Asian Americans for Community Involvement

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.

California State Conference NAACP

American GI Forum of California

California Small Business Association

Department of California

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, Director of Advocacy and Development Asian Americans for Community Involvement (AACI) Tracy Hernandez, Founder & CEO Los Angeles County Business Federation (BizFed) Fred A. Romero, State Commander American GI Forum of California

Ronald O. Nichols, President Southern California Edison Deborah Howard, Secretary California Senior Advocates League

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,

Alice Huffman, President California State Conference NAACP

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

Jeanne Orcutt, Executive Director Coastal Energy Alliance

Julian Cañete, President & CEO California Hispanic Chambers of Commerce

Letitia Hanke, CEO ARS Roofing, Solar and Electric Hector V. Barreto, President, Chairman & CEO The Latino Coalition

Shawn Lewis, Policy Director National Federation of Independent Business (NFIB) Eugene “Mitch” Mitchell, Vice President, State Government Affairs & External Affairs San Diego Gas & Electric Company

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

Letitia Hanke, President North Bay Black Chamber of Commerce Mariko Kahn, Executive Director Pacific Asian Counseling Services Jessica Duboff, Vice President of Policy and Business Advocacy Los Angeles Area Chamber of Commerce Lorraine Plass, State Legislative Chair AMVETS Department of California Scott Ashton, CEO Oceanside Chamber of Commerce Pilar Pinel, Founder Embracing Latina Leadership AllianceS (ELLAS) 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 Council 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 Alice Lei, Founder Asian Women Entrepreneurs (AWE) Wendy Urushima-Conn, President & CEO Asian Business Association of San Diego

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 Dan B. Walden, Executive Director Alameda County Taxpayers Association 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 Jack Weir, President Contra Costa Taxpayers Association Rasmey Sam, President & CEO Asian-American Resource Center

Alameda County Taxpayers Association