Quarterly Audit and Performance Review Report — CleanPowerSF Sfpuc Commission, August 22, 2023 (part 2 of 2)

x Confirm that the entity listed under “If Seller is providing only RECs to Purchaser and selling the associated electricity to a utility or load-serving entity, please write the name of the utility or load-serving entity here” on the Generator Attestation matches the entity listed as the Entity Purchasing Electricity in the Facility Information table. x Note any exceptions.

Step III.1.10 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: The City of Corcoran facility listed in the Facility Information Table is registered in the WREGIS tracking system.

11. Examine each of the Participant’s Tracking System Reports and for all MWh sold from each facility in a Tracking System, as indicated by a valid Tracking System name appearing on the Facility Information table for the facility or as identified in Step III.1.7, perform the following steps. For guidance on what documentation is appropriate if a question arises, refer to Appendices D and E, covering attestations and tracking system reports, respectively.

Participants do not need to upload tracking system reports for facilities tracked in M-RETS, NAR or PJM-GATS to the verification software, and auditors have the option of performing the checks below by logging into the Participant’s tracking system account(s). However, auditors may still need tracking system reports if they don’t have direct access to the Participant’s tracking system account(s) or if the Participant is reporting a large number of facilities in the Supply section of the verification software. Accordingly, the Participant must be able to provide auditors tracking system reports for M-RETS, NAR and PJM-GATS upon request.

Facility Information table
x Confirm that the following information on the Facility Information table corresponds to what is listed in the Tracking System or Tracking System Report: generating facility name (Facility), facility ID number (Tracking System ID), and fuel/resource type (Resource Type). Note any exceptions. ERCOT Tracking System Reports list only a facility’s ID number and not its name; you do not need to note this as an exception. x Review the facility online date listed in th e Tracking System or Tracking System Report and note all facilities that have a First Operation Date prior to 1/1/2008. x If the fuel/resource type listed in the Tracking System or Tracking System Report is biomass-based, check that the fuel/resource type matches the corresponding Resource Type on the Facility Information table according to the following breakdown: “Gaseous Biomass” includes landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases; “Non-gaseous Biomass” includes wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass.

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equal to what is listed in the Tracking System or Tracking System Report in aggregate for that month (in the case of ERCOT, confirm by quarter of generation). x For facilities with “Yes” under the “Approved Tracking Attestation?” column on the Facility Information table, confirm that the date of generation listed in Month/Quarter and Year on the Generation Information table falls between the Start Date and Exp.

Date listed on that facility’s row on the downloadable list of approved facilities on the Audit Protocol and Training page within the verification software. x If a facility is in a Tracking System for t he period of generation listed on the Generation Information table, but the Tracking System column on the Facility Information table does not show a tracking system name, the Participant will still have to provide a valid Tracking System Report for the generation and/or a login to their Tracking System account.
x Confirm that the MWh listed under “Total Generation Volume (MWh)” on the Facility Information table for tracked facilities were retired or transferred to another account holder according to the Tracking System or Tracking System Reports. “Pending” or “Active” transactions are not acceptable. Confirm that the “Retirement Reason” or “Memo” field of each retirement includes, at minimum, the terms “Green-e Energy” and “2022”. See Appendix F for required Tracking System memo language for each Tracking System.
x Participants may provide the Serial Numbers of RECs in Tracking Systems, in the Generation Information table. Providing serial numbers is an optional step in the software system, but if this information may be useful in conducting the audit if it is provided. Comparison of provided serial numbers to Tracking System Reports is not required under this Protocol.

General
x Note if Participant is not named as the owner of the Tracking System account that generated the Tracking System Report. If Participant is not named as the owner of the account, note whether Participant is named as the retirer or transferor of the amount of MWh on the Tracking System Report. All Participants that purchased and sold RECs that are tracked in a tracking system must have their own tracking system account. In certain circumstances, Green-e® Energy may allow RECs to be retired for a certified retail product in the tracking system account of a different Green-e® Energy participant, rather than the account of the participant offering the retail product.

Participants must receive approval from a Green-e® Energy representative to qualify for this exception.
x If Participant is not named as the owner of the Tracking System account that generated the Tracking System Report, and the Participant has not received approval from Green- e® staff for RECs to be retired in the tracking system account of a different Green-e® Energy participant, Participant must supply chain of custody documentation back to the point of retirement. Therefore, note whether Participant has provided one or more completed Wholesale Attestations that match the retirement and that document the chain of custody starting from REC retirement on the Tracking System Report. x Log into Participant’s corresponding Tracking System account, or view an employee of Participant accessing the account, and compare each Tracking System Report to data

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in Participant’s corresponding Tracking System account. If facilities are tracked in M- RETS, NAR or PJM-GATS, this check may be skipped if the Participant did not provide tracking system reports.
x The Participant does not need to provide Tracking System documentation showing transfer of the RECs into Participant’s account.
x Note any exceptions discovered at any point during this step.

Step III.1.11 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”:

Facility Information Table:

1. Crowe observed that the identifying information for the City of Corcoran facility listed on the Facility Information table corresponds to what is listed on CleanPowerSF's WREGIS Tracking System account. No exceptions were noted.

2. Crowe observed the facility online date listed on CleanPowerSF's WREGIS Tracking System account and observed that the City of Corcoran facility listed by CleanPowerSF have a First Operation Date after January 1, 2007.

Generation Information Table:

1. Crowe observed that the dates of generation listed on the Generation Information table for the City of Corcoran reported generating facility matches what is listed on CleanPowerSF’s WREGIS Tracking System account, and that the corresponding volume of MWh on the Generation Information table is equal to what is listed on CleanPowerSF’s WREGIS Tracking System account in aggregate.

2. Crowe observed that the Company indicated "Yes" under the “Approved Tracking Attestation” column on the Facility Information table for the City of Corcoran reported facility. Therefore, for the facility that indicates “Yes” Crowe observed that the date of generation listed in Month/Quarter and Year on the Information table falls between the Start Date and Expiration Date listed for that facility on the downloadable list of approved facilities that is located on the Audit Protocol and Training page within the verification software.

3. Procedure 3 under "Generation Information table" is not applicable because CleanPowerSF did fill in a tracking system name under the Tracking System column of the Facility Information table for all facilities.

General:

1. Crowe observed that CleanPowerSF is named as the owner of the Tracking System account that the Company provided us access and walkthrough instructions.

2. Crowe observed that none of the CleanPowerSF supply was listed as “Pending” or “Active” transactions in the Tracking System.

12. For all facilities that have “No” listed under “Approved Tracking Attestation” and that have a tracking system name under “Tracking System” and for which Participant submitted Generator, Wholesale or Small Generator Attestations (this includes those facilities identified in Step III.1.4 as using Generator, Wholesale or Small Generator Attestation), AND for all facilities identified in Step III.1.7 as being in a tracking system, AND for facilities that have “Yes” listed under “Approved Tracking Attestation” and that Participant purchased as a Green-e® Energy certified wholesale purchase and did not provide a Tracking System Report:
x Use Appendix D for general guidance on attestation types and chain of custody documentation.

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x From the attestations, note all facilities (and the corresponding dates) that have a First Operation Date prior to 1/1/2008, and all facilities that list any date under Date of Repowering or Upgrade.
x Trace and confirm complete documentation of the chain of custody of the renewable MWh:
o Obtain a completed and signed Wholesale Attestation that lists the Participant as the purchaser and the Seller as the entity listed as the Supplier in the Facility Information table.
o Obtain one or more completed and signed Wholesale Attestations, one for each transfer of ownership of the renewable MWh from the generator, all intermediaries, and the Participant. Each purchaser named on the preceding attestation must be the seller on the next attestation, until the Participant is listed as the purchaser on the final attestation.
o Obtain a completed and signed Generator Attestation from the generator that names the seller in the last Wholesale Attestation as the purchaser of the renewable MWh.
x If no Generator Attestation is provided, and the earliest Wholesale Attestation in the chain of custody both lists a Seller that is listed in Appendix G and indicates “Yes” under “Selling as Green-e® Energy certified Wholesale?” in the rightmost column of the sales table, then no attestation documents further up the chain of custody than such a Wholesale Attestation are necessary. This is because the upstream seller of a certified wholesale transaction will provide documentation further up the chain of custody.
x Confirm that the generating facility name, fa cility ID number, nameplate capacity, first operational date, and fuel/resource type listed in the Facility Information table match what is listed on each Wholesale Attestation and the Generator Attestation. x If the fuel/resource type is biomass-based, check that either “Gaseous Biomass” is entered in the Facility Information table for landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases, or “Non-gaseous Biomass” is entered for wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass. Confirm that Section IV of the Generator Attestation, “Additional statement required for and applicable to biomass facilities only,” has been completed.
x Confirm that the generator location (state or province) listed on the Facility Information table matches the Generator Attestation.
x Confirm that the date of generation and volume of MWh listed in the Generation Information table match what is listed in each Wholesale Attestation and the Generator Attestation. The MWh volume listed on the attestation must be greater than or equal to the MWh volume listed in the Generation Information table. x For the Wholesale Attestation that names the Participant as the purchaser, in the Declaration Section of the Wholesale Attestation (Section II), confirm that if the “electricity bundled with renewable attributes” is marked, then “Electricity” is listed in the Purchase Type column of the Facility Information table. If “renewable attributes only” is marked, confirm that “REC” is listed in the Facility Information table.

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x Confirm that the “No” box is checked in the cap-and-trade section of the Generator Attestation (Declaration, Section III). If the “Yes” box is checked, note the cap-and-trade program, refer Participant to footnote 21 of the Standard for Canada and the US and contact Green-e® Energy staff immediately.
x Confirm that each attestation is signed by an agent of the Seller. x Confirm that the entity listed under “If Seller is providing only RECs to Purchaser and selling the associated electricity to a utility or load-serving entity, please write the name of the utility or load-serving entity here” on the Generator Attestation matches the entity listed as the Entity Purchasing Electricity in the Facility Information table. x Note any exceptions
Step III.1.12 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: The City of Corcoran facility has “Yes” listed under “Approved Tracking Attestation” and the only facility is registered in the WREGIS Tracking

13. This Step III.1.13 applies to MWh for which no Tracking System Report is required. Use the Sampling Guidelines listed in Section II.11 of this Protocol to determine the appropriate sample size for the number of entries and apply this step for those entries in the sample.

For this step, the sampling unit is purchases and/or generation quarters from a facility.

Compare each selected item per the Generation Information and Facility Information tables to a copy of the billing invoice that contains information regarding renewable MWh purchased and/or generated, date of generation (the date of generation can be in terms of month/year), and resource type. Note, it may be necessary to also examine a copy of the contract or other documents to test this information (specify in the Auditor’s Agreed-Upon Procedures Report if the contract or other documents were used). Note any exceptions.

This step is not necessary for purchases and/or generation for which a Tracking System Report was provided from Participant’s account or naming Participant specifically in the retirement reason / memo.

Step III.1.13 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: The City of Corcoran facility listed in the Facility Information Table is registered in the WREGIS tracking system and the Company provided tracking system reports.

Population Size (required, must fill in): N/A
Sample Size (required, must fill in): N/A

14. For all purchases sampled in Step III.1.13, examine the purchase date on each billing invoice. Report as an exception any purchases after June 1, 2023. For supply in a Tracking System reported toward RY2022 sales, if the Date of Submission to the Auditor (Reporting Tools>>Audit Status) is after June 1, 2023, also examine the date of transfer to the Participant in each Tracking System or Tracking System Report (this can be done in conjunction with Step III1.11); if you find any transfers occurring after June 1, 2023, review the corresponding supply contract for the date of signature. If the date of signature is after June 1, 2023, note as an exception. If the Participant is submitting the Annual Verification Submission beyond the June 1, 2023 verification submission deadline, check all purchase dates (not just a sample) and all dates of REC receipt in Tracking Systems.

Step III.1.14 was performed: Yes. No. N/A.

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15. Check that all facilities have a date on or afte r 1/1/2008 in the First Operation Date column of the Facility Information table. For all facilities with a date before 1/1/2008 in that column or with “Yes” in the Re-Powered column, check that there is a Repowering Letter signed by a Center for Resource Solutions employee on file with CRS, either uploaded by Participant in the verification software or otherwise indicated as approved in the verification software. If letter has been uploaded by Participant, confirm that information on the submitted letter agrees with corresponding facility information in the verification software system: Facility Name, First Operation Date, Re-Powered Date, and Resource Type. Note any exceptions.

Step III.1.15 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed the City of Corcoran generating facility listed on the Facility Information table has a First Operation Date that is after January 1, 2007.

16. For all facilities with a “No” under “Approved Tracking Attestation” in the Facility Information table with Gaseous Biomass or Non-gaseous Biomass listed as a resource type on the Facility Information table, examine the Biomass section of the attestation and note any biomass fuels that are not allowed under the Green-e® Renewable Energy Standard for Canada and the US, Section II.A.5. Be aware that the resource type “Gaseous Biomass” in includes landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases, and that “Non-gaseous Biomass” includes wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass. Note any exceptions.

Step III.1.16 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: The City of Corcoran facility listed on the Facility Information table is in the WREGIS tracking system and is listed as a "solar" resource type and has "Yes" under "Approved Tracking Attestation".

17. For all facilities not in a Tracking System listing a resource type of Gaseous Biomass or Non-gaseous Biomass compare the generator’s name and location to the appropriate government database of renewable electricity generators. For US facilities, use the Form 860 database (available at: https://www.eia.gov/electricity/data/eia860/) to determine whether the biomass fuel is being co-fired with a non-eligible fuel as defined in the Green- e® Renewable Energy Standard for Canada and the US. For Canadian facilities, check the database of the Province of facility location. List biomass facilities that are labeled as co- firing or multi-fuel, or that do not appear in the most recent EIA Form 860 database or Provincial database, or do not have corresponding Co-firing Approval Letters uploaded into the verification software. Note any exceptions.

Step III.1.17 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: The City of Corcoran facility listed on the Facility Information table is in the WREGIS tracking system and is listed as a "solar" resource type.

18. For all facilities not in a Tracking System (e ven if EcoLogo certified) with a number greater than 5% in the “Co-Firing %” column, check that there is a Co-firing Letter signed by a Center for Resource Solutions employee on file with CRS, either uploaded by Participant in the verification software or otherwise indicated as approved in the verification software. If letter has been uploaded by Participant, confirm that the details of the letter correspond to facility information entered in the software system. If no letter was submitted, check that the Participant submitted a Tracking Attestation and Tracking Report to substantiate their

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ownership of the facility’s renewable MWh. The most common co-firing facilities are industrial facilities that burn Non-gaseous Biomass with fossil fuels (for example, pulp and paper mills). Note any exceptions.

Step III.1.18 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: ”: The City of Corcoran facility listed on the Facility Information table is in the WREGIS tracking system and does not have a number in the "Co-Firing %" column.

19. If the Participant sold Green-e® Energy certified products in RY2021, and the purchases and/or generation reported as supply for RY2022 includes generation that occurred July 1, 2021, through March 31, 2022, verify that generation from that 9-month period was not claimed for sales made in RY2021 by reviewing the Participant’s Annual Verification Submission from RY2021. If the facilities being reviewed are in tracking systems or were at the time of use in the prior RY, also check Tracking System Reports for the prior RY to check that the MWh reported as supply in RY2022 were not already retired for a purpose other than support of RY2022 certified sales. Note any exceptions.

Step III.1.19 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Step was not performed because management indicated the program did not exist.

20. If the Participant’s Checklist (Home>>Review Participant Data>>Participant’s Products, Notes, Customers, and Additional Steps) denotes an electricity product by listing either Competitive Electricity, Utility Green Pricing, or Community Choice Aggregation (in some cases) in the Product Category Type field, examine the geographic location of facilities listed as supplying generation in the Facility Information table and verify that it meets the geographic eligibility requirements in sections IV.A and IV.B of the Green-e® Renewable Energy Standard for Canada and the US. Note any exceptions.

Step III.1.20 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed the geographic location of the facility listed and verified and the facility met the requirements set forth in Sections IV.A and IV.B of the Geographic Eligibility Requirements. No exceptions were noted.

21. For facilities located in Maine, note if the “Check box if sale is part of a Qualifying Facility (QF) contract” field on the Generation Attestation(s) is checked off. If so, note the date that the contract with the utility was initiated and if the facility is a Qualifying Facility (QF) under the Federal Energy Regulatory Commission.

Step III.1.21 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Maine.

22. For facilities located in Connecticut a nd where only RECs were purchased by the Participant, note if the Generation Attestation has the “Check box if sale is part of a Qualifying Facility (QF) contract” box checked off.

Step III.1.22 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Connecticut.

23. For facilities located in Arizona, verify th at the facility does not appear in the Utility EPS/REST Compliance Reports of Arizona Public Service Company and Tucson Electric

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Power Company for the calendar year of generation
(https://edocket.azcc.gov/search/docket-search/item-detail/19403). If the facility does appear in the Utility EPS/REST Compliance Reports of Arizona Public Service Company and Tucson Electric Power Company, check table 1a. of that report to confirm that the Utility meets its required Compliance Measure targets with enough RES resources. Confirm that REST report subtracts out the MWh associated with RECs proposed for Green-e® Energy certification before total generation is reported. Confirm that REST report contains (e.g. in a table) a listing for each source of generation that clearly shows whether the RECs were used towards REST compliance. Confirm that REST Report includes a statement identifying the MWh that are subtracted out (identified above) and that those MWh were not counted towards REST compliance. (As an example: “Green Product sales are subtracted from total Renewable Generation, and do not count toward compliance with REST targets.”)
Step III.1.23 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Arizona.

24. Note any generators located in Texas that use renewable resources other than wind and were first operational on or after September 1, 2005.

Step III.1.24 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Texas.

25. Confirm that an appropriate amount of Compliance Premiums (CP) were retired in ERCOT based on the supply reported from all Texas non-wind generators. The Participant must provide Tracking System Reports and/or other documentation substantiating that the appropriate number of CP have been retired. Note any exceptions.

Step III.1.25 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Texas.

26. Note whether any facilities are located in Hawaii. Facilities in Hawaii are not eligible and should not be included in the Participant’s Green-e® Energy certified products.

Step III.1.26 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Hawaii.

27. If any hydropower supply is located in Canada, confirm that the facility was EcoLogo certified during the period of generation being claimed toward the RY being verified by checking the EcoLogo website, at: https://spot.ul.com/main- app/products/catalog/?keywords=Renewable+Low-Impact+Electricity. Note any exceptions.

If the EcoLogo website does not list the supplying facility, request documentation from the Participant that shows that the hydropower facility is EcoLogo certified. Note any exceptions.

Step III.1.27 was performed: Yes. No. N/A.

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Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Canada, nor is hydropower the resource type.

28. For facilities on the Facility Information ta ble that are owned by the Participant and not tracked in a Tracking System, compare the MWh recorded as “Total Generation Volume (MWh)” on the Facility Information table to meter readings made by an independent third- party (such as a scheduling coordinator or a meter data management agent) at the generation side of the busbar. Agree the generator name and location to an attestation or to other documents such as the generator FERC registration or state operating permit that substantiates the name and type of generation facility. Also obtain from the Participant a copy of the most recent meter certification and note the date of the certification below.

Note any exceptions.

Step III.1.28 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are owned by CleanPowerSF.

29. If any Small Generator Attestations were supplied for a generator on the Facility Information table, compare each Small Generator Attestation and the respective small generator’s entry in the Generation Information table for the renewable MWh supplied to Participant. If the generation supplied is broken down by quarter in the Generation Information table and the attestation does not record generation by quarter:
x 2021 generation listed on the attestation should be listed as Q3/2021 in the Generation Table
x 2022 generation listed on the attestation should be listed as Q1/2022 in the Generation Table
x 2023 generation listed on the attestation should be listed as Q1/2023 in the Generation Table
If the generation supplied is broken down by quarter in the Small Generator Attestation and the corresponding generation on the Generation Information table is broken down by quarter, no further action is necessary for that attestation under this step.

Step III.1.29 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not provide any small generator attestations.

30. Obtain from the Participant a copy of the Green-e® Energy Attestation from Program Participant (which is Appendix H of the Getting Started Guide). Make sure this attestation is included with the final Annual Verification Submission. Note any exceptions.

Step III.1.30 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe obtained the Attestation from the verification software and observed that the attestation was included in the final Annual Verification Submission.

31. Check the Participant’s Products, Notes & Customers (Audit Participant Data>>Participant's Products, Notes & Customers) for any additional audit steps to be performed. Describe here what steps were performed. Note any exceptions.

Step III.1.31 was performed: Yes. No. N/A.

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Exceptions, Notes, Reason for “No” or “N/A”: Crowe checked the "Additional Verification Steps Entered by Green-e Staff" section of the verification software system. No additional audit steps were listed.

32. For all facilities located in California, and for all facilities listed in documents uploaded under “California” on the “Special Cases” page that refer to California allowances, check that greenhouse gas allowances have been retired. The following options can demonstrate that allowances have been retired:
x For MWh from facilities that were not used in wholesale sales:
i. Confirm that RECs were retired in WREGIS and that the “CARB” retirement reason specifies “Green-e Energy RYXXXX,” and any other applicable details as outlined in Appendix F;
ii. Check that there is an application to the California Air Resources Board (ARB) requesting allowance retirement for the MWh claimed from the facility uploaded under “Other Supporting Documents”;
iii. Confirm that the application is for the correct number of MWh and that all facility information matches what has been reported under the Facilities table and on the WREGIS retirement report;
iv. Check that there is a response from the ARB confirming allowance retirement uploaded under “Other Supporting Documents” for the correct number of MWh from the facility; or
x For MWh from facilities that were used in wholesale sales:
v. Check that a completed “Green-e® Energy Attestation for the Retirement of California Greenhouse Gas Allowances” (“Allowance Attestation”) was uploaded under “Other Supporting Documents” along with proof of retirement of allowances in the form of a retirement report from the Compliance Instrument Tracking System Service (CITSS);
vi. Confirm that the number of MWh an d facility information on the Allowance Attestation matches the information on the Facilities table, and that the allowances retired in CITSS matches the allowances listed on the Allowance Attestation.

List all California facilities and all facilities for which California-related allowance documentation was uploaded under “Other Supporting Documents”. Note any exceptions.

Step III.1.32 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed CleanPowerSF reported the City of Corcoran facility was located in California. Crowe observed that the RECs were retired in WREGIS. No exceptions were noted.

33. For all facilities located in BC, AB, WA, ID, MT, OR, WY, CA, NV, UT, CO, AZ, or NM, confirm that the Participant has answered the “Is this facility directly importing electricity into

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California?” question in the “Electricity/REC” section of the Facility Summary. If the question does not appear, note as an exception.

Step III.1.33 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed the City of Corcoran generation facility is located in California. Crowe observed that CleanPowerSF answered "Yes” to the question "Is this facility directly importing electricity into California?" No exceptions were noted.

34. For all facilities located in QC, check that greenhouse gas allowances have been retired.

Since Quebec and California’s carbon markets are linked, it’s possible to use California allowances to satisfy this requirement. The following options can demonstrate that allowances have been retired:
x For MWh from facilities that were not used in wholesale sales:
i. Confirm that RECs were retired in WREGIS and that the “CARB” retirement reason specifies “Green-e Energy RYXXXX,” and any other applicable details as outlined in Appendix F;
ii. Check that there is an application to the California Air Resources Board (ARB) requesting allowance retirement for the MWh claimed from the facility uploaded under “Other Supporting Documents”;
iii. Confirm that the application is for the correct number of MWh and that all facility information matches what has been reported under the Facilities table and on the WREGIS retirement report;
iv. Check that there is a response from the ARB confirming allowance retirement uploaded under “Other Supporting Documents” for the correct number of MWh from the facility; or
x For MWh from facilities that were used in wholesale sales:
v. Check that a completed “Green-e® Energy Attestation for the Retirement of California Greenhouse Gas Allowances” (“Allowance Attestation”) was uploaded under “Other Supporting Documents” along with proof of retirement of allowances in the form of a retirement report from the Compliance Instrument Tracking System Service (CITSS);
vi. Confirm that the number of MWh an d facility information on the Allowance Attestation matches the information on the Facilities table, and that the allowances retired in CITSS matches the allowances listed on the Allowance Attestation.

Step III.1.34 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the facilities listed on the Facility Information table are located in Quebec.

Step III.1.35 only needs to be performed for Participants offering a certified broker product

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35. This step applies to all facilities reported by the Participant that are registered in approved Tracking System that is not M-RETS, NAR or PJM-GATS. Participant must provide a Tracking System Report reflecting the renewable MWh reported within the verification software exported from either the supplier’s or the purchaser’s Tracking System account. For guidance on what documentation is appropriate if a question arises, refer to Appendices D and E, covering attestations and Tracking System Reports, respectively. None of the checks below need to be performed for facilities tracked in M-RETS, NAR or PJM-GATS.

Facility Information table
x Confirm that the following information on the Facility Information table corresponds to what is listed on the Tracking System Report: generating facility name (Facility), facility ID number (Tracking System ID), and fuel/resource type (Resource Type). Note any exceptions. ERCOT Tracking System Reports list only a facility’s ID number and not its name; you do not need to note this as an exception.
x Review the facility online date listed in th e Tracking System or Tracking System Report and note all facilities that have a First Operation Date prior to 1/1/2008. x If the fuel/resource type listed in the Tracking System or Tracking System Report is biomass-based, check that the fuel/resource type matches the corresponding Resource Type on the Facility Information table according to the following breakdown: “Gaseous Biomass” includes landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases; “Non-gaseous Biomass” includes wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass.

Generation Information table
x Confirm that the date of generation listed on the Generation Information table for each facility (Audit Participant Data>>View Participants Data>>Supply>>View Generation; accessed by clicking on “View Generation” on the Facility Information table) matches what is listed in the Tracking System or Tracking System Report, and that the corresponding volume of MWh on the Generation Information table is less than or equal to what is listed in the Tracking System or Tracking System Report in aggregate for that month (in the case of ERCOT, confirm by quarter of generation). x For facilities with “Yes” under the “Approved Tracking Attestation?” column on the Facility Information table, confirm that the date of generation listed in Month/Quarter and Year on the Generation Information table falls between the Start Date and Exp.

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“Active” transactions are not acceptable. Confirm that the “Retirement Reason” or “Memo” field of each retirement includes, at minimum, the terms “Green-e Energy” and “2022”. See Appendix F for required Tracking System memo language for each Tracking System.
x Participants may provide the Serial Numbers of RECs in Tracking Systems, in the Generation Information table. Providing serial numbers is an optional step in the software system, but if this information may be useful in conducting the audit if it is provided. Comparison of provided serial numbers to Tracking System Reports is not required under this Protocol.

General
x If the Participant provides a Tracking System Report from the purchaser’s Tracking System account, all certified renewable MWh reported on the Facility Information table must be retired within the Tracking System following the retirement guidance found in Appendix F.
x If the Participant has their own account for the relevant Tracking System, verify that the RECs were transferred into the specified purchaser’s account. x Note any exceptions discovered at any point during this step.

Step III.1.35 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF's product is not a certified broker product. Therefore, this step does not apply.

Additional Auditor Comments

16. Green-e® Energy Certified Wholesale Sales
Applicability and Intent of the Section
This section applies to Participants that sold renewable MWh in Green-e® Energy certified wholesale transactions, with the intent of verifying certified sales made to other sellers of renewable MWh.

Background and Important Reminders for the Section
x In almost all cases, certified sales to any other Green-e® Energy Participant will be a wholesale sale and should be listed under the Wholesale Sales section; see Appendix G for a list of Participants taking part in Green-e® Energy in RY2022. x Customers that are using the renewable energy and not reselling it are retail customers and should not be accounted for under Wholesale Sales.

Software System Pages needed:

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x Wholesale Sales table (Audit Participant Data>>View Participant’s Data>>Wholesale Sales), also found on the “View All” table (Audit Participant Data>>View Participant’s Data>>View All)
x Wholesale Details table (Audit Participant Data>>View Participant’s Data >>Wholesale Sales>>Wholesale Details); accessed by clicking on “Details” on the Wholesale Sales table

Audit Procedures for Wholesale Sales

1. Obtain from Participant:
x Sales contracts with wholesale customers
x bills of sale or invoices for sales to wholesale customers x any other company records that contain information on wholesale customers and their purchases of Green-e® Energy certified products
Step III.2.1 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: All of CleanPowerSF’s RY2021 sales were retail sales.

2. Using the Sampling Guidelines in Section II.11, select a sample of wholesale customers listed on the Wholesale Sales table and perform the following for each item. For this step, the sampling unit is an individual quarter/month of wholesale sale delivery to an individual customer from and individual facility. Compare each selected sampling unit to a copy of the corresponding billing invoice (e.g. the bill sent to the Participant’s customer) that contains information regarding generator name, MWh resold, date of generation, date of sale to wholesale customer, name of wholesale customer and resource type for the wholesale transaction to the customer (the date of generation can be in terms of month/year or quarter/year). Note, it may be necessary to also examine a copy of the contract or other documents to test the information (specify in the Agreed-Upon Procedures Report if the contract or other documents were used). Be aware that contracts may be written to cover multiple years of sales, so only compare 2022 sales and deliveries to wholesale sales information in the software system for multi-year contracts. For Participants sourcing from a facility that is registered in an approved electronic Tracking System (as indicated on the Facility Information table), a Tracking System Report can substitute for the billing invoice if it substantiates generator name, MWh resold, date of generation, date of sale to wholesale customer, name of wholesale customer, resource type and the fact that the sale was Green- e® Energy certified in the RY being verified (see Appendix F for acceptable ways that certification and RY can be indicated in each Tracking System). Note any exceptions.

Step III.2.2 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: All of CleanPowerSF’s RY2021 sales were retail sales.

Population Size (required, must fill in):

Sample Size (required, must fill in):

3. Compare customers listed in the Wholesale Sales table (Audit Participant Data>>View Participant’s Data>>Wholesale Sales) with an “N” under “Green-e® Energy Participant” to the list of Green-e® Energy Participants in Appendix G. Note any such customers on the Wholesale Sales table that have names similar to a company listed in Appendix G.

Step III.2.3 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: All of CleanPowerSF’s RY2021 sales were retail sales.

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4. For facilities listed in Wholesale Details page that are in a Tracking System, check that the corresponding MWh were transferred to or retired in the Tracking System Reports on behalf of the corresponding customer. “Pending” or “Active” transactions are not acceptable. Note any exceptions.

Step III.2.4 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: All of CleanPowerSF’s RY2021 sales were retail sales.

Additional Auditor Comments

17. Green-e® Energy Certified Retail Sales
Background and Important Reminders for Retail Sales Review x Companies listed in Appendix G are not retail customers. Sales to such companies should only be listed under Wholesale Sales.
x Each certified retail product appears on a single Retail Sales Detail page. x Each Retail Sales Detail page contains information on:
o Non-Residential Sales;
o Residential Sales;
o Resource Mix: Claimed and Calculated (Product Content Labels); o Block/percent of use
o Marketplace Customers;
o LEED Customer Data;
o Electric Vehicle (EV) Charging Stations;
o Retail Customers Purchasing 10,000 MWh or More;
o Retail Sales of Product through Distributor Utilities x For companies with offices in multiple locations, count the customer location as where they were billed. If offices of the same company in different locations bought certified products separately, count them as separate customers.

Software Pages Needed for These Steps
x Retail Sales Details for each retail product for which they reported certified sale: Audit Participant Data>>View Participant’s Data>>Retail Sales>>Sales Details, also available on the “View All” table (Audit Participant Data>>View Participant’s Data>>View All) x Participant’s Products, Notes & Customers: Audit Participant Data>>Participant's Products, Notes & Customers

Total Retail Sales
Applicability and Intent of the Section
This section of the Protocol applies to all participants who had retail sales in the given calendar year. It does not apply to wholesale sales.

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The intent of Retail Sales reporting is to verify the volume of certified sales made to retail customers by the Participant in the RY2022.

Audit Procedures for Retail Sales

1. Obtain from Participant:
x Participant company billing statements, which may include invoices to customers, evidence of paid invoices, and/or delivery receipt letters x documentation supporting the amount of renewable energy sold under each product name / contract with Green-e® Energy
x contracts for sale of certified products if such contracts call for very specific renewable resources
x documentation supporting the number of customers buying each product, with type of customer (residential vs. non-residential / commercial), the MWh sold to each customer, and the customer location (state or province)
x for Utility Green Pricing products only, a copy of documentation that verifies that the Green-e® Energy certified green pricing products sold are cost-based rates x for products being used solely to supply the charging of EVs, a spreadsheet demonstrating the methodology used to calculate or estimate the MWh used to charge the EVs (if applicable)
Step III.3.1 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe obtained the following items from CleanPowerSF:

1. Customer billing statements, which included a sample of invoices/billings selected by Crowe of CleanPowerSF customers who were Green Power customers during RY2022.

2. Documentation supporting the amount of renewable energy sold. Internal documents for monthly pricing per kWh, the dollar amounts of Green-e Energy sales, and the related number of total kWh per month.

3. Documentation supporting the number of customers who purchased the SuperGreen product, type of customer (residential or non-residential), the number of MWh sold to each customer, and the customer location (state or province). CleanPowerSF provided a listing of SuperGreen customers during 2022, which included all customers that had participated in its SuperGreen program by month during RY2022. The listing provided by the Company was used as the basis for the sample selection for residential customer billings in Step III.3.6 of the Audit Protocol, as described in the discussion for that step.

2. Using copies of internal reporting documents that the Participant used to provide retail sales data, recalculate the amount of MWh of sales and number of customers by product for each customer type, residential and non-residential and agree this to the retail sales reported by state in the respective tables in “Audit Participant Data>>View Participant’s Data>>Retail Sales>>Sales Details”. Note any exceptions.

Step III.3.2 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Using CleanPowerSF’s internal documents, which shows MWh by month for RY2022 for CleanPowerSF's SuperGreen Program, Crowe recalculated the total MWh of Green Power sales of 349 MWh to 172 residential customers for RY2022. Crowe observed CleanPowerSF reported 349 MWh and 163 residential customers for RY2022.

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3. For products with a “Block Size” listed in Block Product section of the Block, Percent, or Capacity table, divide the total MWh sold by the block size. Confirm that this result matches the total blocks sold in Participant’s internal sales records. Note any exceptions.

Step III.3.3 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not have any products with “Block Size” listed in the Block Product section of the Block, Percent, or Capacity table.

4. Viewing the “Block, Percent or Capacity” (shown as “Block, Percent and Capacity” in the user interface) table on the “Retail Sales >> Sales Details” page for each retail product, for each entry of the Percent-of-Use Product section, verify the percent renewable listed in the “Percentage Offered” column by comparing total renewables sold in the product in the “Total MWh” column (which indicates MWh) with total electricity sales for the product from Participant’s internal sales records. Note any exceptions.

Step III.3.4 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed that all customers in CleanPowerSF's SuperGreen program reflect 100% participation. Crowe compared the information in the "Block/Percent" table to the information in the internal documentation provided by CleanPowerSF.

Crowe observed the total MWh from internal sales records was 341 MWh for RY2022 and the Block, Percent or Capacity of 349 MWh.

5. For electricity products where the “Percentage Offered” in the Percent-of-Use Product section of the Block, Percent or Capacity table is less than 100%, confirm with Participant that the MWh listed for that product are only for the eligible renewable MWh sold, and do not include MWh from non-eligible resources. Specifically, products sold at less than 100%-of- use should not contain any renewable MWh that were used to meet Renewable Portfolio Standards or Low Carbon Fuel Standard (LCFS). Note any exceptions.

Step III.3.5 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF's SuperGreen program has a percent-of- use product, however, all customers in the program reflect 100% participation. Therefore, this step does not apply.

6. Using the Sampling Guidelines in Section II.11, select a sample of customer sales transactions detailed in the internal company documents for customers that purchased fewer than 10,000 MWh of renewable electricity or RECs from Participant. For this step, the sampling unit is defined as an individual REC sale to a retail customer (for Participants with REC contracts with Green-e® Energy) or all delivery of renewable electricity over 2022 to an individual customer (for Participants with electricity contracts with Green-e® Energy). i. Compare for each selected item (from the internal company documents) the MWh sold per customer to a copy of the billing statements and any other necessary records that contain the MWh retail sales by product by customer (specify in the report what, if any, other record was used). Note any exceptions. ii. For each transaction of a block electricity product or REC product sold to residential customers, verify that the amount of renewables sold was equal to or greater than 100 kWh. Note any exceptions.
iii. For each transaction of a percent-of-use product to sold to residential customers, verify that each residential customer received renewable MWh to cover at least 25% of their electricity use. Note any exceptions.

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iv. For Participants selling certified Green Pricing or Competitive Electricity products: if Participant does not have customer billing records for the full calendar year, then sample from the month(s) in the calendar year that are available, and note those months below. Note any exceptions.
v. For Multiple Mix contracts, note instances when internal records indicate that residential or individual customers purchased the certified product. vi. For Multiple Mix contracts, for each customer sampled, review the purchase agreement, contract or other document from prior to product delivery, and identify whether RECs or renewable electricity from a particular generating facility were promised. For those sales that did specify a facility up front, track the total MWh from each specified facility and each sampled contract, and check that each facility and a sufficient number of MWh from the specified generation dates appear on the Facility Information table and / or aggregated Generator Information tables. Note any exceptions.

Step III.3.6 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”:

Population Size (required, must fill in): Residential - 172 Sample Size (required, must fill in): Residential - 47

1. Crowe observed MWh sold in the Participant billing records and compared the amounts of MWh sold to the SuperGreen kWh line item for each customer on the sampled bills. No exceptions were noted.

2. Step was not performed because SuperGreenSaver is not a block electricity product.

3. Crowe observed that each residential bill sampled had renewable kWh to cover at least 25% of their electricity use. No exceptions were noted.

7. If Participant’s billing cycles do not corresp ond exactly with the calendar year, Participant may prorate the sales for the first and/or last billing cycle of the year. If sales are prorated, note this in the Agreed-Upon Procedures Report and describe method used for prorating.

Step III.3.7 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed that CleanPowerSF prorated sales because billing cycles do not correspond exactly with the calendar year. The customers participating in the SuperGreen program have different billing periods, based on PG&E's billing cycles. The PG&E billing cycles are typically for periods that correspond with meter readings and are typically 30 to 32 calendar days of electricity usage, and thus cover some usage days occurring in each of the two calendar months. The detailed monthly SuperGreen billing documentation provided shows how CleanPowerSF prorates their SuperGreen sales based on the number of days in the calendar month versus the number of days in each billing cycle. Crowe observed the method to prorate sales for customers and verified the method was implemented correctly by observing customer bills. No exceptions were noted.

8. This step applies to Utility Green Pricing Participants only. Obtain a copy of documentation from the Participant that verifies that the Green-e® Energy certified green pricing product(s) sold by the Participant were offered at cost-based rates in the RY under consideration. Note any exceptions.
i. If the product offering has been approved by the state Public Utilities Commission (or equivalent) or other state regulatory agency, obtain a copy of the regulatory agency’s approval of the rate charged for the green pricing product as being cost-based.

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ii. If no regulatory agency documentation is available, then examine other regulatory documents, such as filings submitted to the Federal Energy Regulatory Commission and other company documents to verify that the product was sold at rates determined in a manner similarly to the Participant’s other product offerings. iii. If the Participant is a municipal utility, then cost-based rates may not be applicable.

Documents such as Board meeting minutes approving the program and rate structure are sufficient
Step III.3.8 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF is not a Utility Green Pricing Participant.

9. This step applies to Utility Green Pricing Participants only. Obtain from the Participant the contact information for the utility’s oversight body (public utilities commission, utility board, city council, or other oversight body). Contact the oversight body and confirm with them in writing that the utility’s green pricing program was in compliance with all rules imposed upon the program by the oversight body during 2022. If the Participant is a municipal utility and there are no rules imposed on the program other than Green-e® Energy certification, then no contact with the oversight body is necessary. Note any exceptions.

Step III.3.9 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF is not a Utility Green Pricing Participant.

10. This step applies only to Participants selling bundled electricity products (i.e. Utility Green Pricing, Competitive Electricity and some Community Choice Aggregation products.) Compare the geographic location of all customers listed in the Residential and Non- Residential Sales tables against the facility locations denoted in the Facility Information table of the Supply section. Verify that all sales meet the geographic eligibility requirements in sections IV.A and IV.B of the Green-e® Renewable Energy Standard for Canada and the US. Note any exceptions.

Step III.3.10 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Crowe observed the geographic location of the facility listed and verified the facility met the requirements set forth in Sections IV.A and IV.B of the Geographic Eligibility Requirements by agreeing the eligibility requirements to the generating facility information. No exceptions were noted.

11. If the Participant is selling a community renewables product (i.e. community solar), verify that all monthly invoices to customers are for 100 kWh or more. If you find an invoice of less than 100 kWh:
i. Check to see if the product is sold in kW installments of capacity or as shares of a facility. If yes, check the rest of that customer’s bills for the year and confirm that on average, the customer received at least 100 kWh per month or 25% coverage over the course of the calendar year. Note any exceptions.
ii. If the customer is signed up for a percentage of use product, check whether the kWh on all monthly invoices represent the correct percentage of use. Note any exceptions.

Step III.3.11 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF does not sell a community renewables product.

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Verification of Retail Product Content

Audit Procedures for Resource Mix: Claimed and Calculated

12. For each Single Mix retail product for which the Participant reported certified sales, on the “Audit Participant Data>>View Participant’s Data >>Retail Sales>>Sales Details>>PCL” page under the “Calculated Resource Mix” table:
i. Agree the percentages reported in the “Calculated PCL” column with the “PPCL Percent” column in the “Participant entered Resource Mix” table.. Note any differences that are greater than 4 percentage points (as rounded), and if any differences are noted, check that Participant has uploaded a Mix Change Worksheet. Confirm that the “PPCL Percent” percentages match those percentages found in the “Prospective PCL” document. Note any differences. ii. Agree the percentages reported in the “Calculated PCL” column with the “HPCL Percent column in the “Participant entered Resource Mix” table. Note any differences that are greater than 1 percentage point (as rounded), and if any differences are noted, check that Participant has uploaded a Mix Change Worksheet. Confirm that the “HPCL Percent” percentages match those percentages found in the “Historic PCL” document. If Participant utilized any facilities considered as repowered under the Green-e® Renewable Energy Standard for Canada and the US and identified in Step III.1.16, confirm that Footnote 2 in the HPCL includes mention that generation from a facility approved as repowered is included in the product. Note any differences.

Step III.3.12 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Step was not performed because the SuperGreen Saver has a calculated PCL of 100% for solar energy.

Sales to Individual Retail Customers – Marketplace, EV Chargers, 10,000 MWh or More, and LEED customers

Applicability and Intent of the Section
This section applies to Participants that sold retail products to commercial customers, and does not apply to Participants with only retail residential and wholesale certified sales. It is intended to verify the sales made to customers that participate in Green-e® Marketplace or that are EV charging stations..

Audit Procedures for the Section

13. Using the Sampling Guidelines in Section II.11, select a sample of customers listed on the “Retail Customers Purchasing 10,000 MWh or More” page. For this step, the sampling unit is defined as an individual REC sale to a retail customer (for Participants with REC contracts with Green-e® Energy) or all delivery of renewable electricity over 2022 to an individual customer (for Participants with electricity contracts with Green-e® Energy). Obtain retail sales records documents for the customers sampled.

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i. Compare for each selected item (from the internal company documents) the MWh sold per customer to a copy of the billing statements and any other necessary records that contain the MWh retail sales by product by customer (specify in the report what, if any, other record was used). Note any exceptions. ii. For each transaction of a block electricity product or REC product sold to residential customers, verify that the amount of renewables sold was equal to or greater than 100 kWh. Note any exceptions.
iii. For each transaction of a percent-of-use product to sold to residential customers, verify that each residential customer received renewable MWh to cover at least 25% of their electricity use. Note any exceptions.
iv. For Participants selling certified Green Pricing or Competitive Electricity products: if Participant does not have customer billing records for the full calendar year, then sample from the month(s) in the calendar year that are available, and note those months below. Note any exceptions.
v. For Multiple Mix contracts, note instances when internal records indicate that residential or individual customers purchased the certified product. vi. For Multiple Mix contracts, for each customer sampled, review the purchase agreement, contract or other document from prior to product delivery, and identify whether RECs or renewable electricity from a particular generating facility were promised. For those sales that did specify a facility up front, track the total MWh from each specified facility and each sampled contract, and check that each facility and a sufficient number of MWh from the specified generation dates appear on the Facility Information table and / or aggregated Generator Information tables. Note any exceptions.

Step III.3.13 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: Step was not performed because no customers purchased 10,000 MWh or more during RY2022.

Population Size (required, must fill in): N/A
Sample Size (required, must fill in): N/A

14. Confirm that all customers listed on Audit Participant Data>>Participant's Products, Notes & Customers as being Green-e® Marketplace participants also appear under “Marketplace Customers” on “Audit Participant Data>>View Participant’s Data >>Retail Sales>>Sales” Details. Note any exceptions.

Step III.3.14 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not have any Marketplace Customers in RY2022.

15. For each customer listed under “Marketplace Customers”, compare the MWh sold to the customer to a copy of the billing statements and any other necessary records that contain the MWh retail sales by product by customer for 2022 (specify in the report what, if any, other record was used). Multi-year contracts that cover some or all of 2022 should indicate the amount delivered for 2022, or contain information sufficient to determine the amount delivered for each year of the contract, note if this is not the case.

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i. Confirm that the information entered in the data table corresponding to Marketplace customers matches information on the document/record used. Note any exceptions. ii. For Multiple Mix contracts, for each customer sampled, review the purchase agreement, contract or other document from prior to product delivery, and identify whether RECs / renewable electricity from a particular generating facility were promised. Note any exceptions.

Step III.3.15 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not have any Marketplace Customers in RY2022.

16. If the Participant sold a certified REC product to a Marketplace customer, confirm that the date of sale is listed in the corresponding retail sales table. If the Participant sold a certified electricity product (competitive electricity or utility green pricing program) to the customer, confirm that the contract date of electricity sale is accurately represented on the corresponding retail sales table. Unless the certified retail product is sold under a multi-year contract, the date of sale must cover at least a portion of calendar year 2022. For multi-year contracts, check that the contract covers 2022. Note any exceptions.

Step III.3.16 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not have any Marketplace Customers in RY2022.

17. If there is data in the “LEED Customer Data” table, check internal records against total number of LEED customers (certified green buildings) and aggregate MWh sold to customers per state of customer location. Note any exceptions.

Step III.3.17 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not have any LEED customers in RY2022.

18. Check that in aggregate Marketplace, large customer and LEED customers and MWh per state is less than or equal to the corresponding state information on Non-Residential sales for the certified product. Some customers may appear in both the Marketplace and large customer sections of the verification software; ensure that these customers are only counted once in the sum of Marketplace, large customer and LEED customer renewable MWh. Note any exceptions.

Step III.3.18 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not have any Non-Residential sales for the RY 2022.

19. If Green-e® Energy certified sales are consumed by Electric Vehicles (EVs) and the Participant is estimating the amount of electricity or RECs being consumed through charging, check that the MWh reported in the methodology spreadsheet matches the calculation or documentation provided by the Participant. Note any exceptions.

Step III.3.19 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF did not estimate or report any sales through EV Charging Stations in RY2022.

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Sales by Distributors Other than Participant
This section applies only to Green-e® Energy Participants selling certified electricity products that are also being sold through one or more distributors (such as spokes in a hub-and-spoke arrangement, co-ops or other sales channels) other than the Participant.

20. Obtain internal records showing sales of certified products by Participant and their distributor utility(ies).

Step III.3.20 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF's electricity product is not sold through distributors.

21. Verify that the sales of each product in the Distributor Spreadsheet match Participant’s internal records of product sales through each distributor utility. Note any exceptions.

Step III.3.21 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF's electricity product is not sold through distributors.

22. Verify that the totals in the Distributor Spreadsheet match the totals for the corresponding product sales reported in the Non-Residential and Residential Sales tables. Note any exceptions.

Step III.3.22 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF's electricity product is not sold through distributors.

23. Verify that the total sales all of products listed on the Distributor Spreadsheet matches the sum of the same products’ total sales in the Retail Sales table. Note any exceptions.

Step III.3.23 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: CleanPowerSF's electricity product is not sold through distributors.

Additional Auditor Comments on Retail Sales

18. Special Cases
Software Pages Needed for These Steps
x Special Cases: Audit Participant Data>>View Participant’s Data>>Special Cases x Facility Information Table: Audit Particip ant Data>>View Participant’s Data >>Supply x Wholesale Details tables: Audit Participant Data>>View Participant’s Data >>Wholesale Sales>>Wholesale Details
x RGGI table: “Regional Greenhouse Gas Initiative (RGGI)” table on Audit Participant Data>>View Participant’s Data >>Special Cases
x Supply from RGGI: “Supply from RGGI States “table on Audit Participant Data>>View Participant’s Data >>Special Cases
x All above tables area also accessible on the “View All” page, Audit Participant Data>>View Participant’s Data>>View All

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Audit Procedures for the Section

Michigan Facilities

1. Note whether any facilities are located in Michi gan. For all facilities located in Michigan that are not identified in the Facility Information table as being tracking in the Michigan Tracking System (MIRECS), check MIRECS to confirm that facility is not registered using the following URL: https://portal1.mirecs.org/myModule/rpt/myrpt.asp?r=111. For all facilities located in Michigan, the Participant must note whether and how many incentive renewable energy credits (IRECs) were or will be retired to support sales of MI generation. The Participant must provide Tracking System Reports and/or other documentation substantiating that the appropriate number of IRECs have been retired. A description of IRECs is in Appendix A.4 of the Green-e® Renewable Energy Standard for Canada and the US. Review the Michigan form in Audit Participant Data>>View Participant’s Data >>Special Cases and confirm that the form is filled out completely, references all Michigan facilities from the Facility Information Table (Audit Participant Data>>View Participant’s Data >>Supply), and is signed. Note any exceptions.

Step III.4.1 was performed: Yes. No. N/A.

Exceptions, Notes, Reason for “No” or “N/A”: None of the MWh listed on the Facility Information table were generated in Michigan.

Verification of Sales of RGGI MWh
Applicability and Intent
This section applies to Participants that made retail Green-e® Energy certified sales of renewable MWh generated in Regional Greenhouse Gas Initiative (“RGGI”) states, which are Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont and Virginia. The intent is to verify that the specific rules for sales of RGGI state renewable MWh were met, and that certain reporting to RGGI state environmental oversight bodies were made or will be made.

Background and Important Reminders for the Section
x Appendix C contains background on RGGI rules, as well as contact information for each RGGI state, in case questions on a specific state’s reporting requirements arise.

Audit Procedures for the Section

2. Obtain from Participant:
x Participant company billing statements for customers located in RGGI states, which may include invoices to customers, evidence of paid invoices, and/or delivery receipt letters x Tracking System Reports that show retirement of the MWh used in certified retail sales x all reports submitted to RGGI state environmental oversight bodies to substantiate sales into those RGGI states
x responses from RGGI state environmental oversight bodies responding to receipt and review of submitted reports, if responses have been received.

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Step III.4.2 was performed: Yes. No. N/A.