Item 11
VALLEY CLEAN ENERGY ALLIANCE
Staff Report – Item 11
TO: Board of Directors
FROM: Gordon Samuel, Assistant General Manager & Director of Power Services SUBJECT: Accept and attest to the veracity of VCE’s Power Content Label for the Standard Green and Ultra Green products for 2021
DATE: September 8, 2022
RECOMMENDATION:
Attest to the veracity of the information presented in Valley Clean Energy’s 2021 Power Source Disclosure Annual Reports and Power Content Label for the Standard Green and Ultra Green products.
BACKGROUND:
California Public Utilities Code requires all retail sellers of electric energy, including Valley Clean Energy (VCE), to disclose “accurate, reliable, and simple-to-understand information on the sources of energy, and the associated emissions of greenhouse gases,” that are delivered to their respective customers.1 Applicable regulations direct retail sellers to provide such communications no later than October 1st of each year. The format for requisite communications is highly prescriptive, offering little flexibility to retail sellers when presenting such information to customers. This format has been termed the “Power Content Label” by the California Energy Commission (“CEC”).
Information presented in the Power Content Label includes the appropriate share of total energy supply based on resource type, including both renewable and conventional fuel sources.
In the event that a retail seller meets a certain percentage of its supply obligation from unspecified resources, the report must identify such purchases as “unspecified sources of power.” Unspecified sources of power refer to electricity that cannot be sourced back to a specific generator, such as energy purchased through open market transactions.
During the 2021 calendar year, VCE delivered a portion of its electric energy supply from various renewable energy sources, including eligible hydroelectric, solar, and wind. Consistent with its multi-year transition to renewables strategy, VCE is ramping up renewables from 2020 to 2024 where it’s default product “Standard Green” is forecast to exceed 80% renewable content sourced from long-term energy contracts (solar, solar + storage, geothermal, and small hydro). As part of this approach, 12.6% of the energy delivered to VCE Standard Green 1 California Public Utilities Code Section 398.1(b).
Item 11
customers in 2021 was from renewable energy resources with a greenhouse gas emissions intensity of 722 lbs CO2e/MWh. For Ultra Green customers, 100% of the energy delivered in 2021 was generated from renewable energy resources with a greenhouse gas emissions intensity of 0 lbs CO2e/MWh. A copy of VCE’s Power Content Label listing the energy resources used during 2021 is attached.
Consistent with applicable regulations and CEC guidance, VCE will complete required customer communications in accordance with the October 1, 2022 deadline. All customers currently enrolled in the VCE program will receive the Power Content Label via mail or e-mail, as applicable.
To fulfill its Power Content Label reporting obligation, VCE may provide the CEC with the Board’s attestation regarding the veracity of the information presented in VCE’s 2021 Power Source Disclosure Annual Reports and Power Content Label for the Standard Green and Ultra Green products. Staff recommends VCE self-certify both the Standard Green and Ultra Green products in lieu of submitting them to a third-party Certified Public Accountant for a formal audit. VCE’s technical consultants (SMUD) prepared the Power Source Disclosure annual reports and Power Content Label, which were subsequently reviewed by another VCE consultant (EQ Research). EQ Research’s review, as detailed in the attached report, verified that the information contained in the annual reports and Power Content Label is accurate.
Based on the foregoing, staff requests that the Board accept this determination and attest to the veracity of the information included in VCE’s Power Source Disclosure annual reports and Power Content Label for the Standard Green and Ultra Green products for the 2021 calendar year.
ATTACHMENTS:
1) 2021 Annual Power Source Disclosure Report for the Standard Green Product 2) 2021 Annual Power Source Disclosure Report for the Ultra Green Product 3) 2021 Power Content Label
4) EQ Research Report re 2021 Power Source Disclosure Annual Reports and Power Content Label
Version: May 2022
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 805-7439.
NOTE: Information submitted in this report is not automatically held confidential. If your company wishes the information submitted to be considered confidential an authorized representative must submit an application for confidential designation (CEC-13), which can be found on the California Energy Commissions's website at https://www.energy.ca.gov/about/divisions-and-offices/chief-counsels-office.
WEBSITE URL FOR
PCL POSTING https://valleycleanenergy.org/power-sources/ Submit the Annual Report and signed Attestation in PDF format with the Excel version of the Annual Report to [email protected]. Remember to complete the Retail Supplier Name, Electricity Portfolio Name, and contact information above, and submit separate reports and attestations for each additional portfolio if multiple were offered in the previous year.
CITY, STATE, ZIP Davis, CA 95616
PHONE 1-855-699-8232
EMAIL [email protected]
NAME Gordon Samuel
TITLE Assistant General Manager & Director of Power Services MAILING ADDRESS 604 2nd Street
CONTACT INFORMATION
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2021
RETAIL SUPPLIER NAME
Valley Clean Energy Alliance
ELECTRICITY PORTFOLIO NAME
Standard Green
Retail suppliers are required to use the posted template and are not allowed to make edits to this format. Please complete all requested information.
GENERAL INSTRUCTIONS
Version: May 2022
Schedule 1: Procurements and Retail Sales
Schedule 2: Retired Unbundled RECs
Schedule 3: Annual Power Content Label Data
ACS Resource Mix Calculator
Retail suppliers may report specified purchases from ACS system power if the ACS provided its fuel mix of its specified system mix to the Energy Commission. Use the calculator to determine the resource-specific procurement quantities, and transfer them to Schedule 1.
GHG Emissions Factors
Specified Purchases: A Specified Purchase refers to a transaction in which electricity is traceable to specific generating facilities by any auditable contract trail or equivalent, such as a tradable commodity system, that provides commercial verification that the electricity claimed has been sold once and only once to retail consumers. Do not enter data in the grey fields. For specified purchases, include enter following information for each line item:
Facility Name - Provide the name used to identify the facility.
Fuel Type - Provide the resource type (solar, natural gas, etc.) that this facility uses to generate electricity.
Location - Provide the state or province in which the facility is located.
Identification Numbers - Provide all applicable identification numbers from the Western Renewable Energy Generation Information System (WREGIS), the Energy Information Agency (EIA), and the California Renewables Portfolio Standard (RPS).
Gross Megawatt Hours Procured - Provide the quantity of electricity procured in MWh from the generating facility.
Megawatt Hours Resold - Provide the quantity of electricity resold at wholesale.
Unspecified Power: Unspecified Power refers to electricity that is not traceable to specific generation sources by any auditable contract trail or equivalent, or to power purchases from a transaction that expressly transferred energy only and not the RECs associated from a facility. Do not enter procurements of unspecified power. The schedule will calculate unspecified power procurements automatically.
Complete this schedule by entering information about unbundled REC retirements in the previous calendar year.
This schedule is provided as an automated worksheet that uses the information from Schedule 1 to calculate the power content and GHG emissions intensity for each electricity portfolio. The percentages calculated on this worksheet should be used for your Power Content Label.
Retail suppliers of electricity must complete this schedule by entering information about all power procurements and generation that served the identified electricity portfolio covered in this filing in the prior year. The schedule is divided into sections: directly delivered renewables, firmed-and-shaped imports, specified non-renewables, and procurements from ACSs. Insert additional rows as needed to report all procurements or generation serving the subject product. Provide the annual retail sales for the subject product in the appropriate space. At the bottom of Schedule 1, provide the retail suppliers’ other electricity end-uses that are not retail sales, such as transmission and distribution losses. Retail suppliers shall submit a purchase agreement or ownership arrangement documentation substantiating that any eligible firmed-and-shaped product for which it is claiming an exclusion was executed prior to January 1, 2019. Any retail supplier that offered multiple electricity portfolios in the prior year must submit separate Annual Reports for each portfolio offered.
Schedule 2 - Retired Unbundled Renewable Energy Credits (RECs) Schedule 3 - Annual Power Content Label Data
Asset-Controlling Supplier (ACS) Procurement Calculator PSD Attestation
INSTRUCTIONS
Schedule 1 - Procurements and Retail Sales
INTRODUCTION
Retail suppliers are required to submit separate Annual Reports for each electricity portfolio offered to California retail consumers in the previous calendar year. Enter the Retail Supplier Name and Electricity Portfolio Name at the top of Schedule 1, Schedule 2, Schedule 3, and the Attestation.
A complete Annual Report includes the following tabs:
PSD Intro
Instructions
Version: May 2022
GHG Emissions Factors
Attestation
This template provides the attestation that must be submitted with the Annual Report to the Energy Commission, stating that the information contained in the applicable schedules is correct and that the power has been sold once and only once to retail consumers. This attestation must be included in the package that is transmitted to the Energy Commission. Please provide the complete Annual Report in Excel format and the complete Annual Report with signed attestation in PDF format as well.
This tab will be displayed for informational purposes only; it will not be used by reporting entities, since the emissions factors below auto-populate in the relevant fields on Schedules 1 & 3.
Version: May 2022
751,490
176,609
574,881
-
-
-
176,609
246,049
0.3274
DIRECTLY DELIVERED RENEWABLES
Facility Name Fuel Type
State or
Province WREGIS ID RPS ID N/A EIA ID
Gross MWh
Procured
MWh
Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions Factor
(in MT CO2e/MWh)
GHG Emissions (in MT
CO2e) N/A
Biglow Canyon Wind Farm - Biglow Canyon 3 Wind OR W1588 63056A 56485 4,269 4,269 4,269 - - Biglow Canyon Wind Farm - Biglow Phase 2 Wind OR W1268 63055A 56485 30,984 30,984 30,984 - - Tucannon River Wind Farm - Tucannon River 1 Wind WA W4482 63027A 58571 11,015 11,015 11,015 - - Aquamarine Westside, LLC - Aquamarine Westside, LLC Solar CA W12082 64553A 62547 34,800 34,800 34,800 - - Tucannon River Wind Farm - Tucannon River 2 Wind WA W4483 63027A 58571 13,732 13,732 13,732 - - - - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
FIRMED-AND-SHAPED IMPORTS
Facility Name Fuel Type
State or
Province WREGIS ID RPS ID
EIA ID of
REC
Source
EIA ID of
Substitute
Power
Gross MWh
Procured MWh Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions
Factor (in MT
CO2e/MWh)
GHG Emissions
(in MT CO2e)
Eligible for
Grandfathered
Emissions?
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
SPECIFIED NON-RENEWABLE PROCUREMENTS
Facility Name Fuel Type
State or
Province N/A N/A N/A EIA ID
Gross MWh
Procured MWh Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions
Factor (in MT
CO2e/MWh)
GHG Emissions
(in MT CO2e) N/A
Boundary Hydroelectric Units Large hydro WA 6433 31 31 31 - - Mid-C Hydro - Rock Island 6200 and Rocky Reach 3883 (Chelan County PUD) Large hydro WA 3883 29,396 29,396 29,396 - - Mid-C Hydro - Wells (Douglas County PUD) Large hydro WA 3886 11,383 11,383 11,383 - - Mid-C Hydro - Priest Rapids and Wanapum dams (Grant County PUD) Large hydro WA 3887 3,617 3,617 3,617 - - Balch #1 PH Large hydro CA 217 352 352 352 - -
Balch #2 PH Large hydro CA 218 1,155 1,155 1,155 - -
Belden Large hydro CA 219 1,443 1,443 1,443 - -
Bucks Creek Large hydro CA 220 177 177 177 - -
Butt Valley Large hydro CA 221 204 204 204 - -
Caribou 1 Large hydro CA 222 379 379 379 - -
Caribou 2 Large hydro CA 223 1,485 1,485 1,485 - -
Cresta Large hydro CA 231 1,133 1,133 1,133 - -
Drum #1 Large hydro CA 235 403 403 403 - -
Drum #2 Large hydro CA 236 1,473 1,473 1,473 - -
Electra Large hydro CA 239 1,566 1,566 1,566 - -
Haas Large hydro CA 240 986 986 986 - -
James B Black Large hydro CA 249 3,227 3,227 3,227 - -
Kerckhoff #2 PH Large hydro CA 682 1,306 1,306 1,306 - - Kings River Large hydro CA 254 315 315 315 - -
Pit 1 Large hydro CA 265 1,159 1,159 1,159 - -
Pit 3 Large hydro CA 266 1,587 1,587 1,587 - -
Pit 4 Large hydro CA 267 1,841 1,841 1,841 - -
Pit 5 Large hydro CA 268 4,006 4,006 4,006 - -
Pit 6 Large hydro CA 269 1,984 1,984 1,984 - -
Pit 7 Large hydro CA 270 2,407 2,407 2,407 - -
Poe Large hydro CA 272 2,042 2,042 2,042 - -
Rock Creek Large hydro CA 275 1,920 1,920 1,920 - -
Salt Springs Large hydro CA 279 709 709 709 - -
Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
Standard Green
GHG Emissions Intensity (in MT CO2e/MWh)
Net Specified Natural Gas
Net Specified Coal & Other Fossil Fuels
Net Specified Nuclear, Large Hydro, Renewables, and ACS Power GHG Emissions (excludes grandfathered emissions)
Instructions: Enter information about power procurements underlying this electricity portfolio for which your company is filing the Annual Report.
Insert additional rows as needed. All fields in white should be filled out. Fields in grey auto-populate as needed and should not be filled out. For EIA IDs for unspecified power or specified system mixes from asset-controlling suppliers, enter "Unspecified Power", "BPA", or "Tacoma Power" as applicable. For specified procurements of ACS power, use the ACS Procurement Calculator to calculate the resource breakdown comprising the ACS system mix. Procurements of unspecified power must not be entered as line items below; unspecified power will be calculated automatically in cell N9. Unbundled RECs must not be entered on Schedule 1; these products must be entered on Schedule 2. At the bottom portion of the schedule, provide the other electricity end-uses that are not retail sales including, but not limited to transmission and distribution losses or municipal street lighting. Amounts should be in megawatt-hours.
Version: May 2022
Stanislaus Large hydro CA 285 1,064 1,064 1,064 - -
Tiger Creek Large hydro CA 287 1,380 1,380 1,380 - -
Forbestown Large hydro CA 417 398 398 398 - -
Woodleaf Large hydro CA 419 665 665 665 - -
NID-Chicago Park Large hydro CA 412 617 617 617 - -
PROCUREMENTS FROM ASSET-CONTROLLING SUPPLIERS
Facility Name Fuel Type N/A N/A N/A N/A EIA ID
Gross MWh
Procured MWh Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions
Factor (in MT
CO2e/MWh)
GHG Emissions
(in MT CO2e) N/A
- #N/A
- #N/A
- #N/A
- #N/A
END USES OTHER THAN RETAIL SALES MWh
Distribution losses 50,182
Version: May 2022
-
RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Total Retired Unbundled RECs
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
Standard Green
INSTRUCTIONS: Enter information about retired unbundled RECs associated with this electricity portfolio.
Insert additional rows as needed. All fields in white should be filled out. Fields in grey auto-populate as needed and should not be filled out.
Version: May 2022
Adjusted Net Procured
(MWh)
Percent of Total Retail
Sales
Renewable Procurements 94,800 12.6%
Biomass & Biowaste - 0.0%
Geothermal - 0.0%
Eligible Hydroelectric - 0.0%
Solar 34,800 4.6%
Wind 60,000 8.0%
Coal - 0.0%
Large Hydroelectric 81,809 10.9%
Natural gas - 0.0%
Nuclear - 0.0%
Other - 0.0%
Unspecified Power 574,881 76.5%
Total 751,490 100.0%
751,490
722
0.0%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
Standard Green
Instructions: No data input is needed on this schedule. Retail suppliers should use these auto-populated calculations to fill out their Power Content Labels.
Version: May 2022
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
ATTESTATION FORM
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
Standard Green
I, Gordon Samuel, Assistant General Manager & Director of Power Services, declare under penalty of perjury, that the statements contained in this report including Schedules 1, 2, and 3 are true and correct and that I, as an authorized agent of Valley Clean Energy Alliance, have authority to submit this report on the company's behalf. I further declare that the megawatt-hours claimed as specified purchases as shown in these Schedules were, to the best of my knowledge, sold once and only once to retail customers.
Name: Gordon Samuel
Representing (Retail Supplier):Valley Clean Energy Alliance Signature: __________________________________________________________ Dated: June 15, 2022
Executed at: Davis, California
Version: May 2022
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 805-7439.
NOTE: Information submitted in this report is not automatically held confidential. If your company wishes the information submitted to be considered confidential an authorized representative must submit an application for confidential designation (CEC-13), which can be found on the California Energy Commissions's website at https://www.energy.ca.gov/about/divisions-and-offices/chief-counsels-office.
WEBSITE URL FOR
PCL POSTING https://valleycleanenergy.org/power-sources/ Submit the Annual Report and signed Attestation in PDF format with the Excel version of the Annual Report to [email protected]. Remember to complete the Retail Supplier Name, Electricity Portfolio Name, and contact information above, and submit separate reports and attestations for each additional portfolio if multiple were offered in the previous year.
CITY, STATE, ZIP Davis, CA 95616
PHONE 1-855-699-8232
EMAIL [email protected]
NAME Gordon Samuel
TITLE Assistant General Manager & Director of Power Services MAILING ADDRESS 604 2nd Street
CONTACT INFORMATION
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2021
RETAIL SUPPLIER NAME
Valley Clean Energy Alliance
ELECTRICITY PORTFOLIO NAME
UltraGreen
Retail suppliers are required to use the posted template and are not allowed to make edits to this format. Please complete all requested information.
GENERAL INSTRUCTIONS
Version: May 2022
Schedule 1: Procurements and Retail Sales
Schedule 2: Retired Unbundled RECs
Schedule 3: Annual Power Content Label Data
ACS Resource Mix Calculator
Retail suppliers may report specified purchases from ACS system power if the ACS provided its fuel mix of its specified system mix to the Energy Commission. Use the calculator to determine the resource-specific procurement quantities, and transfer them to Schedule 1.
GHG Emissions Factors
Specified Purchases: A Specified Purchase refers to a transaction in which electricity is traceable to specific generating facilities by any auditable contract trail or equivalent, such as a tradable commodity system, that provides commercial verification that the electricity claimed has been sold once and only once to retail consumers. Do not enter data in the grey fields. For specified purchases, include enter following information for each line item:
Facility Name - Provide the name used to identify the facility.
Fuel Type - Provide the resource type (solar, natural gas, etc.) that this facility uses to generate electricity.
Location - Provide the state or province in which the facility is located.
Identification Numbers - Provide all applicable identification numbers from the Western Renewable Energy Generation Information System (WREGIS), the Energy Information Agency (EIA), and the California Renewables Portfolio Standard (RPS).
Gross Megawatt Hours Procured - Provide the quantity of electricity procured in MWh from the generating facility.
Megawatt Hours Resold - Provide the quantity of electricity resold at wholesale.
Unspecified Power: Unspecified Power refers to electricity that is not traceable to specific generation sources by any auditable contract trail or equivalent, or to power purchases from a transaction that expressly transferred energy only and not the RECs associated from a facility. Do not enter procurements of unspecified power. The schedule will calculate unspecified power procurements automatically.
Complete this schedule by entering information about unbundled REC retirements in the previous calendar year.
This schedule is provided as an automated worksheet that uses the information from Schedule 1 to calculate the power content and GHG emissions intensity for each electricity portfolio. The percentages calculated on this worksheet should be used for your Power Content Label.
Retail suppliers of electricity must complete this schedule by entering information about all power procurements and generation that served the identified electricity portfolio covered in this filing in the prior year. The schedule is divided into sections: directly delivered renewables, firmed-and-shaped imports, specified non-renewables, and procurements from ACSs. Insert additional rows as needed to report all procurements or generation serving the subject product. Provide the annual retail sales for the subject product in the appropriate space. At the bottom of Schedule 1, provide the retail suppliers’ other electricity end-uses that are not retail sales, such as transmission and distribution losses. Retail suppliers shall submit a purchase agreement or ownership arrangement documentation substantiating that any eligible firmed-and-shaped product for which it is claiming an exclusion was executed prior to January 1, 2019. Any retail supplier that offered multiple electricity portfolios in the prior year must submit separate Annual Reports for each portfolio offered.
Schedule 2 - Retired Unbundled Renewable Energy Credits (RECs) Schedule 3 - Annual Power Content Label Data
Asset-Controlling Supplier (ACS) Procurement Calculator PSD Attestation
INSTRUCTIONS
Schedule 1 - Procurements and Retail Sales
INTRODUCTION
Retail suppliers are required to submit separate Annual Reports for each electricity portfolio offered to California retail consumers in the previous calendar year. Enter the Retail Supplier Name and Electricity Portfolio Name at the top of Schedule 1, Schedule 2, Schedule 3, and the Attestation.
A complete Annual Report includes the following tabs:
PSD Intro
Instructions
Version: May 2022
GHG Emissions Factors
Attestation
This template provides the attestation that must be submitted with the Annual Report to the Energy Commission, stating that the information contained in the applicable schedules is correct and that the power has been sold once and only once to retail consumers. This attestation must be included in the package that is transmitted to the Energy Commission. Please provide the complete Annual Report in Excel format and the complete Annual Report with signed attestation in PDF format as well.
This tab will be displayed for informational purposes only; it will not be used by reporting entities, since the emissions factors below auto-populate in the relevant fields on Schedules 1 & 3.
Version: May 2022
4,418
4,418
-
-
-
-
4,418
0 0.0000
DIRECTLY DELIVERED RENEWABLES
Facility Name Fuel Type
State or
Province WREGIS ID RPS ID N/A EIA ID
Gross MWh
Procured
MWh
Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions Factor
(in MT CO2e/MWh)
GHG Emissions (in MT
CO2e) N/A
Indian Valley Hydro - Indian Valley Hydro Eligible hydro CA W607 60161A 50129 1,177 1,177 1,177 - - Aquamarine Westside, LLC - Aquamarine Westside, LLC Solar CA W12082 64553A 62547 3,241 3,241 3,241 - - - - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
FIRMED-AND-SHAPED IMPORTS
Facility Name Fuel Type
State or
Province WREGIS ID RPS ID
EIA ID of
REC
Source
EIA ID of
Substitute
Power
Gross MWh
Procured MWh Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions
Factor (in MT
CO2e/MWh)
GHG Emissions
(in MT CO2e)
Eligible for
Grandfathered
Emissions?
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
SPECIFIED NON-RENEWABLE PROCUREMENTS
Facility Name Fuel Type
State or
Province N/A N/A N/A EIA ID
Gross MWh
Procured MWh Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions
Factor (in MT
CO2e/MWh)
GHG Emissions
(in MT CO2e) N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
UltraGreen
GHG Emissions Intensity (in MT CO2e/MWh)
Net Specified Natural Gas
Net Specified Coal & Other Fossil Fuels
Net Specified Nuclear, Large Hydro, Renewables, and ACS Power GHG Emissions (excludes grandfathered emissions)
Instructions: Enter information about power procurements underlying this electricity portfolio for which your company is filing the Annual Report.
Insert additional rows as needed. All fields in white should be filled out. Fields in grey auto-populate as needed and should not be filled out. For EIA IDs for unspecified power or specified system mixes from asset-controlling suppliers, enter "Unspecified Power", "BPA", or "Tacoma Power" as applicable. For specified procurements of ACS power, use the ACS Procurement Calculator to calculate the resource breakdown comprising the ACS system mix. Procurements of unspecified power must not be entered as line items below; unspecified power will be calculated automatically in cell N9. Unbundled RECs must not be entered on Schedule 1; these products must be entered on Schedule 2. At the bottom portion of the schedule, provide the other electricity end-uses that are not retail sales including, but not limited to transmission and distribution losses or municipal street lighting. Amounts should be in megawatt-hours.
Version: May 2022
- - #N/A
- - #N/A
- - #N/A
- - #N/A
- - #N/A
PROCUREMENTS FROM ASSET-CONTROLLING SUPPLIERS
Facility Name Fuel Type N/A N/A N/A N/A EIA ID
Gross MWh
Procured MWh Resold
Net MWh
Procured
Adjusted Net MWh
Procured
GHG Emissions
Factor (in MT
CO2e/MWh)
GHG Emissions
(in MT CO2e) N/A
- #N/A
- #N/A
- #N/A
- #N/A
END USES OTHER THAN RETAIL SALES MWh
Distribution losses 295
Version: May 2022
-
RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Total Retired Unbundled RECs
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
UltraGreen
INSTRUCTIONS: Enter information about retired unbundled RECs associated with this electricity portfolio.
Insert additional rows as needed. All fields in white should be filled out. Fields in grey auto-populate as needed and should not be filled out.
Version: May 2022
Adjusted Net Procured
(MWh)
Percent of Total Retail
Sales
Renewable Procurements 4,418 100.0%
Biomass & Biowaste - 0.0%
Geothermal - 0.0%
Eligible Hydroelectric 1,177 26.6%
Solar 3,241 73.4%
Wind - 0.0%
Coal - 0.0%
Large Hydroelectric - 0.0%
Natural gas - 0.0%
Nuclear - 0.0%
Other - 0.0%
Unspecified Power - 0.0%
Total 4,418 100.0%
4,418
-
0.0%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
UltraGreen
Instructions: No data input is needed on this schedule. Retail suppliers should use these auto-populated calculations to fill out their Power Content Labels.
Version: May 2022
2021 POWER SOURCE DISCLOSURE ANNUAL REPORT
ATTESTATION FORM
For the Year Ending December 31, 2021
Valley Clean Energy Alliance
UltraGreen
I, Gordon Samuel, Assistant General Manager & Director of Power Services, declare under penalty of perjury, that the statements contained in this report including Schedules 1, 2, and 3 are true and correct and that I, as an authorized agent of Valley Clean Energy Alliance, have authority to submit this report on the company's behalf. I further declare that the megawatt-hours claimed as specified purchases as shown in these Schedules were, to the best of my knowledge, sold once and only once to retail customers.
Name: Gordon Samuel
Representing (Retail Supplier):Valley Clean Energy Alliance Signature: __________________________________________________________ Dated: June 15, 2022
Executed at: Davis, California
2021 POWER CONTENT LABEL
Valley Clean Energy Alliance
https://valleycleanenergy.org/power-sources/
Greenhouse Gas Emissions Intensity
(lbs CO2e/MWh) Energy Resources Standard Green UltraGreen 2021 CA Power Mix Eligible Renewable1 12.6% 100.0% 33.6%
Biomass & Biowaste 0.0% 0.0% 2.3%
722 0 456 Geothermal 0.0% 0.0% 4.8%
Eligible Hydroelectric 0.0% 26.6% 1.0%
Solar 4.6% 73.4% 14.2%
Wind 8.0% 0.0% 11.4%
Coal 0.0% 0.0% 3.0%
Large Hydroelectric 10.9% 0.0% 9.2%
Natural Gas 0.0% 0.0% 37.9%
Nuclear 0.0% 0.0% 9.3%
Other 0.0% 0.0% 0.2%
Unspecified Power2 76.5% 0.0% 6.8%
TOTAL 100.0% 100.0% 100.0%
Percentage of Retail Sales Covered by Retired Unbundled RECs3: 0% 0% 1 The eligible renewable percentage above does not reflect RPS compliance, which is determined using a different methodology. 2 Unspecified power is electricity that has been purchased through open market transactions and is not traceable to a specific generation source.
3 Renewable energy credits (RECs) are tracking instruments issued for renewable generation. Unbundled renewable energy credits (RECs) represent renewable generation that was not delivered to serve retail sales. Unbundled RECs are not reflected in the power mix or GHG emissions intensities above.
For specific information about this electricity
portfolio, contact:
Valley Clean Energy Alliance
1-855-699-8232
For general information about the Power Content
Label, visit: http://www.energy.ca.gov/pcl/
For additional questions, please contact the
California Energy Commission at:
Toll-free in California: 844-454-2906
Outside California: 916-653-0237
Standard Green UltraGreen 2021 CA Utility Average
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Valley Clean Energy Alliance
POWER SOURCE DISCLOSURE INDEPENDENT REVIEW OF
STANDARD GREEN PRODUCT AND ULTRAGREEN PRODUCT
FOR REPORTING YEAR 2021
To: Gordon Samuel, Asst. General Manager & Director of Power Resources From: Miriam Makhyoun, CEO, EQ Research, LLC
Blake Elder, Principal Analyst, EQ Research, LLC
Date: August 25, 2022
______________________________________________________________________ Introduction
Valley Clean Energy Alliance (VCE) has engaged EQ Research, LLC (EQ Research) to assist with an independent review of VCE’s Standard Green Power Source Disclosure (PSD) Annual Report and UltraGreen PSD Annual Report (together, the “Annual Reports”) for the year ending December 31, 2021.
EQ Research performed the procedures enumerated below to assist VCE with complying with the auditing and verification requirements of the PSD Program, as defined in Section 1394.2 of the California Code of Regulations, Title 20.
EQ Research obtained the underlying documentation1 used by VCE to complete the Annual Reports from VCE and accepts the accuracy of the information provided by VCE. EQ Research did not access VCE’s Western Renewable Energy Generation Information System (WREGIS) account information to verify the authenticity of the information provided by VCE but was provided an export of information from WREGIS. 2 1 All files referenced in this report can be accessed at: https://eq-research.sharefile.com/d-s4e4f26f20f12499f8b7a55bd43da30f1 2 See the file entitled, “2021PSDSupplyProductAllocations.xlsx” in the ShareFile link. 2 | For internal use by VCE only
Review Procedures and Findings
EQ Research based its detailed review of the Annual Reports on the audit procedures detailed in Section 1394.2(b) of the PSD program regulations. The procedures and associated findings for the Annual Reports are detailed below.
Standard Green PSD Report Review and UltraGreen PSD Report Review (b) Audit Procedures (1)(A)
EQ Research used the following publicly available sources in order to validate the information in the Annual Reports:
Source 1 (EIA): Energy Information Administration (EIA), Form EIA-923 detailed data, 2021: EIA-923 Early release Zip File, EIA923_Schedules_2_3_4_5_M_12_2021_Early_Release.xlsx, Page 1 Generation and Fuel Data, accessed on August 17, 2022 from https://www.eia.gov/electricity/data/eia923/
Source 2 (CEC): California Energy Commission (CEC), California’s Renewables Portfolio Standard (RPS) Public Search exported to Excel, accessed on August 17, 2022 from https://rps.energy.ca.gov/Pages/Search/SearchApplications.aspx EQ Research agreed the specified purchases3 by (a) facility name, (b) facility number provided by EIA, RPS ID, (c) kilowatt-hours, and (d) fuel type from the information used to prepare used to prepare the Annual Reports is consistent with what is presented in the Annual Reports Schedule 14 with one exception:
• Row 42 of Schedule 1 of Standard Green PSD Annual Report, resource, “Mid-C Hydro - Rock Island 6200 and Rocky Reach 3883 (Chelan County PUD)” includes two resources on one row (Rock Island, which is EIA Plant ID 6200 and Rocky Reach, which is EIA Plant ID 3883) and lists only EIA Plant ID 3883 (Rocky Reach’s EIA ID) in the EIA ID column of Schedule 1. The PSD report Schedule 1 is missing the 6200 EIA Plant ID in the EIA ID column even though the EIA ID is included in the Facility Name on Schedule
1. This inconsistency has no material impact on the resource percentages or greenhouse gas content of the Standard Green Product. Both resources are considered large hydro and both have a greenhouse gas emissions content of 0 MT CO2e/MWh (per “GHG Emissions Factors” tab of the PSD Annual Report spreadsheet). The combined output of the two plants is represented equally in EQ Research’s validation in Appendix A since VCE has confirmed that it does not have detail on the specific output for each plant.
EQ Research verified that the MWh listed in the Annual Reports do not exceed the annual MWh from EIA 923 data as expected (see Appendix A. Specified Facility Review Results) with one exception:
• EIA 923 2021 Early Release data shows there were 1,174 net MWh of electricity supplied by Indian Valley Hydro in 2021 but VCEA’s Schedule 1 for Standard Green shows that it purchased 1,177 MWh or 100.3% of that amount. EQ Research does not see this as a major discrepancy and expects that it could be due to rounding.
EQ Research also tested the mathematical accuracy of Schedule 1 and noted no exceptions. 3 There were no resales.
4 This information was checked against information in the following links: Source for RPS IDs:
https://rps.energy.ca.gov/Pages/Search/SearchApplications.aspx; Source for EIA IDs:
https://www.eia.gov/electricity/data/eia923/
3 | For internal use by VCE only
(b) Audit Procedures (1)(B)(1)
EQ Research agreed the facility name, facility numbers provided by EIA and RPS, kilowatt-hours, and the fuel type from the invoice match the information used to prepare Schedule 1 of the Annual Reports.
EQ Research verified the above information by comparing information from a sample of two invoices for power purchases represented in the 2021 Annual Reports and the information used to prepare Schedule 1 of the Annual Reports along with the CEC and EIA data mentioned in (b) Audit Procedures (1)(A) above. The invoices were for purchases of 60,000 MWh of the total 181,027 MWh or 33% of the total MWh purchased by VCE for its green tariffs. The two invoices represent 60% of the RPS purchases (RECs and electricity) out of the total 99,218 MWh RPS portfolio for both green tariffs in the 2021 Annual Reports.
See Appendix B. Sample of Purchases VCE used to Prepare Schedule 1 which shows two limitations to EQ Research’s review that have been clarified by VCE as being limited only by the sample provided with no exceptions to note otherwise:
VCE confirmed that outside of the sample of two invoices reviewed by EQ Research, there are additional invoices that were not reviewed by EQ Research for the remaining 39,218 MWh of RPS purchases and invoices for another remaining 81,809 MWh of carbon-free electricity, representing a total of 121,027 MWh not contained in the invoices.
Only four resources out of 41 resources in Schedule 1 were included in the sample of two invoices but VCE confirmed the other resources also have corresponding invoices not represented in this limited sample used to examine the RPS portion of its portfolio. (b) Audit Procedures (1)(B)(2)
This is not applicable since there are no facilities in the Annual Reports owned by VCE. (b) Audit Procedures (1)(B)(3)
EQ Research verified a match between the date of generation from the two invoices in the sample to the reporting period of the information used to prepare Schedule 1.
See the “Energy Delivery Term” column in Appendix B. Sample of Purchases VCE used to Prepare Schedule 1.
(b) Audit Procedures (1)(B)(4)
This requirement is not applicable since VCE did not use unbundled Renewable Energy Credits (RECs) in its Annual Reports.
(b) Audit Procedures (1)(C)
Section 1393(d) provides that emissions from purchases of eligible firmed-and-shaped products under a purchase agreement or ownership arrangement executed prior to January 1, 2019 are excluded from a portfolio’s emissions intensity calculation. As shown on Schedule 1 of the Annual Reports, VCE did not claim any purchases from firmed-and-shaped imports for either Standard Green or UltraGreen products.
4 | For internal use by VCE only
(b) Audit Procedures (2)
EQ Research obtained a copy of the 2021 Power Content Label to be provided to VCE customers for the Standard Green and UltraGreen products. EQ Research verified that the resource portfolio percentages listed for each product on the 2021 Power Content Label match the respective percentages listed in Schedule 3 of the Power Source Disclosure Annual Reports. EQ Research also verified that the greenhouse gas emissions intensity for each product listed on the Power Content Label match those calculated on the Power Source Disclosure Annual Reports.
This report is intended solely for the information and use of the specified parties listed above and is not intended to be and should not be used by anyone other than those specified parties Appendix A. Specified Facility Review Results
Appendix B. Sample of Purchases VCE used to Prepare
Schedule 1