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