Item 10 – Accept and attest the accuracy of Valley Clean Energy’s 2022 Power Content Label for the Standard Green and UltraGreen products. — Valley Clean Energy Board of Directors, September 14, 2023

Item 10

VALLEY CLEAN ENERGY ALLIANCE
Staff Report – Item 10
TO: Valley Clean Energy Alliance Board of Directors
FROM: Gordon Samuel, Chief Operating Officer
SUBJECT: Accept and attest to the veracity of VCE’s Power Content Label for the Standard Green and UltraGreen products for 2022
DATE: September 14, 2023
RECOMMENDATION:

Attest to the veracity of the information presented in Valley Clean Energy’s 2022 Power Source Disclosure Annual Reports and Power Content Label for the Standard Green and UltraGreen products.

BACKGROUND:

California Public Utilities Code requires all retail sellers of electric energy, including 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.2 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 refers to electricity that cannot be sourced back to a specific generator, such as energy purchased through open market transactions.

During the 2022 calendar year, VCE delivered a substantial portion of its electric energy supply from various renewable energy sources, including eligible hydroelectric, solar, and wind. For VCE Standard Green customers, 17.5% of the energy delivered was from renewable energy resources with a greenhouse gas emissions intensity of 709 lbs CO2e/MWh. For UltraGreen 1 California Public Utilities Code Section 398.1(b).
2 Since October 1, 2023 occurs on a Sunday, Power Content Labels must be posted on VCE’s website and provided to the CEC no later than October 2, 2023. The CEC will also consider Power Content Labels provided to customers in written promotional materials by January 2, 2024 as timely.

Item 10
customers, 100% of the energy delivered 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 2022 is attached.

Consistent with applicable regulations and CEC guidance, VCE will complete required customer communications in accordance with the October 2, 2023 and January 2, 2024 deadlines. 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 2022 Power Source Disclosure Annual Reports and Power Content Label for the Standard Green and UltraGreen products. Staff recommends VCE self-certify both the Standard Green and UltraGreen products in lieu of submitting them to a third-party Certified Public Accountant for a formal audit. VCE’s technical consultants (The Energy Authority) prepared the Power Source Disclosure annual reports, 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 2022 calendar year.

ATTACHMENTS:
1) 2022 Annual Power Source Disclosure Report for the Standard Green Product 2) 2022 Annual Power Source Disclosure Report for the Ultra Green Product 3) 2022 Power Content Label
4) EQ Research Report re 2022 Power Source Disclosure Annual Reports and Power Content Label
Version: April 2023
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 639-0573.

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
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2022

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: April 2023
732,719
182,317
550,402
‐‐‐
182,317235,572

0.3215

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
Aquamarine Westside, LLC Solar CA W12082 64553A 62547 128,429 128,429 - 128,429 - Aquamarine Westside, LLC (Phase 2) Solar CA W12582 64553A 62547 2 2 - 2 - ‐ #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
Balch #1 PH Large hydro CA 217 660 660 - 660 -
Balch #2 PH Large hydro CA 218 2,347 2,347 - 2,347 -
Belden Large hydro CA 219 1,946 1,946 - 1,946 -Bucks Creek Large hydro CA 220 667 667 - 667 - Butt Valley Large hydro CA 221 833 833 - 833 -Caribou 1 Large hydro CA 222 635 635 - 635 -Caribou 2 Large hydro CA 223 3,100 3,100 - 3,100 - Cresta Large hydro CA 231 1,565 1,565 - 1,565 -Drum #1 Large hydro CA 235 434 434 - 434 - Drum #2 Large hydro CA 236 2,669 2,669 - 2,669 -
Electra Large hydro CA 239 3,362 3,362 - 3,362 -Haas Large hydro CA 240 1,837 1,837 - 1,837 -James B Black Large hydro CA 249 3,236 3,236 - 3,236 -Kerckhoff #2 PH Large hydro CA 682 3,103 3,103 - 3,103 -Kings River Large hydro CA 254 786 786 - 786 - Pit 1 Large hydro CA 265 1,134 1,134 - 1,134 -
Pit 3 Large hydro CA 266 1,170 1,170 - 1,170 -Pit 4 Large hydro CA 267 2,731 2,731 - 2,731 -Pit 5 Large hydro CA 268 4,682 4,682 - 4,682 -Pit 6 Large hydro CA 269 2,094 2,094 - 2,094 - Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2022
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: April 2023
Pit 7 Large hydro CA 270 2,131 2,131 - 2,131 -
Poe Large hydro CA 272 3,306 3,306 - 3,306 -Rock Large hydro CA 275 2,488 2,488 - 2,488 -Salt Springs Large hydro CA 279 1,361 1,361 - 1,361 -Stanislaus Large hydro CA 285 2,191 2,191 - 2,191 -Tiger Creek Large hydro CA 287 2,368 2,368 - 2,368 -NID-Chicago Park Large hydro CA 412 1,048 1,048 - 1,048 -

RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Total Retired Unbundled RECs
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2022
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: April 2023
Adjusted Net
Procured (MWh)
Percent of Total
Retail Sales
Renewable Procurements 17.5% 128,431
Biomass & Biowaste 0.0% -
Geothermal 0.0% -
Eligible Hydroelectric 0.0% -
Solar 17.5% 128,431
Wind 0.0% -
Coal 0.0% -
Large Hydroelectric 7.4% 53,886
Natural gas 0.0% -
Nuclear 0.0% -
Other 0.0% -
Unspecified Power 75.1% 550,402
Total 100.0% 732,719
732,719
709

0.0%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2022
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: April 2023
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2022
Valley Clean Energy Alliance
Standard Green
I, Gordon Samuel, Assistant General Manager & Director of Power Services, declare under penalty of perjury, that the information provided in this report is true and correct and that I, as an authorized agent of Valley Clean Energy Alliance, have authority to submit this report on the retail supplier's behalf. I further declare that all of the electricity claimed as specified purchases as shown in this report was sold once and only once to retail customers.

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
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2022

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: April 2023
7,205
7,205
‐‐‐‐
7,205
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
Aquamarine Westside, LLC Solar CA W12082 64553A 62547 6,093 6,093 - 6,093 - Putah Creek Solar Farm North Solar CA W13206 64810A 66088 1,112 1,112 - 1,112 - ‐ #N/A -‐ #N/A -‐ #N/A -‐ #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 479
Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2022
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: April 2023
‐

RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Total Retired Unbundled RECs
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2022
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: April 2023
Adjusted Net
Procured (MWh)
Percent of Total
Retail Sales
Renewable Procurements 100.0% 7,205
Biomass & Biowaste 0.0% -
Geothermal 0.0% -
Eligible Hydroelectric 0.0% -
Solar 100.0% 7,205
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 100.0% 7,205
7,205
-

0.0%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2022
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: April 2023
2022 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2022
Valley Clean Energy Alliance
UltraGreen
I, Gordon Samuel, Assistant General Manager & Director of Power Services, declare under penalty of perjury, that the information provided in this report is true and correct and that I, as an authorized agent of Valley Clean Energy Alliance, have authority to submit this report on the retail supplier's behalf. I further declare that all of the electricity claimed as specified purchases as shown in this report was sold once and only once to retail customers.

Name: Gordon Samuel
Representing (Retail Supplier):Valley Clean Energy Alliance Signature: __________________________
Dated: May 23, 2023
Executed at: Davis, California
VCE 2022 POWER CONTENT LABEL
Why am I receiving this notice?
VCE is required by the California Energy Commission to send this information to customers who receive VCE electric service. The Power Content Label illustrates the content of the power you buy, compared to the standard Power Mix in California.
2022 POWER CONTENT LABEL
Valley Clean Energy Alliance
https://valleycleanenergy.org/power-sources/
Greenhouse Gas Emissions Intensity
(lbs Co2e/MWh) Energy Resources Standard Green UltraGreen 2022 CA Power Mix Standard Green UltraGreen 2022 CA Utility
Average
Eligible Renewable1 17.5% 100.0% 35.8%
Biomass & Biowaste 0.0% 0.0% 2.1%
709 0 422 Geothermal 0.0% 0.0% 4.7%
Standard Green
UltraGreen
2022 CA Utility
Average
1000
800
600
400
200
0 Eligible Hydroelectric 0.0% 0.0% 1.1%
Solar 17.5% 100.0% 17.0%
Wind 0.0% 0.0% 10.8%
Coal 0.0% 0.0% 2.1%
Large Hydroelectric 7.4% 0.0% 9.2%
Natural Gas 0.0% 0.0% 36.4%
Nuclear 0.0% 0.0% 9.2%
Other 0.0% 0.0% 0.1%
Unspecified Power2 75.1% 0.0% 7.1%
TOTAL 100% 100% 100%
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
Valley Clean Energy Alliance

POWER SOURCE DISCLOSURE INDEPENDENT REVIEW OF

STANDARD GREEN PRODUCT AND ULTRAGREEN PRODUCT
FOR REPORTING YEAR 2022
To: Gordon Samuel, Chief Operating Officer
From: Miriam Makhyoun, CEO, EQ Research, LLC
Blake Elder, Director, EQ Research, LLC
Date: September 6, 2023
______________________________________________________________________ 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, 2022.

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://eqresearch.sharefile.com/d-s04fabee08d4e445b90c84c33af6e067d. 2 See the file entitled, “2022PSDSupplyProductAllocations.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 923 detailed data, eia8602022ER Zip File, EIA923_Schedules_2_3_4_5_M_12_2022_Early_Release.xlsx, Page 1 Generation and Fuel Data, accessed on August 22, 2023 from https://www.eia.gov/electricity/data/eia923/ Source 2 (EIA): EIA Form 860 detailed data, f923_2022 Zip File, 3_1_Generator_Y2022_Early_Release.xlsx, Operable tab, accessed on August 22, 2023 from https://www.eia.gov/electricity/data/eia860/
Source 3 (CEC): California Energy Commission (CEC), California’s Renewables Portfolio Standard (RPS) Public Search exported to Excel, accessed on August 15, 2023 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:
• There is no EIA Form 923 generation data for Putah Creek Solar Farm North so the kWh could not be cross-verified with EIA data.

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:
• There is no EIA Form 923 generation data for Putah Creek Solar Farm North so the kWh could not be cross-verified with EIA data.

EQ Research also tested the mathematical accuracy of Schedule 1 and noted no exceptions. (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 17 invoices for power purchases represented in the 2022 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 135,634 MWh of the total 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
189,522 MWh or 72% of the total MWhs purchased by VCE for both green tariffs in the 2022 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 17 invoices for the two PCC1 resources reviewed by EQ Research, there are additional invoices that were not reviewed by EQ Research for the remaining 53,888 MWh of carbon free purchases.

Only the two PCC1 resources out of 29 resources total, 27 of which are carbon free, in Schedule 1 were represented in the sample of 17 invoices but VCE confirmed the other resources also have corresponding invoices not represented in this limited sample. (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 17 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.
(b) Audit Procedures (2)
EQ Research obtained a copy of the 2022 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 2022 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

Valley Clean Energy Board of DirectorsSeptember 14, 2023

Valley Clean Energy Board of Directors
September 14, 2023