Illustrative Case: PG&E Indoor Cultivator Weighs Direct Access Against CCA and Bundled Service

The facility and starting situation

Assume an annual-license indoor cultivator in Humboldt County on a single PG&E account in CAISO [cpuc-direct-access]. The building is 12,000 square feet with 6,500 square feet of flowering canopy under LED lighting. DCC reported 7,912 active annual cannabis licenses statewide at its last reporting period, with provisional licensing repealed effective January 1, 2026 [dcc-supplemental-report-fy24-25]. This operator converted from provisional to annual before that deadline.

Lighting and HVAC were permitted under Title 24 controlled environment horticulture rules: spaces above 40 kW of connected horticultural load must meet minimum photosynthetic photon efficacy and dehumidification standards [title24-ceh]. The site runs a 12-hour flower photoperiod with dehumidifiers tied to room setpoints. Coastal North Coast humidity keeps latent loads high even though statewide normals are only 929 cooling degree days and 2,814 heating degree days [noaa-cag-california].

Interval data shows a summer peak demand of 420 kW and winter peak of 380 kW. That places the account on PG&E's demand-metered business schedules (B-10 Medium General Demand-Metered Service stepping to B-19 Medium General Demand-Metered TOU Service above the B-10 threshold), not on small general service [pge-tariffs]. Supply is bundled PG&E portfolio service. The operator heard about Direct Access from a consultant and assumed a supplier contract was a simple sign-up.

Annual usage is assumed at 2.1 million kWh. At the EIA June 2026 California commercial average of 27.33 cents per kWh, that usage alone implies roughly $574,000 a year before demand charges [eia-epm-5-6-a]. The industrial average was 20.74 cents in the same period [eia-epm-5-6-a], but this account pays business delivery schedules, not industrial class rates.

What the baseline bills showed

The table mixes cited program facts with assumed usage. Only rates, caps, and class names are facts; kWh, kW, and dollar totals are inputs for this example.

Line item	Assumption or rate	Monthly (summer)	Notes
Flower and veg lighting	280 kW on 18 h/day combined	151,200 kWh	Assumed load
HVAC and dehumid	120 kW average	86,400 kWh	Assumed load
House and irrigation	20 kW continuous	14,600 kWh	Assumed load
Measured peak demand	420 kW	420 kW	Sets demand schedule
Bundled supply (modeled)	Assume 18.2 cents per kWh energy	~$44,200	Modeled input
Maximum demand charge (modeled)	Assume $32 per kW on B-19	~$13,440	Pull current sheet [pge-tariffs]
Delivery and riders (modeled)	Assume 9.5 cents per kWh	~$23,100	Modeled input
Approximate total		~$80,700	Excludes taxes and PCIA

Annualized, the modeled all-in spend is about $920,000 on 2.1 million kWh, well above the EIA commercial average because demand-metered delivery and time-of-use supply stack on top of energy [eia-epm-5-6-a] [pge-tariffs].

Three supply paths the operator compared

Bundled PG&E service. Simplest administratively. Supply moves with PG&E procurement and rate cases. No lottery, no opt-out window. Demand charges stay on the B schedule regardless of who procures energy [pge-tariffs].

Community Choice Aggregation. The county sits in a CCA territory. Enrollment is automatic with opt-out rights; no lottery [cpuc-direct-access]. Generation price follows the CCA's power content label. PG&E still delivers and bills distribution plus non-bypassable charges, including PCIA on departed load [cpuc-direct-access].

Direct Access through an Electric Service Provider. Non-residential customers may buy from ESPs while PG&E delivers [cpuc-direct-access]. PG&E's Overall Load Cap is 11,393 GWh [pge-direct-access]. New entrants must file Form 79-1117 during the June submission period (June 8 through 12, 2026, 9 a.m. to 5 p.m. PDT) [pge-direct-access]. PG&E runs a randomizer and assigns waitlist numbers; the waitlist expires December 31 each year and must be re-entered [pge-direct-access] [cpuc-da-lottery-2023].

The 2023 lottery illustrates PG&E scarcity: only 185 GWh of headroom existed at lottery commencement, while 560 valid notices were filed and 836 customers remained waitlisted with 3,023 GWh of associated load at year end [cpuc-da-lottery-2023]. SCE cleared its waitlist with 1,206 GWh open; this facility is not in SCE territory [cpuc-da-lottery-2023]. The CPUC declined further DA cap expansion in D.21-06-033 [cpuc-direct-access].

The math on each path

Assume the same 2.1 million kWh and 420 kW peak. Supply-side cents per kWh are modeled inputs, not quotes.

Path	Modeled supply all-in	Modeled annual supply cost	Delivery and demand (unchanged)	Modeled annual all-in
Bundled PG&E	18.2 cents per kWh	~$382,000	~$538,000	~$920,000
Local CCA	16.8 cents per kWh	~$353,000	~$538,000 + PCIA	~$898,000
DA ESP (if admitted)	15.9 cents per kWh fixed	~$334,000	~$538,000 + PCIA	~$879,000

The CCA path saves about $22,000 a year in this model against bundled supply. DA saves about $41,000 if the operator ever clears the lottery, but timing is uncertain. A 2.1 GWh annual load (2.1 million kWh) is large relative to PG&E's 185 GWh lottery headroom in 2023 [cpuc-da-lottery-2023], so a single-account win is unlikely without waitlist attrition over multiple years.

PCIA and other non-bypassable charges can erase part of the supply spread. The operator requested a departed-load estimate from PG&E before filing the Six-Month Notice.

What changed in the plan

The operator filed the June Six-Month Notice to preserve lottery position while switching to the CCA for immediate supply savings [pge-direct-access]. Parallel work included:

LED efficacy upgrade in two veg rooms. Fixtures were below Title 24 thresholds from a 2022 build [title24-ceh]. PG&E's Agriculture Energy Savings Action Plan lists per-fixture rebates for DLC horticultural QPL LEDs at 3.24 umol/J or higher [pge-aesap-grow-lighting]. Assumed savings: 18 kW continuous and 95,000 kWh a year.

Peak demand review. See demand charges explained and peak demand vs. peak usage. Staggering one flower room photoperiod by two hours cut modeled peak demand from 420 kW to 395 kW. That does not change schedules but lowers the monthly demand charge input.

Contract structure. The CCA default was a 36-month portfolio. The operator also priced a DA ESP fixed contract to compare against the CCA if lottery number clears. See fixed vs. index vs. block-and-index contracts.

After twelve months on CCA service with re-entered lottery notices, modeled all-in spend fell from ~$920,000 to ~$885,000: ~$29,000 from supply, ~$6,000 from lower demand, with PCIA modeled at ~$4,000 a year.

What did not work

Assuming agricultural rates. PG&E lists AG schedules for qualifying agricultural power use [pge-tariffs]. Licensed indoor cannabis in a industrial building did not meet the operator's account classification without a tariff fight they chose not to pursue.

Waiting only on DA. Two lottery cycles produced waitlist numbers but no transfer offer. Supply would have stayed on bundled service for 24 months if they had not enrolled in the CCA.

Ignoring PCIA in the ESP quote. The first ESP proposal excluded non-bypassable adders. All-in cost matched the CCA once PCIA was included [cpuc-direct-access].

Skipping LED rebates before a supply decision. Rebates required pre-approval [pge-aesap-grow-lighting]. Ordering fixtures first would have forfeited roughly $12,000 in modeled incentives.

DA wait list monitoring

CPUC Direct Access load caps mean enrollment is not guaranteed even after lottery submission. Track wait list position and maintain bundled service pro forma until DA assignment confirms. Supply savings do not offset delivery demand on bundled SCE schedules until DA transfer completes [cpuc-direct-access].

Six-month notice discipline

PG&E Direct Access requires six-month notice submitted during the June window [pge-direct-access]. Indoor cultivators planning competitive supply should calendar the window at schematic design, not at first harvest. Missing the window delays supply choice by up to twelve months while delivery charges accrue on bundled service.

Bundled delivery while waiting for DA assignment

Until Direct Access assignment completes, delivery demand and TOU rules stay on bundled SCE service. Supply shopping before DA approval does not change delivery class. Budget bundled all-in costs in pro forma until the lottery assigns load space [pge-direct-access].

CCA comparison while on bundled service

Community choice aggregation may offer lower energy rates than bundled PG&E generation while delivery remains on utility schedules. Compare CCA all-in to DA path if lottery wait is long. Neither path removes delivery demand charges on IOU tariffs [pge-direct-access].

Lessons that transfer to other California indoor grows

Treat DA as a lottery ticket and CCA as the practical near-term lever in most PG&E counties [cpuc-direct-access] [cpuc-da-lottery-2023]. File the Six-Month Notice in June if you want DA optionality, but do not delay supply action while waitlisted [pge-direct-access]. Delivery and demand charges follow the B or AG schedule regardless of supplier [pge-tariffs]. Model PCIA before you compare cents per kWh. Confirm Title 24 compliance on any lighting change [title24-ceh]. Read the California switching guide and the PG&E utility page for territory-specific detail.