Item 10 – Accept and attest the accuracy of Valley Clean Energy’s 2023 Power Content Label. — Valley Clean Energy Board of Directors, November 14, 2024

Item 10

VALLEY CLEAN ENERGY ALLIANCE
Staff Report – Item 10
TO: Board of Directors
FROM: Gordon Samuel, Chief Operating Officer
SUBJECT: Accept and attest to the veracity of VCE’s 2023 Power Source Disclosure Reports for the Base Green, Standard Green, and UltraGreen products and 2023 Power Content Label
DATE: November 14, 2024
RECOMMENDATION:

Attest to the veracity of the information presented in Valley Clean Energy’s 2023 Power Source Disclosure Annual Reports and Power Content Label for the Base Green, 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 2023 calendar year, VCE delivered a substantial portion of its electric energy supply from various renewable energy sources, including eligible hydroelectric and solar resources. For VCE Base Green customers, 26.3% of the energy delivered was from renewable energy resources with a greenhouse gas emissions intensity of 695 lbs CO2e/MWh. For VCE Standard 1 California Public Utilities Code Section 398.1(b).
2 This year, the California Energy Commission extended this deadline due to WREGIS reporting delays. For the 2023 compliance year, the Power Content Labels and self-attestation is due January 31, 2025.

Item 10
Green customers, 39.5% of the energy delivered was from renewable energy resources with a greenhouse gas emissions intensity of 449 lbs CO2e/MWh. For UltraGreen 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 2023 is attached.

Consistent with applicable regulations and CEC guidance, VCE will complete required customer communications in accordance with the January 31, 2025 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 2023 Power Source Disclosure Annual Reports and Power Content Label for the Base Green, Standard Green, and UltraGreen products. Staff recommends VCE self-certify the Base Green, 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 Base Green, Standard Green and Ultra Green products for the 2023 calendar year.

ATTACHMENTS:
1) 2023 Annual Power Source Disclosure Report for the Base Green Product 2) 2023 Annual Power Source Disclosure Report for the Standard Green Product 3) 2023 Annual Power Source Disclosure Report for the Ultra Green Product 4) 2023 Power Content Label
5) EQ Research Report re 2023 Power Source Disclosure Annual Reports and Power Content Label
Version: April 2024
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 (530) 446-2750
EMAIL [email protected]
NAME Gordon Samuel
TITLE Chief Operating Officer
MAILING ADDRESS 604 2nd Street

CONTACT INFORMATION
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2023

RETAIL SUPPLIER NAME
Valley Clean Energy Alliance

ELECTRICITY PORTFOLIO NAME
Base 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 2024
110
29 81
-
-
-
29 35

0.3154

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
Resurgence Solar I, LLC Solar CA W16178 65013A 64489 29 29 #N/A 29 - #N/A -
- #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 -

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 23
Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2023
Valley Clean Energy Alliance
Base 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 2024
17 RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Big Fork Hydroelectric Water MT 60579A 17
Total Retired Unbundled RECs
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2023
Valley Clean Energy Alliance
Base 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 2024
Adjusted Net
Procured (MWh)
Percent of Total
Retail Sales
Renewable Procurements 26.3% 29
Biomass & Biowaste 0.0% -
Geothermal 0.0% -
Eligible Hydroelectric 0.0% -
Solar 26.3% 29
Wind 0.0% -
Coal 0.0% -
Large Hydroelectric 0.0% -
Natural gas 0.0% -
Nuclear 0.0% -
Other 0.0% -
Unspecified Power 73.7% 81
Total 100.0% 110
110
695

15.5%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2023
Valley Clean Energy Alliance
Base 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 2024
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2023
Valley Clean Energy Alliance
Base Green
I, Gordon Samuel, Chief Operating Officer, 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: August 21, 2024
Executed at: Davis, California
Version: April 2024
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 639-0573.

WEBSITE URL FOR

CITY, STATE, ZIP Davis, CA 95616
PHONE (530) 446-2750
EMAIL [email protected]
NAME Gordon Samuel
TITLE Chief Operating Officer
MAILING ADDRESS 604 2nd Street

CONTACT INFORMATION
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2023

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 2024
645,384
338,052
307,332
-
-
-
338,052
131,538

0.2038

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 Eligible hydro CA W607 60161A 50129 1,987 1,987 - 1,987 - Resurgence Solar I, LLC Solar CA W16178 65013A 64489 140,897 140,897 #N/A 140,897 Aquamarine Westside, LLC Solar CA W12082 64553A 62547 112,095 112,095 - 112,095 - - #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 1,800 1,800 - 1,800 -
Balch #2 PH Large hydro CA 218 4,951 4,951 - 4,951 -
Belden Large hydro CA 219 2,122 2,122 - 2,122 -
Bucks Creek Large hydro CA 220 705 705 - 705 -
Butt Valley Large hydro CA 221 1,454 1,454 - 1,454 -
Caribou 1 Large hydro CA 222 1,955 1,955 - 1,955 -
Caribou 2 Large hydro CA 223 4,192 4,192 - 4,192 -
Cresta Large hydro CA 231 1,217 1,217 - 1,217 -
Drum #1 Large hydro CA 235 853 853 - 853 -
Drum #2 Large hydro CA 236 2,659 2,659 - 2,659 -
Electra Large hydro CA 239 3,849 3,849 - 3,849 -
Haas Large hydro CA 240 4,946 4,946 - 4,946 -
James B Black Large hydro CA 249 4,600 4,600 - 4,600 -
Kerckhoff #2 PH Large hydro CA 682 5,257 5,257 - 5,257 - Kings River Large hydro CA 254 2,091 2,091 - 2,091 -
Pit 1 Large hydro CA 265 1,879 1,879 - 1,879 -
Pit 3 Large hydro CA 266 3,303 3,303 - 3,303 -
Pit 4 Large hydro CA 267 3,859 3,859 - 3,859 -
Pit 5 Large hydro CA 268 6,677 6,677 - 6,677 -
Pit 6 Large hydro CA 269 2,463 2,463 - 2,463 -
Pit 7 Large hydro CA 270 2,739 2,739 - 2,739 -
Poe Large hydro CA 272 6,270 6,270 - 6,270 -
Rock Creek Large hydro CA 275 4,326 4,326 - 4,326 -
Salt Springs Large hydro CA 279 1,948 1,948 - 1,948 -
Stanislaus Large hydro CA 285 3,221 3,221 - 3,221 -
Tiger Creek Large hydro CA 287 2,431 2,431 - 2,431 -
NID‐Chicago Park Large hydro CA 412 1,307 1,307 - 1,307 -

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 132,390
Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2023
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.

Version: April 2024
99,983

RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Big Fork Hydroelectric Water MT 60579A 8,283
Ashton Hydroelectric Water ID 60578A 3,500
Soda Springs Hydroelectric Water OR 60516A 9,000
Pioneer Hydroelectric Water UT 60578A 1,200
Slide Creek Hydroelectric Water OR 60515A 10,700
Soda Hydroelectric Water ID 60590A 2,600
Weber Hydroelectric Water UT 60595A 1,600
Iron Gate Hydroelectric Water CA 60540A 16,200
Fish Creek Hydroelectric Water OR 60513A 5,200
Copco 2 Hydroelectric Water CA 60538A 16,900
Copco 1 Hydroelectric Water CA 60537A 14,200
Blundell 2 Geothermal Energy UT 60821A 10,600
Total Retired Unbundled RECs
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2023
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 2024
Adjusted Net
Procured (MWh)
Percent of Total
Retail Sales
Renewable Procurements 39.5% 254,979
Biomass & Biowaste 0.0% -
Geothermal 0.0% -
Eligible Hydroelectric 0.3% 1,987
Solar 39.2% 252,992
Wind 0.0% -
Coal 0.0% -
Large Hydroelectric 12.9% 83,073
Natural gas 0.0% -
Nuclear 0.0% -
Other 0.0% -
Unspecified Power 47.6% 307,332
Total 100.0% 645,384
645,384
449

15.5%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2023
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 2024
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2023
Valley Clean Energy Alliance
Standard Green
I, Gordon Samuel, Chief Operating Officer, 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.

WEBSITE URL FOR

CITY, STATE, ZIP Davis, CA 95616
PHONE (530) 446-2750
EMAIL [email protected]
NAME Gordon Samuel
TITLE Chief Operating Officer
MAILING ADDRESS 604 2nd Street

CONTACT INFORMATION
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2023

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 2024
9,141
9,141
-
0 -
-
9,141
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
Putah Creek Solar Farm North Solar CA W13206 64810A 66088 5,219 5,219 - 5,219 - Indian Valley Hydro Eligible hydro CA W607 60161A 50129 3,922 3,922 - 3,922 - - #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 1,875
Retail Sales (MWh)
Net Specified Procurement (MWh)
Unspecified Power (MWh)
Procurement to be adjusted
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 1: PROCUREMENTS AND RETAIL SALES
For the Year Ending December 31, 2023
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.

Version: April 2024
-

RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Total Retired Unbundled RECs
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 2: RETIRED UNBUNDLED RECS
For the Year Ending December 31, 2023
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 2024
Adjusted Net
Procured (MWh)
Percent of Total
Retail Sales
Renewable Procurements 100.0% 9,141
Biomass & Biowaste 0.0% -
Geothermal 0.0% -
Eligible Hydroelectric 42.9% 3,922
Solar 57.1% 5,219
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% 9,141
9,141
-

0.0%
Total Retail Sales (MWh)
GHG Emissions Intensity (converted to lbs CO2e/MWh)
Percentage of Retail Sales Covered by Retired Unbundled RECs
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT
SCHEDULE 3: POWER CONTENT LABEL DATA
For the Year Ending December 31, 2023
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 2024
2023 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2023
Valley Clean Energy Alliance
UltraGreen
I, Gordon Samuel, Chief Operating Officer, 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: August 21, 2024
Executed at: Davis, California
2023 POWER CONTENT LABEL
Valley Clean Energy Alliance
https://valleycleanenergy.org/power-sources/
Greenhouse Gas Emissions Intensity
(lbs CO2e/MWh) Energy Resources Standard
Green UltraGreen Base Green 2023 CA Power Mix
Eligible Renewable1

39.5% 100.0% 26.3% 36.9%
Biomass & Biowaste 0.0% 0.0% 0.0% 2.1%
449 0 695 373 Geothermal 0.0% 0.0% 0.0% 4.8%
Eligible Hydroelectric 0.3% 42.9% 0.0% 1.8%
Solar 39.2% 57.1% 26.3% 17.0%
Wind 0.0% 0.0% 0.0% 11.2%
Coal 0.0% 0.0% 0.0% 1.8%
Large Hydroelectric 12.9% 0.0% 0.0% 11.7%
Natural Gas 0.0% 0.0% 0.0% 36.6%
Nuclear 0.0% 0.0% 0.0% 9.3%
Other 0.0% 0.0% 0.0% 0.1%
Unspecified Power2

47.6% 0.0% 73.7% 3.7%
TOTAL 100.0% 100.0% 100.0% 100.0%
Percentage of Retail Sales Covered by Retired Unbundled RECs3: 16% 0% 16% 1 The eligible renewable percentage above does not reflect RPS compliance, which is determined using a different methodology. 2Unspecified power is electricity that has been purchased through open market transactions and is not traceable to a specific generation source. 3Renewable 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: https://www.energy.ca.gov/programs-and-topics/programs/power-source-disclosure-program Standard Green UltraGreen Base Green 2023 CA Utility
Average
0 200
400
600
800
1000
Standard Green
UltraGreen
Base Green
2023 CA Utility Average
Valley Clean Energy Alliance

POWER SOURCE DISCLOSURE INDEPENDENT REVIEW OF

STANDARD GREEN, ULTRAGREEN, AND BASE GREES PRODUCTS
FOR REPORTING YEAR 2023
To: Gordon Samuel, Chief Operating Officer
From: Miriam Makhyoun, CEO, EQ Research, LLC
Date: October 31, 2024
______________________________________________________________________ Introduction
Valley Clean Energy Alliance (VCE) has engaged EQ Research, LLC (EQ Research) to assist with an independent review of VCE’s Base Green, Standard Green, and UltraGreen Power Source Disclosure (PSD) Annual Reports (together, the “Annual Reports”) and Power Content Label (PCL) for the year ending December 31, 2023. 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’s consultant, The Energy Authority (TEA), to complete the Annual Reports and accepts the accuracy of the information provided by VCE and TEA. 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/public/share/web-s7f2a2b1531d042bcb77cfcc8b558a703 2 See the file entitled, “2023 PSD Supply Product Allocations.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.

Base Green, Standard Green, and UltraGreen PSD Report Review 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, EIA923_Schedules_2_3_4_5_M_12_2023_Final.xlsx, Page 1 Generation and Fuel Data, accessed on October 27, 2024 from https://www.eia.gov/electricity/data/eia923/ Source 2 (EIA): EIA Form 860 detailed data, 3_1_Generator_Y2023.xlsx, Operable tab, accessed on September 24, 2024 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 September 24, 2024 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 and/or 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 note and two minor exceptions:
• Note: The listed EIA Plant ID # 64489 for Resurgence Solar I, LLC includes two rows in the EIA data: one for the battery portion showing negative MWh and another for the solar portion showing only positive MWh. The solar portion was used to validate the contents of this report.
• Exception 1: 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. • Exception 2: Aquamarine Westside, LLC was reported to supply 112,095 MWh and this is shown in the WREGIS REC export but invoices show it to be 0.44 MWh less than reported (112,094.56 MWh). This is likely an artifact of rounding from the invoice process and is inconsequential to the filing.

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 two minor exceptions:
• Resurgence Solar I (EIA Plant ID # 64489) solar row shows 98,700 MWh in months August through December 2023 instead of the expected 140,925.93 MWh shown as retired 2023 RECs (140,897 MWh for the Standard Green tariff and 28.93 MWh for the Base Green tariff). This is because test energy of 42,354.29 MWh produced between May and July 2023 was not reported to the EIA. If it had been reported, 141,054.29 would be the total amount of MWh in EIA 923 for Resurgence Solar 1 which is an excess of 128.36 MWh.
• 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.
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/. (Last accessed September 24, 2024). 3 | For internal use by VCE only
EQ Research also tested the mathematical accuracy of each Annual Report and noted no exceptions.

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 all 42 invoices for power purchases represented in the 2023 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 364,150.15 MWh, which is 16,928.24 MWh more than reported. For reference, 264,150.15 MWh of the total 347,221.915 MWh reported or 76% were for PCC1 renewable energy. The other 100,000 MWh shown on one of the invoices was for unbundled PCC3 RECs from carbon-free power sources.

See Appendix B. Sample of Purchases VCE used to Prepare Schedule 1.

Audit Procedures (1)(B)(2)
This is not applicable since there are no facilities in the Annual Reports owned by VCE.

Audit Procedures (1)(B)(3)
EQ Research verified a match between the date of generation from the 41 PCC1 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 and review the PCC1 delivery dates.

Audit Procedures (1)(B)(4)
VCE used 83,072.99 MWh of unbundled PCC3 RECs for the Base Green and Standard Green products in 2023 and these RECs were retired in 2023 according to WREGIS statements.

Audit Procedures (1)(C)
Section 1393(d) provides that the 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 the Base Green, Standard Green, or UltraGreen products.

Audit Procedures (2)
EQ Research obtained a copy of the 2023 Power Content Label to be provided to VCE customers for the Base Green, Standard Green, and UltraGreen products. EQ Research verified that the resource portfolio percentages listed for each product on the 2023 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 DirectorsNovember 14, 2024

Valley Clean Energy Board of Directors
November 14, 2024