HomeMy WebLinkAbout9/18/2018 Item 14, Read
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City of San Luis Obispo, Council Memorandum
DATE: September 14, 2018
TO: City Council
FROM: Robert Hill, Interim Deputy Director, Office of Sustainability
VIA: Derek Johnson, City Manager
PREPARED BY: Chris Read, Sustainability Manager
SUBJECT: Item 14 - Community Choice Energy Public Hearing Updated Information
This memo provides updated information on two Community Choice Energy (CCE) related items:
1. California Public Utilities Commission (CPUC) Proceeding regarding the Power Charge
Indifference Adjustment (PCIA); and
2. September 11, 2018, City of Morro Bay City Council, CCE Study Session summary.
PCIA Proceeding
As noted in the Council Agenda Report for Item 14:
“The PCIA is one of the most critical variables in projecting future CCE program financial
viability. The PCIA is an exit fee charged by investor-owned utilities to customers that switch to
another provider of electricity generation service through direct access or community choice
aggregation. The fee is designed to cover above-market costs from contracts that the utilities
entered into but no longer need and cannot sell in the market for the price they paid. The California
Public Utilities Commission has an open proceeding, the PCIA Rulemaking Proceeding R.17-06-
026, intended to make changes to how the fee is calculated. The final outcome of this proceeding
is expected to be known on September 13, 2018 but may not be known until October. If the CPUC
issues a ruling on the PCIA on September 13, 2018, staff will provide an assessment of the ruling’s
impact on feasibility via a written addendum to this report and presentation at the September 18,
2018 City Council meeting.”
Ahead of the the September 13, 2018 CPUC meeting, Commissioner Peterman held the PCIA
items (#31 and #31A) until the September 27, 2018 meeting. Given this timeline, staff has worked
with the City’s technical consultant, The Energy Authority (TEA), and outside counsel to develop
contingencies, should the outcome of the ruling render a local CCE program financially infeasible.
The following contingencies provide a path for continuing with the program’s forward momentum
on the current timeline, while allowing for no cost and no risk “offramps” should the CPUC PCIA
ruling render the program financially infeasible:
Item 14 - Community Choice Energy Public Hearing Updated Information Page 2
1. TEA has agreed to “pause” transitioning to Phase II of the work program until the CPUC
has issued a ruling on the PCIA. This means that the “go/no go” decision point triggering
City responsibility for deferred time and material costs to TEA would be not occur until
after the ruling. Should the City elect to not move forward based on the PCIA ruling, it
would not be responsible for repaying TEA for work completed to date.
2. Should the CPUC further delay of the PCIA ruling beyond September 27, the City will
formally request a waiver from the CPUC allowing for submittal of the Implementation
Plan after January 1, 2019, while still being allowed to begin service in 2020. It is not
known if the CPUC would grant the waiver.
3. Staff has conferred with outside counsel regarding the ability to cancel the CCE ordinance.
If a negative PCIA decision occurs on September 27, staff could alert Council, who could
then “pull” the second reading of the ordinance from the October 2, 2018 Consent Agenda
and vote against adopting the ordinance. If a negative PCIA decision occurs after
September 27, Council could simply adopt an Ordinance in the future rescinding the CCA
Ordinance.
4. Staff has conferred with outside counsel regarding the ability to dissolve Central Coast
Community Energy (CCCE) joint powers authority (JPA). To dissolve CCCE, consistent
with Section 6.4 (Mutual Termination) of the agreement (Council Agenda Report
Attachment C), the Board of Directors could vote unanimously to dissolve the agency.
City of Morro Bay City Council CCE Study Session Summary
As noted in the Council Agenda Report for Item 14:
Staff will be present at the City of Morro Bay CCE study session on September 11, 2018 and will
ask Morro Bay’s City Council to communicate intention of proceeding and to provide any
requested changes to the JPA. Due to the potentially dynamic nature of this coordination, staff
anticipates supplemental written information to be provided as an addendum after this report has
been posted to the public. This information will be made publicly available on the City’s website
and presented during the presentation at the City of San Luis Obispo City Council meeting on
September 18, 2018.
City of San Luis Obispo staff attended the September 11, 2018 meeting of the Morro Bay City
Council, which included the same information that was provided to the City of San Luis Obispo
City Council at its study session on September 4, 2018. The City of Morro Bay’s Council
unanimously expressed support for the proposed path of creating a JPA with the City of San Luis
Obispo and submitting in Implementation Plan by the end of 2018 to begin serving customers in
2020. Notable feedback provided by the City of Morro Bay City Council included a request for a
minor edit to the JPA agreement and a proposal for sharing exposure to start-up credit risk.
Item 14 - Community Choice Energy Public Hearing Updated Information Page 3
Requested Joint Exercise of Power’s Document Edits
The City of Morro Bay requested two minor edits to the JPA agreement:
Edit Request 1 (Recital C). C: Carrying out programs to increase energy efficiency reduce
energy consumption
Edit Request 2 (Section 2.4) The purpose of this Agreement is to establish an independent
public agency in order to exercise powers common to each Party to establish and operate a
CCE Program that achieves long-term GHG emission reductions by offering clean, cost
effective and price stable electricity to residents, businesses, and agricultural producers,
while carrying out innovative programs to increase customer energy efficiency reduce
customer energy use, substantially increase local renewable energy production, and power
the local transportation system. To that end, CCCE will study, promote, develop, conduct,
operate, and manage energy, energy efficiency and conservation, and other energy-related
programs, and to exercise all other powers necessary and incidental to accomplishing this
purpose. Without limiting the generality of the foregoing, the Parties intend for this
Agreement to be used as a contractual mechanism by which the Parties are authorized to
participate in the CCE Program, as further described in Section 4.1. The Parties intend
other agreements shall define the terms and conditions associated with the implementation
of the CCE Program and any other energy programs approved by CCCE.
It is staff’s opinion that the requested edits are reasonable and agreeable. Staff recommends that
any motion made by Council to adopt the JPA include direction to update the agreement with these
edits
Support for Shared Financing and Responsibility of Deferred Compensation Risk
The City of Morro Bay City Council also provided a proposal for shared financing and
responsibility for deferred compensation risk. The proposal discussed provided for Morro Bay
providing credit backing for 20 percent of the financing based on Morro Bay’s electricity load
relative to San Luis Obispo’s electricity load. Under an “80/20” split, and assuming the $1,100,000
startup capital need included in the TEA technical study pro forma, the City of San Luis Obispo
would provide credit backing for $880,000 and the City of Morro Bay for $220,000. Specifics
around potential financing approaches and packages will be brought before Council in late 2018
or early 2019.
If you have any questions, please contact Chris Read, Sustainability Manager at (805) 781-7151
or cread@slocity.org.