Noble Americas is currently providing these services to all three of the existing California CCAs: Marin Clean Energy, Sonoma Clean Power and Lancaster Choice Energy. E. Service Offerings and Comparison with PG&E CleanPowerSF has performed a detailed review of various additional services provided by PG&E and the availability of these services and comparable service provisions to cover any gaps for customers who opt-in to CleanPowerSF. See Appendix 2 for more details. F. Other Activities 1. Regulatory Advocacy Activities at the major regulatory bodies as well as the legislature can impact virtually all aspects of CleanPowerSF’s operations. California Public Utilities Commission (CPUC). While the CPUC does not regulate CCA’s pricing, they do enforce various operational requirements placed on them by the legislature. These include the Renewable Portfolio Standard, Energy Storage mandates, Resource Adequacy (RA) requirements, public goods charge energy efficiency funding, and rate comparison disclosures. CleanPowerSF regulatory staff must be knowledgeable concerning the requirements of these programs and the reporting protocols so as to remain in compliance. In addition, there are numerous proceedings at the CPUC that can directly or indirectly affect CleanPowerSF, such as PG&E procurement and rate setting proceedings or Commission Rulemaking proceedings that address the exit fees CCA customers must pay. CleanPowerSF regulatory staff will collaborate with other local governments and CCA programs or other strategic partners to leverage resources and influence CPUC policy and proceeding outcomes. The staff will also proactively engage with the CPUC Commissioners and Energy Division staff to inform them of CCA program benefits and challenges. 35 California Independent System Operator (CAISO): The CAISO operates the power grid throughout most of the state, including in San Francisco. CleanPowerSF must remain in compliance with all market rules and requirements as it schedules power to be delivered to the city. California Air Resources Board (CARB): The CARB manages greenhouse gas reporting and operates the state’s Cap and Trade Program. Thus, the CleanPowerSF must comply with all GHG requirements as directed by the CARB. California Energy Commission (CEC): The CEC has must approve any thermal power plant over 50 MW, as well as collect various data (e.g., sales, distributed PV) from all the load- serving entities for forecasting and setting state energy policy. Further, the CEC implements the state’s Power Content Disclosure requirements, and the CleanPowerSF staff must report to the CEC in compliance with those requirements annually. 2. Legal
CleanPowerSF will utilize the San Francisco Office of the City Attorney (City Attorney) as legal counsel to advise regarding administration of CleanPowerSF; review contracts; represent the program as necessary before the CPUC, other regulatory agencies, and the courts; and to provide overall legal support to the activities of CleanPowerSF.