Letter to Monterey Bay Community Power Policy Board: Review of Monterey Bay Community Power Procurement Plan and Power Supply Mix – September 12, 2017

September 12, 2017

Re: Policy Board Review of Monterey Bay Community Power Procurement Plan and Power Supply Mix

Dear Monterey Bay Community Power Policy Board Members:

I am writing on behalf of Clear Honest Options in Clean Energy (CHOICE), an association created in March 2017 to promote diverse perspectives in the Monterey Bay region about community choice aggregation and broaden the range of options for bringing community choice aggregation to the Monterey Bay region.

On September 6, 2017, the Operations Board for Monterey Bay Community Power approved a resolution, as recommended in a staff report from agency staff, entitled Approval of MBCP Procurement Plan and Power Supply Mix. This resolution directs staff to issue a Request for Offers (RFOs) for the provision of short-term electricity supply.

Although approval of this directive is not an item on your September 13, 2017 meeting agenda, the proposed agency action deserves your attention and public deliberation. The directive approved by the Operations Board on September 6 selected one of six options considered for power supply. See those six options listed in the staff report extracted from the Operations Board meeting materials package and posted on the CHOICE website at Approval of MBCP Procurement Plan and Power Supply Mix. The entire meeting materials package for the meeting is on the Monterey Bay Community Power website at September 6, 2017 MBCP Operations Committee Meeting Agenda Materials.

In the interests of potential ratepayer customers and the local governments that share the agency’s credit guarantee, the Policy Board must be committed to complete analysis and comprehensive review of fiscal implications before choosing one option among several options. As indicated in the staff report, the recommended option (Portfolio Content Category 1) is likely to be more expensive for ratepayers than at least one other viable option (Portfolio Content Category 3). But the staff report also indicates that “certain stakeholders” object to the Portfolio Content Category 3 option.

Under these circumstances, CHOICE recommends that the Policy Board take the following five actions:

1. The staff report for the Operations Board included fiscal calculations for the recommended Portfolio Content Category 1 option but did not include the same fiscal calculations for the other five considered options. The Policy Board and the public (potential customers and ratepayers) should know about the cost differentials for each of the considered options for short-term power supply.

2. At the Operations Board meeting on September 6, representatives of stakeholder groups called for elimination of hydroelectric power from the Portfolio Content Category 1 option. The Policy Board and the public (potential customers and ratepayers) should know about the cost differential between the Portfolio Content Category 1 with hydroelectric power and the Portfolio Content Category 1 without hydroelectric power.

3. The staff report for the Operations Board stated that “certain stakeholders” object to the Portfolio Content Category 3 option. The Policy Board and the public (potential customers and ratepayers) should know the identity of these stakeholders and whether their objections are based on valid assumptions. The Policy Board and the public (potential customers and ratepayers) should also know if there is a legitimate threat of public objections under the California Environmental Quality Act (CEQA) to the agency’s environmental reviews if the Portfolio Content Category 3 option or the Portfolio Content Category 1 option (with the inclusion of hydroelectric power) is chosen.

4. The option to “maximize the use of local (Monterey Bay region) renewable resources, namely solar” should be analyzed by the agency and the Policy Board under two different approaches: (1) an option that allows for public-private partnerships in energy supply and wholesale contracts with private owners of renewable power generation facilities up to at least ten (10) megawatts (MW); and (2) an option that establishes exclusive public ownership, planning, construction, and maintenance of the facilities that provide the agency’s renewable power supply.

5. Prompt establishment of a “Community Advisory Committee” that is organized to include a broad and diverse range of stakeholders, including business and ratepayer organizations. This would provide the public and all stakeholders with a structured official forum to provide formal input and understand the reasoning behind decisions of the agency leadership.

These five actions will ensure greater public accountability and transparency and allow for greater public understanding of the fiscal implications when Monterey Bay Community Power chooses energy supply portfolios and other administrative and operational policies. The success of Monterey Bay Community Power depends on keeping rates reasonable and competitive for customers while providing clean, renewable energy to the people of Monterey, Santa Cruz, and San Benito counties. Thank you for your consideration.

Sincerely,

Kevin Dayton
Representative of Clear Honest Options in Clean Energy (CHOICE)