BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking to Develop an Electricity Integrated Resource Planning Framework and to Coordinate and Refine Long-Term Procurement Planning Requirements.

Rulemaking 16-02-007 (Filed February 11, 2016)

JOINT COMMUNITY CHOICE AGGREGATORS NOTICE OF EX PARTE COMMUNICATION

/s/ Daniel Settlemyer Daniel Settlemyer Regulatory and Legislative Assistant MARIN CLEAN ENERGY 1125 Tamalpais Avenue San Rafael, CA 94901 Telephone: (415) 464-6658 dsettlemyer@mceCleanEnergy.org

October 26, 2018

1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking to Develop an Electricity Integrated Resource Planning Framework and to Coordinate and Refine Long-Term Procurement Planning Requirements.

Rulemaking 16-02-007 (Filed February 11, 2016)

JOINT COMMUNITY CHOICE AGGREGATORS NOTICE OF EX PARTE COMMUNICATION

Pursuant to Rule 8.4 of the California Public Utilities Commission (“Commission”) Rules

of Practice and Procedure and Public Utilities Code (“Cal. P.U. Code”) Section 1701.1 and

1701.3(h)(2), Marin Clean Energy (“MCE”) and the California Community Choice Association

(“CalCCA”) hereby give notice of an ex parte communication that took place on October 24, 2018

regarding the Integrated Resources Planning (“IRP”) proceeding.1

The ex parte communication was initiated by MCE, on behalf of other Community Choice

Aggregators (“CCAs”). The ex parte meeting took place in person on October 24, 2018 at the

Commission’s headquarters in San Francsico. Attendees at each of the meetings were C.C. Song,

MCE Senior Policy Analyst; and Sam Kang, Managing Director for Pacific Energy Advisors and

Consultant to CalCCA.

The oral ex parte communication was initiated by MCE and involved Rachel Peterson,

Chief of Staff to Commissioner Randolph; and Joanna Gubman, Advisor to Commissioner

Randolph. The meeting took place from approximately 1:00pm to 1:30pm.

1 Pursuant to Rule 1.8(d) of the Commission’s Rules of Practice and Procedure, CalCCA has given MCE permission to sign this notice on their behalf.

2

In the meeting, the attendees described CCAs’ resource planning processes and their

portfolios’ alignment with the Commission’s Reference System Portfolio. The attendees also

discussed the CCAs’ compliance with the Renewable Portfolio Standard (“RPS”) and the 2030

Greenhouse Gas (“GHG”) emissions targets, and that no advance RPS procurement is necessary

before the federal tax credits expire. The attendees also addressed concerns raised by parties about

CCAs’ hydro-electric resource assumptions feasibility and that most out-of-state hydro resources

are already under contract. Lastly, the attendees discussed CCAs’ activities in serving

disadvantaged communities, and challenges in calculating local criteria pollutants that are

attributable to each CCA’s procurement activities.

This ex parte included oral and written communications. Written materials were provided

during each of the communications, and are attached to this notice as Attachment A.

Respectfully submitted, /s/ Daniel Settlemyer Daniel Settlemyer Regulatory and Legislative Assistant MARIN CLEAN ENERGY 1125 Tamalpais Avenue San Rafael, CA 94901 Telephone: (415) 464-6658 dsettlemyer@mceCleanEnergy.org

October 26, 2018

3

Attachment A

CCA Integrated Resource PlansCalCCA Public Comment Key Takeaways

October 2018

Agenda

CCAs’ resource planning process

CCAs’ compliance with Renewables Portfolio Standard (RPS) and 2030 Greenhouse Gas (GHG) Emission Targets

CCAs’ integrated resource plans alignment with CPUC Reference System Portfolio and hydro feasibility

CCAs’ renewable procurement to date

CCAs’ activities in underserved communities

CalCCA members have sound procurement planning and processes in place

Progress

Time

Planning

Execution

Contract Management

Post execution, CCAs manage the contracts by reviewing schedules and invoices to ensure proper billing and payments per terms.

For contracts with new build construction, developers’ schedules are monitored to ensure compliance with key milestones.

Recontracting potential is always considered for optimal contracts.

Any contractual disputes are dealt with in a timely manner.

Depending on the product, solicitations are issued on a regular basis and bids are ranked according to criteria includingcost, relative value, portfolio fit, location, and other considerations that may be important to the CCAs at that time.

Certain product types such as resource adequacy require more frequent and direct contact with suppliers.

Contracts are generally based on WSPP and EEI templates.

Counterparty credit risk is also weighed and considered.

The CCA Board determines resource mix based upon regulatory requirements (e.g., RPS mandates and GHG emissions target) community’s goals/ambitions, and potential rate impact.*

Based on energy risk management policies and/or Board risk tolerances, procurement targets and ranges are established by product type and year to ensure a transparent and disciplined approach to procurement.

*CCAs are regulated by their local governing boards, who have sole authority over CCA procurement decisions and policies, unless expressly authorized otherwise by statute (Public Utilities Code Section 366.2(a)(5)).

CalCCA members have either already met, or have plans to meet or exceed RPS mandates …

CCA

RPS % of Retail Sales

2020

RPS % of Retail Sales

2030

LT RPS Contract %

of Retail Sales in 2021

Apple Valley Clean Energy 37% 53% 28%Lancaster Choice Energy 36% 51% 27%Monterey Bay Community Power 33% 50% 24%Pioneer Community Energy 33% 50% 27%Pico Rivera Innovative Municipal Energy 53% 53% 26%Rancho Mirage Energy Authority 35% 51% 26%San Jacinto Power 37% 53% 27%Marin Clean Energy 54% 100% 43%Peninsula Clean Energy 50% 100% 33%Silicon Valley Clean Energy 50% 50% 23%East Bay Community Energy 40% 57% 23%Clean Power Alliance 63% 81% 62%Clean Power San Francisco 51% 72% 44%Sonoma Clean Power 50% 50% 36%San Jose Clean Energy 44% 61% 49%Valley Clean Energy 42% 50% 21%Redwood Coast Energy Authority 33% 50% 24%Solana Energy Alliance 33% 50% 21%

Average 43% 60% 31%

… and have 2030 GHG emission forecasts that are less than half of their emissions benchmark targets

CalCCA forecasted 2030 new build portfolio aligns well with the Commission’s Reference System Portfolio

CPUC Recommended Portfolio of Additional Supply Resources, Beyond Baseline, to Meet 42 MMT Planning Target

2030 resource mix consists predominantly of solar paired with battery storage and also wind

Based on current contracted out-of-state large hydro resources, concerns about future contracting appears to be misplaced

Capacity Inputs (MW)Candidate Resource Type 2018 2022 2026 2030Existing_CAISO_LargeHydro Large Hydro 279 1,691 1,479 1,352 Existing_Non-CAISO_CA_LargeHydro Large Hydro - 549 - - Existing_OOS_LargeHydro Large Hydro 1 2,532 2,760 2,728 Existing ACS Large Hydro - 203 203 203 Total Large Hydro 280 4,975 4,442 4,283

Future Contracts (including Recontracting) with Existing Resources (MW) - Resources with CAISO Resource ID or WECC CEC-RPS-ID

Capacity Inputs (MW)Candidate Resource Type 2018 2022 2026 2030Existing_CAISO_LargeHydro Large Hydro 1,063 151 - - Existing_Non-CAISO_CA_LargeHydro Large Hydro - - - - Existing_OOS_LargeHydro Large Hydro 2,328 170 - - Existing ACS Large Hydro 648 - - - Total Large Hydro 4,039 321 - -

Contracted with Existing Resources (MW) - Resources with CAISO Resource ID or WECC CEC-RPS-ID

As of September 2018, there are approximately 1,900 MW of CCA-driven new build renewable projects

Agency Project Size (MW) Resource Resource Provider/Project Name LocationService Start Date

Contract Length (Years)

MCE 4.8 Biogas Genpower / Lincoln Landfill Lincoln, Placer Co. 2013 2020 Solar Dominion / RE Kansas Solar Stratford, Kings Co. 2015 323 Solar Dominion / Cottonwood Solar Stratford, Kings Co. 2015 2599 Wind EDP Renewables / Rising Tree III Mojave, Kern Co. 2015 3.53.6 Biogas Waste Management / Redwood Landfill Novato, Marin Co. 2017 20

10.5 Solar MCE / Solar One Richmond, Contra Costa Co. 2017 2530 Solar Recurrent Energy / Mustang Solar Power Project Lemoore, Kings Co. 2018 15100 Solar Recurrent Energy / Tranquillity 8 Tranquility, Fresno Co. 2018 15105 Solar sPower / Antelope Expansion 2 Lancaster, Los Angeles Co. 2018 2042 Wind Terra-Gen / Voyager Wind III Mojave, Kern County 2018 12125 Wind Terra-Gen / Los Banos Wind Los Banos, Merced Co. 2018 12160 Solar First Solar / Little Bear Solar Mendota, Fresno Co. 2020 2080 Solar EDF Renewables / Desert Harvest Desert Center, Riverside County 2020 20100 Wind Strauss Wind Lompoc, Santa Barbara County 2020 15

SCP 70 Solar Mustang 1 & Mustang 3 (Recurrent) Lemoore, Kings County 2016 2046 Wind Golden Hills North (NextEra) Livermore, Alameda County 2017 2080 Wind Sand Hill C, LLC (sPower) Alameda County 2021 2050 Solar Proxima Solar, LLC (NextEra) Stanislaus County 2023 205 Storage Proxima Solar, LLC (NextEra) Stanislaus County 2023 20

LCE 10 Solar sPower / Western Antelope Dry Ranch Lancaster, Los Angeles County 2016 20PCE 200 Solar Wright Solar Park Santa Nella, Merced County 2019 20

100 Solar Mustang II Whirlaway Lemoore, Kings County 2019 15CleanPowerSF 47 Wind Terra-Gen/ Voyager IV Expansion Mohave, California 2020 15

100 Solar sPower/ San Pablo Raceway Lancaster, California 2019 22MBCP & SVCE 200 Wind Duran Mesa LLC/Corona Wind Project New Mexico 2021 15

Key Projects

Projects are located throughout California using various renewable resource types and utilizing Union labor where possible

CCAs also create value for underserved communities

CleanPowerSF• Innovative contracting mechanism encourages community benefits from contractors• Eco2Schools Program led by Center for Climate Protection inspires students in two high schools and a youth

organization in Hunters Point to be more sustainable and reduce carbon footprints• $2M allocated for solar rebates for underserved residential customers through GoSolarSF• Low income homeowners can save up to 100% off the installed cost of a solar electric system • Partnership with GRID Alternatives to provide local job training, focusing on underserved communities

CCAs also create value for underserved communities (continued)

Lancaster Choice Energy• Focus on low-income customers with California HERO and California first to offer Property Assessed Clean Energy

(PACE) financing• Partnering with Antelope Valley Transit Authority to convert to all-electric bus fleet in three years • AVTA provides free local transit to seniors

Sonoma Clean Power• Electric vehicle purchase and lease discounts for CARE customers• 30% of electric vehicle rebates allocated for low-income customers • Property Assessed Clean Energy (PACE) financing for home retrofits and solar• Free Do it Yourself Toolkit for home efficiency retrofits in all public libraries

MCE• $1.7 M/year for Low-Income Tenants & Families (LIFT) energy efficiency• $75,000 allocated for 150 low-income solar rebates • $100,000 to RichmondBUILD solar and energy efficiency job training academy • $85,000 allocated to Rising Sun Energy Center to train San Pablo and El Cerrito youth for green collar jobs • Partners with Communities for a Better Environment, the Greenlining Institute, Grid Alternatives, and environmental

justice groups for inclusive programs and policies

Conclusion

CCAs have resource planning processes that balance risks and costs with meeting regulatory mandates such as RPS requirements and GHG emission targets

All CCAs have forecasted portfolios that meet or exceed RPS requirements and GHG emission targets and expected resources appear available and feasible

The combined CCA portfolio in 2030 matches the CPUC’s reference system portfolio well, and the potential sites for renewable development in California and the Western interconnection are plausible per the RESOLVE model

CCAs have already contracted for the development of approximately 1,900 MW of renewable projects, almost all of which was without a credit rating, obviating the need for a third-party centralized procurement entity

Further, advanced procurement ahead of tax credit expiration is risky due to potential stranded costs, and contrary to CCA procurement plans and energy risk management policies

CCAs actively participate and invest in underserved communities, and continuously work with their respective communities to develop more programs