CCAs and Climate Action Plans:
Start Strong and Plan for Success

SDED has advocated for Community Choice Aggregation (CCA) since 2011 because it's one of the fastest ways to achieve climate objectives.  Climate Action Plans (CAP) can be vital support.  Executive orders from Governors Brown and Schwartzenegger, CAPs require cities and towns comply with the greenhouse gas emission reduction targets in AB 32, the 2006 Global Warming Solutions Act.

CAPs need aggressive action targets and short-term, binding deadlines. The City of San Diego's draft CAP sets a great example: with a CCA at it's core, the plan targets cutting the City's carbon footprint 50% by 2035.

SDED totally supports tough targets. We urge all communities to do the same: put a CCA at the core of your CAP. With the people back in charge of their power, we can choose cleaner, local and ultimately cheaper, power.  To make your plan as strong as possible, here are two issues that require management -- one obvious and one more tricky:

---

Plan Backward from CCA Launch

In a strong CAP, the reduction targets should bind the municipality to action -- with penalties when targets are missed.  To achieve political consensus, however, deadlines can get pushed out years.

To count the CCA's emissions reductions, set the CAP deadline to coincide with the CCA's "Launch Date".  CCA formation requires considerable grass-roots outreach and education.  While this is starting now, there's no reason to delay.  Local actions - market studies, public resolutions, not to mention creation of the supporting infrastructure -- must all precede the CCA launch date. 

When the new non-profit, community-guided CCA is actually delivering clean kilowatt-hours, THAT's when we can count its carbon reductions. 

---

NO Options are "Off the Table"  

Climate planning committees must be free to consider all climate mitigation measures. Including and especially CCAs.  To place any tool “off limits” robs local planners of cost-effective, high-impact options.  Yet to fund local committee efforts, planners may welcome grants from a frequent supporter of energy-efficiency measures, their investor-owned utility (IOU).

To eliminate IOU misconduct toward CCAs, the Assembly passed Senate Bill (SB) 790 in 2011.  Among other things, SB 790 required creation of a Code of Conduct for IOU dealings with and communications about CCAs.  The Code prohibits IOUs from acting against present or potential CCAs. They cannot market-, lobby or speak against CCA's or exercise market power in a way that removes a CCA from consideration. 

An inappropriate use of IOU market power has been reported to SDED.  It came as “strings” in the IOU's grants to local climate action committees.   Funding was conditioned on a requirement that the committee focus on energy efficiency measures only.   The IOU claimed that, in funding any CAP considering a CCA, it might be in violation of SB 790.

Consider it a cautionary tale for CAP planners. This IOU requirement is an effort to keep CCAs off the table.  The IOU undermines a potential source of customer choice and competition, while robbing climate change planners of one of their strongest tools against climate damage.

If you suspect that IOU funding comes with “anti-CCA strings”, you have alternatives.  You can reject the funding and cite the anti-CCA requirement to appeal to other funders.  You can also accept the funding and use SB 790's complaint process to adjudicate the appropriateness of those "strings".    

IN SUM:  Climate Action Plans can offer critical support to Community Choice.  Set aggressive deadlines, working backward from the end result.  Use all the tools available.  Beware of quiet voices arguing “there's plenty of time” to start CCA outreach “later”. Or “energy efficiency is the most important tool you need”.  SDED will continue to shine a spotlight on this climate-CCA interaction, to keep both strong.  Stay tuned.