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HomeMy WebLinkAboutCity of San Luis Obispo Comment Opposing Charges On 3CE Customer Bills - Application 25-05-011City of San Luis Obispo, Office of the City Council, 990 Palm Street, San Luis Obispo, CA, 93401-3249, 805.781.7114, slocity.org December 12, 2025 President Alice Reynolds California Public Utilities Commission Public Advisor 505 Van Ness Avenue San Francisco, CA 94102 RE: Request for the CPUC to Reconsider its Decision Requiring Double- payment From Customers to Prevent Unfair Charges On 3CE Customer Bills - Application 25-05-011. Dear President Reynolds and Commissioners: I write on behalf of the City of San Luis Obispo to express strong concern with the proposed change to the Power Charge Indifference Adjustment (PCIA) that would significantly increase electricity bills for local families, seniors, and small businesses served by Central Coast Community Energy (3CE). At a time when energy affordability is one of the top concerns we hear from our community, the Commission is considering a methodology that would create unjust cost shifts among customers statewide. Some households could see annual bills increase by more than $500, driven by a more than 350% increase in the PCIA. When our community was bundled with PG&E, customers paid for renewable energy through their monthly bills, including Renewable Energy Credits (RECs) that verify energy from solar, wind, and other renewable sources. PG&E retained and banked those RECs, which have significant financial value. PG&E now proposes to use those previously purchased RECs to meet its 2026 renewable energy requirements, while assigning the associated costs to customers who already paid for them years ago but have since exercised their choice to leave PG&E’s generation service. Under the proposed decision, those customers would effectively pay again through higher monthly charges. The California Community Choice Association estimates this billing methodology could cost community choice customers more than $1 billion statewide. For households in San Luis Obispo, this represents a meaningful increase on monthly electric bills for energy they have already paid for. Right now, many families in our community are making difficult choices about basic necessities. Small businesses and agricultural operations are facing rising costs across the board. The last thing they need is an unfair charge tied to past purchases. The solution is straightforward: the Commission should not change longstanding rules that credit customers for what they paid for in the year those costs were incurred. If San Luis Obispo customers paid for renewable energy credits in 2015, they should retain that benefit rather than see it reassigned to different customers in 2026. This “vintage-year allocation” approach reflects how the Commission has handled similar situations in the past and aligns costs with benefits. Public Utilities Code § 366.2(g) already requires this fairness by ensuring that customers who switch energy providers receive the benefits of the resources they funded. When the City of San Luis Obispo joined 3CE, we did so to provide our residents with more affordable rates, cleaner energy, and greater local choice—goals supported by California law and Commission policy. Those goals depend on fair and consistent treatment of customers. I respectfully urge the Commission to reject this billing methodology and adopt vintage-year allocation for renewable energy credits. While characterized as an “interim” decision, the financial impacts beginning January 1, 2026 would be immediate and lasting for our community. If additional policy development is needed, the appropriate approach is to maintain the current fair system for the time being. Thank you for considering how this decision will affect working families, seniors on fixed incomes, small businesses, and agricultural operations across the Central Coast. Respectfully, Erica A. Stewart Mayor, City of San Luis Obispo cc: Governor Gavin Newsom Senator John Laird Assemblymember Dawn Addis California Energy Commission Chair David Hochschild Commissioner Darcie L. Houck Commissioner John Reynolds Commissioner Karen Douglas Commissioner Matt Baker Administrative Law Judge Elizabeth Fox Central Coast Community Energy CEO Robert Shaw