April 10 Support for SB 1138 (Padilla): Load-serving entities: resource adequacy requirements

April 10^th, 2026

Senator Padilla

1021 O Street, Suite 7630

Sacramento, CA 95814

RE: SB 1138 Load-serving entities: resource adequacy requirements – support 

Dear Senator Padilla,

On behalf of the Marin County Board of Supervisors, I write in support of your authored bill, SB 1138, that supports energy affordability by lowering the cost to consumers of California’s Resource Adequacy (RA) program by allowing load-serving entities (LSEs), including community choice aggregators (CCAs), to transact RA load obligations on an hourly basis to align with the new “slice-of-day” RA program. As a community served by MCE, our local CCA, we support SB 1138 as it will have a materially beneficial impact on the rates of our residents.

The new “slice-of-day” compliance framework for the state’s RA program added requirements for LSEs like MCE to demonstrate that they are buying enough RA to meet their obligations on an hour-by-hour basis, rather than monthly. Unfortunately, current rules only allow RA products to be traded in one-month increments rather than hourly increments, forcing LSEs to buy more RA than they need in order to meet their load obligations for specific hours. This unnecessarily increases demand for a limited supply of RA resources, which puts upward pressure on RA prices and the electric rates that pay for them. These costs fall directly on California ratepayers, including our community members, totaling tens of millions of dollars annually.

SB 1138 addresses this problem head on by allowing LSEs to trade RA load obligations on an hourly basis, thereby aligning RA market rules with the new SOD framework and lowering costs for customers at a time of rapidly rising rates — all without impacting system reliability or LSE accountability.

For these reasons, the County of Marin supports SB 1138 to make California’s RA program more transparent, predictable, and fair. Thank you for your leadership on this issue.

Sincerely,

Eric Lucan, President
Marin County Board of Supervisors

CC:       Marin County Board of Supervisors

Assemblymember Damon Connolly

Senator Mike McGuire