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