We Support CCA in California
CalCCA supports legislation and regulatory policies that protect and foster CCAs within the state. We promote competitive neutrality and a level playing field. We oppose legislation and regulatory policies that unfairly discriminate against CCAs or CCA customers, or reduce CCA policy- or decision-making autonomy.
Regulatory Compliance
CCAs, as load serving entities, engage with numerous state and federal agencies, including the California Energy Commission, the California Public Utilities Commission, California Air Resources Board, and the Federal Energy Regulatory Commission, to ensure compliance in a number of areas including renewable energy mandates, grid reliability, and power content reporting. CCAs work cooperatively with all agencies having authority over CCA operations to ensure efficient and safe delivery of energy and energy-related programs. CCAs strive to be highly responsive and transparent in their efforts to provide clean, affordable energy to our customers.
CalCCA Policies
Procurement and Reliability
- Protect CCAs’ procurement autonomy
- Protect CCAs’ right to self-procure their customers’ portions of system reliability needs
- Encourage results-oriented policymaking over prescriptive procurement mandates
Local Control
- Protect the authority of the CCA Board of Directors as the primary governing body of a CCA
- Develop roles for state agencies that are complementary to rather than competitive with the CCA Boards of Directors
Non-Bypassable Charges
- Prevent new non-bypassable charges (“NBCs”) and phase out or eliminate existing NBCs
- Ensure that NBC inputs and methodologies are transparent and developed through public processes that allow for full stakeholder input
- Foster market certainty by maximizing year-to-year consistency and/or predictability of all NBCs
Customer Indifference and Legacy Costs
- Protect indifference of all ratepayers to load migration between LSEs
- Increase the transparency and certainty of PCIA charges, and phase out unreasonable PCIA charges over a time period that addresses stranded costs
- Reform IOU procurement practices to minimize stranded load and mitigate CCA charges
Grid Edge
- Protect CCAs’ right to develop and administer energy efficiency and integrated distributed energy resources
- Protect CCA customers’ right to select, install, and operate energy efficiency and behind-the-meter distributed energy resources
- Foster and develop integrated distributed energy resources as non-wires alternatives to expanding distribution infrastructure and centralized generation
The Broader Landscape
- Support further CCA growth and formation
- Build energy market structures and regulatory paradigms that benefit all California ratepayers and facilitate affordability, reliability, decarbonization, and social equity
Utilities Restructuring
- Support refocusing the utilities’ electric business on the safe management of wires infrastructure
- Support options for local governments to expand their electricity program offerings, including the option to serve as sole retail provider and provider of last resort and support local jurisdictions’ existing right to establish publicly-owned utilities
- Encourage establishment of a statewide public agency to serve bundled utility customers without a public power option until such time as a local agency option becomes available
- Support the operation of investor-owned utility distribution systems as transparent neutral, open-access platforms which facilitate the deployment of distributed energy resources and other demand-side management strategies
- Promote optimization and rebalancing of IOUs’ portfolio
Key Legislation
AB 117 – Passed in 2002 in response to the California Electricity Crisis, AB 117 outlined the steps that must be taken to form a CCA, and laid out how CCAs would be regulated and coexist with the local investor-owned utility (IOU). Among many points, AB 117 mandated that a CCA become the default provider for residents and businesses in its service territory.
SB 790 – Created a code of conduct which IOUs must adhere to in regards to CCAs operating in their service area. Specifically, it prohibited utilities from marketing against CCAs except through a separate marketing division separated by a ‘firewall’ from the other operations of the utility. It was passed in response to several IOUs efforts to stem CCA growth.
Recent Regulatory Filings
December 2020
SDCP CEA and CCA Opening Comments on Alternative PD (01-07-21)
Motion for Party Status by CCA (01-05-21)
Reply Comments to Law Judge Kline’s Proposed Decision on SCE 2021 ERRA and PCIA (12-15-20)
Reply Comments in Extreme Weather Event OIR (12-10-20)
Letter Extending CalCCA FSR Posting Deadline in Resolution E-5059 (12-08-20)
CalCCA Comments Letter on DR E-5114 (12-07-20)
Joint Comments on SDGE U 902 E under the PCIA Account Trigger Mechanism (12-03-20)
Request for Extension of Posting Requirement in Resolution E-5059 (12-02-20)
November 2020
Protest to the IOUs’ FSR Compliance Advice Letters (11-30-20)
CalCCA CAISO RA Enhancement Comments (11-30-20)
Joint Comment on SDGE November Update Application (11-18-20)
October 2020
Comments on CAISO Hybrid Resources Revised Final Proposal (10-30-20)
Reply Comments on CAISO’s Business Practice Manual (BPM) Change Proposed Revision (10-20-20)
Joint Opening Brief of CalCCA and SoCal CCAs in SDG&E PCIA Trigger Application Proceeding (10-20-20)
Comments on CAISO RA Enhancements (10-1-20)
September 2020
CCA Integrated Resource Plans (IRPs)
Protest to PG&E AMP Advice Letter in response to Decision 20-06-003 (9-29-20)
CalCCA and DACC Response to the Joint IOU Advice Letters in Response to Decision 20-03-19 (9-21-20)
Comments on PD Granting CalCCA PFM of Decision 19-11-016 in IRP Proceeding (9-14-20)
Comments on the proposed competitive neutrality rules submitted by PG&E (9-11-20)
Response to Line Loss PFM in PCIA Proceeding (9-8-20)
August 2020
Comments on CAISO Hybrid Resources Draft Final Proposal (8-26-20)
Protest to Expedited Application of SDG&E Application Under the PCIA Trigger Mechanism (8-13-20)
Comments on Draft Resolution E-5059 (8-13-20)
CalCCA and Edison’s Track 3 Proposal in RA Proceeding (8-7-20)
Informal Comments on LCR Compensation Mechanism (8-3-20)
July 2020
Comments on Draft Resolution E-5080 (7-27-20)
Reply Comments on PD For Working Group #2 (Prepayment) in PCIA Proceeding (7-27-20)
Comments on Backstop Procurement and Cost Allocation Mechanisms in IRP Proceeding (7-22-20)
2022 Building Standards Comment Letter to CEC (7-16-2020)
Comments on Three-Year Planning Schedule in IRP Proceeding (7-6-20)
Amicus curiae brief in support of Protect Our Communities’ appeal of CPUC PCIA decision (7-6-20)
June 2020
Comments on CAISO Resource Adequacy Enhancements Working Group (6-24-20)
CalCCA Comments on OIR in IRP Proceeding (6-15-20)
Comments on PD in Confidentiality Proceeding (6-9-20)
Comments on Resource Adequacy Import Requirements PD (6-8-20)
Response to PGE Advice Letter 5827-E (6-4-20)
May 2020
Reply Comments on PD in De-Energization OIR (5-26-20)
Comments on CAISO Hybrid Resources Initiative Second Revised Straw Proposal (5-20-20)
Comments on PD in De-Energization OIR (5-18-20)
Petition for Modification of Decision 19-11-016 in IRP Proceeding (5-14-20)
April 2020
Reply Comments on Resource Adequacy Central Procurement Entity PD (4-20-20)
Joint Response to Motions for Evidentiary Hearings in PCIA Working Group 3 (4-17-20)
Reply Comments on Request for Comments in RPS Proceeding (4-17-20)
Comments on Resource Adequacy Central Procurement Entity PD (4-15-20)
Comments on Limited Rehearing of Decision 19-10-021 (4-6-20)
Track 2 Reply Comments in Resource Adequacy Proceeding (4-2-20)
March 2020
Comments on Request for Comments in RPS Proceeding (3-30-20)
Reply Comments on the Final Report of PCIA Working Group 3 (3-27-20)
Reply Comments on PD considering PCIA working group proposals (3-23-20)
Comments on Track 2 Proposals in RA Proceeding (3-23-20)
Late-Filed Track 2 Proposal in RA Proceeding (3-18-20)
Motion for Leave to Late-Filed Track 2 Proposal in RA Proceeding (3-18-20)
Opening Comments on PD considering PCIA working group proposals (3-17-20)
Motion for Late Acceptance of Opening Comments in PCIA Proceeding (3-17-20)
Reply Comments on RSP PD in IRP Proceeding (3-17-20)
Opening Comments on the Final Report of PCIA Working Group 3 (3-13-20)
Comments on RSP PD in IRP Proceeding (3-12-20)
Reply Comments on Track 1 Proposals in RA Proceeding (3-11-20)
Reply to Responses to CalCCA’s Petition for Modification of D06-06-066 (3-9-20)
Track 1 Comments in Resource Adequacy Proceeding (3-6-20)
February 2020
Comments on Proposed Additional De-Energization Guidelines (2-26-20)
Final Report of PCIA Working Group 3 Co-Chairs (2-21-20)
Opening Comments on Proposed Additional De-Energization Guidelines (2-19-20)
CalCCA Letter of Support to CPUC for GRID Alternatives PFM of D1806027 (2-11-20)
January 2020
Post-Workshop Reply Comments in Direct Access Proceeding (1-27-20)
Comments on Third Straw Proposal – CAISO Resource Adequacy Enhancemants (1-27-20)
Petition for Modification of D.06-06-066 (1-21-20)
Post-Workshop Comments in Direct Access Proceeding (1-21-20)
Comments on CAISO Hybrid Resources Revised Straw Proposal (1-14-20)
Reply comments on Final Working Group 2 Report (Prepayment) by SDG&E, DACC, and AREM (1-13-20)
Comments on IOU post-event reports in De-Energization Proceeding (1-7-20)
Reply Comments on Reference System Portfolio Ruling in IRP Proceeding (1-6-20)
Joint Motion WG 3 to Amend Scoping Memo in PCIA Proceeding (1-3-20)
December 2019
Comments on ALJ Ruling on Proposed Reference System Portfolio and Related Policy Actions (12-17-19)
Comments on AB 1110 Revised Draft Regulations(12-10-19)
Opening Comments on OIR to Oversee RA Program (12-3-19)
November 2019
Comments on PCIA PrePayment Proposal (11-14-19)
October 2019
Comments on Revised Proposed Decision in IRP Proceeding (10-31-19)
Petition for Modification of Decision 19-06-026 in Resource Adequacy Proceeding (10-30-19)
Comments to CAISO on Resource Adequacy Enhancements Second Revised Straw Proposal (10-30-19)
Informal Comments on IRP Resource-to-Busbar Mapping (10-29-19)
Response to ALJ’s Ruling Issuing Staff Reports in Disconnections Proceeding (10-28-19)
Application for Rehearing of Decision 19-10-021 in RA Proceeding (10-24-19)
Motion for Stay of Decision 19-10-021 in RA Proceeding (10-24-19)
Motion to Shorten Time of CPUC Response to Motion for Stay (10.24.19)
Comments to CAISO on Hybrid Resources Straw Proposal (10-21-19)
Responses to Comments in De-energization Rulemaking (10-15-19)
Joint Reply Comments on Motion for Adoption of Settlement Agreement (10-15-19)
Comments on Filing Requirements for 2020 IRPs (10-14-19)
Response to Joint Parties’ Motion on Determining the Capacity Value of Hybrid Resources (10-11-19)
Reply Comments on PD Requiring Electric System Reliability Procurement for 2021-2023 (10-8-19)
Reply Comments on on Electric System Reliability Procurement PD in IRP Proceeding (10-7-19)
Comments on Electric System Reliability Procurement PD in IRP Proceeding (10-2-19)
Reply Comments on PD on WG 1 Issues 1-7 and 11 in PCIA Proceeding (10-1-19)
September 2019
Comments on PD on WG 1 Issues in PCIA Proceeding (9-26-19)
Comments on PD on RA Import Rules in Resource Adequacy Proceeding (9-26-19)
Notice Of Availability Of Second Progress Report Of WG 3 Co-Chairs in PCIA Proceeding (9-26-19)
Proposal in Response to Scoping Memo in De-Energization Proceeding (9-17-19)
Opening Comments in Affordability of Utility Service Proceeding (9-10-19)
August 2019
Joint Motion for Adoption of Settlement Agreement in RA Proceeding (8-30-19)
Reply Comments on IRP Procurement Track Ruling (8-12-19)
Notice of Settlement Conference in RA Proceeding (8-9-19)
Comments on Informal Workshop Reports in RA Proceeding (8-2-19)
July 2019
Reply Comments on Working Group Report in PCIA Proceeding, Questions 8-12 (7-26-19)
Comments on WG One Report on Questions 8-12 in PCIA Proceeding (7-26-19)
Opening Comments on Assigned Commissioner/ALJ Ruling in IRP Proceeding (7-22-19)
Comments on Working Group Report in PCIA Proceeding, Questions 8-12 (7-19-19)
Comments on RA Import Ruling (7-19-19)
CalCCA Comments on RA Import Rules (7-19-19)
Informal Report on Track 2 Workshops 3 and 4 in RA Proceeding (7-17-19)
Motion of Amended Ruling and Extension of Time in IRP Proceeding (7-1-19)
Joint Motion To Amend Scoping Memo in PCIA Proceeding (7-1-19)
June 2019
Progress Report Of WG 3 in PCIA Proceeding (6-24-19)
Response to AReM Petition for Modification of Decision D19-02-022 (6-24-19)
CalCCA Comments on SDG&E/AReM/DACC Suggested Approach to PCIA Prepayment (6-21-19)
Comments on Track 3 Proposed Decision in RA Proceeding (6-13-19)
Post-Workshop Reply Comments in Utility Service Affordability OIR (6-4-19)
May 2019
Reply Comments on Proposed Decision in Direct Access/SB 237 OIR (5-28-19)
CalCCA Comments on Proposed Decision in Direct Access/SB 237 OIR (5-20-19)
Attachment C – in Direct Access/SB 237 OIR (5-20-19)
CalCCA Comments on Draft Resolution E-4998 (5-14-19)
Post-Workshop Comments in Utility Service Affordability OIR (5-13-19)
Notice of Ex Parte Meeting in PCIA Proceeding (5-6-19)
April 2019
Amended Reply Comments on Proposed Decision in IRP Proceeding (4-17-19)
Integrated Resource Planning PD Reply Comments (4-15-19)
CalCCA Reply Comments in Direct Access Proceeding (4-10-19)
Integrated Resource Planning PD Comments (4-8-19)
CalCCA Opening Comments in Direct Access Proceeding (4-5-19)
March 2019
Comments on Track 3 Workshop and Proposals in RA Proceeding (3-22-19)
Comments on Draft Resolution E-4990 (3-4-19)
February 2019
Reply to Response of IOUs’ Motion in PCIA Proceeding (2-19-19)
CalCCA Protest to PGE Advice Letter 5473-E (2-14-19)
Joint Motion of PGE and CalCCA for Workshop Time Extension (2-14-19)
January 2019
IRP – Comments of Joint CCAs on PSP (1-31-19)
Reply Comments on Reliability Ruling (1-14-19)
Comments on Draft Resolution E-49771 (1.11.19)
December 2018
Reply Comments on Proposed Decision in RA Proceeding (12-17-18)
Comments on Proposed Decision in RA Proceeding (12-11-18)
Reply Comments on PD in Tree Mortality Proceeding (12-3-18)
PCIA – Prehearing Conference Statement (12-02-18)
November 2018
Reply in IRP Framework Proceeding (11-30-18)
Opening Comments on Proposed Decision in Tree Mortality Proceeding (11-28-18)
PCIA Application for Rehearing (11-19-18)
Comments on Confidential Treatment in IRP Framework Proceeding (11-16-18)
October 2018
Comments on Assembly Bill 1110 Implementation Plan (10-25-18)
Reply Comments to ALJ Ruling in RA Proceeding (10-24-18)
Response to ALJ Ruling in RA Proceeding (10-17-18)
September 2018
Comments in RA Proceeding (9-14-18)
Reply Comments in PCIA Proceeding (9-13-18)
Comments in IRP Proceeding (9-12-18)
Comments on Alternate Proposed Decision in PCIA Proceeding (9-6-18)
Protest of IOU Advice Letters – Financial Security Requirements (9-4-18)
August 2018
Reply Brief in Tree Mortality Proceeding (8-31-18)
Comments on PCIA Proposed Decision (8-21-18)
Closing Brief in Tree Mortality Proceeding (8-13-18)
Comments on Affordability OIR (8-13-2018)
Comments on Disconnections/Energy Access OIR (8-9-18)
Responsive Comments in RA Proceeding (08-08-18)
July 2018
Protest to PG&E Advice Letter 5322-E (7-19-18)
Direct Testimony in Resource Adequacy Proceeding (7-10-18)
June 2018
Additional Brief in PCIA Proceeding (6-25-18)
CalCCA Reply Brief in PCIA Proceeding (6-15-18)
CalCCA Comments on Green Book (6-11-18)
CalCCA PCIA Opening Brief (6-01-18)
May 2018
CalCCA Tree Mortality NBC Reply Comments (5-18-18)
CalCCA Comments on SB 350 GHG Target Methodology (5-14-18)
CalCCA Comments on the Energy Division Staff Proposal (5-11-18)
CalCCA Reply Comments on Proposed Decision Establishing Reentry fees and Financial Security Requirements for CCAs (5-01-18)
April 2018
CalCCA Reply Comments on GHG Emissions Accounting Methods (4-30-18)
CalCCA_PCIA Rebuttal Testimony (4-23-18)
CalCCA Comments on GHG Emissions Accounting Methods (4-20-18)
CalCCA PCIA Opening Testimony (4-2-18) (zip file)
Exhibit 3-A Sutherland Testimony
Exhibit 3-B Abramson Testimony
Exhibit 3-D Schoenblum Testimony
March 2018
AL_3939-G_5235-E CalCCA Protest_PGE proposed revisions to billing services (3-12-18)
CalCCA Response to Petition for Modification of the Code of Conduct (3-1-18)
January 2018
CCA Parties’ Comments on RA Scoping Memo (1-30-18)
CalCCA Reply Comments on IRP Proposed Decision (1-22-18)
CalCCA Reply Comments – Draft Resolution E-4907 (1-18-18)