
• The Interim Report, due November 30, 2026 must be presented to the Municipal Services Committee (MSC) at an open meeting. The presentation, on a date to be determined, can be via zoom link as has been the case for other PWP consultants. • The Final Report and Recommendations, due April 11, 2027, must be presented to City Council by the project team at an open meeting. To allow time for review, the text of the Final Report and Recommendations should be posted one week in advance of the presentation to City Council.
Thank you for your consideration of these concerns.
Sincerely,
Genette Foster, CD2