Item 9
VALLEY CLEAN ENERGY ALLIANCE
Staff Report – Item 9
TO: Valley Clean Energy Alliance Board of Directors
FROM: Edward Burnham, Chief Financial Officer
SUBJECT: Accept and attest to the veracity of VCE’s 2024 Power Source Disclosure Reports for the Base Green, Standard Green, and UltraGreen products and 2024 Power Content Label
DATE: September 11, 2025
RECOMMENDATION:
Attest to the veracity of the information presented in Valley Clean Energy’s 2024 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. 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 2024 calendar year, VCE delivered a substantial portion of its electric energy supply from various renewable energy sources, including eligible hydroelectric and solar resources.
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. For VCE Standard Green customers, 85% of the energy delivered was from renewable energy resources with a 1 California Public Utilities Code Section 398.1(b).
Item 9
greenhouse gas emissions intensity of 32 lbs CO2e/MWh. For VCE Base Green customers, 100% of the energy delivered was from unspecified power with a greenhouse gas emissions intensity of 944 lbs CO2e/MWh. A copy of VCE’s Power Content Label listing the energy resources used during 2024 is attached.
Consistent with applicable regulations and CEC guidance, VCE will complete required customer communications in accordance with the January 31, 2026 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 2024 Power Source Disclosure Annual Reports and Power Content Label for the UltraGreen, Standard Green, and Base Green products. Staff recommends VCE self-certify the UltraGreen, Standard Green, and Base Green 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 2024 calendar year.
ATTACHMENTS:
1. 2024 Annual Power Source Disclosure Report for the Base Green Product
2. 2024 Annual Power Source Disclosure Report for the Standard Green Product
3. 2024 Annual Power Source Disclosure Report for the UltraGreen Product
4. 2024 Power Content Label
5. EQ Research Report re 2024 Power Source Disclosure Annual Reports and Power Content Label
Version: April 2025
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 and contact information above.
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 California Energy Commission's website.
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 639-0573.
EMAIL [email protected]
WEBSITE URL
FOR PCL
POSTING
https://valleycleanenergy.org/power-sources/
MAILING 604 2nd Street
CITY, STATE, ZIP Davis, CA 95616
PHONE (530) 446-2750
Valley Clean Energy Alliance
CONTACT INFORMATION
NAME Mitch Sears
TITLE Chief Executive Officer
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
VCE Base Green
For the Year Ending December 31, 2024
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
RETAIL SUPPLIER NAME
Base Green Portfolio Totals PCL Data
Retail Sales 1,767.00
Total Specified -
Biomass & Biogas - 0%
Geothermal - 0%
Eligible Hydroelectric - 0%
Solar - 0%
Wind - 0%
Large Hydroelectric - 0%
Nuclear - 0%
Emerging Technologies - 0%
Other - 0%
Natural Gas - 0%
Coal & Petroleum - 0%
Unspecified Power - ACS -
Unspecified Power - Spot Market 1,767.00
Unspecified Power - Total 1,767.00 100%
Total PCL GHGs (MT CO2e) 756.28
Emissions intensity (MT CO2e/MWh) 0.43
PCL GHG Intensity (lbs CO2e/MWh) 944
Unbundled REC % 49%
Base Green
Facility Name Fuel Type Net
Procurement
Annual PCL
GHGs (MT
CO2e)
- - - -
- - - -
- - - -
- - - -
- - - -
- - - -
- - - -
- - - -
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2024
VCE Base Green
870
RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
McFadden Ridge Wind WY 60896A 100
Rolling Hills Wind WY 60806A 770
Total Retired Unbundled RECs
Base Green
Version: April 2025
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 and contact information above.
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 California Energy Commission's website.
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 639-0573.
EMAIL [email protected]
WEBSITE URL
FOR PCL
POSTING
https://valleycleanenergy.org/power-sources/
MAILING 604 2nd Street
CITY, STATE, ZIP Davis, CA 95616
PHONE (530) 446-2750
TITLE Chief Executive Officer
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2024
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
RETAIL SUPPLIER NAME
Valley Clean Energy Alliance
CONTACT INFORMATION
NAME Mitch Sears
VCE Standard Green
Standard Green Portfolio Totals PCL Data
Retail Sales 668,501.00
Total Specified 646,109.32
Biomass & Biogas - 0%
Geothermal - 0%
Eligible Hydroelectric 6,279.00 1%
Solar 538,362.00 81%
Wind 22,359.00 3%
Large Hydroelectric 79,109.32 12%
Nuclear - 0%
Emerging Technologies - 0%
Other - 0%
Natural Gas - 0%
Coal & Petroleum - 0%
Unspecified Power - ACS -
Unspecified Power - Spot Market 22,391.68
Unspecified Power - Total 22,391.68 3%
Total PCL GHGs (MT CO2e) 9,583.64
Emissions intensity (MT CO2e/MWh) 0.01
PCL GHG Intensity (lbs CO2e/MWh) 32
Unbundled REC % 1%
Standard Green
Facility Name Fuel Type Net
Procurement
Annual PCL
GHGs (MT
CO2e)
Resurgence Solar I, LLC Solar 245,825 0
Aquamarine Westside, LLC Solar 82,382 0
Willy 9 Chap 2 Solar 198,793 0
- - - 0
- - - 0
Westlands Solar Blue (OZ) Owner, LLC Solar 10,638 0
Manzana Wind 20,000 0
Narrows No. 1 Powerhouse Eligible Hydroelectric 6,279 0 SEPV Sierra Solar 724 0
Cabazon Wind Partners Wind 2,359 0
Balch #1 PH Large Hydroelectric 1,437 0
Balch #2 PH Large Hydroelectric 4,654 0
Belden Large Hydroelectric 3,843 0
Bucks Creek Large Hydroelectric 953 0
Butt Valley Large Hydroelectric 1,530 0
Caribou 1 Large Hydroelectric 2,566 0
Caribou 2 Large Hydroelectric 3,516 0
Cresta Large Hydroelectric 3,424 0
Drum #1 Large Hydroelectric 316 0
Drum #2 Large Hydroelectric 1,513 0
Electra Large Hydroelectric 2,962 0
Haas Large Hydroelectric 4,866 0
James B Black Large Hydroelectric 4,532 0
Kerckhoff #2 PH Large Hydroelectric 4,488 0
Kings River Large Hydroelectric 1,139 0
Pit 1 Large Hydroelectric 2,122 0
Pit 3 Large Hydroelectric 3,343 0
Pit 4 Large Hydroelectric 3,461 0
Pit 5 Large Hydroelectric 4,621 0
Pit 6 Large Hydroelectric 2,479 0
Pit 7 Large Hydroelectric 3,274 0
Poe Large Hydroelectric 5,571 0
Rock Creek Large Hydroelectric 5,642 0
Salt Springs Large Hydroelectric 1,125 0
Stanislaus Large Hydroelectric 2,778 0
Tiger Creek Large Hydroelectric 2,351 0
NID‐Chicago Park Large Hydroelectric 605 0
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2024
VCE Standard Green
9,130
RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Rolling Hills Wind WY 60806A 2,730
Campbell Hill Wind WY 61017A 6,400
Total Retired Unbundled RECs
Standard Green
Version: April 2025
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 and contact information above.
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 California Energy Commission's website.
If you have questions, contact Power Source Disclosure (PSD) staff at [email protected] or (916) 639-0573.
EMAIL [email protected]
WEBSITE URL
FOR PCL
POSTING
https://valleycleanenergy.org/power-sources/
MAILING 604 2nd Street
CITY, STATE, ZIP Davis, CA 95616
PHONE (530) 446-2750
Valley Clean Energy Alliance
CONTACT INFORMATION
NAME Mitch Sears
TITLE Chief Executive Officer
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
VCE UltraGreen
For the Year Ending December 31, 2024
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
RETAIL SUPPLIER NAME
UltraGreen Portfolio Totals PCL Data
Retail Sales 10,189.00
Total Specified 10,189.00
Biomass & Biogas - 0%
Geothermal - 0%
Eligible Hydroelectric 5,673.00 56%
Solar 4,516.00 44%
Wind - 0%
Large Hydroelectric - 0%
Nuclear - 0%
Emerging Technologies - 0%
Other - 0%
Natural Gas - 0%
Coal & Petroleum - 0%
Unspecified Power - ACS -
Unspecified Power - Spot Market -
Unspecified Power - Total - 0%
Total PCL GHGs (MT CO2e) -
Emissions intensity (MT CO2e/MWh) -
PCL GHG Intensity (lbs CO2e/MWh) 0
Unbundled REC % 0%
UltraGreen
Facility Name Fuel Type Net
Procurement
Annual PCL
GHGs (MT
CO2e)
Resurgence Solar I, LLC Solar 645 0
Putah Creek Solar Farm North Solar 3,871 0
Indian Valley Hydro Eligible Hydroelectric 5,673 0
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT
For the Year Ending December 31, 2024
VCE UltraGreen
-
RETIRED UNBUNDLED RECS
Facility Name Fuel Type
State or
Province RPS ID Total Retired (in MWh)
Total Retired Unbundled RECs
UltraGreen
Standard Green UltraGreen Base Green CA Utility Average Greenhouse Gas Emissions Intensity
(lbs of CO2e emitted per megawatt hour) 32 0 944
Electricity Sources
■ Renewables and Zero-Carbon Resources
■ Fossil Fuels and Unspecified Power
RPS Eligible Renewables 85% 100% 0%
Biomass & Biogas 0% 0% 0%
Geothermal 0% 0% 0%
Eligible Hydroelectric 1% 56% 0%
Solar 81% 44% 0%
Wind 3% 0% 0%
Large Hydroelectric 12% 0% 0%
Nuclear 0% 0% 0%
Emerging Technologies 0% 0% 0%
Other 0% 0% 0%
Natural Gas 0% 0% 0%
Coal & Petroleum 0% 0% 0%
Unspecified Power (primarily fossil fuels) 3% 0% 100%
Total 100% 100% 100% 100%
Retail sales covered by retired unbundled RECs 1% 0% 49% https://valleycleanenergy.org/power-sources/ Want to learn more? Visit https://www.energy.ca.gov/pcl
2024 POWER CONTENT LABEL
Valley Clean Energy Alliance
■ This label does not reflect compliance with the Renewables Portfolio Standard (RPS), which measures the use of tracking instruments called Renewable Energy Credits (RECs) over the course of multi-year compliance periods. RECs that are purchased separately from the renewable energy ("Unbundled RECs") can be used for RPS compliance, but they do not factor into the power mixes or GHG emissions intensities above. ■ GHG intensity figures exclude biogenic CO2 and emissions from geothermal sources and grandfathered imports of firmed-and-shaped energy. For detailed information about all GHG emissions from California's retail electricity suppliers, visit the CEC link below. ■ Unspecified power is electricity purchased from a genericized pool on the open market.
Valley Clean Energy Alliance
POWER SOURCE DISCLOSURE INDEPENDENT REVIEW OF
STANDARD GREEN, ULTRAGREEN, AND BASE GREES PRODUCTS
FOR REPORTING YEAR 2024
To: Edward Burnham, Chief Financial Officer
From: Miriam Makhyoun, CEO and Nikhil Tyagi, Senior Analyst, EQ Research, LLC Date: August 28, 2025
______________________________________________________________________ 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, 2024. 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-sf4ce4c98aa674799b43f60e928f8d799 2 See the file entitled, “VCE 2024 WREGIS RETIREMENT REPORT” 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 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_2024_Early_Release.xlsx, Page 1 Generation and Fuel Data, accessed on August 11, 2025, from https://www.eia.gov/electricity/data/eia923/ Source 2 (EIA): EIA Form 860 detailed data, 3_1_Generator_Y2024_Early_Release.xlsx, Operable tab, accessed on August 11, 2025, 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 July 28, 2025, 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 Reports4 with two notes and two minor exceptions:
• Note 1: 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.
• Note 2: The listed EIA Plant ID # P393 for Leeward Renewable Energy’s (“Leeward”) Willow Spring/Willy 9 Chap 2 is not consistently reported under that EIA ID. In other EIA forms, such as EIA 923, the plant is reported under EIA ID # 64864. TEA informed EQ Research that Leeward combined Willow Springs 3 with Chaparral Springs in approximately the year 2024 and renamed the project Willy 9 Chap 2. • 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: There is no EIA Form 923 generation data for Westlands Solar Blue (OZ) Owner, LLC 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 minor exception:
• Exception 1: There is an overage of 1,998 MWh reported in the PSD Annual Reports for EIA Plant ID # 64489 Resurgence Solar I, LLC when compared to the net MWh reported in Form 923 2024 Early Release.
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 August 11, 2025). 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 the Annual Reports.
EQ Research verified the above information by comparing information from 52 invoices for power purchases represented in the Annual Reports along with the CEC and EIA data mentioned in (b) Audit Procedures (1)(A) above. The invoices were for purchases of 582,246.25 MWh out of the total 656,298 MWh reported (89% of the portfolio). TEA confirms there are additional invoices not included in the sample EQ Research reviewed which cover the remaining 11% of the MWhs reported in the Annual Reports. The sample of 52 invoices includes full records of deliveries from the following PCC1 resources: Aquamarine Westside, LLC, Putah Creek Solar Farm North, Resurgence Solar I, LLC, and Willy 9 Chap 2. The sample also includes invoices for 40,000 MWh of other PCC1 RECs and 10,000 MWh of unbundled RECs.
EQ Research notes one exception which is explained by WREGIS exports and TEA’s correspondence:
• Exception 1: VCE’s invoices for PCC1 RECs from Putah Creek Solar Farm North are short by approximately 7 MWh. The WREGIS export confirms VCE did retire all MWh reported in its Annual Reports. TEA notes that VCE contacted the Seller to rectify the invoice shortage and make the proper payment for the additional 7 MWh.
See Appendix B. Sample of Purchases VCE used to Prepare Appendix B. Sample of Purchases VCE used to Prepare Annual Reports.
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 52 invoices in the sample to the reporting period of the information used to prepare Annual Reports.
See the “Energy Delivery Term” column in Appendix B. Sample of Purchases VCE used to Prepare Annual Reports and review the PCC1 delivery dates.
Audit Procedures (1)(B)(4)
VCE used 9,130 MWh of unbundled PCC3 RECs for the Base Green and Standard Green products in 2024 and these RECs were retired in 2024 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 in 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 2024 Power Content Label to be provided to VCE customers for the Base Green, Standard Green, and UltraGreen products. EQ Research verified that the 4 | For internal use by VCE only
resource portfolio percentages listed for each product on the 2024 Power Content Label match the respective percentages listed in the Annual Reports. EQ Research also verified that the greenhouse gas emissions intensity for each product listed on the Power Content Label match those calculated in the 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
Annual Reports