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HomeMy WebLinkAboutCPUCRulemaking17-06-026_LtrToCPUC_20181003San Luis Obispo City Council 990 Palm Street San Luis Obispo, CA 93401 October 3, 2018 President Michael Picker Commissioner Martha Guzman Aceves Commissioner Carla Peterman Commissioner Liane Randolph Commissioner Cliff Rechtstaffen California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 Morro Bay City Council 595 Harbor Street Morro Bay, CA 93442 RE: Rulemaking 17-06-026: Track 2 PCIA Decision Dear President Picker and Commissioners, Thank you for your ongoing efforts in Rulemaking 17-06-026 to address fair and appropriate application of the Power Charge Indifference Adjustment (PCIA) on departing load customers. We write on behalf of the Cities of San Luis Obispo and Morro Bay which recently passed ordinances to form a community choice aggregation (CCA) program in our cities called Central Coast Community Energy (CCCE). On behalf of our future CCA program, we would like to express the following with respect to your upcoming PCIA decision on October 11, 2018. Our cities strongly urge the Commission to adopt the first Proposed Decision (PD) issued on August 1 along with Cal-CCA's proposed modifications submitted on August 21. While we understand that the Commission may be working on a "compromise proposal" somewhere between the original PD and the Alternate Proposed Decision (APD) issued on August 14, we feel the first PD was carefully crafted after ayear-long process and struck a reasonable balance between the cost recovery requirements of the investor -owned utilities and the ability of new load serving entities to exist without undue or excessive cost burdens. Specifically, we ask that you: (1) Exclude legacy utility -owned generation (UOG) from the PCIA (2) Maintain the 10-year limitation on cost recovery for post 2002 UOG Letter from the Cities of San Luis Obispo and Morro Bay RE: Rulemaking 17-06-026: Track 2 PCIA Decision Page 2 of 2 (3) Establish a reasonable capacity benchmark (4) Recognize the value of GHG free power in the market price benchmark (5) Address faulty claims regarding IOU avoidable costs and load forecasting (6) Stabilize PCIA related rate changes to create time for longer -term proposed fixes such as those proposed by Cal-CCA and other parties in Phase 2 of the proceeding. In our cities, CCA will be the mechanism for advancing many critical State and local policy goals related to greenhouse gas reduction, economic development, decarbonization, energy efficiency, and local energy resiliency. In the City of San Luis Obispo, for example, the CCA could be a critical tool for enabling decarbonization efforts while realizing the local and regional economic development potential of a low -carbon economy. Specifically, the CCA could support initiatives to decarbonize building energy use and to transition to carbon free transit and transportation systems. In the City of Morro Bay, the CCA could provide a tool to maximize the local benefits of offshore wind resources. In closing, we recognize the challenge you face in balancing many stakeholder interests in this important policy matter. We are interested in a solution that allows adequate compensation for IOU stranded costs while also allowing our CCA to move forward with a fair cost allocation and PCIA certainty. Thank you very much for your consideration of our position and input. Sincerely, Heidi Harmon Irons Mayor, City of San Luis Obispo Mayor, City of Morro Bay Cc: Derek Johnson, City Manager, City of San Luis Obispo Scott Collins, City Manager, City of Morro Bay