10/30/23, 5:41 PM
https://mail.google.com/mail/u/0/?ik=703fa6ea73&view=pt&search=all&permmsgid=msg-f:1781227978816357797&simpl=msg-f:1781227978816357797 1/1 Adrian Bankhead <[email protected]>
2022 Power Content Label comparisons
Tom Kelly <[email protected]> Mon, Oct 30, 2023 at 5:16 PM To: Adrian Bankhead <[email protected]>
Dear Adrian,
Please provide the Executive Committee with this email and attachment prior to the ExComm's meeting on Wednesday.
Thank you.
Tom Kelly
Dear Members of the AVA Executive Committee,
I listened with interest to the presentation EBCE staff made on the Power Content Label at the last Board meeting. I heard CEO Chaset clearly state that the Board should direct the staff to make the changes in power content that they think are appropriate. This statement to the Board has been made previously. It is clear that he is asking the Board to direct staff to make changes in the power content of Bright Choice.
I am attaching a different view on the CCA Comparison chart that staff provided at the October Board meeting. Rather than rank the CCAs by "RPS" content, I've switched it to show the rankings by GHG content. You will see that 5 of the best 6 CCAs on GHGs do not have nuclear in their power mix. That should put to rest the claim that EBCE's GHG content is the result of the Board's decision not to take the nuclear allocation. Also note that PG&E's renewables (and those of the top 5 CCAs) are primarily PCC-1, while EBCE's are a combination of PCC-1 and PCC-2. PCC-2 renewables do not put Californians to work which was another important reason for the formation of EBCE.
I was also pleased to see that Redwood Coast moved up significantly in the rankings from #13 in 2021 to #4 in 2022.
Granted, Redwood Coast is a small CCA, but it is buying power in the same markets as EBCE. They went from 33% renewable and 56% "unspecified" in 2021 to 50% renewable and 5% unspecified in 2022. Quite a remarkable achievement that demonstrates that a CCA can make significant changes in its power content in a short period of time.
Please also look at the "notes" on the spreadsheet. You'll see that 2 CCAs will be 100% renewable by 2030 (not 100% carbon free) and that PCE plans to be 100% renewable by 2025 on a 24/7 basis.
PCE is an interesting case study. PCE has essentially been 100% carbon free since its inception. It is about half the size of EBCE in terms of total accounts and overall electricity load. Nevertheless, PCE's latest financials show that net reserves are at $266M (1st quarter 2023) while EBCE's are at $324M for the same reporting period. The point I'd like to make here is that PCE is the cleanest CCA in northern CA and is in a very strong financial position. Note too, that PCE launched about a year before EBCE.
One other item caught my attention recently. The US EPA is proposing to increase the "social cost of carbon" (https://www.nrdc.org/bio/mohit-chhabra/epa-finds-higher-benefits-curbing-climate-change) to $190/ton. It's currently $40/ton. If there were a legal requirement to pay for the CO2 generated by EBCE (299,000 metric tons in 2021) at the proposed new rate, EBCE would owe nearly $57M, a sum undoubtedly lower than what it would cost to eliminate EBCE's carbon emissions entirely.
I hope this is helpful. Please let me know if you have questions. All the best! Tom Kelly
Berkeley
2020-2021-2022 PCL comparisons.xlsx
24K
Tom Kelly Public Comment for 11/1/23 Ava Community Energy Executive Committee Meeting 2020
RANK
2021
RANK Load Serving Entity
Lbs CO2e per
MWh % Renewable % Unspecified % Nat. Gas % Large Hydro % Nuclear % Other % Unbundled
RECs
2 1 Peninsula 5 49.20% 0.00% 0.00% 50.80% 0.00% 0.10% 0.00% 1 2 Silicon Valley 18 44.10% 0.00% 0.00% 35.90% 20.00% 0.00% 0.00% 4 3 MCE 75 60.50% 1.70% 0.00% 36.80% 0.90% 0.10% 0.00%
3 4 CleanPowerSF 82 55.40% 6.90% 0.00% 37.60% 0.10% 0.00% 0.00% 7 5 PG&E BASE PLAN 98 47.70% 0.00% 8.90% 4.00% 39.30% 0.00% 2.00% 5 6 Sonoma 130 49.70% 9.20% 0.00% 40.60% 0.50% 0.00% 0.00% 8 7 San Jose 168 36.00% 1.30% 0.00% 31.30% 31.30% 0.00% 0.00% 11 8 CALIF. AVERAGE 456 33.60% 6.80% 37.90% 9.20% 9.30% 0.20% NA 6 9 Central Coast 494 38.40% 49.80% 0.00% 11.80% 0.00% 0.00% 0.00% 14 10 Pioneer 542 30.80% 48.40% 0.00% 0.40% 20.40% 0.00% 5.00% 13 11 EBCE 564 42.30% 40.00% 0.00% 15.90% 1.70% 0.10% 0.00% 12 12 King City 567 40.00% 60.00% 0.00% 0.00% 0.00% 0.00% 0.00% 10 13 Redwood Coast 615 33.10% 56.40% 0.00% 10.50% 0.00% 0.00% 0.00% 9 14 Valley 722 12.60% 76.50% 0.00% 10.90% 0.00% 0.00% 0.00% 5 18
75 82
98 130
168
456
494
542
564
567
615
722
0 100 200 300 400 500 600 700 800
PENINSULA
SILICON VALLEY
MCE
CLEANPOWERSF
PG&E BASE PLAN
SONOMA
SAN JOSE
CALIF. AVERAGE
CENTRAL COAST
PIONEER
EBCE
KING CITY
REDWOOD COAST
VALLEY
lbs. CO2e per MWh
Axis Title
2021 Emissions - lbs. CO2e per MWh
Tom Kelly Public Comment for 11/1/23 Ava Community Energy Executive Committee Meeting 2020
RANK
2021
RANK
2022
Rank Load Serving Entity
Lbs CO2e
per MWh
%
Renewable
%
Unspecified
% Nat.
Gas
% Large
Hydro
%
Nuclear
%
Other
2 1 1 Peninsula Clean Energy 9 51.80% 0.00% 0.00% 48.20% 0.00% 0.00% 4 3 2 MCE 44 59.60% 0.50% 0.00% 39.50% 0.40% 0.00%
3 4 3 CleanPowerSF 47 59.90% 2.90% 0.00% 37.20% 0.00% 0.00% 10 13 4 Redwood Coast 49 50.00% 5.00% 0.00% 45.00% 0.00% 0.00% 7 5 5 PG&E BASE PLAN 56 38.30% 0.00% 4.80% 7.60% 49.30% 0.00% 1 2 6 Silicon Valley 72 44.90% 0.00% 0.00% 30.80% 24.30% 0.00% 5 6 7 Sonoma Clean Power 112 50.30% 8.70% 0.00% 40.00% 0.90% 0.10% 8 7 8 San Jose Clean Energy 116 59.20% 8.60% 0.00% 7.40% 24.80% 0.00% 14 10 9 Pioneer 343 44.10% 27.00% 0.00% 1.30% 27.60% 0.00% 11 8 10 CALIF. AVERAGE 422 35.80% 7.10% 36.40% 9.20% 9.20% 2.20% 13 11 11 EBCE 496 49.40% 28.40% 0.00% 21.90% 0.20% 0.10% 12 12 12 King City 580 38.50% 61.50% 0.00% 0.00% 0.00% 0.00% 6 9 13 Central Coast 637 35.80% 58.30% 0.00% 5.90% 0.00% 0.00% 9 14 14 Valley 709 17.50% 75.10% 0.00% 7.40% 0.00% 0.00% Notes:
EBCE will be 100% carbon free by 2030
Redwood Coast will be 100% renewable by 2030.
Peninsula Clean Energy will be 100% renewable - 24/7 - by 2025.
Valley Clean Energy is committed to 100% renewable by 2030.
Tom Kelly Public Comment for 11/1/23 Ava Community Energy Executive Committee Meeting 2020
RANK Load Serving Entity Lbs CO2e per MWh % Unspecified % Nat. Gas % Other % Unbundled RECs 1 Silicon Valley 7 0.20% 0.00% 0.30% 0.00%
2 Peninsula 13 0.40% 0.00% 0.10% 0.00%
3 CleanPowerSF 40 3.50% 0.00% 0.00% 0.00%
4 MCE 77 1.10% 0.00% 0.20% 0.00%
5 Sonoma 80 7.20% 0.00% 0.00% 0.00%
6 Central Coast 151 13.20% 0.00% 0.00% 0.00%
7 PG&E BASE PLAN 160 0.00% 16.40% 0.00% 2.00%
8 San Jose 178 10.50% 0.10% 0.40% 0.00%
9 Valley 190 19.60% 0.00% 0.00% 0.00%
10 Redwood Coast 447 26.30% 0.30% 0.70% 0.00%
11 CALIF. AVERAGE 466 5.40% 37.10% 0.20% NA
12 King City 486 0.00% 0.00% 0.00% 8.00%
13 East Bay 591 44.70% 0.10% 0.20% 0.00%
14 Pioneer 603 55.90% 0.00% 0.00% 2.00%
Tom Kelly Public Comment for 11/1/23 Ava Community Energy Executive Committee Meeting