September 19, 2018

California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

RE: Proposed Reforms to Power Charge Indifference Adjustment (PCIA)

Thank you for taking up much needed reforms to the Power Charge Indifference Adjustment (PCIA). Choice for an essential service, like electricity, should not create winners and losers.

We are concerned the proposed decision (PD) released on August 1 completely fails to prevent customer cost-shifts as required by law. The alternate decision (ADP) released August 13th by Commissioner Peterman is a big improvement but still allows for some cost-shifts to electricity customers who receive their power from investor-owned utilities.

Before voting on these proposals, we urge you to make modifications that will provide clarity and more effectively ensure all electricity customers, regardless of who provides their power, pay equitably for past investments in clean energy and system reliability.

Commissioner Peterman’s APD is a big improvement over the PD because it appropriately recognizes that current law requires that customers continue to pay for their equitable share of past investments in resources that serve systemwide reliability. This change was critical to ensure that customers who continue to buy power from investor-owned utilities are not forced to shoulder the costs incurred on behalf of other customers.

The ADP also seeks to address concerns with the proposed PCIA cap. However, the notion of a cap of any kind creates an artificial understanding of the cost of past investments. Shielding Community Choice Aggregators’ (CCA) customers from the reality of these costs causes bundled customers of investor owned utilities to pay for them or defers their recovery to a later time, resulting in increased costs for all electricity customers.

Because everyone benefits from clean energy and system reliability, the legislature twice took statutory steps to ensure that all electricity customers, regardless of who ultimately provides their power, would contribute equitably to cover the cost of these legacy investments.

More choices and energy providers are a good thing if they result in innovation and lower costs. But if lower costs for some customers are achieved through shifting of costs to other customers, that is not a legitimately competitive market. It also raises serious questions about how we continue to equitably fund future clean energy and environmental policies.

The message you send with your upcoming vote on this issue will either set the stage for the state to successfully navigate increased customer choice in the future or increase the risk of its failure. As our energy market continues to change and more customers buy power from CCAs and other alternative energy providers, it is critical that we get this right.

Sincerely,

Hector V. Barreto, President, Chairman & CEO
The Latino Coalition

Gary Passmore, President
Congress of California Seniors

Ruben Barrales, President
Latino Leadership & Policy Forum

Betty Jo Toccoli, President
California Small Business Association

Robert C. Lapsley, President
California Business Roundtable

Rex Hime, President & CEO
California Business Properties Association

Edwin T. Tan, Ph.D., Director of Advocacy and Development
Asian Americans for Community Involvement (AACI)

Tracy Hernandez, Founder & CEO
Los Angeles County Business Federation (BizFed)

Pat Fong Kushida, President & CEO
CalAsian Chamber of Commerce

Al Abdallah, COO
Urban League of San Diego County

Ammie Hines, Founder
Another Level for Women

James P. Reber, Executive Director
San Jose Parks Foundation

Dennis J. Huang, Executive Director & CEO
Asian Business Association of Los Angeles

Reverend Gerald W. Brown, Executive Director
United African American Ministerial Action Council

LCDR Art Curtis, Legislative Officer
Reserve Officers Association (ROA), Golden West Department

Stephen Pepe, President
EconAlliance

Blong Xiong, Chair
Asian Business Institute & Resource Center

Letitia Hanke, President & CEO
Lime Foundation

Brenda Ratliff, Executive Director
Volunteer Center of Kern County

Greg McConnell, President & CEO
Jobs and Housing Coalition

Ronald O. Nichols, President
Southern California Edison

Eugene “Mitch” Mitchell, Vice President, State Government Affairs & External Affairs
San Diego Gas & Electric Company

Jack Weir, President
Contra Costa Taxpayers Association

Dan B. Walden, Executive Director
Alameda County Taxpayers Association

Rasmey Sam, President & CEO
Asian-American Resource Center

Fernand Fernandez, Interim President & CEO
United States Hispanic Chamber of Commerce

Alice Huffman, President
California State Conference NAACP

Julian Cañete, President & CEO
California Hispanic Chambers of Commerce

Jeanne Orcutt, Executive Director
Coastal Energy Alliance

Letitia Hanke, CEO
ARS Roofing, Solar and Electric

Deborah Howard, Secretary
California Senior Advocates League

Shawn Lewis, Policy & Communications Director
National Federation of Independent Business (NFIB)

Fred A. Romero, State Commander
American GI Forum of California

Letitia Hanke, President
North Bay Black Chamber of Commerce

Mariko Kahn, Executive Director
Pacific Asian Counseling Services

Lorraine Plass, State Legislative Chair
AMVETS Department of California

Scott Ashton, CEO
Oceanside Chamber of Commerce

Pilar Pinel, Founder & CEO
Embracing Latina Leadership AllianceS

Wanda Love, President & Executive Director
Gardena Valley Chamber of Commerce

Michael Turnipseed, Executive Director
Kern County Taxpayers Association

Steve Mackey, President
Vietnam Veterans of America California State Council

W. Erik Bruvold, CEO
San Diego North Economic Development

Moe Ammar, President
Pacific Grove Chamber of Commerce

Alicia Berhow, Senior Vice President of Government Affairs
Orange County Business Council

Steve Van Dorn, President & CEO
Pleasanton Chamber of Commerce

Steve Malnight, Senior Vice President of Strategy and Policy
Pacific Gas & Electric

Jessica Duboff, Vice President of Policy and Business Advocacy
Los Angeles Area Chamber of Commerce

Alice Lei, Founder
Asian Women Entrepreneurs (AWE)

Wendy Urushima-Conn, President & CEO
Asian Business Association of San Diego

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