Report 2022-120 Recommendations

To ensure that OCPA acts in its customers' best interests when contracting for services, by September 2023 OCPA's board should strengthen its procurement processes by directing staff to follow its policy that prohibits splitting purchases into multiple purchases if doing so results in contracts for amounts that are less than the relevant procurement limits for the amount of the combined purchase.

To ensure that OCPA acts in its customers' best interests when contracting for services, by September 2023 OCPA's board should strengthen its procurement processes by reminding staff to follow its policy that all new contracts of more than $50,000 should be reported at the next regular board meeting and that all contracts of more than $125,000 should be approved by the board before their execution.

To ensure that OCPA acts in its customers' best interests when contracting for services, by September 2023 OCPA's board should strengthen its procurement processes by requiring staff to maintain documentation of the evaluations that they perform of responses to competitive bidding processes, regardless of the dollar amount of the proposal or contract.

To ensure that OCPA acts in its customers' best interests when contracting for services, by September 2023 OCPA's board should strengthen its procurement processes by instructing staff to perform periodic evaluations of contractors' performance and provide those evaluations for the board's review when staff request approval of new contracts or contract amendments with those contractors.

To ensure that OCPA acts in its customers' best interests when contracting for services, by September 2023 OCPA's board should strengthen its procurement processes by amending its procurement policy and contract delegation policy to clarify whether the thresholds in these policies apply to contract amendments.

To ensure that OCPA does not spend or incur fees for which it does not have proper board approval, by May 2023 OCPA's board should direct staff to provide reports on at least a quarterly basis that specify the dollar value of each service contract, the amount paid to each contractor to date, and the amount owed to the contractor for work performed but not yet paid.

To enhance transparency and build trust with its member communities and the public, by May 2023 OCPA's board should direct staff to report no less than quarterly on the number of public records requests received, closed, and pending; the average time OCPA took to respond to those requests; and the reasons for withholding or not providing requested documentation, if applicable.

To demonstrate a commitment to transparency and increase the relevant information it shares with its member communities, OCPA's board should develop a policy outlining the means by and circumstances under which OCPA can share key terms of its power purchase agreements with officials from those member communities without compromising the confidentiality of those terms.

To allow OCPA sufficient time to buy or sell the energy necessary to accommodate changes in a member community's participation, OCPA's board should establish a policy specifying a process for member communities to follow when changing their default rate that includes the number of days of advance notification a member agency must provide to OCPA of its decision to change its default rate before the change occurs.

To allow OCPA sufficient time to buy or sell the energy necessary to accommodate changes in a member community's participation, OCPA's board should establish a policy specifying a process for member communities to follow when changing their default rate that includes the maximum number of times a member community may change its default rate in a given period.

To provide meaningful oversight of OCPA's efforts to monitor, measure, report, and control the market and credit risks that it is exposed to in its normal course of business, OCPA's board should amend its risk management policy to alter the membership of the risk oversight committee to include a limited subset of OCPA board members that does not violate open meeting act requirements.

To provide meaningful oversight of OCPA's efforts to monitor, measure, report, and control the market and credit risks that it is exposed to in its normal course of business, OCPA's board should establish a schedule for the risk oversight committee to provide periodic reports on its activities to the full board.

To provide meaningful oversight of OCPA's efforts to monitor, measure, report, and control the market and credit risks that it is exposed to in its normal course of business, OCPA's board should direct the risk oversight committee to fulfill the functions defined in OCPA's risk management policy.

To allow OCPA to more conclusively demonstrate that it is appropriately responding to public records requests, it should improve its tracking and handling of these requests by developing and following written procedures governing how it processes them.

To demonstrate to stakeholders its compliance with the state law requiring open meetings, by May 2023 OCPA should begin tracking information showing when meeting agendas are made publicly available.

To improve customer retention, OCPA should take steps to build trust with current and potential customers by communicating more clearly with them. For example, it should update its website as soon as feasible to provide additional useful information about its operations and communicate whether and how it has provided savings to customers and other relevant benefits to member communities.

To improve the accuracy of its budget projections, beginning with its fiscal year 2023-24 budget, OCPA should implement its plan to use information it has collected on customer power usage and opt-out rates when making projections of its revenues, its expenditures, and its need to procure power.

To provide sufficient oversight of its contractors and better protect public funds, OCPA should immediately devote additional effort to hiring a power resources director with the necessary expertise to update its projections of power needs, to better evaluate power purchase agreements, and to effectively oversee the work performed by its relevant contractors.