Agenda packet — South Lake Tahoe City Council, April 21, 2026 (part 3 of 4)

558
Adopted Fee Proposed Fee Proposed Fee
3/25/2025 per GCP 3.04%
Administrative Citations (Cont.)*
City Code:

4.35.020 - No Operator License - Mobile Vending Occurrence $100 n/a n/a $0 $100

4.40.020 - Nuisances Generally Occurrence $50 n/a n/a $0 $50

4.40.030 - Outdoor Display Occurrence $100 n/a n/a $0 $100

4.40.040 - Nuisances Generally - Noise Occurrence $100 n/a n/a $0 $100

4.45.040 - Abandoned Vehicle Occurrence $150 n/a n/a $0 $150

4.50.030 - Illegal Dumping Occurrence $1,000 n/a n/a $0 $1,000

4.50.050 - Unsuitable Trash Container - Commercial Occurrence $300 n/a n/a $0 $300

4.50.050 - Unsuitable Trash Container - Residential Occurrence $150 n/a n/a $0 $150

4.55 - Graffiti Occurrence $50 n/a n/a $0 $50

4.60 - Abandoned or Damaged Structure Occurrence $1,000 n/a n/a $0 $1,000

4.135.010 Police Service Occurrence $500 n/a n/a $0 $500

4.140.100 Private Patrols Occurrence $25 n/a n/a $0 $25

6.05 - Handbills Occurrence $100 n/a n/a $0 $100

6.10.160 - Exterior Lighting Occurrence $100 n/a n/a $0 $100

6.15 - Building Code Violation Occurrence $100 n/a n/a $0 $100

6.40.050 - Noncompliant Sign Occurrence $100 n/a n/a $0 $100

6.55.280 - No Home Occupation Permit Occurrence $100 n/a n/a $0 $100

7.05 - Sidewalk Snow Removal Occurrence $100 n/a n/a $0 $100

7.05.500 - Placing Snow in Right-of-Way Occurrence $100 n/a n/a $0 $100

7.05.560 - Sidewalk Snow Removal Occurrence $100 n/a n/a $0 $100 All Code Violations Not Listed Above or Specified in the Code Occurrence $250 n/a n/a $0 $250 Police Department (Cont.)
Fee Description Unit $ Change $ Change
*The fines for a second and any subsequent violation within a 12-month period for all violations with the exception of Vacation Home Rental violations will be double that of the previous fine assessed. The above penalties shall not supersede fines and penalties listed in the current City Code for specific violations. Except for Vacation Home Rental violations, under no circumstances shall a penalty be greater than $1,000.

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559
Adopted Fee Proposed Fee
3/25/2025 3.04%
Offices square foot or agreement $2.30 $0.07 $2.37
Ground Lease Rate square foot or agreement $0.35 $0.01 $0.36 Gratuitous Transportation vehicle $61
Conference/Meeting Room hourly rental hour $33 $1 $34
Conference/Meeting Room daily rental day $325 $10 $335
Restaurant Facilities Per agreement Per agreement n/a Per agreement Airport Terminal Lobby (upper/lower) hourly rental hour $64 $2 $66 Airport Terminal Lobby (upper/lower) daily rental day $391 $12 $403 Advertising Negotiated Negotiated n/a Negotiated
Advertising “Paper” Pick-Up Ads monthly $83
Advertising Digital monthly n/a n/a $90
Rental Car Ground Lease Area Negotiated / Market Rate Conditions Negotiated / Market Rate Conditions n/a Negotiated /
Market Rate
Conditions
Other Use of Terminal Negotiated Negotiated n/a Negotiated Commercial Filming:

Small Scale Commercial Filming (less than 50 persons); waived if City promotion per day/winter $472 $14 $486 Small Scale Commercial Filming (less than 50 persons); waived if City promotion per day/summer $786 $24 $810 Large Scale Film Production (film crew larger than 50 persons) - Prep / Strike Location per day $352 $11 $363
Large Scale Film Production (film crew larger than 50 persons) - Filming Days per day $5,857 $178 $6,035 Airport Escort Required on Filming Days per day $293 $9 $302 Movement Area Filming (Runway and/or Taxiway)* per day* $2,500* $0 $2,500* Large Scale Filming (more than 50 persons) Security Deposit Negotiated Based on Location Agreement n/a Based on Location Agreement
Large Scale Film Production (film crew larger than 50 persons) - City Film Support for Permits, Police, Fire, etc. Per Hour Fully Burdened Rate of Employee Used n/a Fully Burdened Rate of Employee Used Aviation Use of Airfield
GA Ramp Fee for A/C under 5,000 lbs (First 15 minutes free) day $10 $0 $10 GA Ramp Fee for A/C over 5,001 lbs (paid with landing fee) day $26 $1 $27 Special Event Fee (Celebrity Golf, A/C under 5,000 exempt) day n/a n/a $50 Monthly Tie Down Fee Flat Rate $79 $2 $81
Helicopter Takeoff Weight
3,001+ $50.00 flat rate $0 $50.00 flat rate
FixedWingTakeoffWeightPer1,000lbs.
5,501 - 19,000 $8 $0 $8
20,000 - 49,000 $10 $0 $10
50,000+ $12 $0 $12
Fuel Flowage Fee per gallon/per agmt $0.20 $0 $0.20
$ Change
Airport
Fee Description Unit
*Any filming conducted on runways or taxiways defined as the Movement Area by the Federal Aviation Administration will have a $2,500 per day additional fee on top of other rates.

Landing Fee
Landing Fee

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560
Adopted Fee Proposed Fee
3/25/2025 3.04%
Building:

All Hangars (Box and Tee) per square foot $0.96 $0 $0.96 All Storage Units (Aeronautical Use) per square foot $0.96 $0 $0.96 All Storage Units (Non-Aeronautical Use) Aeronautical use fee plus 10% Aeronautical use fee plus 10% n/a Aeronautical use fee plus 10%
Other Fees:

Parking per space $105 $3 $108
Airport Parking Lot Rental 100 Spaces 1/2 Parking Lot $1,171/day $35 $1,217/day Ground Transportation - Limousine; yearly per company $777 $24 $801 Gratuitous Transportation - Taxi Cab; yearly, negotiable vehicle $39 $1 $40 GA Ramp; hourly, 300 linear feet full width hourly $325 $10 $335 GA Ramp; day, 300 linear feet full width day $3,901 $119 $4,020 Taxiway A between H and J - North End; hourly hourly $325 $10 $335 Taxiway A between H and J - North End; daily day $3,901 $119 $4,020 Local Emergency Agency Training Ramp Use
(Non Airport Emergency) yearly $5,000 $0 $5,000
Airport Technician Fully burdened hourly rate Fully burdened hourly rate n/a Fully burdened hourly rate
Dump Truck, Sander, Grader, Loader hourly $222 $7 $229
Carpet Cleaning; includes equipment use +actual costs of City staff hourly + actual Fully burdened hourly rate n/a Fully burdened hourly rate
Airport Hangar Waitlist Fee each $250 $0 $250
Airport Lease Security Deposit (refundable deposit) each $750 $0 $750 Airport Key Card (refundable deposit) each $50 $0 $50
Lost/Stolen Key Card Replacement (non- refundable) each $50 $0 $50 Airport Hangar Key (refundable deposit) each $25 $0 $25 Lost/Stolen Hangar Key Card Replacement (non- refundable) each $25 $0 $25 **Local Emergency Agency Partners conducting training exercises to improve interagency airport emergency response is exempted from use fees.

Airport (Cont.)
Fee Description Unit $ Change

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561
Adopted Fee Proposed Fee Proposed Fee
3/25/2025 per GCP 3.04%
Appeals* per appeal $380 $873 $1,253 $0 $1,253
Document Printing and Copying - .10 per page plus postage document page $0.10 $0 $0.10 $0 $0.10 City Council Chambers Use Application Fee per application $28 $7 $35 $0 $35 City Council Chambers Rental, M-F, 8-5 p.m. per hour $44 $6 $50 $0 $50 Video Meeting Electronic File Transfer, 1 per Drive thumb drive $5 $0 $5 $0 $5 Verbatim Transcript Service actual outsource cost hourly or actual outsource cost n/a hourly or actual outsource cost
$0 hourly or actual
outsource cost
Notary Service per signature $15 $0 $15 $0 $15
Notary Service - Providing California Notary
Acknowledgement or Jurat Form per form $1 $0 $1 $0 $1
Agenda Mailing Service, .10 per page plus postage agenda .10 per page plus postage $0 .10 per page plus postage
$0 .10 per page plus
postage
Filming Application Fee application $197 ($33) $164 $0 $164 Public Property Use Fee (for filming only) use $767
Temporary Sign Deposit (yard signs) campaign $174 $0 $174 $0 $174 City Council AV Service Fee each n/a n/a $99 $0 $99
Film Application Fee Special per application n/a n/a $192 $0 $192 Film Appliation Fee Rush (less than 7 business days) per application n/a n/a 150% base fee $0 150% base fee Film Permit Change Fee each n/a n/a $132 $0 $132
Adopted Fee Proposed Fee Proposed Fee
3/25/2025 per GCP 3.04%
Business and Professions Tax Rates:

Schedule A (per $1,000 gross receipts) per 1,000 gross receipts $1.07 n/a n/a $0 $1.07 Schedule B (per $1,000 gross receipts) per 1,000 gross receipts $1.62 n/a n/a $0 $1.62 Schedule C (per $1,000 gross receipts) per 1,000 gross receipts $2.14 n/a n/a $0 $2.14 Schedule D (per $1,000 gross receipts) per 1,000 gross receipts $2.69 n/a n/a $0 $2.69 Schedule E (per $1,000 gross receipts) per 1,000 gross receipts $3.22 n/a n/a $0 $3.22 Schedule N (non-profit 501(c)(3); veterans; etc.) n/a $0.00 n/a n/a $0 $0.00 Maximum Annual Amount of Tax (Measure B, June 2012) application $20,000.00 n/a n/a $0 $20,000.00 Administrative Fee - New license application (Including $13 31 Business License Technology Fee) application $86 $22 $108 $0 $108
Administrative Fee - New Business One Time 6 Month License Application application $42 ($10) $32 $0 $32 Administrative Fee - Annual Renewal (Including $13 31 Business License Technology Fee) application $68 ($5) $63 $0 $63
AB1379 (amended SB1186; ADA info and access fee - State of CA mandated; effective 1/1/2018 through 12/31/2023) per business certificate $4 $0 $4 $0 $4 Business License Technology Fee; collected with admin fee business application $13 $18 $31 $0 $31 Business License Certificate - duplicate copy certificate $19 ($7) $12 $0 $12 Lien Release Fee lien Passed on to Seller through Escrow n/a Passed on to Seller through Escrow n/a Passed on to Seller through Escrow
Administrative Fee for Delinquent Refuse Collections lien $87 $0 $87 $0 $87 City Clerk
Fee Description Unit
Finance
$ Change
$ Change $ Change
Fee Description Unit $ Change
*Cost based Appeal Fee is due at filing; if appellants prevail (the decision is reversed or materially modified in their favor), the full fee will be refunded.

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562
Adopted Fee Proposed Fee Proposed Fee
3/25/2025 per GCP Proposed Fee
TOT and Business License Reports:

Delinquent Tax Analysis per project At cost using fully burdened hourly rate n/a At cost using fully burdened hourly rate n/a At cost using fully burdened hourly rate Motel Tax Master (name/address listing) per report $63 ($23) $40 $0 $40 Individual TOT Report per motel/per year $18 ($1) $17 $0 $17 Vacation Home Rental Master Report per report $68 ($28) $40 $0 $40 Vacation Home Rental Label Report per report $63 + cost of labels ($23) $40 + cost of labels $0 $40 + cost of labels Business License Master Report, Standard Format per report $63 $16 $79 $0 $79 Business License Master Report Requiring Specific Formatting Due to Information Request per report $63 + fully burdened hourly rate $16 $79 + fully burdened hourly rate $0 $79 + fully burdened hourly rate
Business License Label Report per report $63 + cost of labels Miscellaneous Fees:

Returned Check (NSF) Processing 1st Check per check $28 ($3) $25 $0 $25 Returned Check (NSF) Processing Subsequent Checks per check $28 $7 $35 $0 $35 Geobase Information Service, Research per project At cost using fully burdened hourly rate n/a At cost using fully burdened hourly rate n/a At cost using fully burdened hourly rate Stop Payment Fee per check At cost using actual bank charge n/a At cost using actual bank charge n/a At cost using actual bank charge
Finance (Cont.)
Fee Description Unit $ Change $ Change

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563
City of SLT Financial Policies – Strengthening Financial Position 1 Rev. February 2013 Financial Policies:

Strengthening Financial Position
To preserve General Fund revenues, the City will take proactive steps to strengthen its financial condition. The following policies shall guide those efforts.

A. Diversified Economy and Revenues

1. Preservation of Commercial and Industrial Development Opportunities
The City shall diversify its economic base by encouraging a broad range of private sector commercial and industrial employment.

While it is important to maintain an inventory of land zoned for residential use, the City shall carefully consider economic impacts before rezoning any commercial or industrial land to residential use.

The City Council shall be presented with an analysis of trend data comparing percentages of residential development to
commercial/industrial development.

2. Jobs/Housing Balance
The City shall promote an equal ratio of jobs to housing, and shall encourage the expansion of businesses that will provide opportunities for residents to work in the community.

3. Effect of Fees/Charges/Rates on Commercial and Industrial Development
In setting fees, charges, and/or rates on commercial and industrial development, the City shall evaluate the comparative fee structure of other neighboring jurisdictions. The City shall strive to implement fees, charges and/or rates that are competitive with other jurisdictions and that shall not have a negative impact on sales tax or other valuable sources of revenue.

B. Economic Incentives for Commercial and Industrial Development The City shall provide economic incentives for commercial and/or industrial development when such incentives shall lead to a positive economic return for the City in terms of jobs, workforce housing opportunities, enhanced revenues, a more diversified economic base, or enhanced transportation or other public services. Any economic incentive policies shall be attached as an Appendix to this document. 564
City of SLT Financial Policies – Strengthening Financial Position 2 Rev. February 2013 C. Intergovernmental Revenues

1. Grants
Grants from federal, state or private organizations are an appropriate and desirable means of enhancing available revenues. However, grant funding is rarely a long-term, stable economic base. Grant applications and subsequent grant awards shall be approved by the City Council. The City shall ensure that grant funding is appropriately leveraged to enhance City services as set forth in its Grant Funding and Compliance Policy. (See separate policy document).

2. State Shared Revenues
To protect against fluctuations in intergovernmental revenues, the City shall maintain 25 percent General Fund Committed fund balance as a reserve against unanticipated or uncontrollable reductions in state subventions.

D. User Fee Cost Recovery
The City provides certain services to its residents and businesses that are funded in whole or in part by fees that are intended to cover all or a portion of the cost of providing such services. To the extent User Fees do not cover the entire cost of providing such services; the General Fund subsidizes the additional expense. Careful examination of User Fees shall enhance the stability of the General Fund. The following policies shall be implemented to ensure that User Fees keep pace with changes in the cost-of-living as well as changes in methods or levels of service delivery.

1. General Principles
a. Revenues derived from User Fees shall not exceed the reasonable cost of providing the service.
b. Cost recovery goals shall be based on the total cost of delivering the service, including all direct costs, departmental
administration costs, and organization-wide support costs such as accounting, personnel, data processing, building and/or vehicle maintenance, and insurance.
565
City of SLT Financial Policies – Strengthening Financial Position 3 Rev. February 2013 c. The method of assessing and collecting fees shall be as simple as possible in order to reduce the administrative cost of collection. Although a high cost of recovery may be appropriate for specific services, if it is impractical or costly to charge the user, a lower level of cost recovery shall be appropriate. d. Fee levels shall be sensitive to the “market” for similar services, including the provision of services by private sector service or program providers. User Fees shall not be set so high that services shall not be used. Conversely, User Fees shall not be set so low that the City is stimulating a demand by artificially low prices. Specifically, the City shall carefully consider whether it is appropriate to provide services at a subsidized cost (or a cost that does not include all cost of services, such as room rental costs, building maintenance or personnel charges) if such services are available through the private sector.
e. Fee levels shall be sensitive to smaller, infrequent users of the service, for example, small businesses that may have less of an opportunity to recover the cost of User Fees through ordinary business income.
f. The level of cost recovery should consider the community-wide versus special benefit of the program or activity that is the subject of the User Fee. The use of general-purpose revenues shall be appropriate for community-wide services, while User Fees at some level shall be appropriate for services that are of special benefit to easily identified individuals or groups. (For example, it would be unusual to charge a User Fee for a community-wide event such as an Easter Egg Hunt, while it would be appropriate to charge a User Fee at some level for an adult recreational program with a limited number of participants.) g. The level of cost recovery shall consider the financial benefit to the service user, and whether the user is a service driver or a service recipient. In cases where there user benefits financially from the provision of the service, and the service would not be provided but for the expanded business or revenue
opportunities, the level of User Fee should more closely approximate 100% cost recovery. (For example, a developer receives financial benefit at the conclusion of the development review process, and the City would not provide the review of development applications but for the expanded business or revenue opportunity for the developer. While the community may be the actual service recipient of the review of development applications, the developer is the service driver.)
566
City of SLT Financial Policies – Strengthening Financial Position 4 Rev. February 2013

2. Factors Favoring High Levels of Cost Recovery. High cost recovery levels are especially appropriate in the following circumstances:
a. The service is similar to services provided through the private sector.
b. Other private or public sector alternatives could or do exist for the delivery of the service.
c. The demand for the service is high and cost of service is needed as a mechanism to help control demand.
d. The cost of service can be used as a mechanism for
encouraging compliance with the law. (For example, police response to false burglary alarm calls.)
e. The service is regulatory and voluntary compliance is not expected to be the primary method of detecting failure to meet regulatory requirements. (For example, building permit, plan checks and subdivision review services.)

3. Factors Favoring Low Levels of Cost Recovery. In addition to the general policy considerations noted above, low cost recovery levels are appropriate in the following circumstances:
a. The program or services falls within the range of general public services which are provided to the community to promote the general safety, health and well-being of the community, and there is no intended relationship between the amount paid and the benefit received. (For example, police and fire services, general access to park facilities.)
b. The service is not generally available through private sources and is necessary to promote the general safety, health and wellbeing of the community. (For example, teen after school programs.)
c. The service is generally non-recurring, delivered on a “peak demand” or emergency basis, cannot reasonably be planned for on an individual basis, and is not readily available from a private sector source. (For example, police and fire services in response to emergencies.)
d. Collecting fees would discourage compliance with regulatory requirements and adherence to regulatory requirements is not 567
City of SLT Financial Policies – Strengthening Financial Position 5 Rev. February 2013 readily identified by the City. (For example, home-based business licenses.)

4. Periodic Adjustment of User Fees. A comprehensive analysis of User Fees shall be made at least every three years. In the interim, if applicable, fees shall be adjusted by no less than the amount of the annual change in the Consumer Price Index. Fees may also be adjusted more frequently based on supplemental analysis whenever there has been significant change in the method, level or cost of service delivery. A schedule reporting the rate of all User Fees shall be included as an Appendix to the budget, and the City Council may direct adjustment in User Fees as part of the annual budget process.

5. Development Review Programs. Cost recovery for development review programs shall be very high, and in most cases the goal for cost recovery should be 100%. The City shall also impose clear performance standards to ensure that there is high value for services rendered. This cost recovery principle applies to the following types of development review programs:
a. Planning (planned development permits, tentative and parcel maps, rezonings, general plan amendments, variances, use permits, etc.)
b. Building and safety inspections (building permits, structural plan checks, fire inspections, etc.)
c. Engineering (public improvement plan checks, inspections, subdivision requirements, encroachments, etc.)
E. Enterprise Fund Rates
Each of the enterprise funds shall be operated in a manner to fully cover the total direct and indirect costs (including operations, capital outlay and debt service) for operating such functions so as to avoid General Fund subsidies for enterprise operations.

1. Rates shall be reviewed on an annual basis and shall be adjusted as appropriate and equitable.

2. Rates charged for enterprise activities shall be compared periodically against rates charged by other public agencies for purposes of benchmarking cost of service and operations. Private contracting opportunities shall be evaluated as appropriate as a means of reducing expenses, while remaining in compliance with the City’s Purchasing Policies.
568
City of SLT Financial Policies – Strengthening Financial Position 6 Rev. February 2013 F. Collections
The City shall implement a uniform collection program. The costs of this collection program shall be reviewed annually to ensure the total direct and indirect costs are fully covered. The costs shall be passed on to the delinquent customers as a penalty in the collection process.

The City’s options for collection are:
a. Property Liens. A lien shall be placed on the property should the owner fail to pay charges, penalties and interest charges.

Enforcement of liens shall be made in accordance with the applicable section of the City Code subject to delinquent payment, and may be initiated through a court ruling. Collections against property liens are typically done by issuing a warrant for enforcement or foreclosure proceeding in the case where a deed of trust has been secured by the City against the property, and may result in a sale pursuant to a writ of execution.
b. Special Assessments. A resolution must be presented to the City council to declare a special assessment on a delinquent customer’s real property. Upon passage and adoption a certified copy shall be recorded with the County Recorder’s office. The assessment shall be collected at the same time and in the same manner as ordinary municipal taxes. Special assessments are typically levied as a result of delinquent property assessments, non-payment of nuisance abatement costs or refuse fees. c. Withholding Entitlements. The City may withhold issuing any licenses, permits and other entitlements until payment for charges due, including penalties and interest is received. d. Collection Agency (other enforcement procedures). The City can take other actions allowed for enforcement of a civil judgment.

AFFIDAVIT OF PUBLICATION
State of Florida, County of Orange, ss:

Anjana Bhadoriya, being first duly sworn, deposes and says: That (s)he is a duly authorized signatory of Column Software, PBC, duly authorized agent of Tahoe Daily Tribune now is, and during all times herein named, was a corporation duly organized and existing under the laws of the State of California, and now is, and during all times herein named was the printer of Tahoe Daily Tribune, a newspaper of general circulation, as defined by section 6000 of the Government Code of the State of California, printed and published daily (Sundays excepted) in the City of South Lake Tahoe, County of El Dorado, State of California, and that affiant is the principal clerk of said Nevada County Publishing Co.

That the printed advertisement hereto annexed was published in the said Tahoe Daily Tribune, for the full required period of 1 time(s) commencing on Apr. 3, 2026, and ending on Apr. 3, 2026, all days inclusive.

PUBLICATION DATES: Apr. 3, 2026
NOTICE ID: LCylN4iTAt5Zr09v1GGU
PUBLISHER ID: 397567
NOTICE NAME: Master Fee Schedule April 21 Hearing
Publication Fee: $167.73
I certify, under penalty of perjury, the forgoing is true and correct. [$signersig ]
(Signed)______________________________________ [$seal]

VERIFICATION
State of Florida
County of Orange
Subscribed in my presence and sworn to before me on this: [$date] [$notarysig ]
______________________________
Notary Public
[$disclosure]
See Proof on Next Page
Master Fee Schedule April 21 Hearing - Page 1 of 2
04/03/2026
Notarized remotely online using communication technology via Proof. 570
Master Fee Schedule April 21 Hearing - Page 2 of 2
571
Resolution 2026-XXX April 21, 2026 Page 1 of 2
Resolution 2026-XXX
Adopted by the City of South Lake Tahoe
City Council
April 21, 2026
Adopting the Annual Master Schedule of Fees and Charges for City Services 2025-2026

BACKGROUND
A. User fees in California are required to conform to the California Constitution including Proposition 26 and statutory requirements including Government Code Sections 66014 through 66018.5. User fees imposed to provide specific services, to cover reasonable regulatory costs to issue licenses and permits, for entrance to or use of city property, and fines for violating the City Code are generally excluded from the definition of "tax" under Proposition 26. Section 1 (e) of article XIIIC of the California Constitution describes these exceptions.

B. The City of South Lake Tahoe engaged Government Consulting Partners (GCP) in April 2025 to conduct a Comprehensive User Fee Study using 2024 financial and operational data. The study evaluated the full cost of City services and recommended fee structures that support the City's cost‑recovery objectives. At its March 24, 2026 meeting, the City Council directed that fees be set to recover the cost of providing services in order to minimize General Fund subsidies, with the exception of Emergency Medical Services (EMS) and selected recreation and community programs, which will remain partially subsidized based on policy considerations. Additionally, appeal fees shall be set at full cost recovery and refunded if the appellant prevails.

C. The City Council most recently adopted a CPI-based fee adjustment on March 25, 2025.

Because the User Fee Study is based on 2024 financial and operational data, it is fiscally prudent to update the City's fee schedule to reflect CPI changes that have occurred since that adjustment.

D. Pursuant to Government Code Sections 66016 and 66018, certain fees must be adopted by Resolution after providing and holding a public hearing. The City Council held a duly noticed public hearing on April 21, 2026.

BASED ON THE FACTS SET FORTH IN THE BACKGROUND, BE IT RESOLVED, that the City Council of the City of South Lake Tahoe:

1. Adopts the new fee amounts according to the implementation dates as set forth in the applicable codes and all fees and charges as presented in the Master Fee Schedule attached hereto as Exhibit "A."
572
Resolution 2026-XXX April 21, 2026 Page 2 of 2
Adopted by the City of South Lake Tahoe City Council on April 21, 2026 by the following vote:

Yes:

No:

Absent:

Abstain:
________________________ Date: _________
Cody Bass, Mayor
Attest:
_______________________
Susan Blankenship, City Clerk
The presence of electronic signature certifies that the foregoing is a true and correct copy as approved by the South Lake Tahoe City Council.
573
City of South Lake Tahoe
Master Fee Schedule
Adopted April 21, 2026
574
Master Schedule of Fees and Charges for City Services
Table of Contents

PARKS & RECREATION
MULTIGENERATIONAL RECREATION & AQUATICS CENTER .................................................................... 1 OTHER PARKS & RECREATION FACILITIES................................................................................................ 4 GOLF COURSE .......................................................................................................................................... 5 CAMPGROUD........................................................................................................................................... 5 BOAT RAMP ............................................................................................................................................. 5 ICE ARENA................................................................................................................................................ 5

DEVELOPMENT SERVICES & PUBLIC WORKS DEPARTMENTS
DEVELOPMENT SERVICES-BUILDING....................................................................................................... 7 DEVELOPMENT SERVICES-HOUSING........................................................................................................ 7 DEVELOPMENT SERVICES-PLANNING...................................................................................................... 7 PUBLIC WORKS-ENGINEERING ................................................................................................................ 9

POLICE AND FIRE DEPARTMENTS
FIRE ........................................................................................................................................................ 10 POLICE.................................................................................................................................................... 11

INTERNAL SERVICES
AIRPORT................................................................................................................................................. 15 CITY CLERK ............................................................................................................................................. 16 FINANCE................................................................................................................................................. 16 575
Resident Non-Resident
Gym Rentals
Full (2 Courts) hourly $250 n/a
1/2 Gym (1 Court) hourly $125 n/a
1/4 (1/2 Court) hourly $65 n/a
Stage Rental Fee each $150 n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Facility Rental Setup Fee per hour per staff $48 n/a
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Meeting Room Rentals
Rental per hour $25 n/a
Partner/Affiliate Use No Charge No Charge n/a
Recognized Local Youth Sport Organizations May Have Free Use of Meeting Rooms in the Recreation & Aquatics Center No Charge No Charge n/a Youth Organization Meetings hourly $15 n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Senior Services Meetings No Charge No Charge n/a
Community Room Rentals
Rental hourly $55 n/a
Stage Rental Fee each $150 n/a
Recognized Local Youth Sport Organizations May Have Free Use of Meeting Rooms in the Recreation & Aquatics Center No Charge No Charge n/a Youth Organization Meetings hourly $15 n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Senior Services Meetings No Charge No Charge n/a
Facility Rental Setup Fee per hour per staff $48 n/a
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Commercial Kitchen Rental
Commercial Kitchen Rental hourly $50 n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Facility Rental Setup Fee per hour per staff $48 n/a
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Dance/Fitness Room Rental
Rental hourly $55 n/a
Stage Rental Fee each $150 n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Senior Services Meetings No Charge No Charge n/a
Facility Rental Setup Fee per hour per staff $48 n/a
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Event Space Rentals
Event Space Weekday Mon-Thurs $/hr. $350 n/a
Event Space Weekend Fri -Sun $/hr. $450 n/a
Event Space After Hours per hour $100 n/a
Stage Rental Fee each $150 n/a
Audio Video Ad On each $150 n/a
Event Space Facility Rental Setup Fee per hour (2 hour minimum) $48 n/a Ceremony Chair Package $7-$9 per chair comps $8 per chair n/a Non-Profit Organizations 25% off base rate 25% discount n/a Multigenerational Recreation & Aquatics Center
Adopted Fee 11/4/2026 Fee Description Unit

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Resident Non-Resident
Event Space Rentals (Cont.)
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Pool Rental
Swimming Pool Rental Rate hourly $85 n/a
Lap Pool Rental (Full) hourly $85 n/a
Lap Pool Rental (1/2 pool) hourly $45 n/a
Lap Lane Rental (1 Lane) hourly $15 n/a
Play Pool Rental hourly $95 n/a
Stage Rental Fee each $150 n/a
Lifeguard Hourly Rate (Rental) hourly actual cost at fully burdened rate n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Facility Rental Setup Fee per hour per staff $48 n/a
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Party Room
Rental Weekday Mon-Thurs $/hr. $40 n/a
Rental Weekend Fri -Sun $/hr. $50 n/a
Recognized Local Youth Sport Organizations May Have Free Use of Meeting Rooms in the Recreation & Aquatics Center No Charge No Charge n/a Youth Organization Meetings hourly $15 n/a
Non-Profit Organizations 25% off base rate 25% discount n/a Facility Rental Setup Fee per hour per staff $48 n/a
Group Rentals May Be Subject to $500 minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,500 Maximum n/a Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum n/a Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due n/a
Party Packages
Mini Mountain Movers Party Package session rental $225 n/a Batting Cages 2-hour party $300 n/a
Rockwall 1-hour party $200 n/a
Obstacle Course Pool Add On per event $75 n/a
Pool Party Package session rental $200 n/a
Aquatics
Obstacle Course per participant $5 plus facility drop in fee n/a
Lifeguard Certification Course per participant $235 n/a Water Safety Instructor Certification Course per participant $299 n/a Junior Lifeguards per participant per 4-week session $200 n/a Mini Lifeguards per participant per 4-week session $185 n/a Swim Team per participant per month/session $120 n/a
Development Swim Team per participant per month/session $105 n/a Aquatics Special Class (Ex Log Rolling) per participant per class $7 n/a Float Fit Aquatics Fitness Classess 30 minutes each $10 n/a Float Fit Aquatics Fitness Classess 60 minutes each $20 n/a Float Fit Aquatics Fitness Classess 90 minutes each $30 n/a Locker Rental per month $20 n/a
Swimming Programs
H2O Exercise: Adult 18-54 years each $8 $10
H2O Exercise: Senior or Permanent Disability each $6 $8 H2O Exercise: Adult 18-54 years - 10 Use Pass each $60 $75 H2O Exercise: Senior or Perm Disability - 10 Use Pass each $50 $65 H2O Exercise: Individual Annual Pass each $295 $369
Multigenerational Recreation & Aquatics Center (Cont.)
Fee Description Unit Adopted Fee 11/4/2026

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Resident Non-Resident
Swimming Programs (Cont.)
Swimming Lessons (Group) 8 Class Session each $50 n/a
Swimming Lessons (Group) 6 Class Session each $40 n/a
Swimming Lessons (Group) 4 Class Session each $30 n/a
Private Lessons (25 minutes) 1 Student each $33 n/a
Private Lessons (25 minutes) 2 Students each $45 n/a
Private Lessons (25 minutes) 3 Students each $55 n/a
Master Swim Drop In each $10 $12
Master Swim Session 10 Use Punch Card each $70 $85
Non-Profit Organizations 25% off base rate 25% discount n/a Facility Day Use: Includes Gym, Natatorium, Exercise Room, Walking Track Adult: 18-54 Years each $10 $15
Youth: 18 Years and Under each $8 $12
Senior 55 Years and Up or Permanent Disability each $8 $12 Public Shower Adult/Discount for Senior, Disabled, and Youth each $3/$2 n/a Daily Day Rate for Medi-Cal, WIC , and Veteran Participants Adult: 18 and Over each $3 n/a
Youth: 18 Years and Under each $2 n/a
Facility Multi-Use Day Passes: Includes Gym, Natatorium, Exercise Room, Walking Track Adult - 10 use punch card each $80 $100
Adult - Monthly each $65 $81
Adult - 90 Day (City Employees Only) each $45 n/a
Senior or Permanent Disability -10 use punch card each $65 $81 Senior or Permanent Disability - Monthly each $50 $63
Children 3 years and Under Are Free with a Paying Adult for Recreation Drop in only each Youth - 10 use punch card each $65 $81
Youth Monthly each $50 $63
Couple Annual Pass each $690 $863
Individual Annual Pass each $480 $600
Youth Annual Pass each $300 $375
Youth Annual Pass for GPA of 3.5 or higher (Resident Only - Ages 14-17) each $150 n/a Senior Annual Pass each $300 $375
Family Annual Pass (2 adults + 2 children): Includes 20% discount on party packages and access to special member days each $825 $1,031
Family Annual Pass (1 adult + 1 child): Includes 20% discount on party packages and access to special member days each $560 $700
Family Annual Pass - Each Additional Adult each additional adult $345 $431 Family Annual Pass - Each Additional Senior or Child each additional senior or child $150 $188 Administrative Fee for replacement of annual passes only each $10 n/a Non-Profit Organizations 25% off base rate 25% discount n/a Recreation Add Ons
Batting Cages per participant $5 plus facility drop in
fee n/a
Batting Cages - 10 punch card each $100 includes drop in fee n/a
Rockwall per participant $5 plus facility drop in
fee n/a
Rockwall - 10 punch card each $100 includes drop in
fee n/a
Golf Simulator hourly $50 n/a
Rockwall hourly $150 n/a
Rec Center Special Events
Puzzle Event per team $40 n/a
Family Dance per participant (adults and children
age 2 and older)
$15 n/a
Family Dance (Childred Under 2 Years Old) No Charge No Charge n/a Gym Sports Event per team $40 n/a
Pickleball Tournament per team $75 n/a
Family Game Night Part of Season Pass No Extra Charge n/a Pool Special Events per participant $15 n/a
Pickleball Mixer per participant $25 n/a
Adult Programs
Adult Volleyball League Team per season participant $400 n/a Adult Volleyball League Individual per season participant $66 n/a Adult Basketball League Team per season participant $550 n/a Adult Basketball League Individual per season participant $75 n/a Fee Description Unit Adopted Fee 11/4/2026
Multigenerational Recreation & Aquatics Center (Cont.)

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Resident Non-Resident
Adult Programs (Cont.)
Pickleball Clinic Adults per participant per session $30 n/a Pickleball Clinic Youth per participant per session $25 n/a Senior Games per participant per event $10 n/a
Personal Training per participant per hour $60 $75
Adult Cornhole League Individual per season participant $50 n/a Adult Fitness Classes 30 minutes each $10 $12
Adult Fitness Classes 60 minutes each $15 $18
Adult Fitness Classes 90 minutes each $20 $25
Late Payment Registration for league play 10% increase to base fee 10% increase to base fee n/a
Youth and Teens
Parents Night Out per participant $40 n/a
Kid's Summer Day Camp each $40 $50
Kid's Summer Day Camp (Weekly Fee) each $150 $188
Kid's Summer Day Camp Multi-Child Discount 10% off base rate 10% off base rate n/a Youth Basketball League per season participant $65 n/a
Youth Flag Football League per season participant $95 n/a Youth Street Hockey per season participant $70 n/a
After School Enrichment Program per season participant $120 n/a Tiny Tots Sports League per season participant $60 n/a
Youth Volleyball League per season participant $75 n/a
Youth Soccer League per season participant $65 n/a
Multi Child Discount 10% off base fee 10% discount n/a
Late Payment Registration for league play 10% increase to base fee 10% increase to base fee n/a
Adopted Fee
4/21/2026
Senior Center Large Multi-Purpose Room hourly $64
Senior Center, Conference Room hourly $46
Senior Center, Arts & Crafts Room hourly $46
Outdoor Park Facility Rentals:

Alcohol Use Permit, City Sanctioned Public/Private Outdoor Facilities each $68 Bijou Park, Kiwanis Picnic Shelter (4 Hours) hourly $178 Bijou Park, Rotary Picnic Shelter (4 Hours) hourly $178 Recreation Complex Group Picnic Areas (4 Hours) hourly $178 Gazebos and Picnic Areas beyond 4 hour minimum rental hourly $47 Mon-Thur $/hr $229
Fri & Sun $/hr $296
Sat $/hr $360
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
Public Special Event Park Rentals:

Lakeview Commons or Bijou Community Park Special Event Rental, Attendance up to 500 persons day $800
Lakeview Commons or Bijou Community Park Special Event Rental, Attendance 501- 1,000 persons day $1,405
Lakeview Commons or Bijou Community Park Special Event Rental, Attendance 1,001- 2,000 persons day $1,900
Bijou Community Park Lawn Space (up to 100 persons) hourly $50 Bijou Bike Park or Skate Park Rental day $262
Disc Golf Course Rental for Tournaments & Special Events (Bijou Park) day $275 Bijou Park Concession (absent lease agreement) day $299 Bijou Community Park Parking Lot Rental daily $215
Community Playfield Parking Lot Rental daily $215
Facility Rental Setup Fee hourly $48
Special Event Vendor Fee Not to Exceed $125 per event Not to Exceed $125 per event
Non-Profit Organizations 25% off base rate 25% discount Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
Group Rentals May Be Subject to $500 Minimum or $1,500 Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe $500 (Security Deposit) $500 Minimum or $1,000 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe $15 (Cancellation Fee) $15 Minimum or$50 Maximum Multigenerational Recreation & Aquatics Center (Cont.)
Fee Description Unit Adopted Fee 11/4/2026
Private Rental: Regan Beach West (Per Hour; 2-Hour Minimum) Other Parks & Recreation Facilities
Fee Description Unit

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Adopted Fee
4/21/2026
9 Hole each $22
9 Hole Senior each $20
9 Hole Junior (17 and under) each $12
9 Hole Family (1 adult & 1 Junior - 17 and under) each $26 Add 9 Holes each $14
Twilight (last 2 hours of tee times) each $19
Cart Rental each $6
Club Rental each $17
PASSES:
20 Use each $308
10 Use each $171
10 Use Twilight (last 2 hours of tee times) each $143
10 Use Senior each $154
10 Use Family (1 adult & 1 Junior - 17 and under) each $198 10 Use Junior (17 and under) each $94
Individual Adult Season Pass (no restrictions) each $495 Individual Senior Season Pass (no restrictions) each $450 Individual Junior Pass (no restrictions) each $450
Administrative Fee for replacement of annual passes only each $10 Bijou Golf Course use in partnership with Boys and Girls Club No Charge No Charge Adopted Fee
4/21/2026
Campground Site Fee - No hook up, up to 6 people and 1 car (includes $10 infrastructure fee) per day $47
Standard Cabin (includes $10 infrastructure fee) per day $90 Reservation Fee (non-refundable) each $10
Cancellation Fee (Inside 30 days from arrival date) One night rental fee $50 Cancellation Fee (Outside 30 days of arrival date) each $10 Dump Fee (charged to campers not staying in our campground) each $15 Extra person each $6
Visitor Day Use each $5
Pets each $2
Extra Vehicle (no holding tanks) each $6
Motorcycles and Electric Scooters each $3
Late Checkout Fees per site $10
Adopted Fee
4/21/2026
Day Use per day $17
Annual Pass each $138
Adopted Fee
4/21/2026
ICE ARENA:

Learn to Play n/a Free
Morning School Skate n/a Free
School Skate Week (PE program) n/a Free
Military Discount (Served In combat area) n/a Free
Wounded Warriors (military event) n/a Free
Charity Events (i.e. St. Baldrick's), fees subject to review n/a Ice free all day Ice Sheet Rental See schedule for rates by time per hour $491 Party Room Full (hourly - 1 hour minimum) per hour $125 Golf Course
Fee Description Unit
Campground
Fee Description Unit
Boat Ramp*
Ice Arena**
Fee Description Unit
*The Division of Boating and Waterways currently limits these fees to $17 for Day Use and $138 for an Annual Pass.

Fee Description Unit

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580
Adopted Fee
4/21/2026
SKATING PROGRAMS:

Public Skate: 11 years & up per person $20
Public Skate: Youth (10 & under) per person $10
Public Skate: Child (3 & under) per person Free
Public Skate: Senior 55 & up per person $7
Blue Card (available to frequent users/members) each n/a Skate Rental each n/a
Free Style - Drop - In each $15
Hockey - Drop - In per person $20
Hockey League: Adult 18-54 years, 10 games each $250
Hockey League: Single Game each $25
Hockey League: Youth each $113
SKATING LESSONS:

Skate/Hockey School: per lesson per lesson $20
Private Skate lessons (1 student, 2 student, 3 or more) per lesson Varies by instructor City Sponsored Ice Programs:

Partnerships with City recreation programs fee determined by program type and need
Fee determined by program type and
need
Facility Rentals (various use agreements):

Year Round Rentals for Rec Programs/Rec Center typically billed monthly Refer to contract Refer to contract **The listed Ice Arena Fees represent the maximum allowable charges.

Ice Arena (Cont.)**
Fee Description Unit

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Adopted Fee
4/21/2026
Building Permit & Inspection:

Building Permit Fee (25% plan review deposit due with application) Valuation shall be determined at the discretion of the Building Official utilizing the most current square foot valuation based on the proposed use and type of construction as published by the International Code Council or construction contract value submitted by the applicant
% of valuation 2% of valuation - $271 minimum
Administrative Processing per hour/ 1 hr min. $151
Active Building Permit Extension each $197
Building Plan Review Extension each $197
Building Plan Review per hour / 1 hr min. $132
Stop Work Notice of Violation each $441
Stop Work/Red Tag Permit Fee each 2x the Building Permit Fee Special Building Inspections
per hour / 1 hr. min. regular working
hours
per hour / 3 hr. min. outside of
regular working hours
$182
Building Inspection/Reinspection Fee each $182
Document Printing & Copying per page $0.10
Permit Technology Fee each permit $31
Illegal Unit Review each $1,141
Admin Fee for Cost of Collection on Liens, Nuisance, etc. % of collection costs 25% Temporary Certificate of Occupancy Application each $182 Demolition Permit each $453
Residential Fire Sprinkler % of valuation 2% of valuation - $271 minimum Residential Fire Plan Review hourly $132
Notice of Violation (City Code 6.55.550) each $250
General Plan/Community Plan/Area Plan Maint. Fee each $1.18 per construction valuation Re-check Fee (4th + Each Add'l Check) each $256
Fees for Work Not Specifically Identified Elsewhere hourly $182 Vacation Home Rental Fees:

Vacation Home Rental Permit Inspection Fee (Adopted 6/17/2025) each $285 Vacation Home Rental Permit Re-Inspection Fee (Adopted 6/17/2025) each $165 Adopted Fee
4/21/2026
Loan Subordination Fee each $2,227
Multi-Family Dwelling Inspection Fee each unit $107
Single Room Occupancy Inspection Fee each unit $107
Reinspection Service per hour / 1 hr. min. $182
Substandard Condition Inspection each $676
Adopted Fee
4/21/2026
Allocations:

Deposit - Building Permit per application $1,000
Allocation Application Processing each $980
Single-Family Allocation Acceptance per allocation
Under 2,000 sq. ft. $0
2,001-2,500 sq. ft. $2,165
2,501-3,000 sq. ft. $5,413
3,001-5,000 sq. ft. $10,825
>/=5,001 sq. ft. $16,238
Inclusionary Housing Plan Check Process each $157
Inclusionary Housing Requirement each nonexempt unit
Under 2,000 sq. ft. exempt
2,001-2,500 sq. ft. $5.29/Sq. Ft.
2,501-3,000 sq. ft. $5.84/Sq. Ft.
3,001-5,000 sq. ft. $16.77/Sq. Ft.
>/=5,001 sq. ft. $17.65/Sq. Ft.

Development Services - Building
Fee Description Unit
Fee Description Unit
Development Services - Housing
Development Services - Planning
Fee Description Unit

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Adopted Fee
4/21/2026
General Permits:

Major General Planning Application (variance, special use permit, major design review, wireless communications facilities, small wireless communications facilities) application $5,961 Minor General Planning Application (minor variance, minor design review, eligible facilities request) application $4,432
Permit Revision and/or Permit Extension each $1,333
Categorical Exemption each $196
Negative Declaration Review each Cost of consultant + 25% Negative Declaration Preparation each Cost of consultant + 25% EIR/EIS each Cost of consultant + 25%
Other Permits:

Non Residential Fence Permits each $393
Home Occupation Permit each $235
Minor Sign Review and Approval each $471
Major Sign Review and Approval each $628
Sign Application Revision each $393
Locally Unique Sign Application each $4,471
Minor Special Event Permit each $1,059
Major Special Event Permit each $1,059
Non-Profit Producer and Free to the Public - Special Event each $0 Temporary Use/Structure Permit each $941
Certificate of Compliance (Subdivision Map Act) each $941 Tentative Subdivision Map each $6,784
Condominiumization of Existing Residential Dev. each $6,628 Permit Technology Fee each permit $31
Cannabis Use Permit:

Cannabis Use Permit each $5,725
Cost Recovery Deposit Amounts for Cannabis Use Permit and Development Agreement
a) Retailer / Cultivator / Testing Lab/ Manufacturing/ Distribution each $24,751 b) Microbusiness each $26,057
Annual Inspection Fee each $2,164
Re-Inspection Fee each $921
Other Services:

Zoning Letter each $353
Document Copying page $0.10
Planning Review of Building Permits each $157
Admin Fee for Cost of Collection on Liens, Nuisance, etc. % of collection costs 25% Public Notice Label Preparation each $196
Special Plan Inspections
per hour / 1 hr min. regular working
hours
per hour / 3 hrs min. outside of
regular working hours
$182
Planning Documents:

General Plan Amendment each $10,000
Community Plan Amendment/Area Plan/Plan Area Statement each $10,000 Annexation:

Annexation hourly $10,000
Mobile Vending:

Location Permit each $862
Publicly Visible Art On Private Property:

Public Murals each $0
Non-mural Publicly Visible Art each $980
Development Services - Planning (Cont.)
Fee Description Unit

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583
Adopted Fee
4/21/2026
Street/Property Abandonment each $2,942
Single-Family Residential Public Works plan review fee per hour $149 Multi-Family Residential Public Works plan review fee (6 units or less) per hour $149 Large Multi-Family Residential Public Works plan review fee (7 or more units) per hour $149 Commercial Development/Redevelopment Public Works plan review fee per hour / 1 hr min. $149 GIS Fee (special requests for information/maps) each $318 Grading Fee < 10 cubic Yards (no fee) project $0
Grading Fee 10+ Cubic Yards project $777
Parcel Merger/Lot Line Adjustment/Parcel Maps
(does not include county fees paid directly to El Dorado County) per hour / 5 hrs min. $149 Final Subdivision Map
(does not include county fees paid directly to El Dorado County) per hour / 5 hrs min. $149 Tentative Subdivision Map
(does not include county fees paid directly to El Dorado County) per hour $149 Obstruction Permit each $350
Encroachment (Street Cut) Permit/Minor each $350
Encroachment (Street Cut) Permit/Major; base + 1.5% of Construction value >$20,000 each $518
Transportation Yearly Permit each $90
Transportation Single Permit each $16
Permit Violation/Stop Work Fee each $1,579
Storm water Inspection Fee: Commercial each $302
Storm water Inspection Fee: Commercial Reinspection each $302 Storm water Inspection Fee: Industrial each $412
Storm water Inspection Fee: Industrial Reinspection each $412 Easement Request/Review each $4,501
Reproduction Fee per 23x26 sheet file plans and record
maps
$13
Street Name Change; actual costs of City staff, equipment, and materials each actual cost Unapproved Work (ROW)/Correction Fee/Inspections of Repairs to City Infrastructure; deposit plus actual time and materials of various city staff each $975 Public Works Condominiumization of Existing Residential Dev. per hour / 5 hrs min. $149 Public Works Inspections/Re-Inspections each $149
Third Party Plan Reviews each actual cost
Permit Technology Fee each permit $31
Public Works
Fee Description Unit

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Adopted Fee
4/21/2026
Emergency Medical Service:

Advanced/Basic Life Support, incident response* incident $616 + Medicare Mileage Factor
Wild Land Fire Suppression Fee:

Support Vehicle hourly CA OES Rate
Pumping Engine hourly CA OES Rate
Motor Vehicle Accident:

Level 1 Basic Response X incident $1,449
Level 2 Extrication X incident $1,935
Level 3 Multi Casualty X incident $3,438
Hazardous Materials Clean-Up:

Level 1 Basic Response X incident $1,269
Level 2 Full Alarm Response X incident $3,443
Bomb Response/Bomb Squad:

Level 1 Full Alarm Response X incident $1,269
Level 2 Full Alarm Engine Response plus TD Bomb Unit X incident $2,902 Pipeline Breakage/Power Line Incidents:

Level 1 Single Engine X incident $1,210
Level 2 Full Alarm Engine Response X incident $2,723
Fire Watch Service X actual cost
Emergency Assistance to Boats/Water Incidents: Includes boat responses, swift water and ice rescues, etc.

Level 1 Single Engine X incident $1,275
Rescue: Includes working with Search & Rescue for victim recovery, Rope Rescue, etc.

Level 1 in City X incident $1,269
Miscellaneous Fees:

False Alarm Responses 1st Offense X response $169
False Alarm Responses 2nd Offense X response $282
Ceremonial/Special Permit each $72
Arson Investigation - Includes scene safety, investigation, source ID, Arson dog, equipment use, mobile detection and report X investigation at cost using fully burdened rate Fire Investigation Reports report $0
Fire Incident Report report $0
Copies no fee $0
Fireworks/Pyrotechnical Display Permit permit $255
Fire Dance Permit Annual Fee permit $195
Defensible Space Inspections for AB38 (Real Estate Sale) per hour $101 Defensible Space Inspections for Homeowners (includes tree marking) per inspection $101 Tree Removal Permit each $77
Misc. Event Standby per event $348
Fire Plan Review & Inspection Fees:

Underground Main Inspection <2" per inspection $229
Underground Main Inspection >2" per inspection $229
Day Care Facility 6+ per inspection $204
Fire Plan Review - Commercial, MFD, Special Event per hour $199 Basic Fire Inspection, <1k k sq. ft. each $178
Basic Fire Inspection, 1k - 4k sq. ft. each $229
Basic Fire Inspection, 4k - 9k sq. ft. each $279
Basic Fire Inspection, >9 k sq. ft. each $355
Basic Fire Inspection - hourly, after 4 hours per hour $102 Child Care Inspection Occupancy Permit Non-Home each $178 Child Care Inspection Occupancy Permit Home each $178
Miscellaneous Fire Services each actual cost
Fire Inspection/Re-Inspection (incl. Special Events outside of regular working hours) per hour / 1 hr min. special event / 3 hrs min. $182
Operational Permit and Inspection CFC 105.6 each $255
Fire Administrative Processing per hour / 1 hr min. $151 *As it pertains to "Advanced Basic Life Support Fee" also known as a First Responder Fee, the Fire Chief's office has discretionary authorization to waive fees under the following criteria:
• Patients relying on government sponsored insurance plans such as Medicare, Medicaid and Medi-Cal. • Patients demonstrating a financial burden such as those on fixed income. • Patients who petition for a fee waiver for other exigent circumstances may request a waiver with final decision by the Fire Chief.

Fire Department
Fee Description Recovery
USA Unit

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585
Adopted Fee
4/21/2026
Special Business Regulation:

Other Permits - New each $549
Other Permits - Renewal each $285
Pedicab Permit - Owner/Operator New each $281
Pedicab Permit - Owner/Operator Renewal each $94
Pedicab Permit - Driver New each $203
Pedicab Permit - Driver Renewal each $52
Sidewalk Vending Permit - New each $234
Sidewalk Vending Permit - Renewal each $82
Letter of Public Convenience or Necessity each $472
Other Police Functions:

Misdemeanor Booking per booking $47
Fingerprinting each $49
Live Scan Fingerprinting each $49
Local Criminal Clearance Letter each $46
Towed Vehicle Release each $249
Special Police Service each actual cost at fully burdened rate DUI Incident Response - Police & Fire incident actual cost at fully burdened rate Copy of Dispatch Event report $0.11
Restitution Rate each actual cost at fully burdened rate Govt. Code Controlled Activities hourly actual cost at fully burdened rate Other Special Activities hourly actual cost at fully burdened rate Special Police Boat Service hourly actual cost at fully burdened rate Equipment Reimbursement each actual cost
Firearm(s) Release (by appointment only) weapon $47
Ski Run Blvd. Vehicle Control hourly actual cost at fully burdened rate Tape Duplication - Audio tape $24
Tape Duplication - Video tape $24
Crime Scene/Police Photo Reproduction (CD photo) CD $24 Repossession Fee each $15
Taxicab Fees:

Taxicab Company Permit Annual $12
Taxicab Vehicle Permit Annual per vehicle $28
Taxicab Driver Permit Annual $53
Police False Alarm Response:
1st & 2nd False Alarm No Charge
Excessive > 3 False Alarms alarm per city code
Non Permitted False Alarm per city code
Initial Permit Application - Resident, 3 year period permit $63 Renewal Permit - Resident, every 3 years permit $39
Initial Permit Application - Business, 1 year period permit $63 Renewal Permit - Business, every year permit $39
Vacation Home Rentals - Tourist Core:

Vacation Home Rental Application fee each $565
Vacation Home Rental Permit - Late Fee On Renewal violation Counted as Violation Vacation Home Rental Permit Master Report report $70
Vacation Home Rental Permit Label Report report $65 + cost of labels 4 or less occupants $200
5 to 8 occupants $350
9 to 12 occupants $650
13 or more occupants $850
Fractional $19.23 to $850
Vacation Home Rentals - Non-Tourist Core:

Vacation Home Rental Application fee each $565
4 or less occupants $670
5 to 8 occupants $1,340
9 to 12 occupants $2,680
13 or more occupants $3,485
Vacation Home Rental Permit Master Report report $70
Hosted Rental Fees:

Hosted Rental Permit each $297
Hosted Rental Annual Renewal Fee each $297
Police Department
Fee Description Unit
Vacation Home Rental Permit - Annual Fee - Tourist Core Vacation Home Rental Permit - Annual Fee - Non-Tourist Area (Adopted 6/17/2025)

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586
Adopted Fee
4/21/2026
Parking Program:

Parking Garage per 20 min/daily max $1.25/$25
Monthly Garage Pass April 1-Oct 31 each month $125
Winter Full Week Pass Nov 1-Mar 31 each month $175
6 Month Pass per 6 months $500
5 p.m. until 3 a.m. $.50 per 20 min/up to $5 $.50 per 20 min/up to $5 Holiday Rates (can include days before/after Holiday) Double Regular Rates $2.50/$50 Parking validations - 1 packet of 50 - 1 hr validations each packet of 50 $50 Electric Car Charging Electricity Fee each Rate as determined by STJPPFA Electric Car Charging Overstay Fee each Rate as determined by STJPPFA Parking - Bellamy/Transit Way per 20 min/2 hr max $2
Parking - Upper Ski Run (identified in map) per contract per contract Cannabis:

Public Safety License Fee each $1,190 + $85 x's # of employees (fingerprint/background)
Public Safety License Renewal Fee each $1,190 + $85 x's # of employees (fingerprint/background)
Public Safety License Amendment Fee each $313
Shared Mobility:

Shared Mobility Device Fee per device $116
Shared Mobility Device Operator Violation per incident $100 Shared Mobility Device Rider Violation per incident $100 Parking Citations:

City Code:

4.25.300 - Parking, Restricted Parking Occurrence $75

4.25.330 - No Stopping Zone Occurrence $75

4.25.360 - Time Limited Parking Zone Occurrence $55

4.25.370 - Parked in Excess of 72 Hours Occurrence $75

4.25.410 - Parked Wrong Side of Street Occurrence $25

4.25.435 - Parked in an Electric Vehicle Charging Space Occurrence $75

4.25.440 - Designated Taxi Zone / Bus Stop Occurrence $75

4.25.590 - Parking Garage Payment Required Occurrence $75

4.25.600 - Parking Garage Parked within Parking Space Occurrence $55

4.25.620 - Use of Entrance and Exit Occurrence $75

4.25.740 - Paid Parking - No Ticket Occurrence $75

4.25.750 - Paid Parking Time Expired Occurrence $75

4.25.840 - Residential Parking / Permit Zone Occurrence $75

4.95.050 - Private Property - Restrictions Occurrence $200

7.05.420 - Area restricted-Snow Removal Occurrence $205 All other City Parking Codes Occurrence $75
California Vehicle Codes:
21113 - Parking on Public Grounds Occurrence $75
21113(a) - Unauthorized parking on public grounds Occurrence $75 21211(b) - Park in bike path Occurrence $75
21211a - Blocking designated bicycle path Occurrence $75 22500.1 - Parked In Fire Lane Occurrence $105
22500a - Park Within Intersection Occurrence $75
22500b - Park on Crosswalk Occurrence $75
22500d - Park Within 15ft Fire Station driveway Occurrence $105 22500e - Block Driveway Occurrence $75
22500f - Park on a Sidewalk Occurrence $75
22500g - Obstructing Traffic/HWY Construction Occurrence $105 22500h - Double Parking Occurrence $75
22500i - Park in Bus Loading Zone Occurrence $75
22507 (a) - Heavenly Valley No Parking/RPP Area Occurrence $300 22507 (a) - Lakeside Residential Neighborhood No Parking/RPP Area Occurrence $300 22507.8(a) - Handicap Disabled Only Occurrence $455
22507.8(b) - Block Disabled Stall/Space Occurrence $455 22507.8c - Parked in Handicap Crosshatch Occurrence $455 22514 - Within 15ft of Fire Hydrant Occurrence $105
22515 - Unattended Running Vehicle Occurrence $75
22523(b) - Abandoned Vehicle Occurrence $250
4000a - Expired Registration Occurrence $75
5204(a) - No Tabs Occurrence $75
Police Department (Cont.)
Fee Description Unit

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587
Adopted Fee
4/21/2026
California Vehicle Codes (Cont.):

All other California Vehicle Codes Occurrence $75
Administrative Citations*
City Code:

2.30.060 (E) - Administrative Fee for Administrative Citations Occurrence $20

2.30.080 (A) - Administrative Hearing Fee for Administrative Citations Occurrence $100

3.35.040 - No Business License Occurrence $100

3.50.380 (B) - Unpermitted VHR - Owner/Agent Responsible First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (B ) - Vacation Home Rental (Parking Space Availability - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (C )- Vacation Home Rental (Commercial Activity Prohibited - Occupant and Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (D) - Vacation Home Rental (Compliance with SLTCC - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (E) - Vacation Home Rental (Posting of Permit - Owner/Agent Responsible) First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (F) - Vacation Home Rental (Marketing/Advertising Requirements - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (G) - Vacation Home Rental (Authorization to Inspect - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (H) - Vacation Home Rental (Outdoor Spas/Hot Tubs prohibited between 10 p.m.-8 a.m. - Occupant and Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (I) - Vacation Home Rental (Interior Signage - Owner/Agent Responsible) First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (J) - Vacation Home Rental (Exterior Signage - Owner/Agent Responsible) First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (K) - Vacation Home Rental (Parking Requirements - Occupant and Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (L) - Vacation Home Rental (Noise and Amplified Music Prohibited between 10 p.m. - 8 a.m. - Occupant and Owner/Agent Responsible) First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (M) - Vacation Home Rental (Emergency Lighting - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (N) - Vacation Home Rental (Lighting Design - Owner/Agent Responsible) First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (O) - Vacation Home Rental (Parking of Commercial Vehicle - Occupant and Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (P) - Vacation Home Rental (Records Relating to VHR - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (Q) - Vacation Home Rental (Camping Prohibited - Occupant and Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.440 (R ) - Vacation Home Rental (Trash/Bear Boxes Required - Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000

3.50.450 (D) Vacation Home Rental (Operating without a Permit) (Owner/Agent Responsible)
First occurrence
Second occurrence within year
Subsequent occurrence within year
$1,500
$3,000
$5,000
Police Department (Cont.)
Fee Description Unit

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588
Adopted Fee
4/21/2026
Administrative Citations (Cont.)*
City Code:

4.150 - Refuse and Garbage Occurrence $150

4.35.020 - No Operator License - Mobile Vending Occurrence $100

4.40.020 - Nuisances Generally Occurrence $50

4.40.030 - Outdoor Display Occurrence $100

4.40.040 - Nuisances Generally - Noise Occurrence $100

4.45.040 - Abandoned Vehicle Occurrence $150

4.50.030 - Illegal Dumping Occurrence $1,000

4.50.050 - Unsuitable Trash Container - Commercial Occurrence $300

4.50.050 - Unsuitable Trash Container - Residential Occurrence $150

4.55 - Graffiti Occurrence $50

4.60 - Abandoned or Damaged Structure Occurrence $1,000

4.135.010 Police Service Occurrence $500

4.140.100 Private Patrols Occurrence $25

6.05 - Handbills Occurrence $100

6.10.160 - Exterior Lighting Occurrence $100

6.15 - Building Code Violation Occurrence $100

6.40.050 - Noncompliant Sign Occurrence $100

6.55.280 - No Home Occupation Permit Occurrence $100

7.05 - Sidewalk Snow Removal Occurrence $100

7.05.500 - Placing Snow in Right-of-Way Occurrence $100

7.05.560 - Sidewalk Snow Removal Occurrence $100
All Code Violations Not Listed Above or Specified in the Code Occurrence $250 *The fines for a second and any subsequent violation within a 12-month period for all violations with the exception of Vacation Home Rental violations will be double that of the previous fine assessed. The above penalties shall not supersede fines and penalties listed in the current City Code for specific violations. Except for Vacation Home Rental violations, under no circumstances shall a penalty be greater than $1,000.

Police Department (Cont.)
Fee Description Unit

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589
Adopted Fee
4/21/2026
Offices square foot or agreement $2.37
Ground Lease Rate square foot or agreement $0.36
Conference/Meeting Room hourly rental hour $34
Conference/Meeting Room daily rental day $335
Restaurant Facilities Per agreement Per agreement
Airport Terminal Lobby (upper/lower) hourly rental hour $66 Airport Terminal Lobby (upper/lower) daily rental day $403 Advertising Negotiated Negotiated
Advertising Digital monthly $90
Rental Car Ground Lease Area Negotiated / Market Rate Conditions Negotiated / Market Rate Conditions Other Use of Terminal Negotiated Negotiated
Commercial Filming:

Small Scale Commercial Filming (less than 50 persons); waived if City promotion per day/winter $486 Small Scale Commercial Filming (less than 50 persons); waived if City promotion per day/summer $810 Large Scale Film Production (film crew larger than 50 persons) - Prep / Strike Location per day $363
Large Scale Film Production (film crew larger than 50 persons) - Filming Days per day $6,035 Airport Escort Required on Filming Days per day $302
Movement Area Filming (Runway and/or Taxiway)* per day* $2,500* Large Scale Filming (more than 50 persons) Security Deposit Negotiated Based on Location Agreement Large Scale Film Production (film crew larger than 50 persons) - City Film Support for Permits, Police, Fire, etc. Per Hour Fully Burdened Rate of Employee Used Aviation Use of Airfield
GA Ramp Fee for A/C under 5,000 lbs (First 15 minutes free) day $10 GA Ramp Fee for A/C over 5,001 lbs (paid with landing fee) day $27 Special Event Fee (Celebrity Golf, A/C under 5,000 exempt) day $50 Monthly Tie Down Fee Flat Rate $81
Helicopter Takeoff Weight
3,001+ $50.00 flat rate
FixedWingTakeoffWeightPer1,000lbs.
5,501 - 19,000 $8
20,000 - 49,000 $10
50,000+ $12
Fuel Flowage Fee per gallon/per agmt $0.20
Building:

All Hangars (Box and Tee) per square foot $0.96
All Storage Units (Aeronautical Use) per square foot $0.96 All Storage Units (Non-Aeronautical Use) Aeronautical use fee plus 10% Aeronautical use fee plus 10% Other Fees:

Parking per space $108
Airport Parking Lot Rental 100 Spaces 1/2 Parking Lot $1,217/day Ground Transportation - Limousine; yearly per company $801 Gratuitous Transportation - Taxi Cab; yearly, negotiable vehicle $40 GA Ramp; hourly, 300 linear feet full width hourly $335 GA Ramp; day, 300 linear feet full width day $4,020
Taxiway A between H and J - North End; hourly hourly $335 Taxiway A between H and J - North End; daily day $4,020 Local Emergency Agency Training Ramp Use
(Non Airport Emergency) yearly $5,000
Airport Technician Fully burdened hourly rate Fully burdened hourly rate Dump Truck, Sander, Grader, Loader hourly $229
Carpet Cleaning; includes equipment use +actual costs of City staff hourly + actual Fully burdened hourly rate Airport Hangar Waitlist Fee each $250
Airport Lease Security Deposit (refundable deposit) each $750 Airport Key Card (refundable deposit) each $50
Lost/Stolen Key Card Replacement (non- refundable) each $50 Airport Hangar Key (refundable deposit) each $25
Lost/Stolen Hangar Key Card Replacement (non- refundable) each $25 **Local Emergency Agency Partners conducting training exercises to improve interagency airport emergency response is exempted from use fees.

Airport
Fee Description Unit
*Any filming conducted on runways or taxiways defined as the Movement Area by the Federal Aviation Administration will have a $2,500 per day additional fee on top of other rates.

Landing Fee
Landing Fee

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590
Adopted Fee
4/21/2026
Appeals* per appeal $1,253
Document Printing and Copying - .10 per page plus postage document page $0.10 City Council Chambers Use Application Fee per application $35 City Council Chambers Rental, M-F, 8-5 p.m. per hour $50 Video Meeting Electronic File Transfer, 1 per Drive thumb drive $5 Verbatim Transcript Service actual outsource cost hourly or actual outsource cost Notary Service per signature $15
Notary Service - Providing California Notary
Acknowledgement or Jurat Form per form $1
Agenda Mailing Service, .10 per page plus postage agenda .10 per page plus postage Filming Application Fee application $164
Temporary Sign Deposit (yard signs) campaign $174
City Council AV Service Fee each $99
Film Application Fee Special per application $192
Film Appliation Fee Rush (less than 7 business days) per application 150% base fee Film Permit Change Fee each $132
Adopted Fee
4/21/2026
Business and Professions Tax Rates:

Schedule A (per $1,000 gross receipts) per 1,000 gross receipts $1.07 Schedule B (per $1,000 gross receipts) per 1,000 gross receipts $1.62 Schedule C (per $1,000 gross receipts) per 1,000 gross receipts $2.14 Schedule D (per $1,000 gross receipts) per 1,000 gross receipts $2.69 Schedule E (per $1,000 gross receipts) per 1,000 gross receipts $3.22 Schedule N (non-profit 501(c)(3); veterans; etc.) n/a $0.00 Maximum Annual Amount of Tax (Measure B, June 2012) application $20,000.00 Administrative Fee - New license application (Including $31 Business License Technology Fee) application $108
Administrative Fee - New Business One Time 6 Month License Application application $32 Administrative Fee - Annual Renewal (Including $31 Business License Technology Fee) application $63
AB1379 (amended SB1186; ADA info and access fee - State of CA mandated; effective 1/1/2018 through 12/31/2023) per business certificate $4 Business License Technology Fee; collected with admin fee business application $31 Business License Certificate - duplicate copy certificate $12 Lien Release Fee lien Passed on to Seller through Escrow Administrative Fee for Delinquent Refuse Collections lien $87 TOT and Business License Reports:

Delinquent Tax Analysis per project At cost using fully burdened hourly rate Motel Tax Master (name/address listing) per report $40
Individual TOT Report per motel/per year $17
Vacation Home Rental Master Report per report $40
Vacation Home Rental Label Report per report $40 + cost of labels Business License Master Report, Standard Format per report $79 Business License Master Report Requiring Specific Formatting Due to Information Request per report $79 + fully burdened hourly rate
Miscellaneous Fees:

Returned Check (NSF) Processing 1st Check per check $25 Returned Check (NSF) Processing Subsequent Checks per check $35 Geobase Information Service, Research per project At cost using fully burdened hourly rate Stop Payment Fee per check At cost using actual bank charge City Clerk
Fee Description Unit
Finance
Fee Description Unit
*Cost based Appeal Fee is due at filing; if appellants prevail (the decision is reversed or materially modified in their favor), the full fee will be refunded.

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C O M P R E H E N S I V E U S E R F E E S T U DY
Fe b r u a r y 2 0 2 6
GCP
GOVERNMENT CONSULTING PARTNERS, INC.
592

TABLE OF CONTENTS
1 BACKGROUND AND OBJECTIVES
Background…………………………………………….………………………………………..…………….…1
Existing South Lake Tahoe Fee Policy………………………………..………………….…………..……2 2 STUDY METHODOLOGY
Fee Inventory and Fee Structure Review………….………..…………….….…………………...….…4 Table: Proposed Fee Structure Changes and New Fees..………….….……..………5 Costing Methodology…………………….…………………………………..………………………….…....7 SME Focus Groups: Identifying Time Requirements by Task….…………………..………..….…7 Fully Burdened Hourly Rates: ……………………………..……………………….……...............…..8 3 FISCAL IMPACT
Summary Results by Department/ Division………..…..………..……………………….…….……11 4 ANALYSIS AND HIGHLIGHTS
Departmental Writeups………………………………………………………………….…..….….………13 5 FEE ANALYSIS AND RECOMMENDATIONS
Building……………………………………………………………………………...…..………………......…26 City Clerk……………………………………………………….…………………………………………........28 Engineering…………………………………………………….……………………………………….…....…29 Finance…………………………………….…………………………………………..…..…………..……..…31 Fire………………………………………………………………..………………………………………….....…33
Parks and Recreation……………….…………………………………………..…..…………..……….....35 Planning………………………………………………………...……………………………………..……...…40 Police…………………………………………………………….……………………………………..……...…42
6 FEE COMPARISON SURVEY
Survey of Fees Charged by Regional Agencies……………….…………………………………....…44

APPENDIX A
Adopted Recreation and Aquatic Center Fee Schedule…………………………………………….47

APPENDIX B
Citywide Full Cost Simple Rate………………………………….………………………………………….55 593

CITY OF SOUTH LAKE TAHOE
Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 1
Government Consulting Partners, Inc (GCP) is a Sacramento-based consulting firm specializing in cost and revenue studies for state and local government.
1 BACKGROUND & OBJECTIVES

The City of South Lake Tahoe delivers many services to the public for a fee. This report focuses on “user fees”, which are assessed in order to recover the cost of labor-based services or use of city facilities. A comprehensive review of user fees was last conducted in 2015. Since that time fees have been reviewed and increased annually by CPI where and when it was appropriate. The City engaged GCP to conduct a comprehensive review of user fee costs and associated revenues using 2025 financial and operational data.

User fees in California are required to conform to the statutory requirements of the California Constitution, Proposition 218 and the California Code of Regulations, including Government Code 66000 et seq. By law, user fees may not exceed the estimated reasonable cost of providing the services for which they were levied, unless approved by a two-thirds vote of the electorate.

As more fiscal limitations are imposed on local government, user fees have become an increasingly important source of revenue. A user fee is a payment made by an individual or business that primarily benefits the individual or business rather than the community at large. Government agencies can charge a user fee for a service when 1) the individual’s decision to use a service is voluntary, and 2) the fee charged is reasonably related to the level of service rendered and cost of providing the service.

This report presented GCP’s comprehensive review of South Lake Tahoe’s user fees with the goal of aligning fees with current fiscal policy and Council priorities.

The study covered user fees charged by the following departments/divisions:
 Building
 City Clerk
 Engineering
 Finance
 Fire
 Parks and Recreation
 Planning
 Police
AQUATIC CENTER FEES – GCP also reviewed the City’s new Aquatic’s Center. GCP accelerated this portion of the study to accommodate the Center’s grand opening in early 2026. Aquatic Center fees were approved by Council in November 2025 under a separate report.

VACATION HOME RENTAL FEES - GCP reviewed staff’s internally prepared Vacation Home Rental (VHR) annual and inspection fee calculations and provided feedback. Updated VHR fees were adopted by Council in June, 2025 under a separate report.

GCP’s project’s scope included calculating the cost of each fee-related service, conducting a survey of fees charged by regional agencies, and recommending fee adjustments aligned with established Council policy. 594

CITY OF SOUTH LAKE TAHOE
Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 2

S O U T H L A K E T A H O E E X I S T I N G F E E

P O L I C Y
GCP reviewed established Council user fee policy for setting fees and fee structures. The City’s Financial Policy was last revised in 2013. Section D provides the following guidance regarding the imposition of user fees:
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CITY OF SOUTH LAKE TAHOE
Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 3
Key user fee principles from the City’s policy include:
 Revenues from user fees shall not exceed the cost of providing the service.  Cost recovery goals shall be based on the total cost of delivering the service.  The method of assessing and collecting fees shall be as simple as possible.  Fee levels shall be sensitive to the market for similar services.  Fee levels shall be sensitive to smaller, infrequent users of the service.  The level of cost recovery shall consider community-wide versus special benefit.  The level of cost recovery shall consider the financial benefit to the service users.

The goal of this report is to present the study’s findings in a relevant and concise format that allows City leadership to make informed user-fee pricing decisions consistent with existing fee policy. 596

CITY OF SOUTH LAKE TAHOE
Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 4
2 STUDY METHODOLOGY
Upon project commencement -GCP met with Finance staff to better understand the goals and priorities for the new fee schedule. A workplan was then developed to ensure that the proposed fee schedule resulting from the study reflects these priorities.

F E E S T R U C T U R E R E V I E W

A key component of the workplan included
restructuring of existing fees. In collaboration
with GCP, City staff reviewed the existing fee
structure and identified areas where fees
could be realigned to more accurately reflect
the City’s processes and the services being
provided. Every proposed change is
designed to accomplish one of several
things: streamline the fee calculation process;
increase user-friendliness; or increase equity
across the customer base.

As part of the restructuring process, GCP
surveyed fee schedules from comparison
agencies to better understand regional best
practice fee structures and trends. GCP
shared this compiled data with staff as well as
the actual fee schedules themselves.

All flat and tiered fees are supported by average processing times and staffing fully burdened hourly rates.

Reducing reliance on deposit-based fees in favor of flat or tiered structures increases predictability for customers.

The City recently instituted a customer portal enabling electronic plan submittals and payment services, greatly reducing wait times at the public counter.

Streamlining the fee schedule was a significant focus of the study. A streamlined fee schedule saves valuable time for both City counter staff and the City’s customers.

After GCP and City staff discussed and reviewed all available fee structure options a final consensus was reached for each group of fees. Table 1 summarizes the proposed fee structure changes.
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CITY OF SOUTH LAKE TAHOE
Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 5
Table 1: Proposed Fee Structure Changes and New Fees

CITY CLERK
11 Public Property Use Fee (for filming only) Change to See Facility Rental Fee Schedule
See Facility Rental Fee
Schedule
13 City Council AV Service Fee NEW Per Hour (1 hour
minimum)
14 Film Application Fee Special NEW
Applications that require
additional City Clerk, Fire,
Police or Public Works,
review will be charged
the hourly rate of the
Department Head
reviewing the Permit
Application.
15 Film Appliation Fee Rush (less than 7 business days) NEW Base Fee x 1.5 16 Film Permit Change Fee NEW Flat Fee

FINANCE
16 Business License Label Report $63 Flat Fee Remove
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Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 6

FIRE RESCUE
2 EMS: Advanced/Basic Life Support, incident response Per Hour Flat Fee 3 EMS: Advanced/Basic Life Support - with standby to support air ambulance transport, incident response Flat Fee Remove
4 EMS: Advanced/Basic Life Support - with engine standby for CPR, incident response Flat Fee Remove 6 County Fire Services: Lake Valley Fire District Contract Per Hour Remove 7 County Fire Services: Fallen Leaf Fire District Contract Per Hour Remove 11 Wild Land Suppression: Ladder Truck CA OES Hourly Rate Remove 25 Pipeline/Power Lines: Fire Hydrant Flow Test Flat Fee Remove 26 Pipeline/Power Lines: Witnessed Acceptance Test Flat Fee Remove 28 Pipeline/Power Lines: Structure Fire Suppression (includes scene safety, initial investigation, traffic control, patient contact, hazard control) Hourly Flat Fee 37 Open Burning and Recreational Fires Flat Fee Remove
38 Ceremonial/Special Permit New Fee
43 Photographs Flat Fee Remove
44 Video Tape Duplication Flat Fee Remove
47 Per Event Inspection Per Hour Remove
50 Tree Removal Permit New Fee
51 Special Event / Fire Inspections (3 hour min if conducted outside regular work hours) Hourly Remove 55 Auto Alarm/Ext Supression System - 100 1-99 Per Inspection Remove 56 Auto Alarm/Ext Supression- 100+ Per Inspection Remove 57 Suppression Sys-50 hds/Dry Chem sys Flat Fee Remove
58 Suppression Sys-200 hds Flat Fee Remove
62 Board 7 Care Facility 7-50 Flat Fee Remove
63 Board 7 Care Facility 50+ Flat Fee Remove
70 Basic Fire Inspection - Hourly, after 4 hours New Fee 76 Fire Processing Permit Fee New Fee
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Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 7

C O S T I N G M E T H O D O L O G Y
Most fees in this study were calculated via a per-unit analysis approach. Commonly called a “bottom-up” approach, this method analyzes direct staff time required to deliver one unit of service. Indirect rates are then applied to reflect services and supplies, administrative and all overhead costs required to deliver each service. Resulting in a detailed, fully burdened cost perunit assessment.

GCP’s per-unit methodology includes the following five steps to build the individual per unit costs:

1. Define the fees to be analyzed.

2. Analyze direct staff time spent on the fee-related services.

3. Develop fully burdened hourly rates for direct staff.

4. Compare total costs to the current fee schedule.

5. Annualize results by extrapolating per-unit results by typical volume demand.

1. Define the fees to be analyzed
GCP worked with staff to identify any proposed new fees, obsolete fees and fee structure changes to establish a final list of fee-related services to be analyzed.

2. SME Focus Groups: Identifying time requirements by task Once all fee structure decisions were finalized, GCP interviewed subject matter experts (SME) to estimate the average time spent by task on each fee category. Each fee was reviewed individually, and City staff worked collaboratively with GCP to identify the specific tasks associated with each service. Table 2 below provides an example of the time/task documentation for a major sign review within Planning.
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Comprehensive User Fee Study
Government Consulting Partners, Inc.
` Page 8
Table 2: Sample of Time / Task detail: Planning
Analyzing fee services
at this level of
granularity provides
higher confidence in
study results.

Accurate and
detailed time
estimates, multiplied
by staff FBHR’s form
the maximum the City
may legally charge by
fee category.

Table 3: Methods used to evaluate reasonableness
GCP performed a series of checks to
ensure the reasonableness of data inputs.

After several rounds of reasonableness
checks and data refinement final time
figures were then entered into the fee
model along with associated cost and
demand data.

These checks were used to focus GCP and staff’s internal quality control reviews on fees that are outliers in one way or another. Where possible, the City’s data systems were queried to provide data to either inform or corroborate staff’s efforts.

3. Develop fully burdened hourly rates (FBHR’s)
Establishing FBHR’s is essential to any user fee study engagement because these rates lay the foundation to calculating the full cost of providing services. FBHR’s can be used to determine how much it costs the City to deliver any labor-based service. Reliable FBHR’s ensure the study’s findings, recommendations and resulting fee schedules are based on real defensible costs. This promotes both transparency and financial sustainability.

Calculate the Annual Full Cost of Direct Staff: The FBHR calculation process incorporated data from the following sources:
 Staffing costs were calculated using the City’s budgeted compensation data, including salaries and benefits, for employees responsible for performing the feerelated services. 601

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 Operating costs directly associated with service delivery—such as materials, supplies, and contracted services—were incorporated into the fully burdened rate to ensure a comprehensive reflection of total service costs.
 Overhead costs were included and applied to the division’s direct salary and benefit expenses to calculate the fully burdened hourly rates.
o Division overhead: Division overhead includes indirect costs such as labor from managers, supervisors and support staff, internal meetings, training, general counter time and shared supplies that support overall service delivery within the division.
o Citywide overhead: represents the allocation of indirect costs from the City’s cost allocation plan, covering central support service departments such as Human Resources, Information Technology, and Finance that provide essential resources and support to all departments throughout the organization.

Identify Annual Available Work Hours per FTE: This becomes the denominator in the rate.

Conceptually, the idea is to reflect the average number of hours in a year that an FTE is typically available to deliver services. By including only available work hours in the denominator, instead of the traditional 2,080, the rates are “fully burdened” sufficient to recover the full annual cost of one FTE, assuming normal construction demand levels.

For this study GCP used the industry-standard staffing available hours figure of 1,800.

4. Compare total service cost to the current fee charged Once the fully burdened hourly rate is applied to the time estimates for each fee category, this creates the “total cost” per unit. GCP compared the total cost for each fixed-fee service to the fee currently charged. This provided the initial results on the percentage of current cost recovery under the City’s existing fees.

If the current cost recovery for a particular service is under 100%, this implies the fee does not cover the cost of providing the service and can be increased. If the current cost recovery is over 100%, then the fee is set too high and must be lowered to comply with State laws prohibiting the making of a profit on user fee activities.

5. Annualization of the Per Unit results
GCP projected the annual fiscal impact by multiplying current and proposed fees by annual demand figures. Demand figures were estimated based on the following assumptions:
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 Estimates of demand are used for any new or restructured fee categories.  Revenue produced by deposit-based fee categories is often difficult to predict. These fees are based on the type and complexity of the project. Deposit based fees are seen as revenue neutral since they are based on actual time spent multiplied by the hourly rate and therefore are assumed to be 100% cost recovery.
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3 FISCAL IMPACT

S U M M A R Y R E S U L T S B Y D E P T / D I V I S I O N In cooperation with city staff, GCP developed cost and revenue projections for each area under study. Costs and revenues were primarily projected by extrapolating individual per-unit results for an entire year of demand activity. The combined findings result shows an overall $269,001 net revenue increase on an annual basis, assuming historic demand levels. The table below summarizes the fiscal impact of our findings and recommendations for each fee area under study.

The study’s fiscal projections are approximations and should be approached conservatively. It is recommended that staff monitor actual fiscal impacts beginning with the first six months of actual revenue data.

The fiscal impact table shows the current annual fee revenue of $4,002,706. With associated costs of $5,009,900 for an overall cost recover rate of 80%. Leaving $1,007,194 (20%) in unrecovered or subsidized costs.

If the recommended fee adjustments are adopted, annual revenues are projected to increase to $4,271,707 representing a $269,001 revenue increase.

Staff made careful considerations when developing these recommendations. While many fees are projected to increase, several are proposed at less than full cost recovery at this time. Moving to full cost would result in significant impacts to users. GCP recommends gradually monitoring these fees over the coming years to ensure they remain aligned with actual staff time and service delivery costs.
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T E C H N O L O G Y S U R C H A R G E
The City assesses a flat $13 transaction fee to cover the cost of technology related to business licenses and building permits. The technology fee provides a dedicated revenue stream for the acquisition, update and regular
maintenance of the City’s HdL and
Community Development data licensing
and permitting systems and other related
technologies required to provide
advanced cloud-based services to its
customers.

The City’s projected cost of providing
technology services to permit-holders is
$180,719 annually, or $31 per business
license or development permit issued in a
typical year.

Having a dedicated revenue source for
technology costs improves transparency
and facilitates future cost/fee alignments.

Chapter 6 of this report compares the
proposed Technology Fee against similar
fees charged by regional cities and
counties.
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4 ANALYSIS AND HIGHLIGHTS
The User Fee program chapter summarizes findings and recommendations for each department reviewed in the study. They present key financial results, including cost-of-service calculations, current cost recovery rates, and anticipated changes in revenue based on proposed fee updates.

This section also highlights recommended adjustments to each of the fee schedules, such as eliminating outdated fees, introducing new ones, and combining similar charges to enhance transparency and consistency. The full list of the proposed fees can be found in section 5 of this report.

B U I L D I N G
The Building division’s mission is to enforce minimum building code requirements to safeguard the public health, safety and general welfare through structural strength, means of egress, stability, sanitation, adequate light and ventilation, energy conservation and green building systems.

The Building division provides these services at the request of property owners and developers seeking to build or enhance and change the current use of their property.

GCP used a variety of methods to test whether the division’s fees meet the cost vs revenue standards of Government Code 66014 et seq. which states that revenue received in return for a service must not exceed reasonable related costs.

South Lake Tahoe’s building division operates in an environment that has complexities beyond most other departments, including:
 A limited five-month development window.
 Additional TRPA regulations and requirements add an additional layer of complexity to the City’s review and approval processes.

Building permits are charged based on the construction valuation (market value, less land costs and profit) of the proposed project. A flat 2% fee is applied against construction valuation to cover the cost of inspecting projects for adherence to the California Building Code. The division charges separate flat fees for individual electrical, plumbing and mechanical permits.

GCP prepared a total cost vs total revenue matchup for the Building division. 606

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The analysis for the Building division projects an overall cost of $2,152,802 with associated revenues of $2,294,906, for a $142,104 revenue surplus. GCP recommends no adjustments to Building division fees in light of the fiscal analysis (aside from an increase in the Technology Fee as discussed on page 13 of this report, which would add $27,486 revenue). Building fees and costs are intended to even out over the course of a development cycle. GCP reviewed South Lake Tahoe’s Building revenues over a five-year period and finds revenue generated by current fee levels offsets the average cost of operating the Building division.

Multi-Year Trend Analysis
It is important to analyze a Building division over a period of years because building revenues are highly dependent on demand
levels and where we fall within the current
construction-cycle. The Table to the right
presents Building’s cost vs revenue picture
over a 5-year history. Figures reflect budgeted
costs and revenues. The full cost line reflects
internal costs (inspection, plan-check, public
counter) as well as support from Planning,
Public Works and Fire. Future revenue
depends heavily on construction demand,
while staffing and other costs remain relatively
stable over time to ensure projects are plan
checked and inspected within acceptable
timeframes.

C I T Y C L E R K
The City Clerk’s department is directly responsible to the public and serves as a direct link between the residents and their government. While a majority of the duties performed by the City Clerk’s department are non-fee related, there are a handful of user fees that the department is responsible for providing.

The user fee cost analysis for the City Clerk’s department shows an overall cost recovery of $13,015 (37%) with $21,971 (63%) unrecovered. GCP is recommending that all fees on the City Clerk’s fee schedule be set at 100% cost recovery. If the recommendations are adopted, the estimated annual revenue would increase to $34,971 for an increase of $21,956.

FEE AREA

COST OF FEE

SERVICES

CURRENT

USER FEE

REVENUE
COST

RECOVERY
RATE

GENERAL

FUND SUBSIDY

PROJECTED

REVENUE
FROM

PROPOSED
FEES
COST

RECOVERY

RATE AT

PROPOSED
FEES

PROJECTED

REVENUE

INCREASE
City Clerk $34,971 $13,015 37% $21,956 $34,971 100% $21,956 607

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New Fees Added
There are four new fees that are proposed to add to the fee schedule:
 City Council AV Service Fee
 Film Application Fee Special
 Film Application Fee Rush (less than 7 business days)  Film Permit Change Fee

In addition to the four new fees, the department is recommending setting the appeals fee at 100% cost recovery. Based on the comparison survey results below, the recommendation is to increase the current appeals fee from $380 to $1,253.

Note – fees used in a comparison survey are subject to change and present a snapshot in time.

The full list of the proposed fees can be found in section 5 of this report.

E N G I N E E R I N G
Engineering is charged with the task of safeguarding life, health, property, and public welfare through review, design, bid and construction of public improvement projects constructed on City property and within the City’s right-of-way. The division implements water quality programs to reduce the pollutant loads which flow into, and are discharged from the City’s storm water infrastructure to Lake Tahoe.

Engineering is also responsible for inspecting construction in the public right-of-way processing plans, permits and applications for land development. These services were the primary focus of GCP’s analysis.

City/Municipality Appeals Fee Type of Appeal
Douglas County, NV $ 898 Appeal of staff decision To Planning Commission (PC) Douglas County, NV $ 1,047 Appeal PC decision to Board of County Commission Placer County, CA $ 688 Appeal
Nevada County, CA $ 1,976 Planning Agency Appeals
Nevada County, CA $ 1,976 Planning Commission Appeals
Nevada County, CA $ 1,976 Zoning Administrator Appeals
Tahoe Regional Planning Agency $ 1,235 Appeal of Executive Director Decisions Tahoe Regional Planning Agency $ 1,668
Appeal of Local Government Decision Pursuant to Area Plan MOU
Peer Average $ 1,433
South Lake Tahoe (Current) $ 380
South Lake Tahoe (Proposed) $ 1,253
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Engineering expended a total of $40,685 on providing fee-related services while generating $62,816 revenue, for an over recovery of $22,131. GCP recommends all fees be adjusted to 100% cost recovery. If the fee recommendations are adopted, the estimated annual revenue would decrease by $22,148.

F I N A N C E
The Finance department is responsible for protecting the City’s fiscal health and sustainability.

Although many of the Finance department’s duties are non-fee related, there are a handful of user fees that the department is responsible for providing.

The user fee cost analysis for the Finance department shows an overall cost recovery of $342,045 (103%) with an over recovery of $8,782. GCP is recommending that all fees on the Finance department fee schedule be set at 100% cost recovery. For those fees currently experiencing more than 100% cost recovery, the fee would need reduced to 100%. Fees currently experiencing less than 100% cost recovery would need to increase to 100%. If the fee recommendations are adopted, the estimated annual revenue would decrease to $333,263.

There are eight fees that are proposed to decrease. The decreases are a direct result of efficiencies in the process to provide services in addition to shifting work to a lower position title to perform.

Business and Professions Tax Rates
 Administrative Fee - New Business One Time 6 Month License Application  Administrative Fee - Annual Renewal (Including $31 Business License Technology Fee)  Business License Certificate - duplicate copy
TOT and Business License Reports
These four reports will not have an impact on revenue. The was no volume associated with these fees in the past year.

FEE AREA

COST OF FEE

SERVICES

CURRENT

USER FEE

REVENUE
COST

RECOVERY
RATE

GENERAL

FUND SUBSIDY

PROJECTED

REVENUE
FROM

PROPOSED
FEES
COST

RECOVERY

RATE AT

PROPOSED
FEES

PROJECTED

REVENUE

INCREASE
Finance $333,263 $342,045 103% -$8,782 $333,263 100% -$8,782 609

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 Motel Tax Master (name/address listing)
 Individual TOT Report
 Vacation Home Rental Master Report
 Vacation Home Rental Label Report
Miscellaneous
Return Check (NSF) Processing – 1st check was increased by CPI but is set by statue and should be reduced to $25.

The full list of the proposed fees can be found in section 5 of this report.

F I R E
The South Lake Tahoe Fire Rescue Division provides essential life-safety services, including emergency medical response, fire suppression, rescue, hazardous-materials mitigation, wildfire prevention, and community risk-reduction. Because these services require highly trained staff, specialized equipment, and constant readiness, service fees must be reviewed and updated regularly to reflect the true cost of service, meet the City’s cost-recovery goals, and sustain reliable emergency response in a community with significant seasonal demand and unique public-safety risks.

The cost analysis results for Fire Rescue fees is shown below.

The cost analysis for the Fire Recue shows an overall cost recovery of $159,490 (20%) current fee revenue with a cost of $785,699 leaving (80%) uncollected costs.

If staff fee recommendations are adopted, estimated annual revenue would increase to $206,661, an increase of $47,171 These projections are estimates only; actual revenues depend on activity levels, compliance, billing and collection practices, and any future changes to fee structures or City policies.

A significant portion of uncollected revenue is attributable to Fire Advanced and Basic Life Support services, which are rarely reimbursed at full cost. Insurance providers typically cover only a portion of actual expenses, creating a gap between true service costs—including personnel, equipment, supplies, and overhead—and amounts recovered. City staff estimate that only 25– 30% of actual service costs are currently collected.

FEE AREA

COST OF FEE

SERVICES

CURRENT

USER FEE

REVENUE
COST

RECOVERY
RATE

GENERAL

FUND SUBSIDY

PROJECTED

REVENUE
FROM

PROPOSED
FEES
COST

RECOVERY

RATE AT

PROPOSED
FEES

PROJECTED

REVENUE

INCREASE
Fire Rescue $785,699 $159,490 20% $626,209 $206,661 26% $47,171 610

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Updates to the Fee Schedule
GCP collaborated with the division’s staff to align fees with the services provided, confirming that the existing structure was well organized and effectively serving the City. Only a few minor adjustments were made to the overall layout of the fee schedule.

The current Fire Rescue fee schedule includes 60 fees, encompassing flat fees, actual cost, hourly rates, and fines. Following this study, 15 obsolete fees are recommended for removal, resulting in a proposed schedule of 45 fees.

The proposed Fire Rescue fees changes include:

New Fees:
 Ceremonial/Special Permit – Flat Fee
 Tree Removal Permit – Flat Fee
 Basic Fire Inspection, after hours – Per Hour
 Fire Processing Permit Fee – Flat Fee
Fee Removal:
 Following a comprehensive review, select fees are being removed to better align the fee schedule with current service delivery practices, cost recovery principles, and legal requirements. This update helps simplify the fee structure while ensuring fees are applied only where a clear and supportable relationship exists between the service provided and the fee charged. Below is a consolidated list of those services and a brief description of why it’s being removed. 611

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Fee Restructuring
 Eleven fees are proposed to be converted from hourly rates to flat fees, as staff were unaware, they were listed as hourly and they were never intended or charged as such.

The full list of the proposed fees can be found in section 5 of this report.

Fee Removal Reason
EMS: Advanced/Basic Life Support – with standby to
support air ambulance transport, incident response
Not charged separately. EMS services are billed under a flat-rate structure, making an additional standby fee unnecessary.

EMS: Advanced/Basic Life Support – with engine standby
for CPR, incident response
Not charged separately. EMS services are provided under a flat-rate fee regardless of the level or type of medical response.

County Fire Services: Lake Valley Fire District Contract Fees are not charged to other fire agencies. Services are addressed through interagency agreements or invoicing as needed, not user fees.

County Fire Services: Fallen Leaf Fire District Contract Fees are not charged to other fire agencies. Services are handled through interagency agreements or invoicing as needed, not user fees.

Wild Land Suppression: Ladder Truck Ladder trucks are not deployed on wildland incidents.

Pipeline/Power Lines: Fire Hydrant Flow Test Hydrant flow testing is no longer performed by the Fire Department; hydrants are owned and maintained by STPUD.

Pipeline/Power Lines: Witnessed Acceptance Test The Fire Department does not perform witnessed acceptance testing.

Open Burning and Recreational Fires Open burning and recreational fires are not permitted within city limits.

Photographs No fee is charged. Public records requests are processed through the City Clerk’s Office, which may assess fees as applicable.

Video Tape Duplication No fee is charged. Public records requests are processed through the City Clerk’s Office, which may assess fees as applicable.

Per Event Inspection
Per-event inspections are not required for fire dancers holding a valid annual permit, as safety requirements are already demonstrated and approved.

Suppression Sys – 50 hds / Dry Chem Sys Consolidated into the automatic alarm/suppression system fee.

Suppression Sys – 200 hds Consolidated into the automatic alarm/suppression system fee.

Board & Care Facility (7–50) Consolidated into the daycare facility fee.

Board & Care Facility (50+) Consolidated into the daycare facility fee.

Special Event / Fire Inspections (3 hour min if conducted outside regular work hours) Already Covered in Fire Inspection Fee Auto Alarm/Ext Supression System - 100 1-99 Duplicate Fee - Already covered Auto Alarm/Ext Supression- 100+ Duplicate Fee - Already covered 612

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P A R K S A N D R E C R E A T I O N
In phase I of the Parks and Recreation fee analysis, GCP focused on the fees for the new Recreation and Aquatics Center that is scheduled to open in spring 2026. On November 4, 2025, the City Council adopted the new Recreation and Aquatics Center fee schedule which is referenced in Appendix A of this study.

Phase II of the Parks and Recreation fee study represents the analysis of the remaining fee related program categories listed below:
 Outdoor Park Facility Rentals: Picnic Shelters and Picnic Areas  Outdoor Park Facility Rentals: Regan Beach West
 Special Event Facility Rentals (large scale events): Lakeview Commons; Bijou Park (entire park), Regan Beach
 Bijou Golf Course
 Campground
 Boat Ramp
The revenues for these program categories have been updated since the phase I report was issued. The results for the phase II service category analysis are shown below:

The user fee cost analysis for the remaining Parks and Recreation program categories show an overall cost recovery of $656,249 (66%) with $337,481 (34%) unrecovered. If staff recommendations are adopted, projected revenue would be $691,038 (70%) for an increase of $34,789.

Part of the unrecovered costs comes directly from the state capped fees for the Boat Ramp which shows an overall cost recovery of $36,464 (21%) with a cost of $169,971, leaving $133,507 (79%) unrecovered or subsidized by the city.

The individual program category results are listed below:

FEE AREA

COST OF FEE

SERVICES

CURRENT

USER FEE

REVENUE
COST

RECOVERY
RATE

GENERAL

FUND SUBSIDY

PROJECTED

REVENUE
FROM

PROPOSED
FEES
COST

RECOVERY

RATE AT

PROPOSED
FEES

PROJECTED

REVENUE

INCREASE
Parks and Recreation $993,730 $656,249 66% $337,481 $691,038 70% $34,789 613

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Many of the fees within the phase II categories represent facility rentals or use of government property. In 2010, Proposition 26 was adopted and states that user fees are limited to the "estimated reasonable cost of providing a service" by Government Code section 66014(a) and other supplementary legislation. In particular, Proposition 26 established that fees charged for the use of government property are exempt from Proposition 26. These include fees for parks and facility rentals as well as green fees, carts, and other equipment rental fees. All of these fees may be set at a price the market will bear.

Based on the overall results, GCP performed a comparison survey of various outdoor park facility rentals, 9-hole golf courses, and campgrounds. It is common for agencies to want to compare their fees to other agencies, however, it is important to note that not all facilities may be an apples-to-apples comparison. For example, a straight comparison of a 9-hole golf course does not take into account the quality or condition of the course or whether or not the facility offers a club house or other amenities. A comparison survey can provide some guidance when looking at the key considerations but ultimately staff’s comments were heavily considered when making the final recommendations.

Other key considerations that were taken into account when setting the recommendations included:
 Price Elasticity of Demand: When proposing fee recommendations, the elasticity of demand for the service should be considered. For example, will raising the fee result in a loss of participants or number of rentals or is the demand there to sustain participation levels. 29 Outdoor Park Facility Rentals: Picnic Shelters and
Picnic Areas $ 28,102.93 5,091.00 $ 18%
30 Outdoor Park Facility Rentals: Regan Beach West $ 28,102.93 25,902.00 $ 92% 31 Special Event Facility Rentals (large scale events):

Lakeview Commons; Bijou Park (entire park),
Regan Beach $ 25,756.16 6,504.00 $ 25%
39 Bijou Golf Course 203,765.00 $ 437,754.38 $ 47%
40 Campground 378,524.00 $ 304,042.63 $ 124%
41 Boat Ramp 36,464.00 $ 169,970.56 $ 21%
City of South Lake Tahoe
Parks and Recreation
Service Category Name

CURRENT
COST
RECOVERY %

CURRENT

REVENUE

TOTAL ANNUAL
COST
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 Competition: Certain services, such as facility rentals, may be provided by neighboring communities or the private sector, and therefore demand for these services can be highly dependent on what else may be available.

The following represent some of the highlighted fee changes:

Outdoor Park Facility Rentals: Picnic Shelters and Picnic Areas and Regan Beach West - GCP recommends that the fees under this program category increase by CPI.

Special Event Facility Rentals (large scale events): Lakeview Commons; Bijou Park and Regan Beach
Currently there are two tiers for the Lakeview Commons, Bijou Community Park or Regan Beach Special Event Rental: attendance up to 500 persons and attendance 501-1,000 persons.

Staff recommend adding a third tier for attendance 1,001-2,000 persons and adjusting the fees for the three tiers. (see below)
Other fee changes under this program category include:
 Increase in the Bijou Community Park Parking Lot Rental and the Community Playfield Parking Lot Rental fee
 New fee added for the Bijou Community Park Lawn Space (up to 100 persons)  Bijou Bike Park or Skate Park Rental and Disc Golf Course Rental for Tournaments & Special Events (Bijou Park) to increase by CPI.
 Facility Rental Setup Fee increase to match newly adopted fee on the Recreation and Aquatic Center fee schedule.

Bijou Golf Course
Fees are recommended to increase by 10% resulting in $18,872 in additional revenue.

Two new fees are recommended:
 Individual Senior Season Pass (no restrictions)
 Individual Junior Season Pass (no restrictions)
Campgrounds
Fee Name Comments
Lakeview Commons, Bijou Community Park or
Regan Beach Special Event Rental, Attendance up to
500 persons
$1,091 Per Day $800 Per Day
Reduced by 27%
Lakeview Commons, Bijou Community Park or
Regan Beach Special Event Rental, Attendance 501-
1,000 persons
$1,364 Per Day $1,364 Per Day
Increase by CPI
Lakeview Commons, Bijou Community Park or
Regan Beach Special Event Rental, Attendance 1,001-
2,000 persons
New Per Day $1,900 Per Day
Increase fee from $1,364
to $1,900 which is a 39%
increase
Current Fee Proposed Fee
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All but one fee is recommended to stay the same with no increase. The one exception is listed below:
 Campground Site Fee - No hook up, up to 6 people and 1 car (includes $10 infrastructure fee). This fee is recommended to increase 5%, resulting in $15,917 in additional revenue.

In addition to the phase II fees reviewed, staff recommend adding two new fees to the new Recreation and Aquatics Center fee schedule.
a. Family Dance
b. Gym Sports Event (per team)
c. Family Annual Pass (1 adult and 1 child)
d. Stage Rental Fee (Gym Rental, Pool Rental, Dance Fitness, Community Room and Event Space
The full list of the proposed fees can be found in section 5 of this report.

P L A N N I N G
The City’s planning, land use and zoning services are intended to protect, maintain and develop an attractive, safe, and healthy community by providing planning services to the general public, project applicants, and other City Departments.

The Planning division is responsible for reviewing and processing permits and applications for development
The cost analysis for Planning shows an overall cost of processing development projects of $497,592 while generating associated revenue of $340,255, for a 68% cost recovery rate.

If proposed fee adjustments are adopted, annual revenue will increase to approximately $497,259 for an increase of $157,034. These projections are estimates only; actual revenues depend on activity levels, compliance, billing and collection practices, and any future changes to fee structures or City policies.
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P O L I C E
The Police department is primarily responsible for maintaining community quality of life by providing contemporary police response systems to meet the community’s expectations for service. The majority of services provided are not user fee related. However, the department does provide specific services which directly benefit an individual or business rather than the community as a whole and where a user fee charge is appropriate.

Several of the departments fees are restricted by the State of California. These fees have been proposed at the State prescribed amount. The remainder of fees are proposed for 100% cost recovery. The total cost of providing fee-eligible services annually is $171,158, while related revenue generated is $133,960 for a $37,198 subsidy. A combination of fee increases and decreases are proposed for a net $11,495 revenue increase.

FEE AREA

COST OF FEE

SERVICES

CURRENT

USER FEE

REVENUE
COST

RECOVERY
RATE

GENERAL

FUND SUBSIDY

PROJECTED

REVENUE
FROM

PROPOSED
FEES
COST

RECOVERY

RATE AT

PROPOSED
FEES

PROJECTED

REVENUE

INCREASE
Police $171,158 $133,960 78% $37,198 $145,455 85% $11,495 617

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5 FEE ANALYSIS AND RECOMMENDATIONS

CITYWIDE RECOMMENDATIONS

1. GCP recommends the department update its user fees in non-study years by an annual inflation index to keep fees more closely aligned with staffing costs. We recommend the following index be applied as part of the regular budget cycle:
 Bureau of Labor Statistics Consumer Price Index (CPI), San Francisco-OaklandHayward, December release.

Certain fees are exempt from these annual indexed adjustments, such as percentagebased fees or those limited by the State or Federal government to a specific dollar amount.

2. GCP recommends the City monitor the revenue generated by new and adjusted fees and performing a check at both six months and one year to ensure that new and restructured fees are performing the way they were intended.

3. GCP recommends that South Lake Tahoe conduct a detailed analysis at least every three to five years, with minor adjustments, such as new fees arising from new legislation, be incorporated as needed.

ANALYSIS AND RECOMMENDATIONS BY DEPARTMENT/DIVISION
The following pages present GCP’s analysis and proposed fee for each user-fee related service.

618
Building
619
Fee Category
1 Building Permit Fee 2% % of valuation 2% 100% 100% 2% valuation 2 Administrative Processing $128 per hour/ 1 hr min. $128 100% 100% $151 per hour / 1 hr min. 3 Active Building Permit Extension $191 each $191 100% 100% $191 each 4 Building Plan Review Extension $191 each $191 100% 100% $191 each 5 Building Plan Review $128 per hour / 1 hr min. $128 100% 100% $128 per hour / 1 hr min. 6 Stop Work Notice of Violation $428 each $428 100% 100% $428 each 7 Stop Work/Red Tag Permit Fee 2x pmt each n/a n/a n/a 2x pmt 8 Special Building Inspections $177 per hour / 1 hr min. $177 100% 100% $177 per hour / 1 hr min. 9 Building Inspection/Reinspection Fee $177 each $177 100% 100% $177 each 10 Document Printing & Copying $0.10 per page $0.10 100% 100% $0.10 per page 11 Permit Technology Fee $13 each permit $31 42% 100% $31 each permit 12 Illegal Unit Review $1,107 each $1,107 100% 100% $1,107 each 13 Admin Fee for Cost of Collection on Liens, Nuisance, etc. 25% % of
collection costs 25% 100% 100% 25% of collection costs
14 Temporary Certificate of Occupancy Application $177 each $177 100% 100% $177 each 15 Demolition Permit $440 each $440 100% 100% $440 each 16 Resid. Fire Sprinkler Insp: 1-50 heads $248 per inspection $248 100% 100% $248 per insp 17 Resid. Fire Sprinkler Insp: 51+ heads $604 per inspection $604 100% 100% $604 per insp 18 Resid. Fire Plan Review $128 hourly $128 100% 100% $128 hourly 19 General Plan/ Community Plan/Area Plan Maint Fee $1.15 construction
valuation $1.15 100% 100% $1.15 const val
21 Re-check Fee (4th + each add'l check) NEW each NEW 100% 100% $256 each 22 Fees for work not specifically identified elsewhere NEW hourly NEW 100% 100% $177 hourly City of South Lake Tahoe
Building PER UNIT ANALYSIS
Current Fee
Cost Per
Unit
Cost
Recovery
Proposed
Fee
To nearest $5
Fee
Description
Proposed
Cost
Recovery
620

REVENUE
10003110 BUILDING & SAFETY REVENUE ALL SOURCES USER FEE 33132 Federal ARP Act Funding $9,408 $9,408
34008 TRPA MOU $134,428 $134,428
34140 Building Fees $1,538,398 $1,538,398
34180 Printing & Duplicating $19 $19
34230 Fire-Prev Special Inspect Fees $153,184 $153,184
36322 Trans in From Bldg Permits (271) $250,000 $250,000 10003112 MFD REVENUE ALL SOURCES USER FEE
32900 Penalty & Interest $31,549
34151 MFD Annual Fee $160,481 $160,481
34154 SRO Fee $48,988 $48,988
27103110 REVENUE ALL SOURCES USER FEE
34140 Building Fees $502,076
35310 Interest/Dividends $70,354
2024 ACTUAL USER FEE REVENUE $2,294,906

EXPENSES
10003110 BUILDING & SAFETY EXPENSES ALL SOURCES USER FEE STAFFING $489,092 $489,092
BENEFITS $220,316 $220,316
CONTRACT SERVICES $416,306 $416,306
OTHER EXPENSES $20,544 $20,544
CITYWIDE INDIRECT COST $222,659 $222,659
10003112 MFD EXPENSES ALL SOURCES USER FEE
STAFFING $154,251 $154,251
BENEFITS $57,323 $57,323
OTHER EXPENSES $435 $435
CITYWIDE INDIRECT COST $32,707 $32,707
27103110 EXPENSES ALL SOURCES USER FEE
CITYWIDE INDIRECT COST $5,334 $227,993

TRANSFER IN FROM LR PLANNING ALL SOURCES USER FEE
PLANNING SUPPORT TO BUILDING $211,176

TRANSFER IN FROM FIRE ALL SOURCES USER FEE
FIRE SUPPORT TO BUILDING $50,000

TRANSFER IN FROM PUBLIC WORKS ALL SOURCES USER FEE
PW SUPPORT TO BUILDING $50,000
2024 ACTUAL EXPENSES $2,152,802
NET REVENUE SURPLUS $142,104

BUILDING DIVISION
Total Cost vs Total Revenue Matchup
2024 ACTUALS
621
City Clerk
622
1 Appeals $380 Per appeal $1,253 30% 100% $1,253 Per appeal 2 Document Printing and Copying - .10 per page plus
postage $0.10 Per document page $0.10 100% 100% $0.10 Per document page 3 City Council Chambers Use Application Fee $28 Per application $35 80% 100% $35 Per application 4 City Council Chambers Rental, M-F, 8-5 p.m. $44 Per Hour $50 88% 100% $50 Per Hour 5 Video Meeting Electronic File Transfer, 1 per Drive $5 Per Thumb Drive $5 100% 100% $5 Per Thumb Drive 6 Verbatim Transcript Service $0 Hourly or Actual Outsource Cost $0 0% 100% Hourly or Actual Outsource Cost
7 Notary Service $15 Per form $15 100% $15 Per form
8 Notary Service - Providing California Notary
Acknowledgement or Jurat Form $1 Per form $1 100% $1 Per form 9 Agenda Mailing Service, .10 per page plus postage $0.10 Per page plus postage $0 100% $0.10 Per page plus postage 10 Filming Application Fee Basic $197 Fixed Fee $164 120% 100% $164 Fixed Fee 11 Public Property Use Fee (for filming only) $767 Change to See Facility Rental Fee Schedule $0 0% See Facility Rental Fee Schedule 12 Temporary Sign Deposit (yard signs) $174 Refundable Deposit (Campaign) $0 0% $174 Refundable Deposit
(Campaign)
13 City Council AV Service Fee $0 New Fee: Per Hour (1 hour minimum) $99 0% 100% $99 New Fee: Per Hour (1 hour
minimum)
14 Film Application Fee Special $0
New Fee: Applications that
require additional City
Clerk, Fire, Police or Public
Works, review will be
charged the hourly rate of
the Department Head
reviewing the Permit
Application.
$192 0% 100% $192
New Fee: Applications that
require additional City
Clerk, Fire, Police or Public
Works, review will be
charged the hourly rate of
the Department Head
reviewing the Permit
Application.
15 Film Appliation Fee Rush (less than 7 business days) $0 New - Base Fee x 1.5 $0 0% $0 New - Base Fee x 1.5 16 Film Permit Change Fee $0 New - Fixed Fee $132 0% 100% $132 New - Fixed Fee 17 Airport Commercial Filming $0
Airport Commercial Filming
will be processed by Airport
Manager
$0 0% $0
Airport Commercial Filming
will be processed by Airport
Manager
Fee Category Fee Description Proposed Fee

PER UNIT ANALYSIS
Current
Fee
Recommended
Cost Recovery
City of South Lake Tahoe -
City Clerk
Current
Cost
Recovery
Current
Cost Per
Unit
GCP
623
Engineering
624
1 Street/Property Abandonment $3,277 flat $2,855 115% 100% $2,855 flat 2 Single-Family Residential PW plan review $128 per hour $145 88% 100% $145 per hour 3 Multi-Family Residential PW plan review (6 units or less) $128 per hour $145 88% 100% $145 per hour 4 Large Multi-Family Residential PW plan review (7 or more units) $1,711 flat $145 n/a 100% $145 per hour
5 Commercial Development/Redev PW plan review $128 per hour $145 88% 100% $145 per hour 6 GIS Fee (special requests for information/maps) $347 flat $309 112% 100% $309 flat 7 Grading: <10 cubic yards (no fee) $0 free $0 n/a n/a $0 free 8 Grading: 10+ cubic yards $566 flat $754 75% 100% $754 flat 9 Grading: 8 - 350 cubic yards $957 REMOVE n/a n/a n/a REMOVE 10 Grading: 351+ cubic yards $2,468 REMOVE n/a n/a n/a REMOVE 11 Parcel Merger/Lot Line Adjustment/ Parcel Maps $128 per hour $145 88% 100% $145 per hour 12 Final Subdivision Map $128 per hour $145 88% 100% $145 per hour 13 Tentative Subdivision Map $128 per hour $145 88% 100% $145 per hour 14 Obstruction Permit $307 flat $340 n/a n/a $340 flat
15 Encroachment (street cut) Permit/Minor $766 flat $340 226% 100% $340 flat 16 Encroachment (street cut) Permit/Major $766
plus 1.5% of
Val over $20k $503 100% 100% $503
plus 1.5% of
Val over $20k
17 Transportation Yearly Permit $148 Set by State n/a n/a n/a $90 Set by State 18 Transportation Single Permit $105 Set by State n/a n/a n/a $16 Set by State 19 Permit Violation/ Stop Work Fee $1,532 flat n/a n/a n/a $1,532 flat 20 Storm Water Inspection Fee: Commercial $262 flat $293 90% 100% $293 flat 21 Storm Water Inspection Fee: Commercial Reinspection $131 flat $293 45% 100% $293 flat 22 Storm Water Inspection Fee: Industrial $327 flat $400 82% 100% $400 flat 23 Storm Water Inspection Fee: Industrial Reinspection $131 flat $400 33% 100% $400 flat 24 Easement Request/ Review $1,417 flat $4,368 32% 100% $4,368 flat 25 Reproduction Fee $4 per 23x26" $13 31% 100% $13 per 23x26" 26 Street Name Change actual cost actual cost n/a n/a n/a actual cost To nearest $1
Proposed Fee
Cost Per
Unit
Cost
Recovery
Proposed
Cost
Recovery
Public Works - Engineering
Org 3210
Fee Category Current Fee
Fee
Description
City of South Lake Tahoe

PER UNIT ANALYSIS
625
To nearest $1
Proposed Fee
Cost Per
Unit
Cost
Recovery
Proposed
Cost
Recovery
Public Works - Engineering
Org 3210
Fee Category Current Fee
Fee
Description
City of South Lake Tahoe

PER UNIT ANALYSIS
27 Unapproved Work (ROW)/ Correction Fee/ Inspections or Repairs to City Infrastructure $946 flat n/a n/a n/a $946 flat 28 PW Condominimization of Existing Resid. Development $128 per hour $145 88% 100% $145 per hour 29 PW Inspections/ Re-inspections $177 per insp $145 122% 100% $145 per hour 30 Third Party Plan Reviews New Fee Actual Cost n/a n/a n/a actual cost 31 Technology Fee $13 per permit $31 $1 $31 per permit
626
Finance
627
1 Administrative Fee - New license application
(Including $31 Business License Technology Fee) $86 application $108 80% $108 application 2 Administrative Fee - New Business One Time 6
Month License Application $42 application $32 131% $32 application 3 Administrative Fee - Annual Renewal (Including $31
Business License Technology Fee) $68 application $63 108% $63 application 4 AB1379 (amended SB1186; ADA info and access fee
- State of CA mandated; effective 1/1/2018 $4
per business
certificate $4 100% $4
per business
certificate
5 Business License Technology Fee; collected with
admin fee $13
business
application $31 42% $31
business
application
6 Business License Certificate - duplicate copy $19 certificate $12 158% $12 certificate 7 Lien Release Fee $0
lien: Passed on to
Seller through
Escrow $372 0% $372
lien: Passed on to
Seller through
Escrow
8 Administrative Fee for Delinquent Refuse
Collections $87 lien $87 100% $87 lien
9 Delinquent Tax Analysis $0
per project: At
cost using fully
burdened hourly
rate $0
per project: At cost
using fully
burdened hourly
rate
10 Motel Tax Master (name/address listing) $63 per report $40 158% $40 per report 11 Individual TOT Report $18
per motel/per
year $17 106% $17 per motel/per year
12 Vacation Home Rental Master Report $68 per report $40 170% $40 per report 13 Vacation Home Rental Label Report $63
per report plus
cost of labels $40 158% $40
per report plus cost
of labels
14 Business License Master Report, Standard Format $63 per report $79 80% $79 per report 15 Business License Master Report Requiring Specific
Formatting Due to Information Request $63
per report plus
fully burdened
hourly rate $79 80% $79
per report plus fully
burdened hourly
rate
17 Returned Check (NSF) Processing - 1st check $28 per check $25 112% $25 per check 18 Returned Check (NSF) Processing - Subsequent
checks $35 per check $35 100% $35 per check
Fee Category Cost
Recovery Fee Description

PER UNIT ANALYSIS
Finance
Cost Per
Unit
City of South Lake Tahoe
Current Fee Proposed Fee
GCP
628
Fee Category Cost
Recovery Fee Description

PER UNIT ANALYSIS
Finance
Cost Per
Unit
City of South Lake Tahoe
Current Fee Proposed Fee
19 Geobase Information Service, Research $0
At cost using fully
burdened hourly
rate per project $112 0% $112
At cost using fully
burdened hourly
rate per project
20 Stop Payment Fee $0
At cost using
actual bank
charge per check $0
At cost using actual
bank charge per
check
GCP
629
Department
Fire
630
2 EMS: Advanced/Basic Life Support, incident response $532 Hourly --> Flat Rate $646 82% 93% $598 3 EMS: Advanced/Basic Life Support - with standby to support air ambulance transport, incident response
$1,032 Remove Fee Remove
4 EMS: Advanced/Basic Life Support - with engine standby for CPR, incident response $1,032 Remove Fee Remove 6 County Fire Services: Lake Valley Fire District Contract Remove Fee Remove 7 County Fire Services: Fallen Leaf Fire District Contract Remove Fee Remove 9 Wild Land Suppression: Support Vehicle CA OES Rate CA OES Hourly Rate 100% 100% CA OES Rate 10 Wild Land Suppression: Pumping Engine CA OES Rate CA OES Hourly Rate 100% 100% CA OES Rate 11 Wild Land Suppression: Ladder Truck CA OES Hourly Rate - Remove
Remove
13 Motor Vehicle Accident: Level 1 Basic Response $1,159 Hourly --> Flat Rate $1,406 82% 100% $1,406 14 Motor Vehicle Accident: Level 2 Extrication $1,757 Hourly --> Flat Rate $1,879 94% 100% $1,878 15 Motor Vehicle Accident: Level 3 Multi Casualty $2,577 Hourly --> Flat Rate $3,337 77% 100% $3,337 17 Hazmat Cleanup: Level 1 Basic Response $771 Hourly --> Flat Rate $1,233 63% 100% $1,232 18 Hazmat Cleanup: Level 2 Full Alarm Response $2,577 Hourly --> Flat Rate $3,342 98% 100% $3,341 20 Bomb Squat Response: Level 1 Full Alarm Response $1,159 Hourly --> Flat Rate $1,233 94% 100% $1,232 21 Bomb Squat Response: Level 2 Full Alarm Engine Response plus TD Bomb Unit $2,577 Hourly --> Flat Rate $2,816 92% 100% $2,816 23 Pipeline/Power Lines: Level 1 Single Engine $1,159 Hourly --> Flat Rate $1,175 99% 100% $1,174 24 Pipeline/Power Lines: Level 2 Full Alarm Engine Response $2,577 Hourly --> Flat Rate $2,643 97% 100% $2,643 25 Pipeline/Power Lines: Fire Hydrant Flow Test $337 Remove Fee Remove 26 Pipeline/Power Lines: Witnessed Acceptance Test $337 Remove Fee Remove 27 Pipeline/Power Lines: Fire Watch Service Actual Cost Actual Cost Actual Cost 100% 100% Actual Cost 28 Pipeline/Power Lines: Structure Fire Suppression (includes scene safety, initial investigation, traffic control, patient contact, hazard control) $2,577 Hourly --> Flat Rate $2,861 90% 100% $2,860 31 Level 1 Single Engine - Water Indicents $1,159 per incident $1,237 94% 100% $1,237 33 Level 1 in City - Search and Rescue $819 Per incident $1,233 66% 100% $1,232 35 False Alarm Responses 1st Offense $164 Fine $526 31% 31% $164 36 False Alarm Responses 2nd Offense + $274 Fine $526 52% 52% $274 37 Open Burning and Recreational Fires $273 Remove Fee Remove 38 Ceremonial/Special Permit $0 New Fee $70 0% 100% $70 39 Arson Investigation - Includes scene safety, investigation, source ID, Arson dog, equipment use, mobile detection and report Actual Cost Actual Cost Actual Cost 100% 100% Actual Cost 40 Fire Investigation Reports $0 No Fee $41 0% 0% $0
41 Fire Incident Report $0 No Fee $41 0% 0% $0
42 Copies $0 Per Page --> No Fee $0 0% 0% $0
43 Photographs $0 Remove Remove
44 Video Tape Duplication $0 Remove Remove
45 Fireworks/Pyrotechnical Display Permit $448 flat $247 181% 100% $247 46 Fire Dance Permit Annual Fee $225 flat $189 119% 100% $189 47 Per Event Inspection Per Hour Remove Fee Remove
Fee Category
City of South Lake Tahoe
Fire Department PER UNIT ANALYSIS
Current Fee Fee Description Current Cost
Per Unit
Current Cost
Recovery
Proposed Cost
Recovery Proposed Fee
631
Fee Category
City of South Lake Tahoe
Fire Department PER UNIT ANALYSIS
Current Fee Fee Description Current Cost
Per Unit
Current Cost
Recovery
Proposed Cost
Recovery Proposed Fee
48 Defensible Space Inspections for AB38 (Real Estate Sale) $32 Hourly $148 22% 66% $98 49 Defensible Space Inspections for Homeowners (includes tree marking) $32 flat $148 22% 66% $98 50 Tree Removal Permit $0 New Fee $173 0% 43% $75
51 Special Event / Fire Inspections (3 hour min if conducted outside regular work hours) $177 Remove Fee Remove 53 Misc. Event Standby $0 CA OES Hourly Rate $338 0% 100% $337 55 Auto Alarm/Ext Supression System - 100 1-99 $248 Per Inspection Remove 56 Auto Alarm/Ext Supression- 100+ $445 Per Inspection Remove 57 Suppression Sys-50 hds/Dry Chem sys $248 Remove Fee Remove 58 Suppression Sys-200 hds $604 Remove Fee Remove
59 Underground Main Inspection <2” $121 Per Inspection $222 54% 100% $222 60 Underground Main Inspection >2” $248 Per Inspection $222 112% 100% $222 62 Board 7 Care Facility 7-50 $138 Remove Fee Remove
63 Board 7 Care Facility 50+ $343 Remove Fee Remove
64 Day Care Facility 6+ $128 Per Inspection $222 58% 89% $198 65 Fire Plan Review - Commercial, MFD, Special Event $263 Per Hour $199 132% 100% $199 66 Basic Fire Inspection, <1k k sq. ft. $96 flat $173 56% 100% $173 67 Basic Fire Inspection, 1k - 4k sq. ft. $134 flat $222 60% 100% $222 68 Basic Fire Inspection, 4k - 9k sq. ft. $161 flat $272 59% 100% $271 69 Basic Fire Inspection, >9 k sq. ft. $204 flat $346 59% 100% $345 70 Basic Fire Inspection - Hourly, after 4 hours $0 New Fee $99 0% 100% $99 71 Child Care Inspection Occupancy Permit Non-Home $109 flat $173 63% 100% $173 72 Child Care Inspection Occupancy Permit Home $109 flat $173 63% 100% $173 73 Miscellaneous Fire Services Actual Cost Actual Cost Actual Cost 100% 100% Actual Cost 74 Fire Inspection/Re-Inspection (Including Special Events) $177 Per Hour $177 100% 100% $177 75 Operational Permit and Inspection CFC 105.6 - not including inspection $254 flat $247 103% 100% $247 76 Fire Processing Permit Fee New $151 100% $151
632
Parks and
Recreation
633
City of South Lake Tahoe
Parks and Recreation
Current Adopted
Fee
3/25/2025
Outdoor Park
Outdoor Park Facility Rentals
Alcohol Use Permit, City Sanctioned Public/Private
Outdoor Facilities $66 Each $66 $576 $576
Bijou Park, Kiwanis Picnic Shelter (4 Hours) $173 4 Hour Block $173 $2,096 $2,096 Bijou Park, Rotary Picnic Shelter (4 Hours) $173 4 Hour Block $173 $2,419 $2,419 Recreation Complex Group Picnic Areas (4 Hours) $173 4 Hour Block $173 $0 $0 Gazebos and Picnic Areas beyond 4 hour minimum rental $46 Hourly After 4 Hours
$46 $0 $0
Private Rental: Regan Beach West (Per Hour; 2-Hour
Minimum) (Rents for Wedding and special events) $222 Mon-Thur $/hr $222 $738 $738 $287 Fri & Sun $/hr $287 $7,200 $7,200
$349 Sat $/hr $349 $17,964 $17,964
Late Payment Penalty Fee 10% of total rental
fee due
10% of total rental
fee due
10% of total rental
fee due
Public Special Event Park Rentals
Lakeview Commons, Bijou Community Park or Regan
Beach Special Event Rental, Attendance up to 500 persons $1,091 Per Day $800 $0 $0 Lakeview Commons, Bijou Community Park or Regan
Beach Special Event Rental, Attendance 501-1,000
persons
$1,364 Per Day $1,364 $0 $0
Lakeview Commons, Bijou Community Park or Regan
Beach Special Event Rental, Attendance 1,001-2,000
persons
New Per Day $1,900 $0 $0
Bijou Community Park Lawn Space (up to 100 persons) New Per Hour $50 $0 $0 Bijou Bike Park or Skate Park Rental $254 Per Day $254 $2,381 $2,381 Disc Golf Course Rental for Tournaments & Special Events (Bijou Park) $267 Per Day $267 $801 $801
Bijou Park Concession (absent lease agreement) $299 Per Day $299 $1,637 $1,637 Bijou Community Park Parking Lot Rental $105 Per Day $215 $0 $0 Community Playfield Parking Lot Rental $105 Per Day $215 $0 $0

PER UNIT ANALYSIS
Program
Recovery
Percentage
Fee Category Fee Description Proposed Fee Current Revenue Projected Revenue 634
City of South Lake Tahoe
Parks and Recreation
Current Adopted
Fee
3/25/2025

PER UNIT ANALYSIS
Program
Recovery
Percentage
Fee Category Fee Description Proposed Fee Current Revenue Projected Revenue Facility Rental Setup Fee $43 Per Hour Per Staff $48 $0 $0 Special Event Vendor Fee Not to Exceed
$125 per event
Not to Exceed
$125 per event
Not to Exceed $125
per event
$1,575 $1,575
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate 25% Off Base Rate Late Payment Penalty Fee 10% of total rental
fee due
10% of total rental
fee due
10% of total rental
fee due
Group Rentals may be subject to $500 minimum or $1500
maximum security deposit and/or cleaning fees at the
discretion of the City of South Lake Tahoe
$500 $500 (Security
Deposit)
$500 minimum or
$1,500 Maximum
security deposit
and/or cleaning fees
Group Rentals May Be Subject to a Minimum of $15
Cancellation Fee and Maximum of $50 at the Discretion
of City of South Lake Tahoe
$15 Minimum or
$50 Maximum
$15 (Cancellation
Fee)
$15 Minimum or
$50 Maximum $110 $110
Golf Course
9 Hole $20 Each $22 $77,765 $85,542
9 Hole Senior $18 Each $20 $36,990 $40,689
9 Hole Junior (17 and under) $11 Each $12 $1,408 $1,549 9 Hole Family (1 adult & 1 Junior (17 and under) $24 Each $26 $9,000 $9,900 Add 9 Holes $13 Each $14 $2,184 $2,402
Twilight (last 2 hours of tee times) $17 Each $19 $18,258 $20,084 Cart Rental $5 Each $6 $16,540 $18,194
Club Rental $17 Each $17 $15,045 $15,045
Golf Course Passes
20 Use $280 Each $308 $26,575 $29,232
10 Use $155 Each $171
10 Use Twilight (last 2 hours of daylight) $130 Each $143 10 Use Senior $140 Each $154
10 Use Family (1 Adult & 1 Junior (17 and under) $180 Each $198 635
City of South Lake Tahoe
Parks and Recreation
Current Adopted
Fee
3/25/2025

PER UNIT ANALYSIS
Program
Recovery
Percentage
Fee Category Fee Description Proposed Fee Current Revenue Projected Revenue 10 Use Junior (17 and under) $85 Each $94
Individual Adult Season Pass (no restrictions) $450 Each $495 Individual Senior Season Pass (no restrictions) New Each $450 Individual Junior Season Pass (no restrictions) New Each $450 Administrative Fee for replacement of annual passes only $10 Each $10 Bijou Golf Course use in partnership with Boys and Girls Club No Charge No Charge No Charge
Campground
Campground Site Fee - No hook up, up to 6 people and 1
car (includes $10 infrastructure fee) $45 Per Day $47 $318,340 $334,257 Standard Cabin (includes $10 infrastructure fee) $90 Per Day $90 $0 $0 Reservation Fee (non-refundable) $10 Each $10 $32,805 $32,805 Cancellation Fee (Inside 30 days from arrival date) $50 One night rental fee $50 $7,747 $7,747
Cancellation Fee (Outside 30 days of arrival date) $10 Each $10 $1,480 $1,480 Dump Fee (charged to campers not staying in our
campground) $15 Each $15 $1,911 $1,911
Extra person $6 Each $6 $3,138 $3,138
Visitor Day Use $5 Each $5 $5 $5
Pets $2 Each $2 $5,112 $5,112
Extra Vehicle (no holding tanks) $6 Each $6 $7,650 $7,650 Motorcycles and Electric Scooters $3 Each $3 $6 $6
Late Checkout Fees $10 Per Site $10 $330 $330
Boat Ramp*
Day Use $17 Per Day $17 $36,464 $36,464
Annual Pass $138 Each $138
636
City of South Lake Tahoe
Parks and Recreation
Current Adopted
Fee
3/25/2025

PER UNIT ANALYSIS
Program
Recovery
Percentage
Fee Category Fee Description Proposed Fee Current Revenue Projected Revenue Recreation and Aquatic Center
Family Dance New
Per Person (Adults
and Children) $15 $0 $0
New Children under 2
are free Free $0 $0
Gym Sports Event New Per Team $40 $0 $0
Family Annual Pass (1 adult & 1 child) New Each $560 $0 $0 Stage Rental Fee (Gym Rental, Pool Rental, Dance Fitness, Community Room and Event Space)
New $150 $0 $0
*The Division of Boating and Waterways currently limits these fees to $17 for Day Use and $138 for an Annual Pass. 637
Planning
638
Fee Category
1 Deposit - Building Permit $1,000 Deposit n/a n/a n/a $1,000 Deposit 2 Residential Permit Processing $784 REMOVE n/a n/a n/a 3 Allocation Application Processing $784 Flat $951 82% 100% $950 Flat 8 Inclusionary Housing Plan Check Process NEW Flat $152 n/a 100% $150 Flat 13 Major General Planning Application $3,219 Flat $5,785 56% 100% $5,780 Flat 14 Minor General Planning Application $1,019 Flat $4,301 24% 100% $4,300 Flat 15 Permit Revision and/or Extension $600 Flat $1,294 46% 100% $1,290 Flat 16 Categorical Exemption $82 Flat $190 43% 100% $190 Flat 17 Negative Declaration Review $4,414 Flat n/a n/a 100% 18 Negative Declaration Preparation $7,991 Flat n/a n/a 100% 19 EIR/ EIS 25% Contract +25% n/a n/a 100%
20 Fence Permits (Commercial Only) $291 Flat $381 76% 100% $380 Flat 21 Home Occupation Permit $146 Flat $228 100% 100% $225 Flat 22 Minor Sign Review and Approval $161 Flat $457 100% 100% $455 Flat 23 Major Sign Review and Approval $400 Flat $609 100% 100% $605 Flat 24 Sign Permit Revision Application and Review $161 Flat $381 100% 100% $380 Flat 25 Locally Unique Sign Application $3,219 Flat $4,339 100% 100% $4,335 Flat 26 Minor Special Event Permit $231 Flat $1,028 100% 100% $1,025 Flat 27 Major Special Event Permit $459 Flat $1,028 100% 100% $1,025 Flat 28 Non-Profit Producer and Free Special Event $0 Free $1,028 0% 0% Free 29 Temporary Use Permit $689 Flat $913 100% 100% $910 Flat 30 Certificate of Compliance $888 Flat $913 100% 100% $910 Flat 31 Tentative Subdivision Map $5,850 Flat $6,584 100% 100% $6,580 Flat 32 Condominimization of Existing Resid Dev. $6,016 Flat $6,432 100% 100% $6,430 Flat 33 Cannabis Use Permit $5,816 Flat $5,556 100% 100% $5,555 Flat 36 Cannabis Annual Inspection Fee $2,100 Flat n/a n/a n/a $2,100 Flat 37 Cannabis Re-Inspection Fee $894 Flat n/a n/a n/a $894 Flat 38 Zoning Letter $253 Flat $343 100% 100% $340 Flat
39 Document Copying $0.10 Flat $0.10 100% 100% $0.10 Flat 40 Planning Review of Building Permits $128 Flat $152 100% 100% $150 Flat City of South Lake Tahoe
Planning PER UNIT ANALYSIS
Current Fee
Cost Per
Unit
Cost
Recovery
Proposed
Fee
To nearest $5
REMOVE
Contract +25%
Contract +25%
Contract +25%
Fee
Description
Proposed
Cost
Recovery
639
Fee Category
City of South Lake Tahoe
Planning PER UNIT ANALYSIS
Current Fee
Cost Per
Unit
Cost
Recovery
Proposed
Fee
To nearest $5
Fee
Description
Proposed
Cost
Recovery
41 Admin Fee for Cost of Collection on Leins and other
remedies 25% Admin % n/a n/a n/a 25% Admin
42 Public Notice Label Preparation $234 Flat $190 100% 100% $190 Flat 44 General Plan Amendment $8,855 dep Deposit $0 100% 100% 45 Community Plan Amendment/Area Plan/ Plan Area Statement $8,855 dep Deposit $0 100% 100% 46 Annexation Hourly Hourly $0 100% 100%
47 Mobile Vending: Location Permit $586 Flat $837 100% 100% $835 Flat 48 New Vendor Permit $177 Flat n/a n/a n/a REMOVE
49 Mobile Vending: Renewal Permit $88 Flat n/a n/a n/a REMOVE 50 Publicly Visible Art on Private Property: Public Murals $0 Free $799 100% 100% Free 51 Publicly Visible Art on Private Property: Non-Mural $257 Flat $951 100% 100% $950 Flat 52 Technology Fee $0
NEW
for Planning $31 0% 100% $31 Flat
$10,000 dep
$10,000 dep
$10,000 dep
640
Department
Police
641
1 Other Permits - New $474 each $533 89% 100% $533 each 2 Other Permits - Renewal $235 each $277 85% 100% $277 each 3 Pedicab Permit - Owner/Operator New $263 each $273 96% 100% $273 each 4 Pedicab Permit - Owner/Operator Renewal $92 each $91 101% 100% $91 each 5 Pedicab Permit - Driver New $156 each $197 79% 100% $197 each 6 Pedicab Permit - Driver Renewal $61 each $50 122% 100% $50 each 7 Sidewalk Vending Permit - New $165 each $227 73% 100% $227 each 8 Sidewalk Vending Permit - Renewal $28 each $80 35% 100% $80 each 9 Letter of Public Convenience or Necessity $459 each $458 100% 100% $458 each 10 Misdemeanor Booking $44 per booking $46 97% 100% $46 per booking 11 Fingerprinting $27 each $71 38% 100% $71 each
12 Live Scan Fingerprinting $18 each $85 21% 100% $85 each 13 Local Criminal Clearance Letter $10 each $45 22% 100% $45 each 14 Towed Vehicle Release $165 each $242 68% 100% $242 each 15 Special Police Service $0 actual cost actual cost n/a n/a actual cost 16 DUI Incident Response - Police & Fire $0 actual cost actual cost n/a n/a actual cost 17 Copy of Dispatch Event $0.11 per page $0.11 100% 100% $0.11 per page 18 Restitution Rate $0 actual cost actual cost n/a n/a actual cost 19 Govt. Code Controlled Activities $0 actual cost actual cost n/a n/a actual cost 20 Other Special Activities $0 actual cost actual cost n/a n/a actual cost 21 Special Police Boat Service $0 actual cost actual cost n/a n/a actual cost 22 Equipment Reimbursement $0 actual cost actual cost n/a n/a actual cost 23 Firearm(s) Release (by appointment only) $44 per firearm $46 n/a n/a $46 per firearm 24 Ski Run Blvd. Vehicle Control $0 actual cost actual cost n/a n/a actual cost 25 Tape Duplication - Audio $23 tape $23 100% 100% $23 tape 26 Tape Duplication - Video $23 tape $23 100% 100% $23 tape 27 Crime Scene/Police Photo Reproduction (CD photo) $23 CD $23 100% 100% $23 CD 28 Taxicab Company Permit $5 annual $12 42% 100% $12 annual 29 Taxicab Vehicle Permit $5 annual per vehicle $27 19% 100% $27 annual 30 Taxicab Driver Permit $28 annual $51 55% 100% $51 annual To nearest $0.01
Cost
Recovery
Proposed
Fee
Cost per
Unit
Proposed
Cost
Recovery
Fee
Description
City of South Lake Tahoe PER UNIT ANALYSIS Police Department Fee Category
Current
Fee
642
To nearest $0.01
Cost
Recovery
Proposed
Fee
Cost per
Unit
Proposed
Cost
Recovery
Fee
Description
City of South Lake Tahoe PER UNIT ANALYSIS Police Department Fee Category
Current
Fee
31 False Alarm: 1st and 2nd $0 free free n/a n/a free
32 False Alarm: 3rd $50 penalty $161 n/a n/a $50 penalty 33 False Alarm: 4th $100 penalty $161 n/a n/a $100 penalty 34 False Alarm: 5th $150 penalty $161 n/a n/a $150 penalty 35 False Alarm: 6th $250 penalty $161 n/a n/a $250 penalty 36 False Alarm: Additional $25 penalty $161 n/a n/a $25 penalty 37 Non Permitted False Alarm
Penalty equal to
Pmt Fee penalty n/a n/a n/a
Penalty equal
to Pmt Fee
38 Initial Alarm Permit Application - Resident, 3 yr $41 permit $60 68% 100% $61 permit 39 Renewal Alarm Permit - Resident, 3 yr $19 permit $38 50% 100% $38 permit 40 Initial Alarm Permit Application - Business, 1 yr $41 permit $60 68% 100% $61 permit 41 Renewal Permit - Business, 1 yr $19 permit $38 50% 100% $38 permit 42 Public Safety License Fee $1,190 each $1,190 100% 100% $1,190 each 43 Public Safety License Renewal Fee $1,190 each $1,190 100% 100% $1,190 each 44 Public Safety License Amendment Fee $300 each $304 99% 100% $304 each 45 Shared Mobility Device Fee $83 per device $113 73% 100% $113 per device 46 Reposession Fee $0 State Fee $15 n/a n/a $15 Set by State 643
Fee
Comparison
Survey
644

DEPARTMENT/DIVISION
South Lake Tahoe
Current Fee
South Lake Tahoe
Proposed Fee Auburn El Dorado County Folsom Mammoth Lakes Placerville Placer County Truckee Building Permit 2% of valuation 2% of valuation
$2k val: $122
$100k val: $1,400
$1M val: $9,000

1.3% of valuation
$2k val: $138
$100k val: $1,104
$1M val: $7,360
$2k val: $225
$100k val: $2,153
$1M val: $14,495
$2k val: $95
$100k val: $1,200
$1M val: $7,500
SFD < 3,000 sq ft
$265
SFD > 3,000 sq ft
$193
Square Footage
Resid 2,500sf $2,767
Restaurant 5,000sf $
Plan Review $128/ hour $128/ hour 65% of bldg pmt fee $167/ hour 80% of bldg pmt fee included in permit $2k val: $95
$100k val: $600
$1M val: $3,300
50% of bldg pmt fee no information
Temporary Certificate of Occupancy $177 $177 $1,500 + $500 each 30 day extension no information $942 $225 no information no information no information Re-check fee n/a $256 for 4th + each
additional check no information Review of 2nd corrections $247 no information $90/ hour no information $156/ hour no information Technology Fee $13/ permit $31/ permit 4% of development fee 5.65% of development fee no information no information no information 3.5% of development fees ($560 max fee) no information Appeals $380 $1,253 $1,455 $494 Owner Occupied: $264
Others: $536
Staff decision: $2,310
PC decision: $1,942 no information $774 no information
Document Printing & Copying $0.10 per page no information $0.15 per page $0.15 per page $0.10/ page (1st 10 pages free) no information no information 1st Page $2Each Add'l $1 B&W $0.10 per page
Color: $0.15/page
Notary Service $15 no information no information $15 per signature no information no information no information $15 $15 Filming Application - Basic Service $197 $164 no information 1-20 ppl: $255
21-50 ppl: $510
51+ ppl: $1,615
no information no information no information Free no information

BUILDING

CITY CLERK
645

DEPARTMENT/DIVISION
South Lake Tahoe
Current Fee
South Lake Tahoe
Proposed Fee Auburn El Dorado County Folsom Mammoth Lakes Placerville Placer County Truckee Street/ Property Abandonment $3,277 $2,855 ROW Vacation $2,075 $595 $5,750 no information $688 $2,000 deposit
Parcel Merger/ Lot Line Adjustment/ Parcel Map $128/ hour $145/ hour Resid: $1,758
Comm: $2,636
Merger: $732
LLA: $935
Merger: $340 $8,050 no information $500 Minor Land Division $1,993 $3,000 deposit Final Subdivision Map $128/ hour $145/ hour $3,342 + $63/lot $6,175 $11,500 + $144/ lot no information $3,856 + $20/lot deposit
Encroachment Permit/ Minor $766 $340 $296 + $141/year Application $167 $200 no information No dig $104 Other $336 no information $357
Encroachment Permit/ Major $766 + $1.5% of val
over $20k
$766 + $1.5% of val
over $20k
Per estimated value x
LET rate set by State
Application $167
Inspection:

On improved rd $251
Non improv rd $418
Non improved rd and
unstamped plans $585
$200 + $5/LF no information Up to $100k ENR: 2.5%
'$101k+ ENR 1.5%
ENR Cost Estimate:

Under $78k $3,927
$78k-$150k $3,927 +
5% over $78k
$150k-$250k $7,500 +
4% over $150k
ENR Cost Estimate:

Inspection:
$1-50k 6%
$50-250k 4%
Plan Check:
$1-50k 5%
$50-250k 3%
Easement Request/ Review $1,417 $4,368 no information $595 $3,450 no information $650 no information no information Administrative Fee -New License $86 $108 no information no information $29 no information no information no information no information Administrative Fee - License Renewal $42 $32 no information no information $29 no information no information no information no information Lien Release Fee $0 $372 Utility lien filing fee $90 Actual Cost assessed by Revenue Recovery
$125 no information no information
Levy on real property
$2,000
Earnings witholding
order $45
no information
Returned Check (NSF) $28 1st
$35 subsequent
$25 1st
$35 subsequent no information $25 $25 1st$35 subsequent no information no information no information $25 1st$35 subsequent

ENGINEERING

FINANCE
646

DEPARTMENT/DIVISION
South Lake Tahoe
Current Fee
South Lake Tahoe
Proposed Fee Auburn El Dorado County Folsom Mammoth Lakes Placerville Placer County Truckee Major General Planning Application $3,219 $5,780 Comprehensive Plan Amendment $8,524 Variance $6,175 Rezone Request$6,000
Variance and Zone Code
Amendment $6,000
deposit
General Plan Amend
$2,100
Zone Change $2,000
General Plan
Amendment $5,227 Annexation $11,500
Home Occupation Permit $146 $225 $364 no information $31 no information no information no information no information Temporary Use Permit $689 $910
Minor: $257 +$66/
extension
Major: $668 + $66/
extension
$1,112 $65 no information $200 no information $1,250 deposit Certificate of Compliance $888 $910 no information $1,000 deposit Revision: $2,470 no information $500 deposit Regular $600Conditinoal $1,950 $1,094 1-2 parcels $2,250
deposit
3+ parcels $3,750
deposit
Tentative Subdivision Map $5,850 $6,580 $3,213 + $60/lot $1,000 deposit $6,718 + $34/ lot $6,000 deposit $3,000 + $50/lot up to 4
lots
$30/lot over 5 lots
$1,961 deposit $10,000 deposit
Live Scan Fingerprinting $18 $85
As set by FBI.

No fee if required by
City
$17 $50 $40 + State and
DOJ fees $20 no information $20 + DOJ fees
Local Criminal Clearance Letter $10 $45 no information $30 $25 $50 no information Background Clearance Letter $33
Towed Vehicle Release $165 $242 no information $100 admin fee to contest abatement $200 $150 $241 no information $199
Taxicab Driver Permit $28/year $51/year no information $32/ license no information $45 per vehicle $60 no information $68 Renewal Alarm Permit - Business $19/year 38/year $24 $25 $20 no information $85 no information no information

PLANNING

POLICE DEPARTMENT
647
648
Appendix A
Adopted Recreation and Aquatic
Center Fee Schedule
649
Current
Adopted Fee
3/25/2025
Gym Rentals
Full (2 Courts) Hourly
$71 $250
1/2 Gym (1 Court) Hourly
$40 $125
1/4 (1/2 Court) Hourly
$20 $65
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Facility Rental Setup Fee Per Hour Per Staff $43 $48
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Meeting Room Rentals
Rental Per Hour $20 $25
Non Fee No Charge No Charge No Charge
Senior Services Meetings No Charge No Charge No Charge
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Community Room Rentals
Rental Hourly $39 $55
Recognized Local Youth Sport Organizations May Have Free Use of Meeting Rooms in the Recreation & Aquatics Center No Charge No Charge No Charge Youth Organization Meetings Hourly $15 $15
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Senior Services Meetings No Charge No Charge No Charge
Facility Rental Setup Fee Per Hour Per Staff $43 $48
Recreation & Aquatics Center
Fee Description Unit Proposed Fee
Non-Resident Proposed Fee

Page 47 ends

650
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Commercial Kitchen Rental
Commercial Kitchen Rental Hourly $33 $50
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Facility Rental Setup Fee Per Hour Per Staff $43 $48
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Dance/Fitness Room Rental
Rental Hourly New $55
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Senior Services Meetings No Charge No Charge No Charge
Facility Rental Setup Fee Per Hour Per Staff $43 $48
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Event Space Rentals
Event Space Weekday Mon-Thurs $/hr. New $350
Event Space Weekend Fri -Sun $/hr. New $450
Event Space After Hours Per hour New $100

Page 4848 ends

651
Audio Video Ad On Flat Fee New $150
Event Space Facility Rental Setup Fee Per Hour (2 hour minimum) $43 $48 Ceremony Chair Package $7-$9 per chair comps New $8 per chair Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Pool Rental
Swimming Pool Rental Rate Hourly $84 $85
Lap Pool Rental (Full) Hourly New $85
Lap Pool Rental (1/2 pool) Hourly New $45
Lap Lane Rental (1 Lane) Hourly New $15
Play Pool Rental Hourly New $95
Lifeguard Hourly Rate (Rental) Hourly
Actual cost at
fully burdened
rate
Actual cost at
fully burdened
rate
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Facility Rental Setup Fee Per Hour Per Staff $43 $48
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Party Room
Rental Weekday Mon-Thurs $/hr. $45 $40
Rental Weekend Fri -Sun $/hr. $50 $50
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate

Page 4949 ends

652
Facility Rental Setup Fee Per Hour Per Staff $43 $48
Group Rentals May Be Subject to $500 minimum or $1,500
Maximum Security Deposit and/or Cleaning Fees at the Discretion of the City of South Lake Tahoe
$500 (Security Deposit) $500 Minimum or
$1,500 Maximum
$500 Minimum or
$1,500 Maximum
Group Rentals May Be Subject to a Minimum of $15 Cancellation Fee and Maximum of $50 at the Discretion of City of South Lake Tahoe
$15 (Cancellation Fee) $15 Minimum or
$50 Maximum
$15 Minimum or
$50 Maximum
Late Payment Penalty Fee 10% of total rental fee due 10% of total rental fee due
10% of total
rental fee due
Party Packages
Mini Mountain Movers Party Package Session Rental $299 $225 Batting Cages 2 Hour Party New $300
Rockwall 1 Hour Party New $200
Obstacle Course Pool Add On Per Event New $75
Pool Party Package Session Rental $199 $200
Aquatics
Obstacle Course Per Participant New $5 plus facility
drop in fee
Lifeguard Certification Course Per Participant New $235 Water Safety Instructor Certification Course Per Participant New $299 Junior Lifeguards Per Participant Per 4 week
Session
New $200
Mini Lifeguards Per Participant Per 4 week
Session
New $185
Swim Team Per Participant Per
Month/Session New $120
Development Swim Team Per Participant Per
Month/Session New $105
Aquatics Special Class (Ex Log Rolling) Per Participant Per Class New $7 Float Fit Aquatics Fitness Classess 30 minutes Each $10 $10 Float Fit Aquatics Fitness Classess 60 minutes Each $20 $20 Float Fit Aquatics Fitness Classess 90 minutes Each $30 $30 Locker Rental Per month New $20
Swimming Programs
H2O Exercise: Adult 18-54 years Each $7 $8 $10

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653
H2O Exercise: Senior or Permanent Disability Each $6 $6 $8 H2O Exercise: Adult 18-54 years - 10 Use Pass Each $50 $60 $75 H2O Exercise: Senior or Perm Disability - 10 Use Pass Each $40 $50 $65 H2O Exercise: Individual Annual Pass Each $295 $295 $369 Swimming Lessons (Group) 8 Class Session Each $49 $50
Swimming Lessons (Group) 6 Class Session Each $39 $40
Swimming Lessons (Group) 4 Class Session Each $29 $30
Private Lessons (25 minutes) 1 Student Each $33 $33
Private Lessons (25 minutes) 2 Students Each $44 $45
Private Lessons (25 minutes) 3 Students Each $55 $55
Master Swim Drop In Each $10 $10 $12
Master Swim Session 10 Use Punch Card Each $60 $70 $85
Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Facility Day Use: Includes Gym, Natatorium, Exercise Room, Walking Track Adult: 18-54 Year Each $6 $10 $15
Youth: 18 Years and Under Each $4 $8 $12
Senior 55 Years and Up or Permanent Disability Each $5 $8 $12 Public Shower Adult/Discount for Senior, Disabled, and Youth Each $3/$2 $3/$2 Daily Day Rate for Medi-Cal, WIC , and Veteran Participants Adult: 18 and Over Each $3 $3
Youth: 18 Years and Under Each $2 $2
Facility Multi-Use Day Passes: Includes Gym, Natatorium, Exercise Room, Walking Track Adult - 10 use punch card Each $80 $80 $100
Adult - Monthly Each New $65 $81
Adult - 90 Day (City Employees Only) Each $160 $45
Senior or Permanent Disability -10 use punch card Each $50 $65 $81

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654
Senior or Permanent Disability - Monthly Each New $50 $63 Children 3 years and Under Are Free with a Paying Adult for Recreation Drop in only Each
Youth -10 use punch card Each $45 $65 $81
Youth Monthly Each New $50 $63
Couple Annual Pass Each New $690 $863
Individual Annual Pass Each $225 $480 $600
Youth Annual Pass Each New $300 $375
Youth Annual Pass for GPA of 3.5 or higher (Resident Only - Ages 14-17) Each New $150
Senior Annual Pass Each New $300 $375
10% off Annual pass is purchased between January 1, 2026 - March 31, 2026 New
10% off Annual
pass is purchased
between
1/1/2026 -
3/31/2026
Family Annual Pass (2 adults + 2 children): Includes 20% discount on party packages and access to special member days Each $825 $825 $1,031 Family Annual Pass - Each Additional Adult Each Additional Adult New $345 $431 Family Annual Pass - Each Additional Senior or Child Each Additional Senior or Child New $150 $188 Administrative Fee for replacement of annual passes only Each $10 $10 Non-Profit Organizations 25% Off Base Rate 25% Off Base Rate
25% Off Base
Rate
Recreation Add Ons
Batting Cages Per Participant New $5 plus facility
drop in fee
Batting Cages - 10 punch card Each New $100 includes
drop in fee
Rockwall Per Participant New $5 plus facility
drop in fee
Rockwall - 10 punch card Each New $100 includes
drop in fee
Golf Simulator Hourly New $50
Rockwall Hourly New $150
Rec Center Special Events
Free with a paying adult for recreation drop in only

Page 5252 ends

655
Puzzle Event Per team New $40
Family Dance Per Participant New $15
Pickleball Tournament Per Team New $75
Family Game Night Part of Season Pass No Extra Charge No Extra Charge Pool Special Events Per Participant New $15
Pickleball Mixer Per Participant New $25
Adult Programs
Adult Volleyball League Team Per Season Participant $400 $400 Adult Volleyball League Individual Per Season Participant $66 $66 Adult Basketball League Team Per Season Participant $550 $550 Adult Basketball League Individual Per Season Participant $75 $75 Pickleball Clinic Adults Per Participant Per Session New $30 Pickleball Clinic Youth Per Participant Per Session New $25 Senior Games Per Participant Per Event New $10
Personal Training Per Participant Per Hour New $60 $75
Adult Cornhole League Individual Per Season Per Team $30 Per Participant $50
Adult Fitness Classes 30 minutes Each $10 $10 $12
Adult Fitness Classes 60 minutes Each $15 $15 $18
Adult Fitness Classes 90 minutes Each $20 $20 $25
Late Payment Registration for league play 10% increase to base fee New 10% increase to base fee
Youth and Teens
Parents Night Out Per Participant $40 $40
Kid's Summer Day Camp Each New $40 $50
Kid's Summer Day Camp (Weekly Fee) Each New $150 $188
Kid's Summer Day Camp Multi-Child Discount 10% Off Base Fee New 10% Off Base Fee Youth Basketball League Per Season Participant $65 $65

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656
Youth Flag Football League Per Season Participant $95 $95 Youth Street Hockey Per Season Participant New $70
After School Enrichment Program Per Season Participant $120 $120 Tiny Tots Sports League Per Season Participant $60 $60
Youth Volleyball League Per Season Participant $75 $75
Youth Soccer League Per Season Participant $65 $65
Late Payment Registration for league play 10% increase to base fee New 10% increase to base fee

Page 5454 ends

657
Appendix B
Citywide Full
Cost Simple Rate
658
TOTAL EXP ADJUSTMENTS * ADJUSTED
$ 291,576 $ 291,576
$ 362,630 $ 362,630
$ 1,199,863 $ 1,199,863
$ 2,825,766 $ 2,825,766
$ 2,757,845 $ (2,361,939) $ 395,906
$ 991,982 $ 991,982
$ 786,044 $ 786,044
$ 739,585 $ 739,585
$ 7,262,663 $ (6,082,803) $ 1,179,860
$ 1,306,910 $ 1,306,910
$ 34,697 $ 34,697
$ 569,846 $ 569,846
$ 1,581,207 $ 1,581,207
$ 4,902,188 $ 4,902,188
$ 25,612,802 Numerator $ 17,168,060
Denominator $ 68,753,186

25.0%
TOTAL EXP ADJUSTMENTS * ADJUSTED
$ 6,533,253 $ (766,306) $ 5,766,947
$ 23,169,266 $ (15,940,949) $ 7,228,317
$ 18,804,751 $ (2,026,714) $ 16,778,037
$ 20,651,900 $ (1,027,855) $ 19,624,045
$ 13,739,040 $ (10,484) $ 13,728,556
$ 1,673,293 $ 1,673,293
$ 2,287,600 $ 2,287,600
$ 1,741,391 $ (75,000) $ 1,666,391
$ 45,635,979 $ (45,635,979) $ -
$ 134,236,473 $ 68,753,186
have already been included in payroll expenses
** Total Expense amount excludes Transfers Page 55
* Adjustments represent THE removal of operational transfers out and certain payroll costs in internal services funds that Rate - Applied to Total Expenditures

EXHIBIT A - CITYWIDE FULL COST SIMPLE RATE
CALCULATION:

EXCLUDE SPEC REV, DEBT, TRANS, TRUST

AIRPORT

TRANSIT

PARKING GARAGE
FIRE
POLICE

PUBLIC WORKS

DEPARTMENTS AND PROGRAMS

DEVELOPMENT SERVICES

PARKS AND RECREATION
10001840 INFORMATION TECH
10001951 NON-DEPARTMENTAL**

GENERAL SUPPORT SERVICES
10001110 CITY COUNCIL
10001130 CITY CLERK
10001210 CITY ATTORNEY
CITY OF SOUTH LAKE TAHOE - CITYWIDE CENTRAL SERVICE DEPARTMENT SIMPLE INDIRECT COST RATE - 2025/2026 BUDGET BOOK PG 52
FIDUCIARY 601&605
10001511 ACCOUNTING
10001516 TREASURY
10001730 REVENUE COLLECTION
10001220 RISKMANAGEMENT
60201220 WORKERS COMP
10001310 CITY MANAGER
10001320 HUMAN RESOURCES
10001330 COMMUNICATIONS/MARKET
659
City of South Lake Tahoe
Agenda Item Executive Summary
Hilary Roverud, Interim City Manager
__________________________________
Meeting Date: April 21, 2026
Agenda Item #:16
Agenda Item: Liberty Utilities Presentation
Executive Summary: The City Council will hear a presentation from Liberty Utilities representatives on the closure of the walk-in customer service center in South Lake Tahoe, energy supply procurement, rate increases and advanced metering infrastructure. The City Council may provide direction to staff regarding submittal of a comment letter to the California Public Utility Commission.

Requested Action / Suggested Motions: (1) Receive presentation; and (2) Pass a Motion providing direction on submittal of comment letter to the California Public Utility Commission.

Responsible Staff Member: Hilary Roverud, Interim City Manager Reviewed and Approved By: Susan Blankenship, City Clerk Olga Tikhomirova, Finance Director Heather Stroud, City Attorney
Attachments:
01-Staff Report
02-Liberty Utilities Letter from the Mayor.pdf
03-Liberty AL 287-E Liberty Energy Supply RFP Public Version.pdf 04-Protest Letters.pdf
05-Liberty's Reply to Protests
06-Liberty Energy Supply Q & A
07-GRC Decision
08-Liberty Advanced Meters
09-Draft Letter to CPUC April 2026
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Council Agenda Report April 21, 2026 Page 1 of 2
City of South Lake Tahoe
Report to City Council
Meeting Date: April 21, 2026
Title: Liberty Utilities Presentation
Location: Citywide
Responsible Staff Member: Hilary Roverud, Interim City Manager

Background: Liberty Utilities closed their North and South Lake Tahoe walk-in centers for payments as of Monday, December 29, 2025. At the February 24, 2026 City Council meeting, the City Council authorized and directed the Mayor to submit a letter on behalf of City Council to Liberty Utilities opposing the closure of the South Lake Tahoe walk-in center for payments (Attachment 02); and directed staff to hold a meeting with Liberty Utilities prior to sending a letter to the California Public Utilities Commission (CPUC).

Issue and Discussion: City staff has been in contact with Liberty Utilities representatives to clarify local locations where bill paying services are available and opportunities to access customer service representatives to resolve billing issues. Customers can make payments in the following ways:
 Online – Credit Card or Checking Account one-time payments incur processing fees ($1.75 residential, $7.75 commercial).
 Online – Checking Account automatic payments. No processing fee for automatic payments.  Phone – Credit Card or Checking Account one-time payments incur processing fees ($1.75 residential, $7.75 commercial).
 Mail – Check or Money Order.
 Payment Kiosk (Plaza Tapatia: 3564 Lake Tahoe Blvd) - cash In March, city staff became aware of an Advice Letter submitted by Liberty Utilities to the CPUC (attachment 03) seeking approval for expedited review of their request to pursue a proposal process to seek a new energy supplier, after NV Energy notified Liberty that they would not be supplying energy after May 2027 or upon completion of the Greenlink West transmission infrastructure project.

On March 26 city staff met with CPUC staff to discuss the Advice Letter. CPUC staff assured us that the power to our community would not be discontinued due to Liberty seeking a new energy supplier.

Letters in protest of Liberty’s request were submitted to CPUC by Tahoe Spark, Small Business Utility Advocates, California Public Advocates Office (attachment 04). Liberty then submitted a response to the protest letters to CPUC (attachment 05). The CPUC is currently evaluating the request and have not determined if they will be taking the request to the Commission on May 14th, as requested by Liberty. CPUC will notify the public of a future CPUC meeting regarding the Advice Letter and provide a draft decision resolution 30 days prior to the meeting. After contact by City staff, Liberty created an FAQ webpage for customer reference (attachment 06). 661
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CPUC staff also informed us that a Liberty General Rate Case had been approved by the CPUC on March 19. The rate increase is for Jan 1, 2025 - Dec 31, 2027 (three years) with an overall revenue increase to Liberty at 11.4% (Liberty requested 19.1%) (attachment 07). As of an April 8 discussion with a Liberty representative the distribution of the revenue increase across customer account types has not been determined. That determination will also include the collection of rates retroactive to January 1, 2025. The bulk of the rate/revenue increase was due to wildfire costs (mitigation projects + insurance). This is an issue across the state.

Questions regarding advanced metering infrastructure (aka smart meter) installation have also arisen in the community recently. Liberty notified customers of the upcoming upgrades in February (attachment 08). Advanced meters are designed to provide improved service connectivity, outage identification, and energy usage data toward better grid management and reduced costs.

Residential customers have the option to opt out of advanced meter installation, however a monthly fee is charged to these customers for manual meter reading.

City staff has spoken to Liberty Utilities President, Eric Schwarzrock, and other Liberty representatives several times over the past month about these issues and Council requests. Mr.

Schwarzrock will provide a presentation to Council at the meeting and will be available for questions.

The City Council had previously discussed sending a letter to the CPUC to express concerns with the closure of the Liberty walk in center. A revised letter to the CPUC addressing overall expectations from the City is included as a starting point if the Council would like to consider advancing a letter (attachment 09).

Financial Implications: There are no financial implications directly associated with receiving a presentation.

Environmental Considerations: Receiving a presentation and potential City Council action to submit a comment letter to the CPUC are not a “project” subject to review under the California Environmental Quality Act (CEQA) under CEQA Guidelines section 15378(b)(2) (continuing administrative or maintenance activities, such as purchases for supplies).

Policy Implications: Strategic Plan Priority 2 is “Efficient Government.” 662
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Liberty Utilities (CalPeco Electric) LLC
933 Eloise Avenue
South Lake Tahoe, CA 96150
Tel: 800-782-2506
Fax: 530-544-4811
March 6, 2026

VIA EMAIL ONLY
[email protected]
Advice Letter 287-E
(U 933-E)
California Public Utilities Commission
Energy Division, Tariff Unit
505 Van Ness Avenue, 4th Floor
San Franciso, CA 94102-3298
Subject: Liberty Utilities (CalPeco Electric) LLC (U-933 E) – Request for Expedited Approval of its Request for Proposals for Short-Term Energy Supply and Management Services for Electric Supply Following Expiration of Existing Full Services Agreement with NV Energy, Inc.

Liberty Utilities (CalPeco Electric) LLC (U 933-E) (“Liberty”) submits this Tier 3 Advice Letter to request expedited approval to conduct a Request for Proposals and subsequent agreement(s) for Energy Management Services and related supply arrangements for the service territory to follow the end of the existing Energy Services Agreement (“ESA”) with NV Energy. Liberty makes this request in the context of the approved 2022 Integrated Resource Plan (“IRP”) submission because the currently effective IRP assumed that the NV Energy ESA structure would remain available to Liberty, but exigent circumstances have cause that to no longer be the case.

Background
On January 7, 2026, the Commission approved AL 279-E which authorized the current extension of the full-requirements Energy Services Agreement with NV Energy.1 During the negotiations for a longer-term extension of the full-services ESA, NV Energy informed Liberty that it could no longer provide full-requirements services, and that Liberty must arrange for its own supply in 2027. This change of stance by NV Energy was a surprise to Liberty and necessitates immediate action to replace NV Energy with another entity that can provide a similar set of energy management and supply services.

The current NV Energy ESA that provides energy and capacity to Liberty will end on May 2027, when NV Energy’s new Greenlink-West transmission line is expected to be operational.

Because of this impending deadline, Liberty must immediately deviate from its adopted IRP and 1 The NV Energy ESA Extension was filed in FERC Docket ER26-534-000, and authorized by letter order dated January 13, 2026.
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develop and make operational new arrangements to support the provision of energy and capacity by March 2027, ahead of the May 2027 cut-over date. Upon termination of the NV Energy ESA, deliveries into the Liberty service territory will be made under an existing FERC-jurisdictional NV Energy Network Integration Transmission Service Agreement (“NITSA”) that is effective through 2048.2
Liberty makes this request pursuant to its Integrated Resource Plan (“IRP”) submissions made in September 2020 and November 2022.3 At the time of its 2020 IRP, Liberty informed the Commission that its prior plan to develop its own supply portfolio with the assistance of third parties had to be suspended due to the lack of transmission capacity in the northern NV Energy footprint.4 In its 2022 IRP submission, Liberty detailed its intent to continue indefinitely as a full-requirements customer of NV Energy because that service structure provided the best outcome for customers under various scenarios analyzed by Liberty. Accordingly, the last approved IRP assumed a continuing forward resource planning approach utilizing fullrequirements arrangements with NV Energy which incorporates Liberty’s renewables production from its Luning and Turquoise solar projects, plus additional renewables, conventional energy and balancing by NV Energy.

Unfortunately, NV Energy, citing its own resource needs, declined to extend the full-services arrangement beyond the later of May 2027 or when the Greenlink-West transmission project becomes operational. Accordingly, Liberty must now take expedited steps to replace the prior arrangement that was presumed to be available in the last IRP with a new structure that is intended to provide a set of supply and services similar to the ESA arrangement with NV Energy utilizing the NITSA for transmission to the Liberty service territory.

It is critical to acknowledge the market circumstances that currently exist in the northern NV Energy territory. The market for new resources is extremely competitive as a number of entities are seeking to add large loads such as data centers into the area.5 NV Energy itself is seeking to
add a significant quantity of new resources including renewables and storage.6 Transmission 2 Amended and Restated Service Agreement for Network Integration Transmission Service Between Sierra Pacific Power Co. d/b/a NV Energy and Liberty Utilities (CalPeco Electric) LLC, February 13, 2022 (Service Agreement No. 19-00025). 3
The 2022 IRP submission was supplemented by AL 239-E, May 1, 2024, and accepted with an effective date of July 29, 2024. 4
See Liberty’s October 15, 2021, September 30, 2020, Updated Liberty Utilities (CalPeco Electric) LLC (2020 Integrated Resource Plan, Attachment 1, Non-Standard Plan, pages 2-3, posted at https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=415275481. 5 For example, see NV Energy’s discussion of the construction in the Tahoe Reno Industrial Center (“TRIC”) / Fernley Area Master Plan where new large loads are seeking interconnections along with generation and transmission development in NV Energy’s February 27, 2026 Action Plan Progress Report Pursuant to NAC § 704.9498 for the Action Plan Period 2025-2027, PUCN Docket 26-2031, available via https://pucweb1.state.nv.us/PUC2/Dktinfo.aspx?Util=Electric. 6 Ibid.
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service is currently severely constrained for new interconnections, and will be partially relieved when Greenlink-West comes online, and further relieved later should the Greenlink-North project be approved and constructed. It is against this background that NV Energy decided it could no longer provide full requirements to Liberty, and to which Liberty must now immediately secure replacement services and supply.

A Tier 3 advice letter is appropriate under the circumstances because of the presumption inherent to the adopted IRP applicable to Liberty and approved by D.24-02-047 and supplemental AL 239-E. The request made here does not raise important policy questions as it is effectively a continuation of the current full-services resourcing approach approved for Liberty, albeit with a change of provider. As noted above, Liberty assumed in its IRP that NV Energy would continue to provide a full-services at cost of service rates.7
The 2022 IRP states:

Because of the recent developments in the northern Nevada transmission system, namely the Greenlink Initiative and Western RTO developments, Liberty is pivoting its strategy towards developing a portfolio that leverages the existing full-requirements relationship with NV Energy instead of aiming to terminate the service as soon as possible in favor of a bilateral energy procurement strategy. As a result, the objective of the resource planning process for this IRP cycle focused on optimizing a resourcing path for Liberty while remaining largely inside the existing 2021 NV Energy ESA framework. (2022 IRP, page 11.)
Because of NV Energy’s recent decision, Liberty must immediately alter the Commissionapproved resourcing approach approved in 2024 in order to secure the services necessary to provide reliable and affordable supply supplies for our customers into the future. To this end, Liberty will issue a solicitation for a suite of services from qualified bidders to ensure supply sufficiency, continue compliance with the RPS program, manage transmission and resource scheduling, and assist Liberty in developing a portfolio that benefits customers.

The current IRP docket, R.25-06-019, focuses primarily on those LSEs located within the California Independent System Operator (“CAISO”) footprint, which does not apply to Liberty.

The schedule for the current IRP proceeding cannot address Liberty’s immediate need within the timeframe needed to effectuate the replacement of the NV Energy ESA. Because Liberty seeks to replace the existing resourcing structure currently provided by NV Energy with a energy management agreement with a third party, the request made here is effectively a replacement of the currently approved resource planning approach in place for Liberty. This urgent request should not raise new or important policy issues should not trigger the need for hearings, and 7 See Liberty’s 2022 IRP filing (public) version posted at https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=498092954, and D.24-02-047, page 42.
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requires immediate action due to circumstances outside of Liberty’s control. Liberty will address its longer-term resourcing strategy in its next non-standard IRP submission in 2026, after the initial arrangements requested here are in place.

Requested Authority
Liberty requests that the Commission authorize it to immediately effectuate the replacement of the NV Energy ESA with agreement(s) secured via a competitive solicitation for a similar set of services to supply and manage the energy and capacity needs of its customers. This will include provision and scheduling of supply from within or imported through the NV Energy balancing authority under the current NITSA. It will involve the integration of Liberty’s existing renewable resources, potentially additional renewables and/or RECs, as well as other balancing and reliability requirements applicable within the NV Energy balancing authority per FERCapproved tariffs. Liberty proposes an initial term of five years, with an option to extend on mutual agreement. This term is appropriate because of the effort to coordinate and secure reasonable resource options that will provide continuity over time. The draft solicitation materials and details on the services sought are provided in Exhibit 1.

Exhibit 2 is a confidential evaluation document that outlines the indicative approach to reviewing the bids received. Because Liberty is seeking responses from entities able to provide either a one-stop suite of services or distinct services and supplies to be integrated in a way that best serves customers, the evaluation standard must be sufficiently flexible. But the touchstone for the evaluation will be what arrangements best provide customer value while minimizing risks.

Upon completion of the solicitation, evaluation and agreement negotiation processes, Liberty will present the proposed agreement(s) for Commission approval via a Tier 3 advice letter referencing the request made here, and showing that the results are just and reasonable. Liberty will present confidential information regarding the proposals received and its analysis of which suite of arrangements best serves customers’ interests. Liberty will then follow-up in the current IRP docket with additional description of how it intends to achieve state policies on renewables and decarbonization over the much longer planning horizon contemplated by the IRP.

Public Safety
There are no direct safety implications for the approval sought here. The agreement(s) that will ultimately be executed will include provisions for the energy manager to ensure that applicable safety-related requirements are followed by itself and any entity that supplies resources.

Compliance with the Interim Greenhouse Gas Emissions Performance Standard (“EPS”) California Public Utilities Code Sections 8340 and 8341 require the Commission to consider emissions associated with new long-term (five years or greater) power contracts procured on behalf of California ratepayers. When Liberty presents the agreement(s) for approval, it will specifically address EPS compliance in light of the term requested. In the alternative, because the specific resources that will be used to provide full-requirements are not identifiable at this time, and because Liberty currently has no other realistic alternative path to replacing the NV 667
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Energy ESA for the capacity and energy needed for reliable operations, Liberty requests that the Commission acknowledge that the reliability exemption from the EPS requirements be deemed applicable on the grounds that Liberty currently has no other options for the delivery of capacity and energy needed to ensure Liberty’s system reliability after expiration of the NV Energy ESA.

Renewables Portfolio Standard (“RPS”) Compliance
Liberty currently achieves RPS compliance through a combination of bundled energy and RECs from its Luning and Turquoise solar projects, additional bundled renewables from NV Energy, and unbundled RECs procured from the market. Because Liberty is not located within a California balancing authority area, the procurement content categories in the RPS statute are not applicable. Accordingly, Liberty will assess responses to the solicitation with an eye toward securing reasonably priced bundled renewable energy, but may opt to rely on the use of unbundled RECs if that approach presents more favorable for customers. RPS compliance and costs will be addressed when the solicitation results are presented in the subsequent Tier 3 AL.

Effective Date
Liberty requests that this Tier 3 advice filing become effective as soon as possible but not later than May 14, 2026 given the timing demands associated with issuing the solicitation, evaluating responses and negotiating agreement(s) and presenting those agreement(s) to be Commission for approval ahead of the March 2027 when Liberty needs the supply structure to be in place and operational.

Response or Protests
Anyone may respond to or protest this advice letter. A response supports the filing and may contain information that proves useful to the Commission in evaluating the advice letter. A protest objects to the advice letter in whole or in part and must set forth the specific grounds on which it is based. A protest must state the facts constituting the grounds for the protest, the effect that approval of the advice letter might have on the protestant, and the reasons the protestant believes the advice letter, or a part of it, is not justified. A protest shall provide citations or proofs where available to allow staff to properly consider the protest. A response or protest must be made in writing or by electronic mail and must be received by the Energy Division within 20 days of the date this advice letter is filed.

All responses and protests should be sent to:

California Public Utilities Commission
Energy Division, Tariff Unit
505 Van Ness Avenue, 4th Floor
San Francisco, CA 94102-3298
Facsimile: (415) 703-2200
Email: [email protected]
On the same date the response or protest is submitted to the Energy Division, the respondent or 668
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protestant shall send a copy by mail (or e-mail) to Liberty CalPeco, addressed to:

Liberty Utilities (CalPeco Electric) LLC
Attn.: Advice Letter Protests
933 Eloise Avenue
South Lake Tahoe, CA 96150
Email: [email protected]
If you have not received a reply to your protest within 10 business days, contact Dan Marsh at (530) 721-2435.

Notice
In accordance with General Order 96-B, Section 4.3, a copy of this advice letter is being sent electronically and via U.S. mail on March 6, 2026, to parties shown on the attached list.

Conclusion
Liberty respectfully requests that the Commission approve this Advice Letter with an effective date of no later than May 14, 2026.

If additional information is required, please do not hesitate to contact me.

Sincerely,
/s/ Dan Marsh
Dan Marsh
Director, Rates and Regulatory Affairs
cc: Liberty General Order 96-B Service List
Enclosures: Exhibit 1: Solicitation Materials
Exhibit 2: Confidential Evaluation Criteria
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Liberty Utilities (CalPeco Electric) LLC
Advice Letter Filing Service List
General Order 96-B, Section 4.3

Energy Management Agreement with Net Requirements Service that includes Energy Delivery & Scheduling Coordinator Services RFP Posting Date:

Response Deadline:

Liberty Utilities (CalPeco Electric) LLC (“Liberty”) issues this request for proposals (“RFP”) to solicit competitive proposals from qualified firms for energy supply and scheduling services for Liberty to serve its customers. Liberty will be selecting a single entity to provide the supply and services outlined here.

Background
Liberty Utilities (CalPeco Electric), LLC (“Liberty”), a subsidiary of Algonquin Power and Utilities Corp., acquired what is now called California Pacific Electric Company (“CalPeco”) from NV Energy, Inc. on December 21, 2012. Liberty provides electric service to the Lake Tahoe region in California for approximately 49,000 customers. The peak load on Liberty’s system is 141 MW, which occurred in December 2017, and the rolling 12‐month peak wholesale load was 634,000 MWh at the end of April 2023. Liberty is subject to regulatory oversight by the California Public Utilities Commission (“CPUC”).

Liberty is owner of the 50 MW Luning solar facility located in Nevada, generating approximately 145,000 MWh/year and an additional Nevada‐based 10 MW Turquoise solar facility generating approximately 28,000 MWh/year.

Liberty’s electrical system is interconnected at 38 points with NV Energy with limited electrical interconnections with other electrical grids and is not a part of the electrical grid controlled by the CAISO. Instead, Liberty’s service area falls within NV Energy’s Balancing Authority Area.

Liberty currently receives Full Requirements Service from NV Energy to meet the resource needs of its customers receiving Energy Supply (as defined in Liberty’s CA Tariff Rule 1), which include capacity, energy, network transmission service, ancillary services pursuant to an energy services agreement (“ESA”) with NV Energy. The current ESA will be expiring on May 31, 2027, or upon 672
the completion of facilities (“Greenlink West1”) that will make available sufficient capacity NVE to grant Liberty Network Integration Transmission Service for its entire Network load.

A net services and energy management agreement would be dependent on Liberty’s Network Integration Transmission Service Agreement (“NITSA”) taking effect. Currently, service under the NITSA shall commence on the date when construction of any Direct Assignment Facilities and/or Network Upgrades are completed (i.e. Greenlink West). Service under this agreement shall terminate on January 1, 2049.

Liberty must comply with California’s Renewables Portfolio Standard (“RPS”) Program. Under the RPS, retail sellers are required to procure eligible renewable energy credits (“REC”) so that the amount of electricity generated from eligible renewable energy credits equals an average of 60% of total retail sales to customers in California by 2030. Additionally, Senate Bill (SB) 350 requires 65% of RPS procurement to be derived from long‐term contracts of 10 or more years. Liberty is allowed to procure bundled and unbundled RECs to meet its requirements. Currently, Luning, Turquoise, and NVE provide renewable energy to Liberty to help meet its RPS requirements. RPS requirements are currently met by netting the production of the Renewable Generator pursuant to an ESA with NV Energy.

This RFP seeks Proposals from Respondents offering these services (as further defined below).

The selected supplier needs to allow for, and assist in, the delivery of traditional generation resources that may be provided to Liberty from suppliers located either within NV Energy Balancing Authority or imports from outside the NV Energy Balancing Authority during the term of an Energy Services Agreement entered into pursuant to this RFP. Liberty would take ownership of all RECs associated with the underlying bundled RPS‐eligible electricity. Any proposal including renewable energy must show that RECs will be issued, tracked and retired through the Western Renewable Energy Generation Information System (“WREGIS”).

To help meet RPS requirements, proposals for renewable energy as described are encouraged and may receive a higher rating upon bid evaluation.

RFP Scope of Services
The purpose of this RFP is to obtain responses setting forth terms and conditions on which a single, qualifying Respondent would be able to provide the scope of services set forth below.

Liberty intends to select a Respondent to provide a firm block of energy and provide energy service obligations to meet its energy service obligations to its customers including scheduling and coordinating.

1. The Respondents should propose services for a minimum of a 5‐year term designed to meet the following objectives beginning June 1, 2027:
• The Respondents should propose an energy supply under a commercially accepted agreement. The supply should be designed to meet the following objectives beginning June 1, 2027:
1 The latest information on Greenlink West can be found here: https://www.nvenergy.com/cleanenergy/greenlink‐nevada 673
• Meet all of the requirements of a Certified Scheduling Coordinator as defined in Section 36 of the NV Energy OATT.
• Deliver firm energy on behalf of Liberty at an agreed Point of Receipt (POR) to serve 100% of Liberty’s net load requirements.
• Submit Transmission Service Reservations on behalf of Liberty on the OATI WestTrans system.
• Schedule energy delivery and issue all applicable E‐Tags, including but not limited to energy received from the Renewable Generators and supplied under Scope 1 that can be used to meet Liberty’s load
• Manage all required transmission rights, ancillary service charges, and associated tariffs. • Supply firm capacity to meet applicable resource adequacy requirements, including NV Energy’s reliability requirements.

2. Proposals will be to satisfy Liberty’s instantaneous energy requirements. Respondents may use the following data provided by Liberty in developing proposals:
a. Liberty hourly load from January 1, 2017 through December 31, 2024 b. Liberty monthly loads from January 1, 2017 through December 31, 2024 c. Liberty monthly load coincident with NV Energy’s system peak loads from January 1, 2017 through December 31, 2024

3. The Respondent may transmit power as required in 2 above from 1: Sources within the NV Energy BA or 2) Sources outside of the NV Energy BA to the NV Energy Point of Delivery (“POD”) at the Midpoint 345 kV (or Alternate) POD on the NV Energy system and utilize Liberty’s Network Integration Transmission Service (“NITS”) rights to deliver all energy and ancillary services to the Liberty Designated Network Load within the NV Energy Balancing Area Authority. In performing the duties of a Certified Scheduling Coordinator, Respondents will (on behalf of Liberty) deliver firm energy to the POR and act on behalf of Liberty as required of a Network Transmission Customer in compliance with NV Energy’s OATT.

4. Fixed pricing shall be offered at a cost per megawatt‐hour of energy ($/MWh) delivered at the Liberty POD. Proposed pricing may vary by month and On‐Peak or Off‐Peak. Five year initial term with negotiated annual renewals.
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1 Assumptions:
• Contractor must be legally authorized to sell power and qualified and able to deliver such power at the POR.
• The energy provider will provide access to day ahead and hour ahead estimates according to the Western Electricity Coordinating Council (“WECC”) protocol (plus fifteen minutes for hourly data), of the expected energy needs. Liberty will provide access to the hourly facility load data.
• The energy provider will be responsible for scheduling Liberty’s Luning and Turquoise resource(s), pre‐scheduling Liberty’s native load and making adjustments to schedules on a continuous basis to minimize imbalances. The energy provider will be responsible for imbalance transactions and costs.
• Delivery shall be WSPP Schedule C, Firm energy subject to Liquidated Damages. Other forms of wholesale power purchase agreements will be considered. • “On‐Peak” shall be defined as HE 0700 through HE 2200 PPT (16 hrs/day) Monday through Saturday, except for NERC Holidays (Liberty is a winter‐peaking utility). “Off‐Peak” are all remaining hours.
• Contractor shall work with Liberty to assure compliance with existing and potential future changes to applicable CPUC and any other applicable regulatory agency requirements, guidelines and standards throughout the Term of the agreement.

Proposal Submission Required Elements

1. Transmittal Letter: A brief statement of the Proposer’s understanding of the work to be done and commitment to perform the work as scheduled, including a summary of any and all exceptions taken to the scope of services requirements, statement of work, specifications, and reference to any proposed contractual terms and conditions required by the Proposer. An officer authorized to bind must sign the proposal on behalf of the Proposer.

2. Applicant Information: Provide legal name of the company, physical street address, e‐mail address, telephone, name and title of individuals authorized to represent the Respondent and the names of all affiliates or organizations with a controlling interest in the company or its affiliates.

3. Term: The term is a minimum of 5 years with an option to renew.

4. Proposal: Provide a description of the proposed services, how it meets each of the Scopes of this RFP, a detailed description addressing all of the Scope of Services, as well as any tasks, task elements and/or functions that are not part of the proposal.

5. NDA: An executed non‐disclosure agreement between the Respondent and Liberty is required.

6. Fees: Pricing should be made based on good faith estimates of the requirements defined in 675
1 this RFP. Provide detailed specific examples or estimates of the fees.

7. Timeline: Provide a timeline for transaction development and implementation for each potential option.

8. Experience: In addition to providing technical responses to the specific scope of work described above, Respondent will separately provide information on each of the following:
a) State the full name and address of your organization and, if applicable, any branch office that will perform work on this project.
b) Describe your company’s plan for managing this particular project and clearly identify project participants and the members of your management team that would be responsible for providing services to Liberty.
c) Provide a brief overview of your company, including organizational structure, number of employees, number of years the company has been in business, number of years the company has provided energy scheduling coordinator services, technology support resources, FERC market based rate authority references, and a list of representative clients.
d) Describe your firm’s experience as may be applicable to this RFP, including management qualifications, years and descriptions of experience in energy scheduling coordinator services, and other contract‐related qualifications. e) Describe your firm’s experience, if any, with assisting or providing services to clients in California, Nevada, or other western states.
f) State whether proposer will use subcontractors to perform services pursuant to the contract. Should the use of subcontractors be offered, the proposer shall provide the same assurances of competence for the subcontractor, plus the demonstrated ability to manage and supervise the subcontracted work. Subcontractors shall not be allowed to further subcontract with others for work. The provisions of any contract resulting from this RFP shall apply to all subcontractors in the same manner as to the proposer.
g) Respondent shall indicate any and all pending litigation that could affect the viability of Respondent’s proposal, continuance of existing contracts, operation or financial stability.
h) Identify whether any key employees have ever been disciplined, suspended, cited, disbarred, censured, or subject to an investigation by any court or regulatory body responsible for oversight of the key employee in connection with services in the energy industry.
i) Provide the name, address, and telephone number of three or more current clients that can serve as a reference.
j) Provide at least two years of independently audited financial statements, credit ratings from at least two credit agencies and any credit bureau reports applicable to the Respondent. Briefly describe your company’s financial position and financial and other resources available in connection with the performance of the services. k) Describe whether the Proposer has, within the last five years, rendered any service to 676
1 Liberty, or its affiliates, either as a contractor or subcontractor, either under the current proposer’s name or any other name or organization. If so, please provide details (status as prime or subcontractor, brief description of the contract, contract start and end dates, the contract administrator name, and total actual contract expenditures).
l) If the Proposer has not rendered any service within the last five years to Liberty, then please provide references over that period with the requested details described above including the counterparty for which services were provided. m) Identify existing projects or programs which Respondent developed and/or operates similar to service requested by Liberty.
n) Identify expectations from Respondent including requirements definition, strategy refinement, and staffing requirements to support implementation methodology. o) Identify any regulatory fines or penalties Respondent has been subject to in the last five years.

Proposal Terms and Conditions

1. Liberty reserves the right to cancel this RFP at any time, reject any and all proposals and to waive irregularities.

2. Liberty shall determine at its sole discretion the value of any and/or all proposals including price and non‐price attributes.

3. Liberty shall perform an initial screening evaluation to identify and eliminate any Proposals that are not responsive to the RFP, do not meet the minimum requirements set forth in the RFP, are clearly not economically competitive with other proposals, or are submitted by Proposers that lack appropriate creditworthiness, sufficient financial resources, or qualifications to provide dependable and reliable services.

4. Liberty reserves the right to submit follow up questions or inquiries to request clarification of information submitted and to request additional information from any one or more of the Respondents.

5. Liberty reserves the right, without qualification and in its sole discretion, to accept or reject any or all proposals for any reason without explanation to the Respondent, or to make the award to that Respondent, who, in the sole opinion of Liberty, is in the best interests of Liberty and will provide the most value to Liberty and its customers.

6. Liberty may decline to enter into any potential engagement agreement or contract with any Respondent, terminate negotiations with any Respondent, or to abandon the request for qualification process in its entirety.

7. Liberty reserves the right to make an award, irrespective of price or technical ability, if Liberty determines that to do so is in the best interests of Liberty and its customers and will provide the most value to Liberty and its customers.

8. Those Respondents who submit Proposals agree to do so without legal recourse against Liberty, their directors, officers, employees and agents for rejection of their Proposal(s) or for failure to execute or act on their Proposal for any reason.

9. Liberty shall not be liable to any Respondent or party in law or equity for any reason 677
1 whatsoever for any acts or omissions arising out of or in connection with this request for proposals.

10. Liberty shall not be liable for any costs incurred by any Respondents in preparing any information for submission in connection with this RFP process or any and all costs resulting from responding to this RFP. Any and all such costs whatsoever shall remain the sole responsibility of the Respondent

11. Liberty is not responsible or liable for individual interactions with the Respondent which are not entirely conducted through Liberty or at Liberty’s option or election to engage the Respondent as defined within the Terms and Conditions herein.

12. Submission of a Proposal constitutes acknowledgement that the proposer has read and agrees to be bound by the terms and specifications of this RFP and any addenda subsequently issued prior to the due date for a Proposal.

13. Information in this RFP is accurate to the best of Liberty’s knowledge but is not guaranteed to be correct. Proposers are expected to complete all of their due diligence activities prior to entering into any final contract negotiations with Liberty.

14. Liberty reserves the right to reject any Proposal for any reason without cause. Liberty reserves the right to enter into relationships with more than one vendor, can choose not to proceed with any Proposer with respect to one or more categories of services, and can choose to suspend this RFP or to issue a new RFP that would supersede and replace this one.

15. Liberty is subject to regulatory oversight by the CPUC, and anticipates filing the executed Agreement(s) with the CPUC for its review and approval. Liberty may, at its sole discretion, instead file and seek CPUC review and approval of an Agreement prior to its final execution, which lacks only specified energy and/or capacity price(s) for the Products and Services to be provided (“Final Stage Agreement”). Whether Liberty files an executed Agreement or a Final Stage Agreement, the validity and effectiveness of any such Agreement is expressly conditioned on Liberty’s receipt of Regulatory Approval of the filed Agreement. “Regulatory Approval” means a final and non‐appealable order or orders from the CPUC, without conditions or modifications unacceptable to Liberty, finding Liberty’s entry into and performance under the Agreement to be reasonable. Should the CPUC direct changes to the terms and conditions, the parties will be expected to undertake commercially reasonable efforts to amend the agreement to satisfy CPUC regulatory requirements.

16. Liberty agrees that it will treat the information it receives from Respondents in a confidential manner and will not, except as required by law or regulatory authority, disclose such information to any third party or use such information for any purpose other than in connection with this RFP.

Additional Requirements for Proposal

1. Consideration of Responses: Submitted proposals should be prepared simply and economically, without the inclusion of unnecessary promotional materials. Proposals should be submitted on duplex copied (double‐sided pages) where possible.

2. Insurance, Licensing, or other Certification: If selected, the proposer will be required to 678
1 maintain sufficient insurance, licenses, or other required certifications for the type of work being performed. Liberty may require specific insurance coverage to be established and maintained during the course of work and as a condition of award or continuation of contract.

3. Non‐Discrimination/Equal Employment Practices/Affirmative Action Plan: If selected, the proposer and each of its known subcontractors may be required to complete and file an acceptable Affirmative Action Plan.

4. Liberty‐Furnished Property: Liberty or participating utility drawings, specifications, and other media furnished for the Provider’s use shall not be furnished to others without written authorization from the source agency.

5. Contractor‐Furnished Property: Upon completion of all work under any Agreement entered with Liberty, ownership and title to reports, documents, drawings, specifications, estimates, and any other document produced as a result of the Agreement shall automatically be vested to Liberty and no further agreement will be necessary for the transfer of ownership to Liberty. Liberty has the sole right to distribute, reproduce, publish, license, or grant permission use all or portion of the deliverable documentation or presentations.

679
1 Schedule
Liberty RFP for Energy Scheduling Services Selection Process Schedule of Requirements Date(s)
Issue RFP
Responses Due
Review of Responses
Further negotiations and Interviews (if necessary)
Selection of Respondent
Execute agreements with Respondent
File agreements with the CPUC & FERC, as necessary
Liberty RFP for Energy Scheduling Services Selection Process Schedule of Requirements Date(s)
Service Begins June 1, 2027
Proposal Submission Delivery Requirements
There will be no initial Proposer's conference associated with this RFP. Clarification questions may be addressed to: [email protected] All responses, including a transmittal letter of authentic offer with original authority signature and any supporting documentation, should be delivered prior to 5:00 p.m. PST on [DATE] to [email protected]
Except as specified above, no contact shall be made with any employee of Liberty Utilities or its affiliates, its Board of Directors, committees or working group representatives, concerning this RFP.
680
Exhibit 2
Evaluation Criteria
(Confidential and Excluded from the Advice Letter)
681

ADVICE LETTER

SUMMARY

ENERGY UTILITY
Company name/CPUC Utility No.:

Utility type:

Phone #:

EXPLANATION OF UTILITY TYPE

ELC GAS

PLC HEAT
MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Advice Letter (AL) #:

WATER
E-mail:

E-mail Disposition Notice to:

Contact Person:

ELC = Electric
PLC = Pipeline
GAS = Gas
HEAT = Heat WATER = Water
(Date Submitted / Received Stamp by CPUC)
Subject of AL:

Tier Designation:

Keywords (choose from CPUC listing):

AL Type: Monthly Quarterly Annual One-Time Other:

If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:

Does AL replace a withdrawn or rejected AL? If so, identify the prior AL:

Summarize differences between the AL and the prior withdrawn or rejected AL:
&RQÀGHQWLDOWUHDWPHQWUHTXHVWHG" Yes No
,I\HVVSHFLÀFDWLRQRIFRQÀGHQWLDOLQIRUPDWLRQ

&RQÀGHQWLDOLQIRUPDWLRQZLOOEHPDGHDYDLODEOHWRDSSURSULDWHSDUWLHVZKRH[HFXWHD QRQGLVFORVXUHDJUHHPHQW1DPHDQGFRQWDFWLQIRUPDWLRQWRUHTXHVWQRQGLVFORVXUHDJUHHPHQW DFFHVVWRFRQÀGHQWLDOLQIRUPDWLRQ

5HVROXWLRQUHTXLUHG" Yes No
5HTXHVWHGHIIHFWLYHGDWH
No. of tariff sheets:

Estimated system annual revenue effect (%):

Estimated system average rate effect (%):

When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).

Tariff schedules affected:

Service affected and changes proposed1:

Pending advice letters that revise the same tariff sheets:
1 Discuss in AL if more space is needed.

Liberty Utilities (CalPeco Electric) LLC (U-933 E)
✔ 530-807-8987
[email protected]
[email protected]
Elly O'Doherty
287-E 3
Request for Expedited Approval of its Request for Proposals for Short-Term Energy Supply and Management Services for Electric Supply Following Expiration of Existing Full Services Agreement with NV Energy, Inc.

Agreements
✔
N/A
✔
N/A
✔
5/14/26 0
see advice letter
N/A
Clear Form
682
CPUC, Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102
Email: [email protected]
Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

Name:

Title:

Utility Name:

Address:

City:

Telephone (xxx) xxx-xxxx:

Facsimile (xxx) xxx-xxxx:

Email:

Name:

Title:

Utility Name:

Address:

City:

Telephone (xxx) xxx-xxxx:

Facsimile (xxx) xxx-xxxx:

Email:

State:

Elly O'Doherty
Manager, Rates and Regulatory Affairs
Liberty Utilities (CalPeco Electric) LLC
9750 Washburn Road
Downey California
530-807-8987
[email protected]
AnnMarie Sanchez
Coordinator
Liberty Utilities (California)
9750 Washburn Road
Downey California
562-805-2052
[email protected]
Clear Form683
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684
1 March 26, 2026
Via Electronic Mail
CPUC Energy Division
Attention: Tariff Unit, Room 4005
505 Van Ness, Avenue
San Francisco, CA 94102
[email protected]
Subject: Protest to Liberty Utilities (CalPeco Electric) LLC’s (U 933-E) Tier 3 Advice Letter 287-E, Liberty Utilities (CalPeco Electric) LLC (U-933 E) Advice Letter 287-E – Request for Expedited Approval of its Request for Proposals for Short-Term Energy Supply and Management Services for Electric Supply Following Expiration of Existing Full Services Agreement with NV Energy, Inc.

INTRODUCTION
Pursuant to General Order (GO) 96-B, Rule 7.4, the Public Advocates Office at the California Public Utilities Commission (Cal Advocates) submits this protest to Liberty Utilities (CalPeco Electric) LLC’s (U 933-E) (Liberty) Tier 3 Advice Letter (AL) 287-E, Liberty Utilities (CalPeco Electric) LLC (U-933 E) Advice Letter 287-E – Request for Expedited Approval of its Request for Proposals for Short-Term Energy Supply and Management Services for Electric Supply Following Expiration of Existing Full Services Agreement with NV Energy, Inc. Liberty submitted AL 287-E on March 6, 2026, pursuant to Liberty’s California Public Utilities Commission (Commission)-approved Integrated Resources Plan (IRP) in Decision (D.) 24-02-0471 and Liberty’s subsequent
supplemental AL 239-E.2
Liberty AL 287-E requests that the Commission authorize a deviation from Liberty’s approved IRP to conduct an immediate Request for Proposals (RFP) to replace Liberty’s current Energy Services Agreement (ESA) with NV Energy, Inc. (NV Energy).3

Liberty’s NV Energy ESA will expire when NV Energy’s Greenlink West transmission 1 D.24-02-047, Decision Adopting 2023 Preferred System Plan and Related Matters, and Addressing Two Petitions for Modification, February 15, 2024; issued in Rulemaking (R.) 20-05-003, Order Instituting Rulemaking to Continue Electric Integrated Resource Planning and Related Procurement Processes. 2 Liberty AL 287-E at 2-3.
3 Liberty AL 287-E at 4.
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line enters service, but no earlier than May 2027.4 Liberty requests that the Commission authorize Liberty to submit a Tier 3 AL for approval of the selected replacement agreement.5
Liberty indicates that it will seek a minimum five-year6 fixed-price contract.7 Liberty also indicates that, at its “sole discretion,” it may seek Commission review and approval in the Tier 3 advice letter prior to final execution of the ESA so that the advice letter would not include energy and/or capacity price(s).8 For the reasons discussed below, the relief request in Liberty AL 287-E is unreasonable9 and is, in part, inappropriate for the advice letter process.10 The Commission should reject Liberty AL 287-E and:
 Require Liberty to submit its eventual contract pricing for Commission approval;
 Require Liberty to conduct a transitional RFP in two phases. In the first phase, Liberty will solicit offers for the balance of calendar year 2027 and all of calendar year 2028, including the bundled11 attributes that Liberty proposes. In the second phase, Liberty will solicit offers for 2029 and 2030 for the bundled and unbundled offers for the attributes that Liberty seeks;
4 Liberty AL 287-E at 1-2. Greenlink West will increase transmission capacity on the NV Energy system, sufficient to provide NV Energy with enough capacity to provide Network Integration Transmission Service to Liberty, a necessary step for Liberty to procure alternative energy and capacity resources. 5 Liberty AL 287-E at 4.
6 Liberty AL 287-E at 4.
7 Liberty AL 287-E, Exhibit 1 at 3.
8 Liberty AL 287-E, Exhibit 1 at 7.
9 See GO 96-B, Rule 7.4.2, Grounds for Protest (6):

The relief requested in the advice letter is unjust, unreasonable, or discriminatory, provided that such a protest may not be made where it would require relitigating a prior order of the Commission.
10 See GO 96-B, Rule 7.4.2, Grounds for Protest (5):

The relief requested in the advice letter requires consideration in a formal hearing, or is otherwise inappropriate for the advice letter process . . . . 11 Cal Advocates uses “bundled” and “unbundled” to refer to the aggregation of various energy commodities, capacity commodities, and other services in Liberty’s proposed “one-stop suite” procurement approach. This nomenclature does not refer to utility customers that receive “bundled” generation services on top of distribution and transmission services. 686
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 Require Liberty to submit one Tier 3 advice letter for Commission approval of Phase 1 contracts and a second Tier 3 advice letter for Commission approval of Phase 2 contracts;
 Require Liberty to assess the potential for cost-effective staff development opportunities to provide certain services directly, as well as the potential for cost-effective procurement strategies that may emerge if NV Energy participates in the California Independent System Operator Corporation’s (CAISO) Extended Day-Ahead Market (EDAM);
 Require Liberty to file an application for Commission approval of a procurement framework for Liberty’s procurement needs in 2031 and beyond; and
 Consider a consolidated proceeding to establish a procurement framework for both Liberty and Golden State Water Company’s Bear Valley Electric Service Division (U913E) (Bear Valley).

BACKGROUND
Liberty serves approximately 49,000 electric customer accounts in and around the California side of the Lake Tahoe Basin.12 Liberty is a nighttime, winter-peaking utility, with a historical peak load of 141 megawatts (MW).13 Liberty operates within the NV Energy balancing authority area.14 NV Energy provides energy, capacity, ancillary services, scheduling, and network transmission service to Liberty pursuant to the current ESA.15 In addition, Liberty owns and operates two solar plants in Nevada, Luning and Turquoise, and relies on NV Energy’s transmission system to deliver the solar generation to Liberty’s service area. Liberty’s NV Energy ESA allows Liberty to displace up to 60 MW of NV Energy load service with output from Liberty’s solar facilities.16 Liberty has long sought the eventual replacement of the NV Energy ESA. In its 2018 individual IRP filing, Liberty sought Commission approval to replace the NV Energy 12 Liberty Utilities (CalPeco Electric), LLC (U-933-E) 2022 Integrated Resources Plan Public Version, November 1, 2022, attachment Liberty Utilities (CalPeco Electric) LLC (U 933-E) 2022 Integrated Resource Plan (Liberty 2022 IRP) at 1; filed in R.20-05-003. Available at:
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M498/K071/498071350.PDF. 13 Liberty AL 287-E, Exhibit 1 at 1. Liberty’s historic peak load occurred in December 2017. 14 Liberty 2022 IRP at 1 and 29.
15 Liberty 2022 IRP at 1.
16 Liberty 2022 IRP at 1.
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ESA with new contracts. The Commission approved the request in D.19-04-040.17 However, Liberty was ultimately unable to exit the NV Energy ESA due to transmission limitations.18
The Commission approved the current NV Energy ESA extension on January 7, 2026.19 The current extension expires the later of May 31, 2027, or the date of completion of transmission projects that will resolve the current transmission limitations – i.e., NV Energy’s Greenlink West transmission project.20 When Liberty’s NV Energy ESA expires, Liberty will receive transmission services from NV Energy under Liberty’s Network Integration Transmission Service Agreement with NV Energy, effective through 2048.21
Despite the May 2027 expiration date of the current extension, Liberty apparently expected that NV Energy would willingly negotiate an additional extension. Liberty states that it was “surprised” when NV Energy informed it that NV Energy could no longer provide full-requirements services, and that Liberty must arrange for its own supply in 2027.22
Therefore, in AL 287-E, Liberty seeks Commission approval to conduct an RFP to replace the full-services NV Energy ESA by March 2027.23 Liberty requests that the Commission authorize it to submit a Tier 3 advice letter to seek approval of Liberty’s new contract.24 Liberty proposes to submit either a final contract for Commission approval, or a “Final Stage Agreement” that does not include energy and/or capacity price(s).25
17 D.19-04-040, Decision Adopting Preferred System Portfolio and Plan for 2017-2018 Integrated Resource Plan Cycle, Ordering Paragraph (OP) 7 at 178 and Conclusion of Law 8 at 172; issued in R.16- 02-007, Order Instituting Rulemaking to Develop an Electricity Integrated Resource Planning Framework and to Coordinate and Refine Long-Term Procurement Planning Requirements. 18 Liberty 2022 IRP at 3.
19 Liberty AL 287-E at 1.
20 Liberty AL 279-E, Liberty Utilities (CalPeco Electric) LLC (U-933 E) – Request for Approval of 2026 Energy Services Agreement with Sierra Pacific Power Company, dba NV Energy, December 4, 2025 at 2; and Liberty AL 287-E at 2-3.
21 Liberty AL 287-E at 2.
22 Liberty AL 287-E at 1.
23 Liberty AL 287-E at 1-2.
24 Liberty AL 287-E at 4.
25 Liberty AL 287-E, Exhibit 1 at 7.
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DISCUSSION
A. The Commission should require Liberty to submit
the eventual contract pricing for Commission
approval.

Liberty’s proposed RFP instructions notify potential offerors that Liberty will seek Commission approval. However, Liberty states that it may, “at its sole discretion,” submit a “Final Stage Agreement” that “lacks only specified energy and/or capacity price(s) for the [p]roducts and [s]ervices to be provided . . . .”26 Liberty does not propose an alternative price benchmark approach for the Final Stage Agreement.27 Liberty’s proposal to potentially seek Commission approval without the submission of final contract pricing would sidestep the Commission’s oversight over Liberty’s procurement processes and outcomes. Without pricing information, the Commission cannot execute its fundamental obligation to ensure that Liberty’s rates are just and reasonable.28 The Commission should require Liberty to submit the final prices of its contracted products and services for Commission review and approval.

B. The Commission should authorize Liberty to
conduct a transitional RFP, in two phases.

Liberty submitted AL 287-E on March 6, 2026, which leaves limited time for Liberty to conduct the proposed RFP, execute a contract(s), and obtain Commission approval prior to June 1, 2027. An immediate, expeditious procurement solicitation is reasonable because Liberty ratepayers would otherwise face a heightened risk of service disruption in 2027 and 2028.

However, Liberty seeks to procure well beyond these immediate 2027-2028 needs.

Specifically, Liberty requests authorization to solicit offers with a five-year minimum 26 Liberty AL 287-E, Exhibit 1 at 7.
27 The Commission authorized Bear Valley, a small utility with a similar procurement situation to Liberty’s, to submit final negotiated terms and conditions for its power purchase agreements, along with a proprietary product price benchmark. See D.17-04-003, Decision Denying Bear Valley Electric Service Division’s Phase II Request for Alternative Procurement Process and Adopting an Interim Benchmarking Methodology and Power Purchase Agreement Approval Process, April 6, 2017, OP 3 at 28-29; issued in Application (A.) 13-06-018, In the Matter of the Application of Golden State Water Company on behalf of its Bear Valley Electric Service Division (U913E) for Pre-Approval of Power Purchase Agreements with EDF Trading North America, LLC, Pre-Approval of Power Purchase Agreements with Shell Energy North America (US) L.P., Authority to Recover Costs, Authority to Establish Memorandum Account, and Alternative Pre-Approval Process for Future Power Purchase Agreements. 28 Public Utilities Code Section 451.
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contract term that would cover the period from June 2027 through May 2032.29 Liberty’s proposed minimum five-year term means that Liberty would not receive shorter-term offers that Liberty could compare with any longer-term offers to determine which offers provide the greatest value for ratepayers. And as described in more detail below, a five-year minimum contract term could lock in high prices. Therefore, the Commission should require Liberty to solicit offers for various tenures, as short as balance of year 2027 and as long as the five-year-minimum contracts that Liberty proposes to solicit.

Furthermore, Liberty lacks the same urgency to meet its post-2028 needs, compared to its 2027 and 2028 procurement needs. Therefore, the Commission should require Liberty to conduct a transitional RFP with an immediate near-term phase, followed by a second mid-term phase with more careful consideration of alternative procurement strategies. Cal Advocates recommends the following phased approach:
- In Phase 1, Liberty will consider offers for the balance of calendar year 2027 and all of calendar year 2028, including the bundled attributes that Liberty proposes (energy, capacity, ancillary services, and scheduling).30 Liberty will submit its eventual contracts for Commission approval through an initial Tier 3 advice letter submission.
- In Phase 2, Liberty will consider additional contracts for any combination of calendar year 2029 and 2030 deliveries. Liberty will solicit both bundled and unbundled offers for the energy and capacity attributes that Liberty seeks. Liberty will also assess any opportunities for cost-effective energy procurement if NV Energy joins EDAM.31 Liberty will submit any Phase 2 contracts for Commission approval in a new Tier 3 advice letter submission. 29 Liberty AL 287-E at 4.
30 Liberty generally seeks a “one-stop suite of services” contract from a single qualified offeror (Liberty AL 287-E at 4 and Exhibit 1 at 2). However, to the extent possible, Liberty should also solicit and evaluate unbundled offers for the same attributes, in order to draw upon the broadest pool of offerors. For example, some offerors may be able to supply capacity but not firm energy shaped to Liberty’s net load, or scheduling services for Liberty’s Luning and Turquoise solar facilities. 31 The entry of NV Energy into the EDAM would provide Liberty with a new market opportunity because Liberty’s load is part of the native load of the NV Energy balancing authority area. An out-of-market firm energy contract would effectively become a hedge on Liberty’s wholesale load exposure to the CAISO wholesale markets. As such, EDAM may provide Liberty the opportunity to cost-effectively reduce its contracted firm energy volumes and procure some of its load through EDAM directly (unhedged).
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- Liberty should examine the potential for Liberty staff to develop the competence to provide certain services in-house, if cost-effective, such as scheduling for Liberty’s Luning and Turquoise solar facilities.

Cal Advocates’ recommended phased approach is superior to Liberty’s proposed singlephase RFP with a five-year minimum contract term, because the phased approach reduces Liberty ratepayers’ exposure to the risk that Liberty could lock in high prices for five years. Prices could be high under Liberty’s proposed RFP for the following reasons:
- Bespoke product specification: Liberty’s proposed RFP instructions seek “a single, qualifying Respondent” to provide a “one-stop suite of services[,]” including various capacity and energy commodities, scheduling services, and a firm energy component to serve Liberty’s net load after generation from Liberty’s Luning and Turquoise solar facilities.32 This “one-stop suite” is a bespoke and likely illiquid product. What few offerors there are who can provide such a bespoke “one-stop suite” in the first place may demand a price premium for the effort to assemble a qualifying “one-stop suite” offer. - Evident duress: Liberty’s AL 279-E and AL 287-E publicly establish that Liberty faces an urgent need for contracted energy and capacity deliveries as soon as June 1, 2027. This urgency reduces Liberty’s bargaining power against its future RFP offerors, because Liberty has limited alternative procurement options. Liberty’s offerors may leverage their strong bargaining position to extract higher prices or other favorable contract terms.
- Adverse market conditions: Liberty’s immediate RFP would occur in 2026, a year with potentially adverse market conditions. As Liberty notes, Liberty faces a tightened market for resources, with NV Energy seeking to divert resources to serve its own load, along with data centers seeking to offtake directly from Nevada resources.33 The broader market also shows indications of potential structural tightness, including the withdrawals of multiple balancing authority areas from the Western Resource Adequacy Program34 and rising load forecasts 32 Liberty AL 287-E at 4 and Exhibit 1 at 2. Liberty AL 287-E includes one statement (at 4) that suggests Liberty may consider “distinct services and supplies to be integrated in a way that best serves customers . . . .” However, Liberty’s proposed RFP instructions state that Liberty seeks a single offeror to meet the entire scope of the RFP.
33 Liberty AL 287-E at 2.
34 Henrik Nilsson, PacifiCorp Next to Leave WRAP After Raising Concerns, RTO Insider, October 30, 2025. Available at: https://www.rtoinsider.com/118598-pacificorp-next-withdraw-wrap/. 691
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and potential resource shortfalls in the Pacific Northwest.35 The CAISO’s EDAM and the Southwest Power Pool’s Markets+ may also divert some supply from the bilateral market, in increasing amounts over the coming years.36 Overall, these factors could contribute to a seller’s market for capacity and energy that could be delivered to the NV Energy border to serve a future Liberty contract.
- Failure to consider alternative procurement strategies: Liberty’s proposed five-year term would prevent Liberty from any assessment of the cost-effectiveness of alternative options that could become available over those five years (2027 through 2032). Such alternative procurement strategies and opportunities could include:
o Solicitations for unbundled (i.e., separately procured) energy and capacity commodities for 2029 and 2030, which could allow Liberty to draw from multiple liquid commodity
markets, compared to the bundled, illiquid “one-stop suite” product that Liberty seeks;37
o The development of staff competence to provide certain services in-house, such as scheduling for Liberty’s Luning and Turquoise solar facilities, could prove more cost-effective than continued bundled procurement of scheduling services and energy and capacity commodities; and
o The future participation of Liberty’s balancing authority area (NV Energy) in EDAM, which could enable Liberty to costeffectively procure some portion of its net load on an unhedged basis directly through EDAM, rather than through a firm contract.38
35 Bonneville Power Administration, 2025 Pacific Northwest Loads and Resources Study, May 2025 at 21-23 and 29-32. Available at: https://www.bpa.gov/-/media/Aep/power/white-book/2025- whitebook.pdf.
36 Currently, CAISO expects EDAM to go live on May 1, 2026, while Southwest Power Pool expects Markets+ to go live on October 1, 2027.
37 Liberty AL 287-E at 4 and Exhibit 1 at 2. Liberty AL 287-E includes one statement (at 4) that suggests Liberty may consider “distinct services and supplies to be integrated in a way that best serves customers . . . .” However, Liberty’s proposed RFP instructions state that Liberty seeks a single offeror to meet the entire scope of the RFP.
38 NV Energy continues to lean towards joining EDAM. See letter from Michael Wilding, Vice President, Energy Supply Management, PacifiCorp (on behalf of identified utilities) to Gabriel Aguilera, Chair, and John Hammond, Vice Chair, Body of State Regulators of the Western Energy Market, Re: Extended Day Ahead Market (EDAM) Resource Adequacy Program, March 7, 2026. Available at:
https://www.westernenergyboard.org/wp-content/uploads/March-7-2026-Regional-RA-Letter.pdf. 692
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Ultimately, Liberty’s proposed single-phase RFP exposes Liberty’s ratepayers to the risk of a five-year replacement ESA that may come with a premium price. Cal Advocates’ recommended phased approach would mitigate this risk.

C. The Commission should require Liberty to submit
Tier 3 advice letters for Commission approval of
Phase 1 and Phase 2 contracts.

The Commission should require Liberty to submit a Tier 3 advice letter for approval of its Phase 1 contracts. A Tier 3 advice letter, instead of a formal application, is appropriate for Liberty’s Phase 1 contract approval process due to the urgency of Liberty’s 2027-2028 procurement need.39 As described above, Cal Advocates also recommends that the Commission require Liberty to submit a second Tier 3 advice letter for approval of Phase 2 contracts. While Liberty’s 2029 and 2030 needs are less urgent than Liberty’s 2027 and 2028 needs, Cal Advocates expects that the same Liberty staff will need to execute Phase 2 similarly expeditiously.40 39 The alternative avenue for Commission approval of Liberty’s contracts would be a formal application.

However, even if the Commission were to require Liberty to submit its contracts for Commission approval through a formal application, Liberty would still need time for the Commission to authorize Liberty’s RFP, and then time to run the RFP. If Liberty’s RFP does not produce a contract and application until late 2026 or early 2027, then a Commission decision on a hypothetical formal application may not come until late 2027 or early-to-mid-2028 – well beyond the expiration of Liberty’s NV Energy ESA.

See also D.12-12-031, Decision Granting Authority to Enter into a Research and Development Agreement with Lawrence Livermore National Laboratory for 21st Century Energy systems and for Costs Up to $152.19 Million, December 20, 2012 at 18; issued in A.11-07-008, Application of Pacific Gas and Electric Company (U39M), San Diego Gas & Electric Company (U902E)) and Southern California Edison Company (U338E) for Authority to Increase Electric Rates and Charges to Recover Costs of Research and Development Agreement with Lawrence Livermore National Laboratory for 21st Century Energy Systems:

In a Tier 3 advice letter review, a matter is subject to the scrutiny of the full Commission in a public meeting and enables the Commission to address matters through advice letters that go beyond a ministerial review. In addition, over the course of years, a Tier 3 advice letter review has come to signal that the Commission views the issues addressed in the advice letter as rising to a level of high importance to California, and deserving of review at the highest levels of the Commission.
40 Liberty would likely resource its Phase 1 and Phase 2 activities with the same staff. Cal Advocates expects that Liberty staff would need the remainder of 2026 to run Liberty’s Phase 1 RFP, execute contracts, and seek Commission approval, by the first quarter of 2027. Then, Liberty staff would need to repeat this exercise for Liberty’s Phase 2 RFP, with a second advice letter submission in early 2028.

Under this schedule, it may be unreasonable to expect staff to develop a more fully formed procurement framework application until later in 2028, for a Commission decision in late 2029 or early 2030. 693
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However, as discussed below, the Commission should not set Liberty on a path of indefinite Tier 3 advice letter submissions for future procurement contracts and transaction approvals, beyond the transitional 2027-2030 time frame. The advice letter process “provides a quick and simplified review of the types of utility requests that are expected neither to be controversial nor to raise important policy questions.”41 In contrast, the replacement of Liberty’s NV Energy ESA – its sole source of energy and capacity – is a major development for Liberty. But for the extraordinary circumstances that Liberty now faces, Liberty’s request to deviate from its approved IRP to conduct an immediate RFP to replace Liberty’s current ESA with NV Energy is the type of request more suitable for a formal application.42
D. The Commission should require Liberty to file an
application for Commission approval of a
procurement framework for Liberty’s procurement
needs in 2031 and beyond.

To prevent a scenario where Liberty is reliant on indefinite Tier 3 advice letter submissions for future procurement contract and transaction approvals, the Commission should require Liberty to file an application with a proposal for a procurement framework. The Commission has yet to establish any prescriptive procurement process or regulations for Liberty, as small utilities may receive exemptions from the procurement planning requirements that govern large utilities.43 The lack of a procurement framework for Liberty complicates Liberty’s prospective transition from the NV Energy ESA to a new procurement regime.

In particular, the illiquidity of Liberty’s proposed bundled “one-stop suite” product means that it may prove more cost-effective for Liberty’s ratepayers for Liberty to 41 GO 96-B, General Rule, Rule 5.1 (Matters Appropriate to Advice Letters). 42 Liberty itself submitted an application for Commission approval of the original NV Energy ESA: A.15- 04-19, In the Matter of the Application of Liberty Utilities (CalPeco Electric) LLC (U 933 E) for Authority to Execute 2016 NV Energy Services Agreement and for Rate Recovery of the Costs It Will Incur Pursuant to the Agreement, and Urging Issuance of Expedited Decision Granting Such Relief.

Also, the Commission rejected a proposal from Golden State Water Company to replace its Bear Valley Electric Service Division’s procurement applications with advice letters. (See D.17-04-003 at 15-17.) See also GO 96-B, General Rules, Rule 5.2 (Matters Appropriate to Formal Proceedings):

A utility must file an application, application for rehearing, or petition for modification, as appropriate, in the following circumstances:
. . .
(2) The utility seeks Commission approval of a proposed action that the utility has not been authorized, by statute, by this General Order, or by other Commission order, to seek by advice letter . . . .
43 Public Utilities Code Section 454.5(i).
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eventually procure different combinations of unbundled energy and capacity contracts and transactions. But with no procurement framework in place, Liberty would be left to submit those contracts and transactions for Commission review through an unknown number of applications, on a rolling basis, indefinitely. In anticipation of this administrative complication, the Commission should proactively establish new procurement regulations for Liberty, which would take effect for Liberty’s 2031 procurement and beyond.

Specifically, the Commission should create a new procurement framework to streamline Liberty’s procurement of unbundled energy and capacity commodities and the Commission’s review thereof. This framework would be a simplified version of the more prescriptive procurement plans that large utilities must file pursuant to statute.44 Liberty’s procurement framework should specify:
- The definition of the various energy and energy hedge commodities that Liberty must or may procure for any given delivery period; - The definition of the various capacity commodities that Liberty must or may procure for any given delivery period, with a specified resource accreditation methodology for any capacity products, as necessary;
- Liberty’s ancillary services obligations for any given delivery period; - Rules for and the prioritization of Liberty’s use of competitive solicitations, bilateral negotiations, and brokers to procure; - The methodology to derive the load forecast that Liberty will use to support its procurements;
- The evaluation methodology that Liberty will use to evaluate offers received in any solicitation;45
- The general cadence of any regular solicitations;
- The accounting of any attributes from Liberty’s owned electricity resources;
- Rules for Liberty’s interaction with the CAISO wholesale markets, in the event that NV Energy joins the EDAM;
44 Pursuant to Public Utilities Code Section 454.5(i), the Commission may grant small utilities exemptions from California’s procurement plan statute.
45 This element may require confidential treatment due to market sensitivity. 695
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- The cadence and procedural venue (e.g., quarterly advice letter filings or other venue) for Liberty’s submission of contracts and transactions to the Commission for review;
- The cadence for updates to Liberty’s Energy Cost Adjustment Clause for cost recovery; and
- The cadence and process for updates to the procurement framework.

The Commission should require Liberty to file an application with its proposal for a procurement framework that includes the elements enumerated above. Due to this significant scope and need for intervenor participation and record development, an application is the appropriate venue for the Commission to develop a new procurement framework for Liberty.46 The Commission should require Liberty to submit this application by the third quarter of 2028, which in turn enables a Commission decision in late 2029 or early 2030, in advance of Liberty’s 2031 procurement activities.

E. The Commission should consider a consolidated
proceeding to establish a procurement framework
for both Liberty and Bear Valley.

Liberty’s situation echoes that of Bear Valley, a similarly situated small utility with a history of reliance on “one-stop suite” procurement contracts. In D.17-04-003, the Commission specified an interim procurement process for Bear Valley. In that decision, the Commission also contemplated that the Commission could or would create new procurement process(es) and/or a procurement pricing assessment methodology for small utilities in the IRP proceeding or another proceeding.47 However, the Commission did not do so.

The expiration of Liberty’s NV Energy ESA creates a reasonable opportunity for the Commission to establish such a procurement process for the small utilities. Specifically, the Commission should consider a requirement for Bear Valley to file its own application in 2028 to propose a procurement framework, or else to file a joint proposal with Liberty. 46 An application would enable intervenors to develop the record through discovery, testimony, and hearings, if necessary. While Liberty previously sought new procurement authorities through its individual IRP filing in 2018, Liberty’s upcoming IRP filing is not an appropriate venue for the Commission to develop a simplified procurement plan for future Liberty procurement. Pursuant to an Administrative Law Judge’s email Ruling on March 9, 2026, in R.25-06-019, the IRP proceeding, Liberty will file its next individual IRP on August 10, 2026 with party comments due on September 21, 2026.

This schedule includes no reply comments, let alone testimony and hearings on Liberty procurement.

Moreover, party resources will be stretched thin, as all other Commission-jurisdictional load-serving entities will also file individual IRPs on August 10, 2026 for party review, discovery, and comment by September 21, 2026. A standalone Liberty application would therefore be more appropriate for the Commission to consider a simplified procurement plan for Liberty. 47 D.17-04-003, Conclusion of Law 5 at 27, and 9-10, 19, and 22. 696
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The Commission could then consolidate the Bear Valley and Liberty applications into a single proceeding to establish a procurement framework for the small utilities.

CONCLUSION
The Commission should reject Liberty AL 287-E and:
 Require Liberty to submit its eventual contract pricing for Commission approval;
 Require Liberty to conduct a transitional RFP in two phases. In the first phase, Liberty will solicit offers for the balance of calendar year 2027 and all of calendar year 2028, including the bundled attributes that Liberty proposes. In the second phase, Liberty will solicit offers for 2029 and 2030 for the bundled and unbundled offers for the attributes that Liberty seeks;
 Require Liberty to submit one Tier 3 advice letter for Commission approval of Phase 1 contracts and a second Tier 3 advice letter for Commission approval of Phase 2 contracts;
 Require Liberty to assess the potential for cost-effective staff development opportunities to provide certain services directly, as well as the potential for cost-effective procurement strategies that may emerge if NV Energy participates in the CAISO’s EDAM;
 Require Liberty to file an application for Commission approval of a procurement framework for Liberty’s procurement needs in 2031 and beyond; and
 Consider a consolidated proceeding to establish a procurement framework for both Liberty and Bear Valley.

Please contact Christian Lambert at [email protected] or 415-703-1419 with any questions regarding this protest.

Sincerely,
/s/ JULIE HALLIGAN
Julie Halligan
Program Manager
Electricity Planning and Policy Branch
cc: Dan Marsh, Director, Rates and Regulatory Affairs, Liberty Service list: GO 96-B
697

BEFORE THE PUBLIC UTILITIES

COMMISSION OF THE STATE OF

CALIFORNIA
Protest of Tahoe Spark to Advice Letter 287-E of Liberty Utilities (CalPeco Electric) LLC Danielle Hughes
Founder & President, Tahoe Spark
5401 Caledonia Circle
Carnelian Bay, CA 96140
I. INTRODUCTION
Tahoe Spark submits this protest to Advice Letter 287-E at a critical junction in the Commission’s oversight of Liberty Utilities’ electric system. This Advice Letter is not a routine administrative filing. It exposes a structural failure that has been building for years: California continues to approve costs, rates, and infrastructure investments for a system that is not modeled in California’s planning framework, not transparently procured, and not supported by a current, integrated evidentiary record.

The Commission has already approved Liberty’s General Rate Case, authorizing significant increases in revenue requirement, wildfire cost recovery, post-test-year capital recovery, and infrastructure cost recovery through advice letter mechanisms while refusing opportunity for Tahoe Spark’s customer base to participate in negotiations while pushing visitor demand increasing cost shifts without transparency. The amended settlement set Liberty’s 2025 revenue requirement at $232.956 million, authorized $30.667 million in wildfire insurance expense, allowed $104.511 million in 2026-2027 PTAM capital recovery, and allowed up to $24 million each for the Meyers and Stateline substations through Tier 2 advice letters.1 Since that approval cycle began, customer rates in Liberty’s territory have increased substantially, effectively doubling over roughly four years, while the underlying drivers of those costs remain unverified 1 A2409010-Amended Joint Motion for Approval of Multi-Party Settlement Agreement (2).pdf, pp. 5-7 698
and fragmented across proceedings, including wholesale cost shares across multiple Investor Owned Utilities.

The most recent independent evaluation of Liberty’s procurement structure remains the Federal Energy Regulatory Commission proceeding in which Liberty’s request for relief from federal requirements was denied because its wholesale activity was sufficiently material to require federal oversight (Attachment A) That federal determination remains the last point at which Liberty’s wholesale framework was meaningfully scrutinized using a verified record. Since then, Liberty appears to have one required filing which can be found and FERC has been unresponsive to emails. The FERC compliance dataset reflects current wholesale activity, and it does not provide a complete or verifiable explanation of cost formation, allocation, or whether California ratepayers are receiving the benefit of any wholesale revenues.

At the same time, California’s own planning framework does not model Liberty’s system.

Liberty is placed in “Zone 0,” no complete forecast is developed for that zone, no hourly or seasonal load forecast is produced, and any extrapolation uses statewide average growth assumptions rather than Liberty-specific conditions. Liberty’s own discovery responses confirm that it does not use statewide demand forecasts from CPUC, CEC, or CAISO in its resource or infrastructure planning because it operates within the Nevada balancing authority.2 That means California continues to approve rates and infrastructure for a system that is excluded from the state’s actual demand and planning architecture while Liberty Customers have been hidden within NV Energy’s wholesale market since inception of the Limited Liability California Retail Company lacking transparency and now CPUC wants to create even less transparency and opportunity to participate through TWO interstate markets AND CPUC AND CEC? Let’s not forget that CPUC already excludes Liberty Customers from any Climate Adaptation Planning, mapping, statewide programs, is taking our climate credits based on lobbying by the large California Investor Owned Utilities, redistributing their nuclear costs, and excluding us from social justice and socioeconomic plans.
2 Liberty CalPecos Response to DR Lib 001.pdf, p. 5
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Advice Letter 287-E now confirms that the underlying procurement structure is not stable as Tahoe Spark presented in the GRC. Liberty has acknowledged that its existing procurement structure is coming to an end in May 2027 and that replacement arrangements must be secured.

The filing further reflects that the existing framework remains subject to termination and transition provisions. Tahoe Spark uses the Advice Letter here because it marks the point at which the Commission can no longer pretend that the existing arrangement is durable or that rate recovery can continue without full proceeding.

This risk is no longer occurring in a stable surrounding system. Nevada’s own legislative record now shows extraordinary load growth from data center development, concentrated overwhelmingly in Northern Nevada, where Liberty procures power. Nevada materials identify 5,900 MW of requested data center load growth and 25,590 GWh of projected annual load growth by 2033, with 96% of that growth in Northern Nevada.3 Nevada legislative presentations further identify broad concern over rising costs, ratepayer inequity, interconnection constraints, and trade-offs with other priorities such as electrification and affordability.4 California ratepayers served by Liberty are therefore dependent on a system that is rapidly being reoriented around large, continuous, high-value loads, with no evidence in this record that California customers are prioritized or protected within any California systems.

Liberty’s filing signals that the company’s existing wholesale supply arrangement—an arrangement entirely outside California’s planning frameworks and dependent on interstate markets—is no longer viable. This raises immediate concerns under the Commission’s statutory duty to ensure safe and reliable service (Pub. Util. Code §§451, 701, 387). A utility’s admission that its procurement structure is unstable is not a routine administrative update; it is a warning that the utility may be unable to meet its most basic obligations to the public.

Moreover, the issues embedded in Advice Letter 287-E extend into areas squarely governed by federal jurisdiction, including interstate wholesale electricity markets, transmission access, and procurement practices regulated under the Federal Power Act (16 U.S.C. §824). When a utility’s retail service depends on opaque, affiliate-controlled wholesale arrangements outside 3 Agenda Item V—Data Center Water and Power Needs (DRI) (Original).pdf, pp. 3, 7-10 4 Agenda Item V—Data Center Water and Power Needs (DRI) (Original).pdf, pp. 8-10 700
California’s oversight, a utility is not paying its bills for public service programs such as University of Nevada’s Fire Camera Systems, charging rate payers for non-disclosed costs in other utility territories, charging for multimillion dollar upgrades to their offices then closing all their doors, and contracting service operations to other utility operators such as Wasatch Electric out of Utah, not reading meters for months and estimating costs without customer explanation, and shifting peak visitation demand on to working class communities the Commission must evaluate whether the utility can continue to provide just, reasonable, and adequate service as required by §451.

General Order 96-B expressly prohibits the use of the advice letter process for matters involving significant policy questions, contested factual issues, or changes that materially affect service quality, reliability, or safety. Liberty’s filing triggers all three beyond any reasonable doubt.

The company seeks to make consequential procurement and reliability determinations through a process designed for ministerial approvals, thereby depriving the public and the Commission of the transparency, evidentiary record, and procedural safeguards required for decisions of this magnitude.

Ratepayers have the right to consider options to serve reliable, just and adequate service though alternative means. This is a failure of oversight, a failure of the record, and a failure to protect Californians from an external procurement structure whose risks are growing while transparency is shrinking.

For these reasons, Advice Letter 287-E cannot be approved through the advice letter process.

The Commission must instead open a formal proceeding to examine:
● Whether Liberty’s procurement structure is capable of ensuring reliable service; ● Whether the company’s reliance on interstate wholesale markets exposes customers to unreasonable risks;
● Whether alternative, public, or community-based delivery models should be evaluated under Pub. Util. Code §387; and
● Whether Liberty’s historical conduct and structural constraints demonstrate an inability to meet California’s safety and reliability standards.
701
In short, Liberty’s own statements in Advice Letter 287-E compel the Commission to treat this as a reliability and public-protection matter, not a routine filing. The Commission must require a transparent, formal review to ensure that the communities served by Liberty receive the safe, reliable, and accountable electric service that California law demands.

II. ADVICE LETTER 287-E CONFIRMS IMMEDIATE

PROCUREMENT INSTABILITY
Advice Letter 287-E is significant because it confirms that Liberty’s California customers are not served under a secure, long-term procurement framework. Rather, Liberty remains dependent on a temporary extension of a full-requirements arrangement within the NV Energy balancing authority, and Liberty itself has acknowledged that the existing structure is coming to an end in May 2027. That is not a stable supply plan. It is a bridge, a long bride to Utah, bound to rapidly increase costs to a declining low-income and working class community that must be frozen until a transparent proceeding occurs.

The Advice Letter does not resolve this problem. It confirms it. Liberty provides no complete replacement procurement strategy, no long-term supply plan, no evaluation of alternative procurement options, no rate impact analysis for replacement supply, and no public record showing how California customers will be protected if the current arrangement is terminated or materially repriced.

This matters because Liberty’s service territory is not in CAISO. Liberty’s own GRC application states that its territory is entirely within the NV Energy Balancing Authority Area and is neither geographically nor operationally part of CAISO, and that it procures the rest of its power through a full-requirements agreement with NV Energy.5 The GRC application also admits Liberty is winter-peaking, that it serves highly variable loads associated with ski resorts and hotel operations, and that approximately 60 percent of residential accounts are vacation homes or rentals.6 Those are not generic utility conditions that can be analyzed using PG&E as a model. 5 A24-09-010 Liberty 2025 GRC Application Draft, pp. 2-4 6 A24-09-010 Liberty 2025 GRC Application Draft, pp. 2-3 702
They are specific system characteristics that make procurement stability, seasonal risk, and load priority central to any reasonable review.

At the same time, the external system on which Liberty depends is changing rapidly. Nevada legislative materials identify approximately 712.83 MW of operating data center demand in Nevada, 495 MW in construction, and 5,914 MW planned, for a total of 7,121.83 MW, with 25,590 GWh of projected annual data center load growth by 2033 and 96 percent of that growth in Northern Nevada.7 Nevada’s own summary identifies rising costs, increasing stress on water and energy resources, trade-offs with electrification and affordability, and explicit “ratepayer inequity” as concerns associated with this expansion.8
The CPUC and CEC have both failed in
oversight of monitoring the impacts to Liberty’s retail customers in California.

That record matters here because Liberty is not procuring power in a vacuum. It is procuring within a balancing authority that is increasingly shaped by very large, continuous, industrialscale loads. Those loads influence generation planning, transmission expansion, interconnection priorities, and capacity valuation, California is doing the same without considering rural California communities. The Commission has no evidence in this record that Liberty’s California customers have any guaranteed priority or protection within CAISO, within Western Power or Nevada’s rapidly changing system.

The Nevada public comment record is also telling. The concern raised there is not simply about development volume, but about the absence of governance, incomplete public disclosure of actual locations and impacts, and the lack of meaningful oversight of environmental, resource, and human impacts as this load growth proceeds.9 That reinforces Tahoe Spark’s central point:

Liberty’s California customers are dependent on an external system undergoing major structural change, while California regulators do not have a complete record of what that change means for price, reliability, or long-term procurement.
7 Agenda Item V—Data Center Water and Power Needs (DRI) (Original).pdf, p. 3 8 Agenda Item V—Data Center Water and Power Needs (DRI) (Original).pdf, pp. 8-10 9 NR GI 3-25-2026 verbal EW.docx
703
To make matters worse, interstate procurement relationships will make public participation impossible. If Liberty is contracting through or alongside entities such as Wasatch in Utah, that only expands the geographic and regulatory fragmentation of this system and further reduces transparency into cost formation and allocation. If Liberty’s procurement footprint extends across Nevada and Utah, while California continues to regulate only the retail endpoint, then the Commission is approving costs without understanding the chain of transactions that produces them.

Advice Letter 287-E therefore cannot be treated as a routine continuation filing. It confirms that the current supply structure is temporary, that replacement procurement is unresolved, that the surrounding system is under extraordinary load pressure, and that Californians have no demonstrated protection within that arrangement.

III. COST ESCALATION WITHOUT A VERIFIED

RECORD, INTEGRATED REVIEW, OR CAUSAL BASIS
The procurement instability described above is not a future concern. It is already embedded in current customer bills.

Over the last several years, Liberty’s customers have experienced substantial increases through a combination of base rate increases, ECAC pass-throughs, wildfire mitigation and insurance recovery, and infrastructure charges. Liberty’s GRC application sought a 2025 base revenue requirement of $247.920 million, reflecting an overall revenue increase of 19.1 percent and a monthly increase of approximately $37.51 for an average residential customer.10 TURN’s testimony confirmed that Liberty’s 2025 request came on the heels of the prior GRC, where Liberty had requested a 30.9 percent increase and received a 14.5 percent overall increase, and that the new request was roughly a 20 percent increase driven heavily by wildfire insurance. 11 Liberty’s own application states that approximately 60 percent of its requested increase was directly related to wildfire insurance cost increases.12 10 A24-090-010 Liberty 2025 GRC Application Draft, pp. 1-4 11 A.24-09-010 TURN-01 Dowdell Testimony.pdf, pp. 1-3.
12 A24-09-010 Liberty 2025 GRC Application Draft, pp. 3-4 704
These costs have not been evaluated together in a single proceeding and the Settlement fails to consider the wholesale relationships to the costs. SBUA and TURN have both openly stated they do not understand FERC and proceeded with settlements knowing the instability of the system and concerns with wholesale costs (pers comm.). Tahoe Spark was never invited to the settlement discussions and Liberty refused to have public meetings in person and has closed both their Northshore and Southshore offices after multi-million-dollar rate payer funded upgrades to operate out of the north east of the US.

Procurement costs continue to be passed through ECAC, yet there is no current, integrated dataset explaining how those costs are formed. The only meaningful post-FERC dataset is the compliance memo and underlying federal filings showing expanded wholesale activity. That record reflects significant wholesale revenues, including PG&E sales and a newly identified NV Energy buyer relationship, but it does not provide a complete explanation of price formation, allocation, or whether California retail customers are receiving any corresponding benefit. Tahoe Spark’s concern is no longer simply whether Liberty filed reports. It is that the only current data available shows increasing wholesale complexity and possible outward value extraction without a corresponding state review.

Wildfire and insurance costs have then been layered on top of those procurement costs. The amended settlement authorized $30.667 million in wildfire insurance expense, subject only to deferred reasonableness review in the next GRC.13 Liberty’s O&M testimony states that wildfire mitigation and wildfire insurance account for $25.513 million, or 74 percent, of Liberty’s total requested increase in O&M and A&G expenses over the prior authorized level.14 Yet there is no integrated record evaluating how these costs interact with procurement cost pass-throughs, infrastructure investments, and external system risks.

Infrastructure costs have likewise been advanced without a validated demand model. The settlement authorizes recovery of $104.511 million in 2026-2027 PTAM capital expenditures and allows recovery of up to $24 million each for the Meyers and Stateline substations through 13 A2409010-Amended Joint Motion for Approval of Multi-Party Settlement Agreement (2).pdf, p. 7 14 Microsoft Word - A2409XXX-Liberty-Rao-Chapter 3 O&M A&G Expenses, pp. 1-3 705
Tier 2 advice letters.15 These systems are likely for the Nevada and PG&E network. Liberty’s capital testimony shows that its forecast includes major spending in wildfire mitigation, substations, and other distribution projects extending through 2027.16 But neither Liberty nor California has provided a validated model linking those investments to actual, Liberty-specific demand conditions.

That is the core problem. Procurement costs, wildfire costs, and infrastructure costs are each advanced through separate mechanisms—GRC, ECAC, PTAM, and advice letters—but imposed collectively on customers. State policies are shifting costs on to permanent residents with no socioeconomic plans. There is no proceeding in which the Commission evaluates the total burden on ratepayers, whether these costs are duplicative or compounding, whether the same system risks are being recovered in multiple ways, or whether customers are receiving any demonstrable benefit proportional to what they are paying.

The Commission therefore lacks a complete record demonstrating how costs are formed, how they interact, and whether they are reasonably allocated. Under Public Utilities Code sections 451, 701, and 728, that is not enough.

IV. ABSENCE OF A CURRENT DATASET AND

FAILURE OF DEMAND, PROCUREMENT, AND

SYSTEM MODELING
The cost increases and procurement risks described above cannot be reasonably evaluated because the Commission does not have a current, complete, or validated dataset describing Liberty’s system.

California does not model Liberty’s system in any meaningful way. The California Energy Commission has confirmed that Liberty is assigned to “forecast zone 0,” that the CEC does not publish forecasts for that zone, does not develop a complete forecast for it, and does not develop hourly load, per-capita usage, or load profiles for that zone. Instead, any annual extrapolation is 15 A2409010-Amended Joint Motion for Approval of Multi-Party Settlement Agreement (2).pdf, pp. 5-7 16 Microsoft Word - A2409XXX-Liberty-Lykens-Chapter 2 Capital, pp. 1-5 706
based on statewide average growth rates….in an area that has historically and increasing declining full time resident populations due to gentrification. That means California does not produce a Liberty-specific forecast of demand, peak conditions, or procurement needed for numerous California communities in a high wildfire risk area serving millions of Californians.

The Commission is therefore approving rates and infrastructure for a system excluded from the state’s actual planning tools.

Liberty does not model the system either. Liberty’s own discovery responses state that it does not overlay transportation or short-term rental mapping data because that data “does not impact Liberty’s load forecasting or system planning,” does not consider STR-concentrated neighborhoods as elevated system risk, does not consider highway congestion or day-use visitation as elevated system risk, and does not track daily vehicle volume in the territory.17 Liberty also confirmed that it does not use statewide demand forecasts from CPUC, CEC, or CAISO in its planning because it operates within the Nevada balancing authority.18 These are not secondary omissions. They are failures to model the primary drivers of Liberty’s actual demand conditions.

Tahoe Spark’s testimony already established that the Tahoe Basin experiences 28.4 million person trips annually, with 24.4 million of those trips by visitors, and that Liberty’s proposal violates cost causation because those who drive seasonal peak demand are not bearing the associated costs.19 That testimony further tied specific infrastructure pressures to resort-driven and visitor-serving projects, including Palisades, Northstar, and Kings Beach development patterns.20 Yet neither Liberty’s forecasts nor California’s planning framework incorporate that reality or the social and economic impacts.

There is also no complete current dataset for procurement or cost formation. The only meaningful post-FERC dataset is the compliance filing and associated review showing expanded wholesale activity, but even that record leaves unresolved issues regarding rate schedule 17 Liberty CalPecos Response to DR Lib 001.pdf, pp. 4-5 18 Liberty CalPecos Response to DR Lib 001.pdf, p. 5
19 TAHOE SPARK Testimony with Exhibits.pdf, pp. 1-5.
20 TAHOE SPARK Testimony with Exhibits.pdf, pp. 3-5.
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authority, internal accounting consistency, and how wholesale activity affects California ratepayers. Beyond that, no state or federal record currently links procurement, load, infrastructure, and rates in an integrated way.

The Commission is therefore operating without:
● a modeled representation of Liberty’s system demand,
● a verified dataset of procurement costs, or
● an integrated analysis linking demand, procurement, and retail rate recovery.

That is not just a technical problem. It is a failure of the evidentiary basis required for ratemaking and for continued cost recovery and requires full investigation.

V. STRUCTURAL FAILURE OF OVERSIGHT,
HISTORICAL PRECEDENT, AND THE STATE’S

AFFIRMATIVE DUTY TO ACT
The conditions described in this protest are not unprecedented.

California has faced them before.

Following the 2000-2001 energy crisis, the California Senate established the Senate Select Committee to Investigate Price Manipulation of the Wholesale Energy Market, chaired by Senator Joseph Dunn. That Committee investigated manipulation in the wholesale electricity markets, failures of transparency, affiliate transactions, and the way fragmented oversight allowed unreasonable costs to be imposed on California communities. The Committee’s work was part of a broader state response to the recognition that California could not simply rely on external markets, opaque wholesale structures, and utility assertions while ratepayers absorbed the consequences.

Federal investigations reinforced these findings. FERC’s Final Report on Price Manipulation in Western Markets documented that market participants engaged in practices that distorted prices and undermined market integrity in western electricity markets. California’s response included 708
direct intervention through the Department of Water Resources, which stepped in to procure power, stabilize the system, and protect customers where the market had failed to provide transparent and reliable service.

Section 387 grants the Commission broad authority to ensure continuity of electric service and to evaluate alternative providers—including municipal, joint powers, or state entities—when an electric corporation is unable to reliably serve its customers. This authority is not limited to financial insolvency. It is triggered whenever the Commission finds that a utility’s structure, procurement practices, or operational conduct prevents it from meeting California’s statutory reliability and safety standards.

1. Circumstances Triggering §387 Authority
The statute encompasses a wide range of failures that jeopardize reliable service, including:
● Persistent operational or procurement failures, including inability to secure resources needed to meet load or reliability obligations.
● Structural constraints—such as affiliate-dominated procurement or out-of-state corporate control—that prevent the utility from participating in California’s planning frameworks or complying with state reliability mandates. ● Chronic exposure to avoidable wholesale risks, including reliance on opaque or unreviewable affiliate transactions.
● Lack of transparency or evidence of manipulation, including withholding of information necessary for Commission oversight.
● Inability to plan or procure resources adequate to meet community needs, particularly in high-risk, climate-vulnerable regions.

Where the record demonstrates that a utility’s business model is fundamentally incompatible with California’s reliability standards, §387 empowers the Commission to examine public or community-based delivery models capable of providing transparent, accountable, and community-aligned service.

2. The Commission’s Options Under §387
709
Section 387 provides the Commission with a suite of tools to ensure continuity of service. These include requiring structural reforms to address deficiencies, including changes to procurement practices, governance, or corporate structure, if such reforms are necessary to ensure reliable service. These options reflect the Legislature’s intent that the Commission act proactively—not reactively—when a utility’s structure or conduct threatens the continuity of safe and reliable service.

Historical Context: Emergency Procurement Authority and DWR’s Continuing Role

1. Senate Bill 7 from the First Extraordinary Session (SB 7X, 2001) Signed January 19, 2001, SB 7X was the Legislature’s first emergency response to the collapse of California’s wholesale electricity market. SB 7X:
● Declared a statewide energy emergency, recognizing that the ISO and PX markets were no longer functioning.
● Directed the Department of Water Resources (DWR) to begin procuring electricity on an interim basis for PG&E, SCE, and SDG&E customers.
● Appropriated $400 million to DWR to immediately enter the wholesale market. ● Triggered DWR’s rapid assumption of procurement responsibilities as the IOUs became insolvent and unable to purchase power.

This statute marks the moment when DWR became California’s emergency procurement entity that remains embedded in statute today.21

2. The “1X” Framework: AB 1X, SB 1X, and the Creation of Water Code Division 27 The Legislature’s broader emergency response—commonly referred to as the “1X” package— was enacted through Assembly Bill 1 from the First Extraordinary Session (AB 1X) and related 21 CPUC, Pulsifer Agenda Decision on DWR Revenue Requirements (summarizing SB 7X. 710
measures. AB 1X created Division 27 of the Water Code (Water Code §§ 80000–80270), which established a durable statutory framework for DWR’s role in electricity procurement.

Under AB 1X and Division 27, DWR was authorized to:
● Procure electricity on behalf of retail customers of the IOUs (Water Code §§ 80100, 80106).
● Enter long-term and short-term power contracts (Water Code § 80110). ● Issue bonds backed by ratepayer revenues to finance procurement (Water Code §§ 80130–80134).
● Recover all procurement costs through CPUC-approved charges (Water Code § 80110). ● Act as a temporary or transitional service provider when IOUs were unable to procure power due to structural or financial failures.

AB 1X also froze residential rates up to 130% of baseline, creating the Tier 1 and Tier 2 rate freeze that shaped California’s rate design for years.

Although enacted during the Enron-era crisis, Division 27 was never repealed. The Legislature intentionally preserved DWR’s authority as a state-level backstop—a provider of last resort capable of stepping in when an IOU cannot ensure reliable service.

This authority remains available whenever:
● A utility’s procurement structure is fundamentally flawed or opaque. ● The utility is exposed to wholesale market risks it cannot manage. ● Corporate governance or out-of-state control prevents compliance with California’s planning and reliability requirements.
● The utility’s conduct raises concerns about transparency, manipulation, or misrepresentation.

In such circumstances, DWR can again assume procurement or operational responsibilities on a temporary basis while the Commission evaluates public or community-based alternatives under Public Utilities Code § 387.
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That history belongs in this protest because the same
structural warning signs are present here.

Today, Liberty’s procurement occurs outside California’s oversight structures, within interstate wholesale markets and a Nevada balancing authority that is being reshaped by external load pressures and further from State reliability concerns. Transparency is limited. California does not model the system. The Commission is approving rates and cost recovery without a current, integrated record. Federal oversight exists only in the form of partial reporting, not a complete state-facing evaluation of retail impacts. These are not identical facts to 2001, but they are the same type of governance failure: fragmented oversight, opaque market structure, and ratepayers left exposed.

Liberty’s Structural Timeline Demonstrating Known Risk
2010 – Creation of CalPeco following restructuring of Sierra Pacific Power Company California assets as a Limited Liability Company but not separately regulated in the NV Energy wholesale market.
2018 – Federal Energy Regulatory Commission determined Liberty’s transactions constituted interstate wholesale sales for resale subject to federal jurisdiction showing questionable sales to PG&E (FERC Order, Jan. 3, 2018).
2020 – Liberty Integrated Resource Plan acknowledged transmission constraints affecting procurement options. Continued non-compliance of the 2018 FERC Order. 2022 – Liberty elected to remain dependent on NV Energy full-requirements supply. Continued non-compliance of the 2018 FERC Order.
2026 – Advice Letter 287-E seeks expedited approval of a replacement procurement framework.

Continued non-compliance of the 2018 FERC Order.

Liberty Utilities has pursued substantial rate increases through multiple CPUC General Rate Case proceedings and numerous asymmetric cost adjustments. These increases have been 712
attributed to wildfire mitigation investments, insurance costs, infrastructure upgrades, and procurement costs. Liberty is not paying the University of Nevada for wildfire camera costs billed to residents and has no transparency in cost causation. Permanent residents in Liberty’s service territory have experienced rapid electricity cost increases relative to larger California investor-owned utilities while there is no oversight of this Investor Owned Utility.

The Commission cannot dismiss this as someone else’s problem because Liberty’s customers are California ratepayers. They are entitled to reliable service, transparent cost formation, and protection from unmanaged market risks. Under sections 451, 701, 728, and 1708 of the Public Utilities Code, the Commission has continuing authority and responsibility to correct prior assumptions, to act when the record is incomplete, and to protect the public interest when external structures are no longer sufficient.

This is also where the State’s broader authority matters. California has acted before through the Department of Water Resources when external procurement arrangements and wholesale market dysfunction threatened Californians. The Commission should not pretend that such options are irrelevant now. If Liberty’s existing structure is unstable, opaque, and increasingly dependent on competing large-load systems outside California, then the Commission must evaluate state-level options again.

That includes evaluating whether Liberty must be brought into California’s planning and procurement frameworks, whether CAISO integration must be considered, whether Community Choice Aggregation procurement authority must be enabled in Liberty’s territory in an expedited manner, and whether DWR or other state authorities must be considered as part of a long-term solution a safe, reliable, pubic utility option. These are not theoretical policy preferences. They are the type of state actions California has previously used when market structures failed to protect communities.

VI. Grounds for Protest
This protest is submitted pursuant to General Order 96-B, Section 7.4.2, which authorizes protests where an advice letter (1) violates statute, Commission rule, or prior Commission decision; (2) raises significant policy issues requiring Commission review; (3) presents material 713
factual disputes inappropriate for the advice letter process; or (4) affects public safety or the reliability of electric service. Advice Letter 287-E satisfies each of these criteria and therefore cannot be approved through the ministerial advice letter process.

A. The procurement issues raised in Advice Letter 287-E were known to Liberty and should have been addressed in the General Rate Case and other formal proceedings The procurement instability described in Advice Letter 287-E is not emergent. Liberty has been aware for years that its wholesale supply arrangement was expiring and that its procurement structure—dependent on opaque interstate transactions and an affiliate-controlled framework— posed foreseeable reliability and cost risks. These issues fall squarely within the scope of the General Rate Case, Integrated Resource Planning, and other formal proceedings where the Commission evaluates long-term procurement, cost recovery, and system reliability.

Liberty’s failure to disclose or litigate these issues in the appropriate proceedings constitutes a material omission and an attempt to circumvent the Commission’s established regulatory processes. GO 96-B does not permit a utility to withhold known procurement deficiencies from formal review and then seek expedited approval through an advice letter at the eleventh hour.

B. Liberty is attempting to evade Commission oversight by using the advice letter process to approve structural procurement changes
Advice Letter 287-E does not propose a routine tariff update or administrative correction. It seeks approval of a fundamental restructuring of Liberty’s wholesale procurement arrangements—changes that will determine the cost, reliability, and risk exposure of Liberty’s California customers for years to come.

GO 96-B expressly prohibits the use of the advice letter process for matters involving:
● significant policy questions,
● contested factual issues,
● changes that materially affect service quality or reliability, or ● issues requiring evidentiary development.
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Liberty’s filing attempts to bypass these requirements and avoid the discovery, testimony, and public scrutiny that accompany a formal application. This constitutes an improper use of the advice letter process and violates both the letter and the intent of GO 96-B.

C. Liberty has failed to provide transparent cost information, as evidenced by the shortterm agreement, the General Rate Case, and its ongoing noncompliance with a FERC denial order
Liberty’s procurement practices are already the subject of federal concern. FERC has denied Liberty’s attempts to shield its procurement arrangements from review (162 FERC 61,003 Docket No. ER17-1620-002 Issued January 18, 2018), yet Liberty continues to operate in a manner inconsistent with that order. The short-term agreement referenced in Advice Letter 287- E further demonstrates:
● a lack of cost transparency,
● absence of competitive procurement,
● no demonstration of prudence or reasonableness, and
● no evidence that the arrangement protects ratepayers.

These deficiencies are not procedural irregularities; they reflect a pattern of withholding material information from regulators and the public. Liberty’s continued noncompliance with federal directives underscores the need for a formal CPUC proceeding with full evidentiary safeguards.

D. The record indicates that Liberty’s conduct may be designed to increase costs and profits through opacity and procedural manipulation
The timing and structure of Advice Letter 287-E, combined with Liberty’s historical procurement behavior, raise serious concerns that the utility is intentionally using procedural mechanisms to:
● embed unreviewable wholesale and transmission costs into retail rates, ● avoid Commission scrutiny of affiliate transactions,
● prevent discovery into procurement alternatives, and
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● increase profits through inflated or opaque wholesale arrangements.

Such conduct is inconsistent with Liberty’s statutory obligations under Public Utilities Code §§451 and 701 to provide just, reasonable, and adequate service and to act in the public interest.

E. Advice Letter 287-E raises significant policy, safety, and factual issues that cannot be resolved through the advice letter process
Advice Letter 287-E presents issues that go far beyond the narrow, ministerial scope of General Order 96-B. The filing implicates core questions of system reliability, public safety in high-firerisk areas, interstate wholesale market exposure, and the prudence of Liberty’s procurement strategy—all of which require a formal proceeding with discovery, testimony, and transparent evidentiary development.

The record already demonstrates that:

1. Reliability risks are substantial and unresolved. Liberty acknowledges that its existing procurement structure is coming to an end in May of 2027 but frames it as a minor issue.

They provide no analysis of contingency planning, resource adequacy, or the reliability impacts on customers in Tier 2 and Tier 3 fire-threat districts.

2. Material factual disputes exist. The filing raises contested questions regarding the nature of Liberty’s wholesale arrangements, the cost impacts of the proposed replacement structure, the cost of existing and previous GRC requests, the prudence of the short-term agreement, and the extent of Liberty’s compliance with federal directives. These disputes cannot be adjudicated through an advice letter.

3. The proposal implicates statewide procurement and planning policy. Liberty’s filing touches on issues traditionally addressed in the Integrated Resource Planning process, and the California Energy Commission’s Integrated Energy Policy Report. These critical planning documents include long-term procurement strategy, transmission access, and alignment with California’s reliability and decarbonization mandates.

4. The filing affects public safety. Any procurement instability or failure to secure reliable supply directly affects communities already facing heightened wildfire risk and limited redundancy in transmission access.
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The Commission lacks a sufficient record to determine reasonableness or cost impacts. Liberty provides no transparent cost data, no alternatives analysis, and no demonstration that the proposed procurement process will facilitate a structure that is just, reasonable, or in the public interest.

Under GO 96-B, matters involving significant policy questions, material factual disputes, public safety, or changes that materially affect service quality or reliability must be reviewed through a formal application or other Commission proceeding—not through an expedited advice letter.

For these reasons, Advice Letter 287-E cannot be approved through the advice letter process and must instead be suspended and transferred to a formal proceeding where the Commission and the public can fully examine the procurement, cost, and reliability implications.

XI. Findings of Fact

1. Liberty relies heavily on interstate wholesale electricity purchases.

2. These purchases fall under federal jurisdiction (Federal Power Act).

3. Liberty has acknowledged structural procurement constraints in prior filings.

4. Electricity costs in Liberty territory have increased significantly in recent rate cases.

5. Residents face wildfire risk and infrastructure constraints unique to mountain communities and tourism demand.

XII. Conclusions of Law

1. The Commission has authority to ensure safe and reliable electric service (Pub. Util.

Code §§451, 701).

2. Advice Letter 287-E raises issues beyond the scope of the advice letter process (General Order 96-B).

3. The Commission may require Liberty Utilities to file a formal application for review.

VII. REQUEST FOR RELIEF
Advice Letter 287-E cannot be approved based on the current record.

The Commission is now on notice that:
● the procurement structure underlying Liberty’s service is temporary and unstable; ● only a limited post-FERC compliance dataset exists, and it raises rather than resolves critical questions;
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● Liberty’s wholesale activity has expanded without corresponding transparency; ● California does not model Liberty’s demand or evaluate its system conditions; ● rates have increased dramatically through stacked cost recovery mechanisms without a single integrated proceeding;
● the GRC failed to include Tahoe Spark in negotiations of settlement; ● Cal Advocates failed to review wildfire plans or consider socioeconomic impacts and refused to work with Tahoe Spark on policy issues; and
● the external system from which Liberty procures power is being rapidly reshaped by high-load data center demand, with no showing that California customers are prioritized or protected anywhere.

Accordingly, Tahoe Spark respectfully requests that the Commission:

1. Reject or suspend Advice Letter 287-E until a complete and current record is developed.

2. Open a formal proceeding to evaluate Liberty’s procurement structure, including:
o all wholesale procurement agreements and counterparties, o termination provisions and transition scenarios,
o all applicable FERC rate schedules and compliance requirements, o the allocation of wholesale costs and revenues to California retail customers, o the effect of external load growth on Liberty’s procurement costs and reliability, and
o the relationship between procurement, infrastructure investment, and retail rate recovery of a California Limited Liability Retail Company operating from afar.

3. Require Liberty to produce full disclosure of:
o all contracts with NV Energy and any other procurement counterparties, o any Wasatch or Utah-related procurement activity,
o all affiliated transactions affecting procurement or pricing, o all current cost allocation methodologies between wholesale and retail functions, and
o all wholesale revenues and how those revenues are credited, if at all, to California customers.

4. Require development of a Liberty-specific demand and system model, including:
o hourly and seasonal load profiles,
o visitor-driven and tourism-related demand,
o winter peak conditions,
o second-home and short-term rental load characteristics, and o infrastructure need based on actual system conditions rather than statewide averages or historical assumptions.

5. Require evaluation of structural alternatives, including:
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o participation or integration into California planning and procurement frameworks, including CAISO,
o enabling Community Choice Aggregation procurement and other long-term local procurement options,
o coordination with the Department of Water Resources and other state entities to secure long-term reliability, and
o long-term structural changes necessary to reduce reliance on opaque external procurement arrangements.

6. Condition or suspend further procurement-related cost recovery through advice letter processes until the Commission has a complete and verified record.

The Commission has acted before when California communities were exposed to opaque, manipulated, or unstable wholesale electricity markets. It must act again here. Advice Letter 287- E is not a routine filing. It is the point at which the Commission can no longer continue approving costs without first confronting the system that creates them.

CONCLUSION
Advice Letter 287-E does not resolve the issues before the Commission. It confirms them.

It confirms that Liberty’s procurement structure is temporary, externally dependent, and unresolved. It confirms that the Commission is operating without a complete dataset or a Liberty-specific model. It confirms that Californians served by Liberty remain exposed to cost increases and procurement risks that are not transparently formed or fully reviewed.

For these reasons, Tahoe Spark respectfully protests Advice Letter 287-E and requests that the Commission reject or suspend it and open the full proceeding necessary to protect California ratepayers.

Tahoe Spark reserves the right to submit the record developed in this proceeding to the Federal Energy Regulatory Commission for review should the issues identified in this protest remain unresolved.

CERTIFICATE OF STATEMENT
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I hereby certify that I have served a copy of the foregoing Protest of Tahoe Spark to Advice Letter 287-E on Liberty Utilities (CalPeco Electric) LLC and the California Public Utilities Commission Energy Division in accordance with the Commission’s advice letter protest. /s/Danielle Hughes
Danielle Hughes
CEO/President
Tahoe Spark
5401 Caledonia Circle
Carnelian Bay, CA 96140
530-721-1070
Date: March 26, 2026
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Attachment A
FERC Denial
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162 FERC ¶ 61,003

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION
Before Commissioners: Kevin J. McIntyre, Chairman;
Cheryl A. LaFleur, Neil Chatterjee,
Robert F. Powelson, and Richard Glick.

Liberty Utilities (CalPeco Electric) LLC Docket No. ER17-1620-002

ORDER DENYING REHEARING AND REQUEST FOR STAY
(Issued January 3, 2018)

1. In an order dated August 29, 2017,1
the Commission accepted Liberty Utilities
(CalPeco Electric) LLC’s (CalPeco’s) Filing of proposed amendments to the existing Electric Service Agreement between CalPeco and Pacific Gas and Electric Company (PG&E) setting forth the cost-based rates for identified services flowed through to or provided by CalPeco to PG&E.2
In that same order, the Commission denied CalPeco’s
request for waivers of the Commission’s accounting, reporting, and filing requirements.

On September 28, 2017, CalPeco timely filed a request for rehearing and stay of the August 29 Order. For the reasons discussed below, we deny CalPeco’s request for rehearing and stay.

Background

2. As relevant here, the charges for services under the Electric Service Agreement consist of a Customer Charge, a Demand Charge, and an Energy Charge. In its Filing, CalPeco explained that the Energy Charge and the Demand Charge, as amended, both entail a direct pass-through of power purchases made by CalPeco from Sierra Pacific 1 Liberty Utils. (CalPeco Elec.) LLC, 160 FERC ¶ 61,037 (2017) (August 29 Order).
2 CalPeco made its Filing on May 17, 2017 and, on July 6, 2017, later amended that Filing. For ease of discussion, we refer below to the original and amended Filing as “the Filing.”
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Power Company (SPPC), and the rate CalPeco pays is based on SPPC’s rates on file with the Commission in SPPC Rate Schedule FERC No. 55.

3. In addition, CalPeco charges a fixed Customer Charge associated with CalPeco’s using its own facilities to supply power to PG&E. In the Filing, CalPeco explained that this charge is based on the revenue requirement associated with those portions of CalPeco’s distribution assets used to provide service under the Electric Service Agreement.

4. CalPeco’s Filing revised the methodology used to calculate the Customer Charge to reflect CalPeco’s total revenue requirement rather than the cost to serve PG&E on a facility by facility basis. That methodology reflected changes to CalPeco’s costs and rates approved by the California Public Utility Commission (CPUC) that resulted from the CPUC permitting CalPeco to include costs from Luning Energy, LLC (Luning), a 50 megawatt solar generating facility in Nevada, in CalPeco’s overall revenue requirement, including revenue from CalPeco’s retail customers. Luning delivers its full output to CalPeco pursuant to a long-term power purchase agreement the Commission accepted by delegated letter order on January 31, 2017.3

5. In its Filing, CalPeco also requested waiver of (1) the accounting, reporting, and other requirements in Parts 41, 101, and 141 of the Commission’s regulations, except sections 141.14 and 141.15, and (2) the filing requirements of Part 35, subparts B and C of the Commission’s regulations, except for sections 35.12(a), 35.13(b), 35.14 and 35.16.

CalPeco cited the Commission’s earlier waiver of these requirements when the Commission accepted CalPeco’s initial Electric Service Agreement filing,4 and CalPeco
asserted that the same factors supporting waiver were still present here. CalPeco argued that its total jurisdictional revenues would be a small part of its primary business of serving retail customers in California, and that it would charge PG&E via a pass-through of power costs and charge for distribution charges that result in $322,414 of annual revenues.

The August 29 Order

6. The Commission, in the August 29 Order, accepted for filing the proposed amendments to the Electric Service Agreement. The Commission denied CalPeco’s request for waiver of the accounting, reporting, and other requirements in Parts 41, 3 Luning Energy LLC, Docket No. ER17-299-000 (Jan. 31, 2017) (delegated letter order).
4 See Cal. Pac. Elec. Co., 134 FERC ¶ 61,024, at P 6 (2011) (2011 CalPeco Order).
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101, and 141 of the Commission’s regulations and the filing requirements of Part 35, subparts B and C, of the Commission’s regulations.5

7. The Commission recognized that it had earlier granted CalPeco’s request for waiver of these requirements due to CalPeco’s “limited jurisdictional activities.” But the Commission found that circumstances had changed materially given, in particular, CalPeco’s purchase of the Luning facility’s output and the modified methodology used to calculate the Customer Charge to reflect CalPeco’s total revenue requirement (which now includes the costs from the Luning facility). The Commission also stated that CalPeco’s annual revenues for jurisdictional activities had increased to $322,414, which it described as “well above” the $100,000 amount the Commission noted in granting these waivers in the 2011 CalPeco Order. Given that CalPeco’s electricity sales are neither from a single facility, nor the entirety of CalPeco’s output, the Commission compared CalPeco to other entities subject to cost-based regulation whose waiver requests the Commission has denied. Citing CalPeco’s explanation that it has several agreements under which it provides wholesale energy and capacity, emergency services, and borderline services, the Commission also found that CalPeco’s jurisdictional activities are no longer limited to such an extent that waiver of the Commission’s accounting, reporting, and filing requirements is justified.6
CalPeco’s Request for Rehearing

8. CalPeco argues that no circumstance has changed to justify revoking waiver of the Commission’s accounting and reporting requirements. CalPeco asserts that it modified the methodology used to assess the Customer Charge to treat PG&E as CalPeco is treated by virtue of its purchases from SPPC. CalPeco maintains that the increased revenues from the Customer Charge are not material and do not alter CalPeco’s status as a distribution utility under the CPUC’s comprehensive jurisdiction.7 Accordingly,
CalPeco states that any additional requirements the Commission imposes “for the extremely limited wholesale activities would be unduly burdensome.”8 CalPeco asserts
that revoking waiver of the Commission’s accounting and reporting requirements runs 5 August 29 Order, 160 FERC ¶ 61,037 at PP 8-9.
6 Id. P 10.
7 Request for Rehearing at 6-7.
8 Id. at 7.
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counter to Commission precedent because CalPeco is not a generation-only affiliate selling wholesale requirements-type power to its affiliate and CalPeco is treating PG&E similarly to itself for services that include the Luning facility.9

9. CalPeco describes itself as a distribution utility whose primary purpose is serving its retail customers in California. CalPeco states that, given its service area’s “unique geographic location” at the California-Nevada border, CalPeco has five service agreements to meet its, SPPC’s, and PG&E’s needs. CalPeco describes the four agreements with SPPC as ensuring that each of SPPC’s and CalPeco’s customers are served reliably during emergencies or when facilities that can serve both entities fail.

According to CalPeco, its retail distribution-based services and “incidental wholesale service” to SPPC under the CPUC’s exclusive jurisdiction are beyond this Commission’s jurisdiction.10

10. CalPeco similarly describes the Energy Service Agreement with PG&E that CalPeco filed in this proceeding as providing “limited service to PG&E (up to 2.5 MW)” that allows PG&E, in turn, to serve remote customers in its service area (namely, a ski resort and ancillary customers).11 CalPeco represents that the CPUC approved the essential Customer Charge’s components, the Customer Charge’s formulation, and CalPeco’s proposed service to PG&E and that the CPUC reviewed all CalPeco’s cost components as a California distribution utility under the CPUC’s “comprehensive rate regulation.”12 Because CalPeco submitted to the Commission the data and information reviewed by the CPUC that support the derivation of the Customer Charge allocable to PG&E under the Energy Services Agreement, CalPeco argues that the Commission’s denying waiver will not provide any further insight into the Customer Charge’s origins.

CalPeco acknowledges that including the Luning facility in its revenue requirement will cause PG&E to pay more in the Customer Charge, but asserts that CalPeco would provide to PG&E the same benefits that CalPeco receives by virtue of including the Luning facility in its revenue requirement and that the corresponding energy and capacity components of the rate flowed through from SPPC to CalPeco to PG&E would decrease.

CalPeco describes its service agreement with SPPC that serves CalPeco’s retail 9 Id.
10 Id. at 7-8.
11 Id. at 8.
12 Id.
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customers as expressly contemplating CalPeco adding renewable resources while continuing to purchase requirements power from SPPC. CalPeco insists that this does not constitute a material change in its participation in wholesale markets that continue to be incidental to CalPeco’s distribution activities.13

11. CalPeco distinguishes this proceeding from previous instances where the Commission denied waiver of accounting and reporting requirements due to the utility’s sale to affiliates whose formula rates were subject to change. CalPeco states that its affiliate relationship with the Luning facility has not changed its status as a distribution utility serving retail customers, noting instead that the CPUC’s approval to include costs from the Luning facility in CalPeco’s revenue requirement is part of a transaction that benefits CalPeco’s retail customers and permits CalPeco to incorporate renewable energy into its purchase portfolio.14 With the exception of its emergency agreements with SPPC, limited borderline arrangements at the California-Nevada border, and its Energy Service Agreement with PG&E, CalPeco describes itself as making retail, not wholesale, sales that are subject to the CPUC’s comprehensive accounting and reporting requirements that differ somewhat from the Commission’s accounting and reporting requirements.

CalPeco asserts that, given its continued limited presence in wholesale markets, the burden on CalPeco to abide by the Commission’s uniform system of accounts and to file FERC Form 1 and audited financials would be onerous with no clear benefit to the Commission. CalPeco states that the Commission will have the opportunity to review cost-based rationales for amending CalPeco’s Commission-jurisdictional agreements if an amendment to those agreements is sought.15

12. CalPeco requests that, while its request for rehearing of the August 29 Order is pending, the Commission stay the effectiveness of the Commission’s accounting and reporting requirements. CalPeco argues that no other party will be harmed by a stay and, without a stay, it will suffer irreparable injury, namely starting the difficult process of adopting the uniform system of accounts, incorporating information to report in the Commission’s required format, and hiring additional employees. CalPeco states that a stay is in the public interest because the Commission erred in revoking a waiver that had been in effect for seven years.16
13 Id. at 8-9.
14 Id. at 8-11.
15 Id. at 10-12.
16 Id. at 12-13.
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Commission Determination

13. For the reasons discussed below, we deny CalPeco’s request for rehearing and stay of the August 29 Order.

14. As the Commission recognized in the August 29 Order, on a prior occasion the Commission had granted CalPeco’s request for a waiver of its accounting, reporting, and filing requirements due to CalPeco charging PG&E a pass-through of power costs CalPeco incurred and a charge for distribution service that resulted in less than $100,000 of annual revenues.17 Contrary to CalPeco’s contention, however, circumstances have changed since the Commission granted that waiver: unlike in 2011, when CalPeco incorporated only its distribution assets in its revenue requirement,18 CalPeco now purchases the Luning facility’s output and incorporates the costs from that output into the revenue requirement for the Customer Charge in the Energy Services Agreement, thereby tripling CalPeco’s jurisdictional annual revenues to more than $322,414. Given the magnitude of this change in jurisdictional revenues, CalPeco’s representation that this change in revenues reduces other aspects of the rate PG&E pays19 is immaterial to whether circumstances have changed to warrant denying waiver of the Commission’s accounting and reporting requirements.

15. While CalPeco characterizes itself as a “distribution utility which has a primary purpose of serving its retail customers in California,”20 CalPeco concedes that it has several jurisdictional agreements on file with the Commission, including the Energy 17 August 29 Order, 160 FERC ¶ 61,037 at P 10 (citing 2011 CalPeco Order, 134 FERC ¶ 61,024 at P 6).
18 2011 CalPeco Order, 134 FERC ¶ 61,024 at P 3 (“the only component of the rate to PG&E that is not a pass-through from [SPPC] is a fixed charge designed to recover costs associated with CalPeco’s use of its own distribution facilities to supply power to PG&E.”).
19 See Request for Rehearing at 9 (“while PG&E would pay more in the Customer Charge, CalPeco would provide to PG&E the same benefits that it receives by virtue of including the Luning facility in its revenue requirements and the corresponding reductions in the energy and capacity component of the rate flowed through from [SPPC] to CalPeco to PG&E”).
20 Id. at 7.
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Services Agreement.21 Through that agreement in particular, CalPeco engages more directly in Commission-jurisdictional activities than it did before: CalPeco now recovers costs from power that is transmitted in interstate commerce from the Luning facility in Nevada to CalPeco’s system in California and sold later for resale to PG&E.22 Contrary to CalPeco’s assertions,23 the amendments to the Energy Services Agreement in this proceeding therefore constitute a material change to CalPeco’s participation in the wholesale markets, regardless of the ratio of its wholesale activities to its distribution activities.

16. Given CalPeco’s multiple Commission-jurisdictional activities described above, and in contrast to CalPeco’s assertions,24 this proceeding is therefore not similar to Dominion Retail, which CalPeco cites in support of its arguments. In Dominion Retail, the Commission granted waiver of accounting, reporting, and filing requirements to an entity whose principal business was selling natural gas and electricity at retail and sold “limited quantities of excess energy and capacity at wholesale” at its “actual purchased power costs to its wholesale customers.”25 Here, while CalPeco describes its primary business as “that of a distribution utility serving retail customers,”26 CalPeco also admittedly has several agreements under which it provides more than just excess energy and capacity at wholesale power purchase costs.27 CalPeco in its rehearing request also 21 See id. at 2-6 (describing CalPeco’s Commission-jurisdictional agreements); August 29 Order, 160 FERC ¶ 61,037 at P 10 (“CalPeco readily explains that it has several agreements under which it provides wholesale energy, capacity, emergency services, and borderline services.”).
22 See Request for Rehearing at 8-9 (describing Energy Services Agreement with PG&E).
23 Id. at 9 (“This does not evidence a material change to CalPeco’s participation in the wholesale markets, which remains incidental to its distribution activities.”). 24 See Request for Rehearing at 10 (citing Dominion Retail, Inc., 104 FERC ¶ 61,091 (2003) (Dominion Retail)).
25 Dominion Retail, 104 FERC ¶ 61,091 at P 7.
26 Request for Rehearing at 10.
27 See Request for Rehearing at 11 (stating “CalPeco is not engaged in wholesale sales of energy and capacity except pursuant to the emergency arrangements, the limited borderline arrangements at the California and Nevada border and pursuant to the limited sales to PG&E so that PG&E can serve the ski resort and ancillary customers in an area remote to PG&E’s service area.” (emphasis added)); August 29 Order, (continued ...)
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ignores the Commission’s description of the differences between CalPeco’s waiver request and an earlier instance where the Commission granted waiver to an entity subject to cost-based regulation.28

17. We reject CalPeco’s attempt to distinguish this proceeding from Ameren and PSEG Fossil.
29 In Ameren, the Commission denied an exempt wholesale generator’s request for waiver of the Commission’s accounting, reporting, and filing requirements because the applicant’s cost-of service sales were not from a single facility, were not to a single customer for a single long-term transaction, and did not constitute all of the applicant’s capacity.30 Here, CalPeco’s cost-of-service sales for resale that are incorporated into its revenue requirement come both from multiple facilities throughout its distribution system and from facilities across state lines in which it has an ownership stake (i.e., the Luning facility). The 2.5 MW of power CalPeco sells to PG&E also does not represent all of CalPeco’s capacity, and CalPeco admittedly sells to more than one customer: retail customers, PG&E, and SPPC.31

18. In PSEG Fossil, the Commission acknowledged that the public utilities seeking waiver sold to an affiliate under a formula rate contract whose costs were subject to change based on the PJM Interconnection, L.L.C. locational marginal price.

The Commission, however, denied waiver of its accounting, reporting, and filing requirements in part because it found that affiliate was “entitled to consider whether costs underlying its cost-based contract no longer support the price.”32 Here, the inclusion of the Luning facility in CalPeco’s overall revenue requirement may also be relevant to all of its customers, not only to PG&E, in evaluating whether the costs of 160 FERC ¶ 61,037 at P 10 (describing CalPeco’s sales of wholesale energy and capacity, emergency services, and borderline services). 28 See August 29 Order, 160 FERC ¶ 61,037 at P 10 (citing Alloy Power, L.L.C., 117 FERC ¶ 61,167 (2006)).
29 Request for Rehearing at 9-10 & n.12 (citing Ameren Energy Generating Co., 93 FERC ¶ 61,024 (2000), reh’g denied, 95 FERC ¶ 61,009 (2001) (Ameren); PSEG Fossil, LLC, 97 FERC ¶ 61,211 (2001), reh’g denied, 98 FERC ¶ 61,169 (2002) (PSEG Fossil)).
30 Ameren, 93 FERC ¶ 61,024 at 61,046.
31 See Request for Rehearing at 8, 11 (noting that the Energy Services Agreement provides PG&E up to 2.5 MW of power and CalPeco itself has 49,000 customers and an average load of approximately 80 MW).
32 PSEG Fossil, 98 FERC ¶ 61,169 at 61,624.
729
Docket No. ER17-1620-002 - 9 -
including this facility in CalPeco’s revenue requirement are just and reasonable.

19. In discussing the Federal Power Act’s accounting requirements in relation to state accounting requirements, the U.S. Court of Appeals for the District of Columbia Circuit has stated that “[t]he Federal Power Commission’s authority over accounts of its licensees covers basic accounts and does not end where State authority begins.”33 CalPeco describes the Commission’s accounting and reporting requirements as both “largely duplicative” of and “similar to” but “not quite the same as those used by the CPUC.”34 We recognize that the Commission’s and the CPUC’s accounting and reporting requirements might, to a certain extent, differ from each other. But beyond mentioning FERC Form 1 and audited financials, CalPeco has explained neither what these differences are nor their significance. And CalPeco has not specified how abiding by the Commission’s accounting and reporting requirements, as well as the CPUC’s accounting requirements, would be unduly burdensome. In fact, nationwide, utilities with both retail and wholesale customers have routinely long been subject to both this Commission’s accounting and reporting requirements as well as any separate state requirements; CalPeco is being treated no differently, in this regard.35 We agree with CalPeco that it would have to make “substantive regulatory filings” to document its Commission-jurisdictional cost-based transactions without waiver of the Commission’s accounting, reporting, and filing requirements. But since the Commission last granted 33 Ark. Power & Light Co. v. FPC, 185 F.2d 751, 752-53 (D.C. Cir. 1950); see also Appalachian Power Co. v. FPC, 328 F.2d 237, 248 (4th Cir. 1964) (“In numerous cases it has been held that the Commission’s accounting is not subordinated if it comes into conflict with state regulatory requirements.”); Louisville Gas & Elec. Co. v. FPC, 129 F.2d 126, 133 (6th Cir. 1942) (“[T]he provision that nothing in the Act should relieve a public utility from keeping such accounts as are required by the laws of the state, impliedly, if not expressly, discloses a purpose that the Commission shall prescribe such accounting system, notwithstanding that the state has required a like or a different system of accounts.”); Metro Edison Co., 11 FERC ¶ 61,027, at 61,042 (1980) (“we view it as our responsibility under Section 301 of the Federal Power Act to administer and enforce a uniform accounting system, not subject to variations resulting from rate-making determinations of state commissions.”). 34 Request for Rehearing at 11.
35 See supra note 33; cf. JAMES E. SUELFLOW, PUBLIC UTILITY ACCOUNTING:

THEORY AND APPLICATION 41 (1973) (“One cannot ignore the fact that state and federal commission accounting requirements may differ. In this regard, the Federal Power Commission’s decision in the Appalachian Power case clearly stated what when such conflicts occur the FPC requirements take precedence.” (citing Appalachian Power Co., 28 FPC 1199 (1962), reh’g denied, 29 FPC 383 (1963), appeal dismissed sub nom.

Appalachian Power Co. v. FPC, 328 F.2d 237 (4th Cir. 1964)). 730
Docket No. ER17-1620-002 - 10 -
waiver of these requirements, as described above, CalPeco’s Commission-jurisdictional activities have developed a more apparent interstate character and have more than tripled in amount. Subjecting the cost-based rationale of these activities to Commission requirements and customer scrutiny only when CalPeco’s Commission-jurisdictional agreements are amended, as CalPeco proposes,36 would become more burdensome to the Commission.

20. Because we reject CalPeco’s request for rehearing, we deny as moot CalPeco’s request for stay of the August 29 Order pending rehearing.

The Commission orders:

CalPeco’s request for rehearing and stay is hereby denied, as discussed in the body of this order.

By the Commission.
( S E A L )
Nathaniel J. Davis, Sr.,
Deputy Secretary.
36 Request for Rehearing at 12.
731
Attachment B
Compliance Report
732
1 MEMORANDUM
Liberty Utilities (CalPeco Electric) LLC - FERC Compliance Review: Filing History, Reported Transactions, and Key Findings
Executive Summary
This memo summarizes Liberty Utilities (CalPeco Electric) LLC's compliance with FERC's 2017 order revoking its reporting waivers. Based on a review of primary source FERC filings — including raw DBF database records (2017–2021) and XBRL submissions (2024 annual and Q2 2025 quarterly) - CalPeco has complied fully with all mandatory filing requirements. The PG&E wholesale transaction that triggered the original proceeding is reported correctly and in detail in every filing reviewed. A second wholesale counterparty, NV Energy, has also emerged in recent filings. Total wholesale revenues have grown from the original ~$322,000 baseline to approximately $1.81 million in 2024, reflecting the amended rate methodology incorporating Luning Energy costs.

1. Background: The FERC Order and What It Required
CalPeco is an electric distribution utility serving approximately 49,000 retail customers near South Lake Tahoe, California. Its primary federally-regulated activity is selling a modest amount of electricity to Pacific Gas and Electric Company (PG&E) under Rate Schedule No. 5, to serve a ski resort near the California– Nevada border (Heavenly, I think). Since 2011, CalPeco had held a FERC waiver exempting it from standard accounting and reporting requirements because its FERC-jurisdictional revenues were below $100,000 per year.¹
In 2017, CalPeco filed to amend Rate Schedule No. 5 to incorporate costs from the Luning Energy LLC solar facility (a 50 MW Nevada project in which CalPeco holds an indirect interest) into the rate charged to PG&E. FERC accepted the rate amendment but simultaneously revoked CalPeco's longstanding reporting waivers, finding that revenues had tripled to $322,414, the transaction's interstate character had expanded, and CalPeco now operated under five separate FERC-jurisdictional agreements. CalPeco sought rehearing and a stay; both were denied on January 3, 2018.² As of that date, CalPeco became subject to the following ongoing obligations:

Requirement Deadline Purpose
FERC Form 1 (Annual Report) April 18 each year Comprehensive financial and operating report; revenues, expenses, plant,
purchased power, sales by
counterparty.
733
2 FERC Form 3-Q (Quarterly) 60 days after quarter-end Quarterly financial supplement to Form

1. CPA Certification 30 days after Form 1 Independent accountant certifies books conform to FERC's Uniform System of
Accounts.

Uniform System of Accounts (18 CFR
Part 101)
Ongoing Internal accounting restructured to
FERC's prescribed chart of accounts.

2. Filing Compliance: Has CalPeco Filed as Required?
Yes. A review of FERC's raw Form 1 DBF database for respondent ID 522 (CalPeco's true internal FERC identifier) confirms an unbroken filing record from 2017 through 2021.³ XBRL filings confirm continued compliance through at least Q2 2025.

2.1 Filing Log (2017–2021, from Raw DBF)
Source: F1_S0_FILING_LOG.DBF, respondent_id = 522. F1_88.DBF confirms entity name 'Liberty Utilities (CalPeco Electric) LLC', address 933 Eloise Ave., South Lake Tahoe, CA.

Year Period(s) Filed Filing Contact Notes
2017 Annual (Period 12) Julie Hammeras First mandatory filing under FERC order.
2018 Q1, Q2, Q3, Q4 Julie Hammeras First full year of quarterly reporting.
2019 Q1, Q2, Q3, Q4 Hammeras / Maya Contact transitioned to Alysia Maya mid-year.
2020 Q1, Q2, Q3, Q4 Alysia Maya All four quarters filed. 2021 Annual (Sep 27, 2021) Alysia Maya Attested by Gregory S.

Sorensen, President – West
Region.
13 consecutive filings across 5 reporting years. No gaps, no missed quarters. 734
3 2.2 XBRL Era Filings (2024–2025)
FERC transitioned to mandatory XBRL filing starting with reporting year 2021. CalPeco's XBRL filings are submitted under CID C000945. Note: CID C000746 (which appears in some databases including PUDL and FERC's eCollection search) is a known migration error that maps to Ameren Illinois Company, not CalPeco. The correct identifier is C000945 as confirmed by the entity name field in the XBRL filing headers.⁴
Filing Period Source File
Form 1 Annual Year ending Dec 31, 2024 wk-20241231.xml
Form 3-Q Electric Q2 2025 (Jan–Jun 2025) 272735-C000945-Form_3Q_Electric2025-Q2.xbrl

3. What Has Been Reported: Wholesale Sales Detail

3.1 Schedule 310: Sales for Resale — 2024 Annual Filing Schedule 310 requires utilities to report each wholesale electricity sale at the counterparty level, including buyer name, volumes, and revenue breakdown. Source: wk-20241231.xml, contexts c-281 (PG&E) and c282 (NV Energy).⁵ Counterparty 1: Pacific Gas and Electric Company (Rate Schedule No. 5) Field Reported Value — Full Year 2024
Buyer Name Pacific Gas and Electric
Statistical Classification RQ — Requirements Service
Average Monthly Billing Demand 1,099 MW
MWh Sold 4,723 MWh
Demand Charges $190,324
Energy Charges $229,385
Other Charges (Luning cost pass-through) $322,416
Total Revenue from PG&E $742,125
735
4 Counterparty 2: NV Energy:

Field Reported Value — Full Year 2024
Buyer Name NV Energy
Statistical Classification RQ — Requirements Service
Other Charges Revenue $1,071,167
Total Revenue from NV Energy $1,071,167
Key Insight — NV Energy: The NV Energy relationship was not part of the original 2017 FERC proceeding, which focused exclusively on the PG&E transaction. NV Energy (Sierra Pacific Power) is CalPeco's primary power supplier — it sells to CalPeco. The emergence of NV Energy as a buyer from CalPeco in Schedule 310 suggests a reciprocal border-service arrangement, possibly capacity, emergency power, or interconnection services flowing back the other way. The $1.07M is reported entirely as 'Other Charges,' with no MWh volume or demand charge breakdown, consistent with a fixed-fee arrangement rather than energy sales.⁶

3.2 Schedule 300: Electric Operating Revenues — Full Picture Source: wk-20241231.xml. Full year 2024 vs. prior year 2023 comparison.⁷ Revenue Category 2024 2023
Residential Sales $79,086,660 $61,255,021
Total Retail Sales to Customers $157,418,634 $117,565,848 Sales for Resale — Acct 447
(PG&E $742,125 + NV Energy
$1,071,167)
$1,813,292 $1,798,588
Purchased Power (expense) $40,745,347 $42,612,530
Electric Plant in Service $776,048,705 —
Retained Earnings $238,319,556 —
736
5 3.3 Q2 2025 Quarterly Filing
Source: 272735-C000945-Form_3Q_Electric-2025-Q2.xbrl. Period: Jan 1 – Jun 30, 2025.⁸ Metric H1 2025 (Jan–Jun)
Residential Sales $40,484,114
Total Retail Sales $79,136,909
Sales for Resale — Acct 447 $950,224 (annualized: ~$1.9M) Purchased Power $20,792,093
Electric Plant in Service (Jun 30) $806,567,776

4. Growth in Wholesale Revenues Over Time
The table below traces the Sales for Resale line (Account 447) across all verified periods. All figures are year-to-date or annual as noted. Sources: FERC Order ER17-1620; DBF F1_25.DBF respondent 522; wk20241231.xml; 272735-C000945-Form_3Q_Electric-2025-Q2.xbrl.⁹ Period Sales for Resale Source Notes
2017 baseline ~$322,414 FERC Order ER17-1620 Pre-amendment figure; triggered waiver revocation.

Q1 2021 (Jan–Mar) $447,654 DBF F1_25 (resp. 522) 2,059 MWh. Luning costs embedded.

H1 2021 (Jan–Jun) $845,780 DBF F1_25 (resp. 522) 2,922 MWh cumulative.

Annualizes ~$1.7M.

Full Year 2023 $1,798,588 Form 1 2024 (prior yr) Combined PG&E and NV Energy.

Full Year 2024 $1,813,292 wk-20241231.xml PG&E: $742,125 (4,723 MWh). NV Energy:
$1,071,167.

H1 2025 (Jan–Jun) $950,224 Form 3-Q Q2 2025 XBRL Annualizes ~$1.9M. 737
6 Growth vs baseline ~5.9x $322,414 → ~$1.9M Driven by Luning passthrough + NV Energy arrangement.

5. Key Findings and Analysis

5.1 Full Compliance Confirmed
CalPeco has filed every required annual and quarterly report since the FERC order took effect. The filing log is unbroken across 13 documented periods (2017–2021), and XBRL submissions confirm ongoing compliance through Q2 2025. There is no evidence of missed filings, late resubmissions, or attempts to circumvent reporting obligations.

5.2 PG&E Transaction Correctly Reported
The wholesale sale to PG&E under Rate Schedule No. 5 is reported in every period examined, on the correct accounting line (Account 447, Sales for Resale), with volumes consistent with the original contract parameters (~4,900 MWh per year). In 2024, CalPeco reported 4,723 MWh sold to PG&E at a total revenue of $742,125, broken down across demand ($190,324), energy ($229,385), and other charges ($322,416 — the Luning cost pass-through). Revenue is higher than the original $322,414 baseline, which is expected given the amended rate methodology.

5.3 NV Energy as a Buyer — New Finding
A significant finding not anticipated by the 2017 FERC proceeding is the appearance of NV Energy (Sierra Pacific Power) as a wholesale buyer from CalPeco. In the 2024 annual filing, NV Energy is listed as a Schedule 310 counterparty with $1,071,167 in revenues — representing 59% of CalPeco's total wholesale revenues that year. The entire NV Energy amount is classified as 'Other Charges' with no MWh or demand charge breakdown, suggesting a fixed-fee capacity, interconnection, or border-service arrangement. This warrants further review to confirm it is covered by an appropriate FERC rate schedule.

5.4 Revenue Growth and Utility Scale
Total Sales for Resale have grown ~5.9x from the 2017 baseline. MWh volumes sold to PG&E remain stable (~4,700–4,900 MWh/year), indicating revenue growth is rate-driven rather than volume-driven.

CalPeco is also a growing utility: electric plant in service grew from $776M (Dec 2024) to $807M (Jun 2025) in six months, and total retail revenues grew 34% year-over-year ($117.6M in 2023 to $157.4M in 2024).

The compliance burden CalPeco argued was disproportionate in 2017 is proportionally smaller relative to its current scale.
738
7 6. Remaining Gaps and Recommended Next Steps
Open Item Why It Matters Where to Look
NV Energy rate schedule authority $1.07M buyer relationship not in original FERC proceeding. Needs a
FERC rate schedule on file.

FERC eLibrary: search CalPeco rate
schedules. FERC eTariff for filed rate.

CPA certification letters Required within 30 days of each annual Form 1. Not reviewed.

FERC eLibrary, name: Liberty Utilities
CalPeco, doc type: CPA Certification.
2022 and 2023 XBRL filings Gap years not directly pulled in this review.

FERC eCollection: search CID C000945
for all Form 1 and 3-Q submissions.

Internal accounting conformance FERC required books restructured to Uniform System of Accounts. Cannot
verify externally.

Requires direct review of CalPeco's
internal accounting records.

EQR counterparty verification FERC EQR data corroborates activity; transaction-level detail needs bulk
download.
eqrreporting.ferc.gov: filter by seller
name Liberty Utilities CalPeco.

7. Data Sources and Methodology
• FERC Legal Orders — Docket ER17-1620: Orders of Aug 29, 2017 (¹) and Jan 3, 2018 (²), and CalPeco's rehearing request (Accession 20170928-5067). Available on FERC eLibrary. • FERC Form 1 Raw DBF Archive (2021) (³): f1_2021.zip from FERC's Zenodo archive. Tables F1_88 (respondent registry), F1_25 (Schedule 300 revenues), and F1_S0_FILING_LOG (filing history) queried via custom Python code parsing Visual FoxPro binary format. CalPeco = respondent_id 522. • FERC Form 1 Annual XBRL 2024 (⁵⁶⁷): wk-20241231.xml, CID C000945. Full year ended Dec 31, 2024. Schedule 300 aggregate revenues and Schedule 310 counterparty detail (PG&E and NV Energy) confirmed.
• FERC Form 3-Q XBRL Q2 2025 (⁸): 272735-C000945-Form_3Q_Electric-2025-Q2.xbrl, CID C000945.

Period Jan 1 – Jun 30, 2025. Most recent filing on record. • PUDL Database (⁴): Attempted use of core_ferc1__yearly_operating_revenues_sched300.parquet.

Found to map utility_id 222 / C000746 to Ameren Illinois — a known data quality error. All PUDLderived figures discarded; raw FERC sources used exclusively. 739
8 FOOTNOTES AND DATA CITATIONS
¹ FERC Order (160 FERC ¶ 61,037), Aug 29, 2017, Docket ER17-1620-001. FERC eLibrary. ² FERC Order Denying Rehearing (162 FERC ¶ 61,003), Jan 3, 2018, Docket ER17-1620-002, Accession 20180103-3053. ³ F1_S0_FILING_LOG.DBF, respondent_id=522: filings Year=2017 Per=12; Year=2018-2020 Per=3,6,9,12; Year=2021 Per=12 (filed 20210927). F1_88.DBF: RESPONDEN2='Liberty Utilities (CalPeco Electric) LLC'; ADDR='933 Eloise Ave., South Lake Tahoe, CA 96150'; CNTC_NAME='Alysia Maya'; ATTESTATIO='Gregory S. Sorensen'. ⁴ PUDL maps utility_id_ferc1=222 / utility_id_ferc1_xbrl=C000746 to 'Ameren Illinois Company'. CalPeco's true DBF respondent_id=522 and XBRL CID=C000945, confirmed by F1_88.DBF and XBRL filing headers. ⁵ wk-20241231.xml, Sched 310, context c-281: NameOfCompany='Pacific Gas and Electric'; StatClass='RQ'; MwhSold=4,723; DemandCharges=$190,324; EnergyCharges=$229,385; OtherCharges=$322,416; TotalRevenue=$742,125. ⁶ wk-20241231.xml, Sched 310, context c-282: NameOfCompany='NV Energy'; StatClass='RQ'; OtherCharges=$1,071,167; TotalRevenue=$1,071,167.
⁷ wk-20241231.xml, Sched 300: ResidentialSales(2024)=$79,086,660; TotalRetail=$157,418,634; SalesForResale=$1,813,292; PriorYear(2023)=$1,798,588; PurchasedPower=$40,745,347; PlantInService=$776,048,705; RetainedEarnings=$238,319,556. ⁸ 272735-C000945-Form_3Q_Electric-2025-Q2.xbrl: SalesForResale(H1 2025)=$950,224; ResidentialSales=$40,484,114; TotalRetail=$79,136,909; PurchasedPower=$20,792,093; PlantInService(Jun 30)=$806,567,776. ⁹ DBF F1_25.DBF resp.522 ROW_NUMBER=11 (Acct 447): REPORT_PRD=3: $447,654/2,059 MWh; REPORT_PRD=6: $845,780/2,922 MWh. Form 1 2024 prior-year column: 2023=$1,798,588.
740
Small Business Utility Advocates
548 Market St., Suite 11200
San Francisco, CA 94104
T: 415.602.6223; F: 415.789.4556
March 26, 2026
Energy Division, Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102
[email protected]
Small Business Utility Advocates’ Protest of Liberty Utilities (CalPeco Electric) LLC (U933 E) – Request for Expedited Approval of its Request for Proposals for Short-Term Energy Supply and Management Services for Electric Supply Following Expiration of Existing Full Services Agreement with NV Energy, Inc.

Dear Energy Division:

Small Business Utility Advocates (SBUA) submits this letter in protest of the above referenced Tier 3 Advice Letter 287 of Liberty Utilities (CalPeco Electric) LLC (Liberty). SBUA represents the interests of small commercial customers in the Liberty territory. As reported in its most recent GRC, Liberty serves 5,490 small commercial customers. Liberty already is imposing rate increases on small commercial customers of approximately 31% in its most recent GRC approved in D.26- 03-017 and also seeking an additional 12.2% near-term increase in Mountain View Fire cost recovery application (A.25-06-017). SBUA is concerned that Liberty’s urgent need to obtain an alternative source for the overwhelming majority of its customers’ electricity needs puts it at a serious competitive disadvantage and poses a high risk that customers will be subject to extreme and unreasonable rate increases.

Background
Liberty’s Advice Letter seeks approval to solicit for a full-requirements contract to provide approximately 85MW of capacity each year. Upon learning of Liberty’s Advice Letter, SBUA initiated discovery with Liberty to understand the context of Liberty’s need to deviate from its approved Integrated Resource Plan. A public version of Liberty’s response is attached as Exhibit 741
2 A. The Advice Letter describes NV Energy’s decision to discontinue full-requirement services as a “change of stance by NV Energy” and “a surprise” to Liberty. The available information indicates that Liberty should not have been surprised by this development.

Liberty was formed when NV Energy’s parent company sold its assets in California.1 This was finalized in 2011. Since that time, Liberty has functioned as a wholesale customer of NV Energy.

This allowed NV Energy to eliminate its liabilities and risks while still selling the same amount of power. NV Energy claims that Liberty always understood that purchasing power from NV Energy could not be permanent:

From the beginning, it has been understood that Liberty Utilities would eventually secure its own transmission access and energy supply so it could serve customers independently.

Liberty’s 2018 request for transmission service signaled that it was taking the steps necessary to arrange for and deliver energy to its customers, and NV Energy’s planning has consistently reflected that expectation.2
Liberty in the past was caught by surprise by NV Energy’s lack of sufficient resources but was able to negotiate an extension for 2022 Liberty IRP.
3 Liberty’s continual extension of its existing
full-requirements contract with NV Energy indicates that long-term supply has been uncertain.

Liberty informed SBUA that it has been monitoring NV Energy’s public reporting to the Nevada Public Utilities Commission, including NV Energy’s most recent three-year integrated resource plan, filed May 2024, in which is stated an intent to discontinue service to Liberty in 2025.4 Volume 6 of the filing also showed very large data center growth and retail growth overall 1 See https://www.sec.gov/Archives/edgar/data/90144/000074150811000006/exhibit99-1.htm; see also D.10-10-017 (approving transfer of control).
2 https://www.carsonnow.org/03/23/2026/nv-energy-to-lake-tahoe-find-electricity-elsewhere; See also https://www.tahoedailytribune.com/news/liberty-utilities-to-find-a-new-energy-supplier-with-a-2027- deadline/ (accord).
3 Liberty 2022 IRP at 2-3 (Nov. 11, 2022), available at https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M498/K071/498071350.PDF. 4 https://www.nvenergy.com/publish/content/dam/nvenergy/brochures_arch/about-nvenergy/ratesregulatory/recent-regulatory-filings/irp/IRP-Volume-4.pdf; https://www.nvenergy.com/aboutnvenergy/rates-regulatory/recent-regulatory-filings. 742
3 that would put Liberty on notice of NV Energy’s interest in discontinuing wholesale supply to Liberty.5 Liberty had an obvious responsibility to closely evaluate the reliability of its primary source of power.

Liberty claims it first became aware that NV Energy would discontinue full-requirements service on November 26, 2025. However, Liberty should have sought clear assurances at many points over the past years and knew or should have known the high probability of discontinuation much earlier. Liberty filed its general rate case in September 2024 and should have included consideration of this issue in the scope of that proceeding to enable transparent and public input on the investments that Liberty would need to undertake to maintain reliable service.

Previously, the Commission found approvingly that “NV Energy is obligated to supply energy to Liberty Utilities at 38 delivery points, as needed, to provide reliable electric service.” 6 It
is unclear whether another provider can meet a similar level of delivery via the Greenlink-West connection or if that provider can have the reserve capacity shown by NV Energy’s portfolio of generation assets. While the Commission has not established a resource adequacy requirement for Liberty, it has in the past looked to Public Utilities Code section 380(c), which requires covered entities to “maintain physical generating capacity adequate to meet its load requirements,” as necessary to provide reliable service.7 The Commission should seek to move Liberty closer to compliance with this standard.

SBUA’s Recommendation
While SBUA does not believe that Liberty demonstrated prudence in preparing for the eventuality that NV Energy would decline to extend the existing full-requirements agreement, 5 https://www.nvenergy.com/publish/content/dam/nvenergy/brochures_arch/about-nvenergy/ratesregulatory/recent-regulatory-filings/irp/IRP-Volume-6.pdf. 6 D.15-12-021 at 17-18
7 See D.15-12-021 at 17 (approving Liberty PPA with NV Energy). 743
4 SBUA also sees that Liberty has presented the Commission with no alternative but to allow Liberty to seek an alternative means of meeting its obligations to customers. Liberty functioning as a wholesale customer of a single supplier results in intrinsic long-term risk, problematic pricing opacity and a weak negotiating position in the event of service termination.

SBUA requests that the Commission require Liberty to explain (a) what steps it took to prepare for this eventuality and (b) steps it will take to obtain a secure and reasonably-diversified power portfolio. SBUA does not concur with Liberty that hearings are not needed. SBUA recommends that the Commission require these responses in writing and also hold workshops and hearings concerning this fundamental change to Liberty’s business model. Longer-term options include Liberty constructing a power connection over the Sierras to the California CAISO grid, subsidizing customer-sited distributed energy resources such as behind the meter solar and battery systems that can be used as virtual power plants and reduce peak demand and developing its own largescale renewal power production facilities.

SBUA recognizes that these discussions can have implications for confidentiality that Liberty has an interest in maintaining to avoid further deterioration of its negotiating position.

Nevertheless, SBUA believes there is a strong public interest in understanding the process that led to this crisis and ensuing that Liberty is taking reasonable steps to avoid being fully beholden to a single power supplier.

Respectfully submitted,
Cc: Dan Marsh, Liberty Utilities ([email protected]) Service lists for Liberty General Order 96-B (e-mail only) __________________________
Ariel Strauss, Regulatory Counsel
Small Business Utility Advocates
548 Market St., Suite 11200
San Francisco, CA 94104
(310) 709-1213
[email protected]
744

ATTACHMENT A
745
Liberty Utilities (CalPeco Electric) LLC
933 Eloise Avenue
South Lake Tahoe, CA 96150
Tel: 800-782-2506
Fax: 530-544-4811
March 24, 2026

DATA REQUEST RESPONSE

LIBERTY UTILITIES (CALPECO ELECTRIC) LLC
Advice Letter 287-E
Data Request No.: SBUA-Liberty DR re AL 287
Requesting Party: Small Business Utility Advocates
Originator: Ariel Strauss, [email protected]
cc: James Birkelund, [email protected]
Date Received: March 10, 2026
Due Date: March 24, 2026
Attachments to these responses contain information marked confidential in accordance with applicable law and regulation. Confidential information is being provided pursuant to the NonDisclosure Agreement executed by SBUA on March 26, 2026. Public disclosure is restricted.

REQUEST NO. 1:

In the AL 287 dated March 6, 2026, (p.1), Liberty reports: “During the negotiations for a longerterm extension of the full-services ESA, NV Energy informed Liberty that it could no longer provide full-requirements services, and that Liberty must arrange for its own supply in 2027.” a) When was the full-services ESA between Liberty and NV energy set to expire in the absence of a negotiated extension?
b) Liberty filed AL 279-E on December 4, 2025, which included the executed Third Amended and Restated Service Agreement, dated October __, 2025. Is this the Energy Services Agreement (“ESA”) referred to in the AL 287? c) Liberty’s Re-Filing of Related 2020 Integrated Resource Plan Information, filed October 15, 2021, reports that Liberty entered into a 2021 NV Energy ESA for a fiveyear term, during which Liberty would remain a wholesale customer of NV Energy. 746
Liberty Utilities (CalPeco Electric) LLC
933 Eloise Avenue
South Lake Tahoe, CA 96150
Tel: 800-782-2506
Fax: 530-544-4811
(i) Is the 2021 NV Energy ESA the agreement that Liberty extended with the Third Amended and Restated Service Agreement? (ii) When did Liberty initiate negotiations of a long-term extension of the 2021 NV Energy ESA? 747
Liberty CalPeco Electric
Data Request No. SBUA-Liberty DR re AL 287
March 24, 2026

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South Lake Tahoe City CouncilApril 21, 2026

South Lake Tahoe City Council
April 21, 2026