Renewable Energy
Procurement and Power
Content Reporting
10/07/2026
2 The purpose of this review is to provide background information to the Executive Committee regarding renewable procurement and upcoming changes to power content reporting.
Topics:
• Compliance Landscape
• What is a Renewable Energy Certificate?
• Types of Renewable Energy Procurement
• Power Content Label Reporting
• Changes to Power Content Label
• Emissions accounting
• Line losses
Introduction & Overview of Topics
Filing Reporting Body Est. Data Reported
PSD,
PCL
Power Source Disclosure,
Power Content Label
Energy
Commission
1997
RPS Renewable Portfolio
Standard
Public Utilities
Commission
2020
RCPPP Reliable and Clean Power
Procurement Program
Public Utilities
Commission
Under
review
Regulatory Landscape
RE Hydro Unsp.
RE
RE Hydro Unsp. RA
Load
Load
Load
Nuke
Nuke
Renewable generation attributes from solar, wind, small hydroelectric, biomass, etc.
Large Hydroelectric carbon-free generation attributes.
Unspecified generation attributes reflecting mix of resources from grid electricity.
Nuclear carbon-free generation attributes.
Electricity Load by plan (Bright Choice and Renewable 100).
Resource Adequacy for back-up power; compliance requirement for the grid’s worst days. 2 3
1 PCC Physical Renewable Energy Renewable Energy Certificate 1 Generated in or delivered into a
California Balancing Authority.
Certificate from same resource
as energy.
2 Delivered to a non-California
Balancing Authority;
substituted with grid energy.
Certificate is not from same
resource as energy.
3 Not paired or substituted with
energy; AKA “Unbundled.”
Certificate is not from same
resource as energy.
What is a Renewable Energy Certificate?
An accounting tool for renewable attributes to fulfill the CPUC’s RPS Program as defined under CPUC D.08-08-028
and implemented through multiple Senate Bills.
The program defines three Portfolio Content Categories
(PCCs), or “buckets.”
RPS-compliant portfolio: ≥75% PCC1s, ≤ 25% PCC2s, and ≤5% PCC3s.
Ava no longer procures PCC3s and will phase out PCC2s by 2030.
Contract Facility Products Benefits Costs
Short
-Term
Indexed Existing
Bundled Existing
Long
-Term
Fixed Power
Purchase
Agreement
(PPA)
Existing
New-Build
Option Power
Purchase
Agreement
(PPA)
New-Build
Types of Renewable Energy Procurement
+ Portfolio Certainty
+ Portfolio Flexibility
+ Renewable Additionality
RECs RA
Energy BESS
RECs RA
Energy BESS
RECs RA
Energy BESS
RECs RA
Energy
RECs
- Counterparty Credit Risk
+ Price Volatility Exposure
- Price Volatility Exposure
- Development Risks
- Development Risks
- Portfolio Certainty
+ Counterparty Credit Risk
+ Portfolio Complexity
- Portfolio Flexibility
+ Renewable Additionality
+ Portfolio Certainty
- Price Volatility Exposure
+ Development Risks
+ Portfolio Flexibility
- Price Volatility Exposure + Cost Premium
+ Counterparty Credit Risk
- Portfolio Flexibility
+ Operational Risks
+ Operational Risks
+ Operational Risks
Timeline of Renewable Energy Procurement
Option LT PPAs
Firm LT PPAs
Future Firm LT PPAs
(Existing + New Build)
Future ST
Transactions
ST Transactions
Present Future
Current Portfolio
What is the Power Content Label?
• Published annually, based on
the Power Source Disclosure
Report for the prior calendar
year’s electricity generation
from owned or contracted-for
resources.
• Detailed breakdown of the
sources of energy used to
provide electricity.
• Submission is reviewed and
approved by the California
Energy Commission.
8 *CCR 20.2.5.5, §1394 –
Public agencies may either engage an auditor or submit an attestation. → Board voted to engage auditor starting in 2023, so no attestation needed.
Board*
Energy
Commission
Power
Source
Disclosure
Power
Content
Label
Published on
website.
Final numbers.
Energy Generation
Energy Settlements
3rd-Party
Audit*
Compliance Filing
Jan. 2025 Jan. 2026
Reviews
Power
Content
Label
Emailed or
mailed.
Joint Rate Mailer
Emailed or mailed.
Draft numbers, PG&E
comparison.
Jun. 2026 Jul. 2026 Oct. 2026 Dec. 2026
What is the Power Content Label?
Hourly
Annual
Undersupply
Unspecified
Renewables
Carbon Free
Battery Discharging
Load
Battery Charging
Year
Hour of Day
(summed over Year)
2028 Upcoming Changes to Power Source Disclosure
Oversupply
→ Increased accounting granularity.
12 AM 12 AM
Load Matching Interval
• Sums hourly generation over reporting year to each hour-of-day. • Captures hourly undersupply, oversupply, and battery storage charge-discharge. • Effective for 2028 submission for Calendar Year 2027 Power Source Disclosure. • Hourly load accounting will not affect emissions accounting methodology.
Loss-Adjusted Load Analysis Resource-Specific Power Procurement Hour of Year Load Battery
Charge
Battery
Discharge
Little Bit
O’ Wind
Always
Sunny
Massive
Hydro
12:00 AM 200 - - 100 - 100
…
12:00 PM 450 100 - 90 300 120
…
11:00 PM 520 - 20 70 - 110
2028 Upcoming Changes to Power Source Disclosure
Load Matching Interval
→ Introducing hourly load accounting in addition to existing annual load accounting.
What are Line Losses?
• Line losses account for energy dissipating over transmission and distribution lines.
• Compliance reporting change will capture the emissions associated with the fraction of electrons that escapes as heat into the environment as they travel across power lines, from a power plant to the customer. • Effective for 2026 submission for Calendar Year 2025 power content. • Line losses reporting is a new requirement in the Power Content Label.
California Code of Regulations, 20.2.5.5 (July 2025)
§1392 (a.8.A) – “A retail supplier’s transmission and distribution losses shall be determined by applying a loss factor to each specified resource and to unspecified power.”
§1393 (b.2.B) – “retail suppliers shall report transmission and distribution losses associated with each procurement.”
-6.6%
-4.4%
Out-of-State
In-State
How much are Line Losses?
• Losses are assigned to each specified resource
by location (in-state or out-of-state.)
• Additional specified procurement can cover
some losses…
• …but said procurement is also subject to
line losses.
2025 Summary
Power Content Label
Bright
Choice
Renewable
100
Total Retail
Sales
Total Loss-Adjusted Load
GHG Emissions
Intensity 194 0 134 169
Biomass & Biogas 12% 0% 9% 8%
Geothermal 1% 0% 1% 1%
Eligible Hydroelectric 1% 0% 1% 1%
Solar 26% 61% 36% 34%
Wind 15% 39% 21% 20%
Total Renewables 55% 100% 68% 64%
Large Hydroelectric 36% 0% 25% 24%
Nuclear 9% 0% 6% 7%
Unspecified Power 1% 0% 1% 4%
2025 Power Procurement
Line Losses
→ Increased ‘Unspecified Power’ and reduced RE/CF in total loss-adjusted load. 14 • This presentation was an informational review and no feedback is required at this time.
• The required regulatory changes relation to the Power Content Label will be implemented for upcoming and future filings.
• The emission reporting changes may be an important consideration for future procurement decisions.
• Staff will continue to evaluate the potential impacts to portfolio management and consider bringing forth future items to the board related to Ava's power procurement targets.
Conclusion