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EBCE customers will have a charge for "PCIA". The Power Charge Indifference <br />Adjustment or "exit fee" is a charge on customers that switch their service over to a <br />CCA from an IOU such as PG&E. PCIA is assessed to cover electricity generation costs <br />acquired by PG&E prior to a customer's departure for EBCE. This ensures that, as <br />PG&E's customer base dwindles, those that remain will not be unfairly burdened with <br />previously acquired energy contract obligations and PG&E's other legacy investments. <br />Since EBCE's rates are pegged to PG&E's, EBCE must absorb the PCIA costs, while <br />still keeping Bright Choice ata 1.5% discount and Brilliant 100 on par with PG&E's <br />rates. Tables 2 and 3 above illustrate the PCIA's effect on EBCE's 3 tiers of rates and <br />PG&E's Solar Choice rate. <br />The California Public Utility Commission (CPUC) determines how the PCIA is <br />calculated. At its October 2018 meeting, the CPUC revisited the PCIA issue, and voted <br />unanimously to restructure it in a way that was generally viewed as favorable to IOUs. <br />Per the new PCIA, CCA customers are now responsible for the IOU's pre -2002 legacy <br />utility -owned generation costs. This means that, for example, utility -owned power plants <br />built before 2002 can be included in the PCIA calculations. In addition, a previously <br />existing 10 -yr cost recovery limit on older generation -related commitments was also <br />removed at the same time, essentially resulting in a lack of sunset date for the PCIA. <br />Both of these methodology changes will result in a PCIA rate increase. Conversely, <br />there will be a $0.005/kWh cap on the year-to-year PCIA rate changes starting in 2020 <br />to prevent the PCIA from fluctuating massively on a yearly basis. <br />According to the CPUC, a typical residential customer leaving PG&E to join a CCA in <br />2018 in PG&E territory can expect a 1.68% increase in their bill under the new PCIA <br />regime, without interference from the CCA. According to EBCE, PG&E's own analysis <br />has found that the CPUC's decision can result in a greater than 18% increase in the <br />PCIA rate. This is concerning for EBCE and will undoubtedly impact their ability to <br />deliver competitively priced power and develop local renewable energy programs. If <br />EBCE is to continue pegging their energy rates to PG&E, they must absorb all PCIA <br />rate increases, which will affect EBCE's projected revenue stream, lengthen the time <br />needed to build up reserves, make it more difficult to enter into long-term renewable <br />energy contracts, slow Local Development Business Plan (LDBP) implementation to <br />fund energy efficiency programs, and limit energy portfolio diversification. Ultimately, <br />EBCE may also be forced to provide smaller rate discounts. <br />However, there is significant uncertainty associated with electricity rates and PCIA, <br />especially in light of PG&E's Chapter 11 bankruptcy filing in January 2019. For example, <br />would PG&E's bankruptcy lead to the restructuring of its debts and financial obligations <br />including past energy contracts? Would it result in future energy purchases with less <br />favorable financial terms for them and, therefore, limit their ability to compete with <br />CCAs? It is very difficult to assess the implications at this time. <br />Page 7 of 20 <br />