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<br /> <br /> <br /> <br /> <br />t: <br /> <br />A. Prohibition on IOUs from marketing or lobbying against CCA programs, except <br />1 <br />through an independent marketing division. <br />An IOU cannot market or lobby against CCA program unless through an independent <br />-E to the Commission, SCE stated it had <br />no intent to form an IMD. Therefore, SCE cannot market or lobby against CCA programs. <br />B. Prohibition on IOUs from speaking on behalf of any CCA program, giving any <br />appearance of speaking on behalf of any CCA program, or making any untrue or <br />2 <br />misleading . <br />It is concerning that such interactions are taking place and we urge you to consider the <br />policy behind such rules when exploring the potential benefits of community choice <br />aggregation. Lastly, existing CCA programs are valuable resources of collective knowledge <br />for interested municipalities. We encourage you or your staff to reach out to nearby CCA <br />programs for information, such as Orange County Power Authorityief Executive Officer, <br />Brian Probolsky at brian@ocpower.org, or the many other CCA programs throughout <br />California. <br /> <br />Thank you for listening to our concerns. <br /> <br /> <br />Respectfully, <br /> <br />/s/ Ty Tosdal <br /> <br />Ty Tosdal <br />Tosdal, APC <br />777 S. Highway 101, Suite 215 <br />Solana Beach, CA 92075 <br />(858) 252-6416 <br />ty@tosdalapc.com <br /> <br /> <br />1 <br /> Decision Adopting a Code of Conduct and Enforcement Mechanisms Related to Utility Interactions with <br />Community Choice Aggregators, Pursuant to Senate Bill 790, D. 12-12-036, December 20, 2012 at A1-2. <br />2 <br /> Id. at A1-5. <br /> 2 <br /> <br />