IBEW 569 & Sierra Club Letter regarding CCA Product Offerings

November 15, 2019

Interim Chair Joe Mosca and Members of the Board of Directors

San Diego Regional Community Choice Energy Authority

RE: Product Offerings and their Power Mix

Dear Chair Mosca and Boardmembers:

We write to express strong concern over the apparent interest in offering a product that is 100% carbon free, rather than 100% renewable.

We support staff and the Board in moving forward with two product offerings: one that is at minimum 50% renewable, and the second one being a 100% renewable opt-up product with a small premium—the latter of which will provide customers with a voluntary choice to go above and beyond what is offered at a small price.

A transition to a 100% clean energy economy needs to focus on investing in new renewable and carbon free energy projects, such as solar, wind, geothermal, and not just whether the energy is carbon free. Carbon free resources that are not renewable are nuclear and large hydroelectric facilities. We object to the CCE procuring nuclear and we are concerned about procurement from large hydroelectric facilities, one reason being this could displace local renewable energy procurement and local job creation from renewable energy projects here in our region.

To that end, we suggest that the staff and Board adopt a requirement that Bucket 1 renewable energy, as defined under the Renewable Portfolio Standard, be the only type of renewable energy to be used in the agency’s 100% renewable opt-up product. Bucket 2* and Bucket 3** are not renewable nor carbon free and using them in a product that is being pitched to customers as 100% renewable would be false marketing. Customers that pay extra go above and beyond what is offered so they can do their part in fighting climate change and creating good clean energy jobs and deserve a product that is truly 100% renewable.

We further suggest that the staff and the Board make good use of the revenue that is generated from the premium in the 100% product by putting the money aside in a fund that is dedicated for developing local programs and projects in the service territory. Marin Clean Energy is employing a similar approach to spur local project development in their service territory. Local investments that are linked with project labor agreements and community benefits agreements, prioritizing communities of concern, will bring much-needed economic and environmental benefits to a community that needs it the most.

As one of the larger Community Choice programs in California, the agency will play a significant role in the energy market as a large power purchaser. When large power purchasers create a demand for a specific source of power, it signals to the market a need of such supply. For this reason and the many outlined above, it is important for the agency to focus on a power mix that contains power generated from clean and renewable resources.

These recommendations are critical to ensuring the agency will play a key role in fighting climate change not just by reducing greenhouse gas emissions but promoting the development of new renewable energy resources that are local and bring high-quality union career opportunities to the San Diego region.

We appreciate the opportunity to comment and are looking forward to continue working with you on these issues.

Sincerely,

Luis Amezcua , Senior Campaign Representative, Sierra Club

Jeremy Abrams, Business Manager, International Brotherhood of Electrical Workers, Local 569


* Renewable energy from out-of-state that is “firmed and shaped” by gas.

** Renewable energy certificates that are bought separate from the power and can be used to count fossil fuel electricity as renewable.

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