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Southern California Energy Users Coalition Letter RE: Three Prong Test – OPPOSE July 31, 2019 The Honorable Michael Picker, President California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 RE: Proposed Decision Modifying the Energy Efficiency Three-Prong Test Related to Fuel Substitution – OPPOSE Dear President Picker: The undersigned organizations, which represent a coalition of concerned energy users and providers from across Central and Southern California, must respectfully oppose the Proposed Decision Modifying the Energy Efficiency Three-Prong Test Related to Fuel Substitution which will lay the groundwork for the electrification of all buildings in the state, regardless of the cost or impact to actual communities. While this regulation does not explicitly mandate electrification of all buildings, it is clear that this is the intent. This regulation will limit consumer choice of energy options and would misallocate utility ratepayer funds to measures that are not cost-effective. This proposed decision would remove the second prong of the test, related to cost-effectiveness, with limited public input and no analysis of the costs or impacts of removing the cost-effectiveness test and an opportunity for affected individuals or organizations to fully gauge the impacts of changing a longstanding test. If adopted, this has the potential to remove or reduce ratepayer protections by masking the cost or inflating the benefit of new technologies which might impact energy affordability and grid reliability. As our state is currently facing historic levels of homelessness and poverty, policies that would drastically increase the cost of building compliance and monthly utility bills, which negatively impact housing affordability, are misguided and regressive. 4 Southern California Energy Users Coalition Letter RE: Three Prong Test – OPPOSE But it isn’t just in the home where additional costs will be incurred. Similarly, businesses forced into allelectric commercial buildings would be faced with higher energy costs that they would likely pass through to consumers. The costs of goods and services will rise as a result, increasing the cost of living even further. These are policies that Californians simply cannot afford. We are supportive of cost-effective methods to reduce greenhouse gas (GHG) emissions and protect our environment, but for these reasons above, this coalition must oppose the Proposed Decision Modifying the Energy Efficiency Three-Prong Test Related to Fuel Substitution and respectfully requests your “NO” vote. Sincerely, American Indian Chamber of Commerce Antelope Valley Board of Trade As You Like It Catering & Events Asian Business Association Inland Empire Azusa Chamber of Commerce BizFed - Central Valley Business Federation BizFed - Los Angeles County Business Federation Black Chamber of Commerce of Orange County Boys and Girls Club of Greater Ventura Boys Republic Brotherhood Crusade Building Industry Association of Southern California – Baldy View Chapter Building Industry Association of Southern California – Los Angeles/Ventura Chapter Building Industry Association of Southern California – Orange County Chapter Burbank Chamber of Commerce California Business Roundtable California Center for Public Policy California Clean Distributed Generation Council (CCDC) California Latino Leadership Institute California Restaurant Association California Small Business Alliance Central City Association Chambers of Commerce Alliance of Ventura & Santa Barbara Counties Coachella Valley Economic Partnership Coalition of Labor, Agriculture and Business (COLAB), San Luis Obispo Community Services Employment Training Congress of California Seniors Covina Chamber of Commerce Desert Valleys Builders Association Duarte Chamber of Commerce Food Share of Ventura County Glendora Chamber of Commerce 5 Southern California Energy Users Coalition Letter RE: Three Prong Test – OPPOSE Greater Coachella Valley Chamber of Commerce Greater Irvine Chamber of Commerce Greater Los Angeles African American Chamber of Commerce Greater West Covina Business Association Hawthorne Chamber of Commerce Hermandad Mexicana Nacional Inland Empire Economic Partnership Kern County Kern County Taxpayers Association Kheir Center Latino Chamber of Commerce of Compton Latino Food Industry Association Latino Kids Health Los Angeles Area Chamber of Commerce Los Angeles Gateway Chamber Mexican American Opportunity Foundation NewStart Housing Corporation Orco Block and Hardscape Palm Desert Area Chamber of Commerce Peabody Engineering Precious Life Shelter Proteus Inc. PTS Advance Regional Hispanic Chamber of Commerce San Gabriel Regional Chamber of Commerce San Gabriel Valley Economic Partnership Santa Barbara County Taxpayers Association Santa Barbara Technology and Industrial Association Santa Clarita Valley Economic Development Corporation South Orange County Economic Coalition Southeast Churches Service Center Southeast Community Foundation Southwest Gas The East Los Angeles Community Union (TELACU) The Valley Economic Alliance Tulare Chamber of Commerce Tulare County Economic Development Corporation Valley Economic Alliance Valley Industry and Commerce Association (VICA) Visalia Economic Development Corporation Visalia Emergency Aid Council Western States Financial 6