HomeMy WebLinkAboutAGENDA REPORT 2019 0619 REG CCSA ITEM 09ECITY OF MOORPARK,
CALIFORNIA
City Council Meeting
of June 19, 2019
ACTION Approved Staff
Reco mmendation. BY
B.Garza
E. Consider Temporarily Opting Out of Clean Power Alliance for Certain Electrical
Accounts. Staff Recommendation: Authorize the City Manager to opt out of
Clean Power Alliance for all accounts with the following rates: LS-1, LS-2, LS-3,
OL-1 AL-2, and TOU-PA-2E, and direct staff to review the rates in one year once
the streetlight acquisition and retrofit are completed, and return to City Council
with a recommendation on whether or not to return to Clean Power Alliance.
(Staff: Jessica Sandifer)
Item: 9.E.
MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
FROM: Jessica Sandifer, Community Services Manager
DATE: 06/19/2019 Regular Meeting
SUBJECT: Consider Temporarily Opting Out of Clean Power Alliance for Certain
Electrical Accounts
BACKGROUND
On January 17, 2018, the City Council voted to join the Los Angeles Community Choice
Energy Authority, now the Clean Power Alliance (CPA). In October 2018, the City
Council set the default rate tier for the Moorpark community to the Clean Power tier to
provide 50% renewable energy to the Moorpark community. At the time that the default
rate tier was set, staff had indicated that they’d return to the City Council to determine
the rate tiers for the individual municipal accounts when the non-residential service
began. Non-residential service began in May 2018, and the City began receiving power
from the Clean Power Alliance at the Clean Power tier.
When CPA began to set their electrical rates, the CPA board set specified discounts or
premiums compared to Southern California Edison’s (SCE) rates. Lean Power, offering
36% renewable energy, was to set to be a 1% to 2% discount over SCE rates; Clean
Power, offering 50% renewable energy, was set to be on par with SCE rates or a 1%
discount; and Green Power, offering 100% renewable energy, was set at a 7% to 9%
premium over SCE rates. During the first year of CPA operation, they have maintained
these bill comparison targets.
DISCUSSION
CPA notified staff in May of potential rate increases, outside of the bill comparison
targets, to select commercial accounts that CPA may have to enact pending rate
changes requested by SCE and approved by the California Public Utility Commission
(CPUC). On June 6, 2019, the Clean Power Alliance Board adopted increased
electrical rates for all customers. The residential rates and most of the commercial rate
tiers have remained within the CPA bill comparison targets. However, due to multiple
Item: 9.E.
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SCE rate changes, a major structural change to time-of-use periods, the restructuring of
the Power Charge Indifference Adjustment (PCIA), including a large increase in the
Lighting PCIA charge, and a special PCIA increase to account for SCE’s $825 million
revenue under-collection in 2018, staff at CPA has recommended that a small subset of
commercial rate accounts exceed the bill comparison targets in order to ensure that the
rates adequately cover the costs to serve these customers. The subset of accounts that
affects municipal operations are generally outdoor lighting accounts. The rate increases
adopted by the Board equate to an approximately 40% increase in costs for the affected
accounts. The June 6, 2019, staff report to the Clean Power Alliance Board explaining
the issues in more detail is attached. This impacts all municipal and governmental
agencies that are members of the CPA.
City of Moorpark accounts with the following rates are affected by these rate increases:
AL-2-F, LS-1-Allnite, LS-2, LS-3, OL-1, and TOU-PA-2E. Five of these rates account for
our outdoor lighting use, the most significant of these accounts is the LS-1 and LS-2
accounts, as these account for all our street lighting costs. These five rate classes
account for 53% of the total municipal electricity use throughout the year.
CPA staff has been very helpful in assisting its municipal member agencies with
navigation of this issue. They have prepared a high level estimate of the impact of the
rate increases to these affected accounts using the last 12 months of electrical usage
data. Based on the average lighting load profile, the CPA rate changes would increase
our electrical costs by approximately $62,000 per year at the Clean Power Tier (default
tier) or $55,000 if we were to opt in to the Lean Power tier, though our actual increase
may be higher or lower. Once the City acquires the streetlight poles, prior to the
completion of the LED retrofit, the costs would increase by approximately $3,000 across
both tiers.
Currently, the City is in the process of acquiring our streetlights from SCE, but the
transaction has not concluded. Until the acquisition and the retrofit of the streetlight
project is completed, continuing with CPA, with these large rate increases, would
significantly increase our electrical bills and decrease the Return on Investment (ROI)
for the streetlight acquisition.
Staff is recommending that we temporarily opt-out of Clean Power Alliance for the AL2-
F, LS-1, LS-2, LS-3, OL-1, and TOU-PA-2E accounts until such time as the rates return
to a more manageable level. Staff can revisit the issue in a year, once the LED retrofit
project on the streetlights has been completed.
It is important to note that SCE has enacted an average 3.4% rate increase, so rates
will increase with SCE, just not at the level that CPA has had to increase their rates.
Additionally, when considering the purchase of the streetlights, the financial analysis
considered a 4% escalation of power costs when calculating the ROI for the acquisition
and retrofit, so the current SCE increase is in line with that assumption.
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FISCAL IMPACT
Opting out of CPA for the AL2-F, LS-1, LS-2, LS-3, OL-1, and TOU-PA-2E accounts will
avoid an increase of approximately $62,000 in anticipated electricity costs over the next
year.
STAFF RECOMMENDATION
Authorize the City Manager to opt out of Clean Power Alliance for all accounts with the
following rates: LS-1, LS-2, LS-3, OL-1 AL-2, and TOU-PA-2E, and direct staff to review
the rates in one year once the streetlight acquisition and retrofit are completed, and
return to City Council with a recommendation on whether or not to return to Clean
Power Alliance.
Attachment: June 6, 2019 Clean Power Alliance Staff Report
602
Staff Report – Agenda Item 6
To: Clean Power Alliance (CPA) Board of Directors
From: Matthew Langer, Chief Operating Officer
Approved By: Ted Bardacke, Executive Director
Subject: Adopt Resolution No. 19-06-010 to Approve 2019 Rates for Phase 1
& 2 Non-Residential Customers, Resolution No. 19-06-011 to
Approve 2019 Rates for Phase 4 Non-Residential Customers, and
Resolution No. 19-06-012 to Approve 2019 Rates for Phase 3
Residential Customers
Date: June 6, 2019
RECOMMENDATIONS
1. Adopt Resolution No. 19-06-010 (Attachment 1) to approve adjusted 2019 rates
for Phases 1 & 2 non-residential customers;
2. Adopt Resolution No. 19-06-011 (Attachment 2) to approve adjusted rates for
Phase 4 non-residential customers; and
3. Adopt Resolution No. 19-06-012 (Attachment 3) to approve adjusted 2019 rates
for Phase 3 residential customers.
CONTEXT
CPA has just completed its major enrollment year, which began in June 2018 and
concluded this past May. CPA is now the largest CCA in the state. During this time, the
organization has experienced several SCE rate changes, a major structural change to
time-of-use periods, the restructuring of the PCIA and a special PCIA increase to account
for SCE’s $825 million undercollection in 2018.1
1 SCE’s improper conduct during the undercollection process is now subject to a penalty phase at the CPUC. CPA
Executive Director Ted Bardacke has provided sworn statements in the penalty phase.
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ATTACHMENT
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CLEAN POWER ALLIANCE BOARD OF DIRECTORS AGENDA ITEM 6
During this past year, CPA has kept intact both its approved bill comparisons with SCE
and the environmental commitments embodied in its three rate offerings. Delivering on
these commitments is important to CPA’s core value proposition of offering a choice to
over one million customers of cleaner power at competitive rates.
CPA’s low opt-out rates across all rate products reflects the strength of that value
proposition and of the CCA business model. In the coming years, CPA intends to also
achieve rate stability, with just one rate change per year, as is standard among CCAs in
California.
In the meantime, CPA staff is proposing to adjust rates for all customers in response to
another SCE rate change, which SCE announced on May 29 and was implemented on
June 1. This SCE rate increase was lower than expected. To ensure CPA maintains its
strong fiscal position, CPA staff is proposing to both increase net energy revenues and to
reduce energy costs.
To increase net energy revenues, staff is proposing an additional rate adjustment for a
small subset of large energy users that would take effect in October 2019. This will result
in rates for these customers that fall outside the ranges previously approved by the Board.
As previously communicated with the Board, absent corrective action, CPA’s residential
and small business customers would be subsidizing these large energy users at an
unsustainable level. Details on this rate adjustment proposal are provided later in this
report.
Addressing these subset customers is only one part of keeping CPA’s finances strong.
Staff is also recommending to reduce energy costs by using unbundled Renewable
Energy Certificates (RECs) in 2019 to meet a small portion of the RPS commitments for
the Lean and Clean rate products. Staff estimates that unbundled RECs will make up less
than 10% of CPA’s total energy mix and the Clean product will continue to have a lower
GHG emissions content than SCE. The 100% Green product will not include any
unbundled RECs. The lower cost of energy is reflected in the Proposed Budget in Item 7.
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CLEAN POWER ALLIANCE BOARD OF DIRECTORS AGENDA ITEM 6
Together, the rate proposal to have large energy users cover their cost of service and the
reduction of energy costs through the temporary use of unbundled RECs for the Lean
and Clean rate products puts CPA on firm financial footing for the coming year.
OTHER OPTIONS CONSIDERED
In developing this pair of proposals, staff considered several other options. On the
revenue side, it would be possible to implement a broad-based rate increase on all
customers, above and beyond matching SCE’s June 1 rate increase. This option was not
selected because: a) it would leave the subsidy of large energy users by residential and
small business customers intact; and b) it is less disruptive to exceed CPA’s approved bill
comparisons for less than 1% of CPA’s customers while they still have the opportunity to
opt-out with no risk rather than implement an immediate rate increase outside of the
approved ranges for all customers so soon after enrollment.
On the cost side, staff considered the option of reducing renewable energy purchases
across the board. This option was not selected because: a) it would have undermined the
value of the 100% Green rate that customers are paying a premium for; and b) it would
have pushed the renewable content of the Lean and Clean rate products to levels below
those offered by SCE for its base product.
Staff recognizes that CPA’s Joint Powers Agreement “discourages the use of unbundled
renewable energy credits.” However, the two recommended actions enable CPA to
maintain bill comparisons for over 99% of CPA customers, maintain RPS levels for Lean
and Clean, keep the 100% Green rate product intact with no unbundled RECs, and place
CPA on solid financial footing.
RATE PROPOSAL
On April 4, 2019, the Board approved Resolution No. 19-04-005 to adopt updated 2019
rates for existing non-residential customers (Phases 1 & 2), Resolution No. 19-04-006 to
adopt 2019 rates for future non-residential customers (Phase 4), and Resolution No. 19-
04-007 to adopt updated 2019 rates for residential customers (Phase 3). Those rate
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CLEAN POWER ALLIANCE BOARD OF DIRECTORS AGENDA ITEM 6
updates were driven mainly by SCE’s April 12 rate increase to all customers, in order to
implement the “trigger” caused by its 2018 Energy Resource Recovery Account (ERRA)
undercollection of $825 million.
Staff is seeking Board approval to adjust rates for all CPA customers effective June 1.
The proposed rate adjustment is driven by SCE’s implementation of its 2019 ERRA
Forecast revenue requirement, which resulted in an increase of approximately 3.4% to
the total average rate paid by SCE bundled customers, effective June 1. CPA staff is
proposing to adjust its rates to follow this rate increase in order to maintain the stated bill
comparison ranges for most customers and to continue to generate the revenue needed
to cover costs.
In addition, staff is seeking the Board’s approval to modify the rate comparison ranges for
a small subset of commercial rate classes (“subset customers”) in order to ensure rates
adequately cover the cost to serve these customers.
SUBSET CUSTOMER IMPACT
Over the course of 2019, CPA has adjusted rates for its customers each time SCE has
changed its rates with the goal of having customers’ bills fall within specified discounts or
premiums compared to SCE rates, depending on which rate tier a customer chooses:
x Lean Power, which provides 36% renewable energy at a 1-2% discount
x Clean Power, which provides 50% renewable energy at a 0-1% discount
x 100% Green Power, providing 100% renewable energy at a 7-9% premium
Given the combined effect of SCE’s many recent rate changes, CPA staff is presenting
rates for Phase 4 customers that reflect adjustments to the rate tier discount/premium
ranges for accounts in the TOU-8, TOU-GS-3, TOU-PA-2 and TOU-PA-3 2 rate classes.
This group of customers represents less than 1% of Clean Power Alliance’s eligible
customer base. For these accounts, CPA rates would stay within the three rate tier ranges
2 The TOU-8 rate covers the largest energy users; GS-3 covers medium-to-large energy users; PA2 and PA3 cover
medium-to-large agricultural and pumping customers.
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CLEAN POWER ALLIANCE BOARD OF DIRECTORS AGENDA ITEM 6
for the summer months (June-September) when energy rates are highest but be outside
those ranges in the winter months (January-May, October-December) when energy rates
are lowest. These higher winter rates will therefore not go into effect this year until October
1, allowing customers an opportunity to opt-out before the end of their 60-day post
enrollment period, which ends in July for most Phase 4 customers.
Staff is asking the Board to consider this change because matching SCE’s new rates for
TOU-8, TOU-GS-3, TOU-PA2 and TOU-PA3 customers is expected to result in a
significant revenue shortfall compared to the cost to serve these customers – particularly
in the winter months. Sustaining such rates would require residential and small
commercial customers to subsidize large commercial, industrial, and pumping and
agricultural customers.
The table below summarizes the proposed bill premiums for the Phase 4 subset rate
types.
Bill Premiums for Winter Rates
(approximate)
Bill Premiums for Summer Rates
(approximate)
Rate Type Lean Clean 100% Green Lean Clean 100% Green
TOU-GS-3 16% 18% 19% -1% 0% 9%
TOU-PA-2 21% 24% 24% -1% 0% 9%
TOU-PA-3 32% 35% 37% -1% 0% 9%
TOU-8-SEC 19% 21% 23% -1% 0% 9%
TOU-8-PRI 23% 26% 27% -1% 0% 9%
TOU-8-SUB 26% 29% 32% -1% 0% 9%
The winter rate premiums above result in total annual revenue from each customer group
sufficient to cover CPA costs including contributions to reserves. The relative increase to
winter rates for 100% Green customers is smaller compared to that of Lean and Clean
because their rates generate more revenue for CPA during the summer months.
Therefore the amount by which their winter rates must be increased to recover their
annual cost to serve is lower.
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CLEAN POWER ALLIANCE BOARD OF DIRECTORS AGENDA ITEM 6
IMPACT TO LIGHTING RATES
CPA staff has also reevaluated the rate tier discount/premium ranges for accounts
dedicated to street and outdoor lighting in the LS-1, LS-2, LS-3, AL-2, and OL-1 rate
classes.3 For lighting accounts on these rates, the new proposed CPA rates will fall
outside of the three rate tier ranges year-round. This is because for most lighting types,
there is no differentiation between summer and winter rates. The exception is AL-2
customers with accounts on time-differentiated lighting rates. Without this change,
matching SCE’s new lighting rates would also result in a significant revenue shortfall for
CPA, in part due to an 89,600% increase in the lighting PCIA. CPA staff is recommending
that these lighting rate changes become effective July 1 to allow customers time if they
choose to opt out before being charged the higher rates.
Customers on TC rates (traffic control) will continue to be served by CPA at rates based
on the previously approved rate ranges.
The table below summarizes the bill impacts for the Phase 4 lighting rates year-round.
New Bill Premiums
(approximate)
Previous Bill Premiums
(approximate)
Rate Type Lean Clean 100% Green Lean Clean 100% Green
LS-1, LS-2, LS-
3, OL-1, and
AL-2 (winter
only)
37% 40% 47% -1% 0% 9%
Bifurcation due to ERRA Trigger
On January 31, the CPUC approved SCE’s request to recover part of its costs related to
its $825 million 2018 undercollection from departing CPA customers through the PCIA.
This retroactive cost recovery is known as the “trigger.” Implementation of the trigger by
SCE resulted in a one-year increase to the PCIA for customers who enrolled in 2019.
Phase 1 and 2 customers, because they enrolled in 2018, are charged a lower PCIA by
3 The LS-1, LS-2, and LS-3 rates cover street and highway lighting; AL-2 and OL-1 rates cover outdoor area lighting.
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CLEAN POWER ALLIANCE BOARD OF DIRECTORS AGENDA ITEM 6
SCE than Phase 4 customers. This difference is accounted for in CPA’s rates so that all
customers on the same rate schedule pay the same net rate after taking into account the
PCIA. CPA will continue to “bifurcate” its commercial rates until the trigger goes away
(currently expected in April 2020), which is the reason for separate Resolutions adopting
rates for Phase 1 and 2 customers and Phase 4 customers.
Demand Response Rate Pilot
Staff is also presenting new commercial demand response rates for Board approval. CPA
staff is requesting approval of these rates in order to administer a limited 5 month “Peak
Management Program” on a pilot basis, similar in structure to the SCE Critical Peak
Pricing program. Participating commercial customers would receive an incentive in the
form of credits to offset their summer on-peak demand charges. During peak energy
“events” CPA will apply a per kWh surcharge to customer bills. Events coincide with the
peak time of use period (4pm – 9pm), when energy is most expensive, and can be called
in response to high energy prices, grid emergencies, or during heat events. Participating
customers will be notified of events by CPA a day in advance, so they can prepare to
manage their electricity demand during the event period to avoid or lessen the energy
surcharge.
The pilot program will run from July 1 – November 30, 2019. The pilot program will be
open to Phase 4 commercial customers on select rate types. The pilot will also offer bill
protection to ensure that customers will not pay more on the new rate than they would
have paid otherwise on their normal rate, thereby eliminating financial risk of participation
in the pilot.
The intent of the pilot will be to evaluate customer responsiveness during events, revenue
impacts of such a program, and the customer experience, to better customize the
program for CPA in anticipation of scaling up participation next year.
Attachments: 1) Resolution 19-06-010
2) Resolution 19-06-011
3) Resolution 19-06-012
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