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Attachment A - Resolution Approving 2024 Annual PSD and PCL Reports

Palo Alto City Council
December 15, 2025

Document
Attachment A - Resolution Approving 2024 Annual PSD and PCL Reports
Meeting
December 15, 2025
Body
Palo Alto City Council
Original file
1.6 MB
Text extracted from the city's file for reading and search. Open the original on cityofpaloalto.primegov.com. That file is the official record.

*NOT YET APPROVED* Attachment A
Resolution No. ____
Resolution of the Council of the City of Palo Alto Approving and Attesting to the Veracity of the City’s 2024 Power Source Disclosure and Power Content Label Reports

R E C I T A L S
A. The California Legislature adopted Senate Bill 1305 in 1997 to ensure that all retail suppliers of electricity, including the City of Palo Alto, disclose to consumers the sources of energy used to provide electric service in an accurate, reliable and easy to understand manner.

B. The SB 1305 Report is commonly referred to as the Power Source Disclosure (PSD) report, which shows the City’s electric portfolio purchases for the prior calendar year, as well as the fuel mix for the City’s retail electricity sales for the prior calendar year.

C. The information contained in the PSD report is used to prepare the City’s annual Power Content Label (PCL), which discloses the fuel mix of the City’s retail electricity sales during the prior calendar year, as well as the fuel mix for the state as a whole, and which is mailed to the City’s electric utility customers via a bill insert every year.

D. California Code of Regs., title 20, section 1394(a)(2) allows the City Council to approve and attest to the veracity of each PSD report for the previous year, including the reports for Palo Alto’s voluntary PaloAltoGreen product, which is provided to commercial customers who participate in the PaloAltoGreen program.

E. The PSD report submissions for both the City’s standard carbon neutral power portfolio, and the City’s PaloAltoGreen product are prepared by the Northern California Power Agency (NCPA), a joint powers agency of which Palo Alto is a member. The draft PSD reports are then checked by City staff against the City’s account in the Western Renewable Energy Generation Information System (WREGIS), where the City tracks its renewable and carbon-free energy. The PaloAltoGreen renewable energy supplies are then verified by a third-party verifier, in order to achieve Green-e certification for that program.

F. In May 2025, Utilities Department staff submitted the 2024 Annual PSD reports for both the City’s standard carbon neutral portfolio and the PaloAltoGreen program, to the Energy Commission in accordance with the applicable regulations.

G. California Code of Regs., title 20, section 139 3.1(b)(2) states that the power content label shall be provided to customers in written promotional materials by the end of the first complete billing cycle for the fourth quarter of the year. For the City, this means the October billing cycle, which is provided to customers in November. *NOT YET APPROVED* Attachment A
The Council of the City of Palo Alto RESOLVES as follows:

SECTION 1. The City Council approves the submission and attests to the veracity of the 2024 Annual Power Source Disclosure reports for the City’s standard carbon neutral portfolio and the City’s voluntary PaloAltoGreen program (attached as Exhibit A to this resolution), which staff submitted to the California Energy Commission in May 2025.

SECTION 2. The City Council approves and attests to the veracity of the 2024 Annual Power Content Label reports for the City’s standard carbon neutral portfolio and the City’s voluntary PaloAltoGreen program (attached as Exhibit B to this resolution) , which staff distribute d to Utilities customers as an insert in their November Utilities bills.

S
ECTION 3. The Council finds that the adoption of this resolution is not subject to California Environmental Quality Act (CEQA) review because it is an administrative government activity that will not result in any direct or indirect physical change to the environment (CEQA Guidelines section 15378(b)(5)).

INTRODUCED AND PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

City Clerk Mayor
APPROVED AS TO FORM: APPROVED:

City Attorney or Designee City Manager
Director of Utilities

Director of Administrative Services
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.

WEBSITE URL

FOR PCL

POSTING
www.paloalto.gov/powercontentlabel
CITY, STATE, ZIP Palo Alto, CA 94301
PHONE (650) 329-2314
EMAIL [email protected]

CONTACT INFORMATION
NAME James Stack
TITLE Senior Resource Planner
MAILING 250 Hamilton Ave.
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
City of Palo Alto Utilities
Exhibit A
Annual Data
Instructions:

1. Enter the electricity portfolio name in cell O25 and additional electricity portfolio names as needed in cells P25-V25.

2. Enter information about all power procurements and retail sales. 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.

3. For all specified purchases, enter the facility name, fuel type, state or province, WREGIS ID of REC source, RPS ID of REC source, EIA ID of delivered energy, gross MWhs procured, and specified resales MWhs.

4. For firmed-&-shaped procurements specifically, enter all fields from step 3. Additionally, enter the EIA ID of the substitute power in the "EIA ID of delivered energy" field and select "Yes" in the "Firmed-&-Shaped Resource?" field. If the associated GHG emissions are eligible for firmed-&-shaped grandfathering, select "Yes" in the relevant field.

5. Proxy EIA IDs for unspecified power and specified system mixes from asset-controlling suppliers have been provided. Enter "Unspecified Power", "BPA", or "Tacoma Power" as applicable.

6. Proxy EIA IDs for aggregated reporting of WAPA CVP or PCIA resoures; Enter "CVP", "PCIA Solar", "PCIA Wind", "PCIA Eligible Hydro", or "PCIA Large Hydro" as applicable.

7. Procurements of unspecified power must not be entered as line items below; unspecified power will be calculated automatically in the individual electricity portfolio tables to the right after all specified resources have been allocated.

8. Allocate net MWhs procured to each electricity portfolio until the loads are balanced across each portfolio. If the total Net MWhs Procured exceeds the total retail sales of all portfolios, allocate only enough MWh to meet the retail sales of each portfolio.

Facility Name Fuel Type State or
Province
WREGIS
ID of REC
source
RPS ID
of REC
source
EIA ID of
delivered
energy
Gross
MWhs
Procured
Specified
Resales
MWhs
GOLDEN FIELDS SOLAR III Solar CA W10886 64555 63859 66476 WAPA - NIMBUS Eligible Hydroelectric CA W1161 61045 444 8176 WAPA - STAMPEDE Eligible Hydroelectric CA W1177 61046 7066 452 NEW SPICER MEADOWS Eligible Hydroelectric CA W1260 61580 54554 762 HIGH WINDS WIND CA W229 60726 56075 5408
KETTLEMAN SOLAR Solar CA W4695 62422 59633 36702
HAYWORTH SOLAR Solar CA W4719 62744 59009 42003
FRONTIER SOLAR - CROW CREEK SOLAR I Solar CA W4962 62248 60039 34253 ELEVATION SOLAR Solar CA W5298 63192 59964 92129
WESTERN ANTELOPE BLUE SKY RANCH B Solar CA W5300 61518 59961 40708 UNITARIAN UNIVERSALIST CHURCH OF PALO ALTO Solar CA W7382 63983 P232 132 HP INC. Solar CA W7686 64036 62732 2002
445 BRYANT ST. PARKING GARAGE Solar CA W5647 63610 P229 327 520 Webster St. Parking Garage Solar CA W5648 63611 P231 560 275 CAMBRIDGE AVE. PARKING GARAGE Solar CA W5649 63982 P228 322 475 CAMBRIDGE AVE. PARKING GARAGE Solar CA W5650 63981 P230 461 WAPA - FOLSOM Large Hydroelectric CA 441 47865
WAPA - GIANELLI Large Hydroelectric CA 448 9592
WAPA - J.F. CARR Large Hydroelectric CA 442 20318
WAPA - KESWICK Large Hydroelectric CA 443 28373
WAPA - NEW MELONES Large Hydroelectric CA 6158 43083
WAPA - O'NEILL Large Hydroelectric CA 446 120
WAPA - SHASTA Large Hydroelectric CA 445 184106
WAPA - SPRING CREEK Large Hydroelectric CA 450 26242
WAPA - TRINITY Large Hydroelectric CA 451 31879
COLLIERVILLE Large Hydroelectric CA 54555 121008

2. Enter information about all power procurements and retail sales. 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.

3. For all specified purchases, enter the facility name, fuel type, state or province, WREGIS ID of REC source, RPS ID of REC source, EIA ID of delivered energy, gross MWhs procured, and specified resales MWhs.

4. For firmed-&-shaped procurements specifically, enter all fields from step 3. Additionally, enter the EIA ID of the substitute power in the "EIA ID of delivered energy" field and select "Yes" in the "Firmed-&-Shaped Resource?" field. If the associated GHG emissions are eligible for firmed-&-shaped grandfathering, select "Yes" in the relevant field.

5. Proxy EIA IDs for unspecified power and specified system mixes from asset-controlling suppliers have been provided. Enter "Unspecified Power", "BPA", or "Tacoma Power" as applicable.

6. Proxy EIA IDs for aggregated reporting of WAPA CVP or PCIA resoures; Enter "CVP", "PCIA Solar", "PCIA Wind", "PCIA Eligible Hydro", or "PCIA Large Hydro" as applicable.

7. Procurements of unspecified power must not be entered as line items below; unspecified power will be calculated automatically in the individual electricity portfolio tables to the right after all specified resources have been allocated.

8. Allocate net MWhs procured to each electricity portfolio until the loads are balanced across each portfolio. If the total Net MWhs Procured exceeds the total retail sales of all portfolios, allocate only enough MWh to meet the retail sales of each portfolio.

Over allocation
check ✓
Under allocation
check
✓
Coal check ✓
Negative
oversupply check ✓
Retail
Sales 29142 863115
Unmet
Load 29142 19656
Net MWhs
Procured
Firmed &
Shaped
Resource?
Eligible for
Firmed &
Shaped
Grandfath
ering?
Total EF
(MT
CO2e/MWh)
Total
GHGs
PCL EF
(MT
CO2e/MW
h)
Palo Alto Green Standard Rate
Remain
der/Ove
rsupply
66476 0.0000 0.0000 66476
8176 0.0000 0.0000 8176
452 0.0000 0.0000 452
762 0.0000 0.0000 762
5408 0.0000 0.0000 5408
36702 0.0000 0.0000 36702
42003 0.0000 0.0000 42003
34253 0.0000 0.0000 34253
92129 0.0000 0.0000 92129
40708 0.0000 0.0000 40708
132 0.0000 0.0000 132
2002 0.0000 0.0000 2002
327 0.0000 0.0000 327
560 0.0000 0.0000 560
322 0.0000 0.0000 322
461 0.0000 0.0000 461
47865 0.0000 0.0000 47865
9592 0.0000 0.0000 9592
20318 0.0000 0.0000 20318
28373 0.0000 0.0000 28373
43083 0.0000 0.0000 43083
120 0.0000 0.0000 120
184106 0.0000 0.0000 184106
26242 0.0000 0.0000 26242
31879 0.0000 0.0000 31879
121008 0.0000 0.0000 121008
#N/A #N/A #N/A
Palo Alto Green Portfolio Totals PCL Data
Retail Sales 29142
Total Specified 0
Biomass & Biogas 0 0%
Geothermal 0 0%
Eligible Hydroelectric 0 0%
Solar 0 0%
Wind 0 0%
Large Hydroelectric 0 0%
Nuclear 0 0%
Emerging Technologies 0 0%
Other 0 0%
Natural Gas 0 0%
Coal & Petroleum 0 0%
Unspecified Power - ACS 0
Unspecified Power - Spot Market 29142
Unspecified Power - Total 29142 100%
Total PCL GHGs (MT CO2e) 12472.8
Emissions intensity (MT CO2e/MWh) 0.428
PCL GHG Intensity (lbs CO2e/MWh) 944
Unbundled REC % 96%
Palo Alto Green
Facility Name Fuel Type Net Procurement
Annual PCL
GHGs (MT
CO2e)
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
- - - 0
Standard Rate Portfolio Totals PCL Data
Retail Sales 863115
Total Specified 843459
Biomass & Biogas 0 0%
Geothermal 0 0%
Eligible Hydroelectric 9390 1%
Solar 316075 37%
Wind 5408 1%
Large Hydroelectric 512586 59%
Nuclear 0 0%
Emerging Technologies 0 0%
Other 0 0%
Natural Gas 0 0%
Coal & Petroleum 0 0%
Unspecified Power - ACS 0
Unspecified Power - Spot Market 19656
Unspecified Power - Total 19656 2%
Total PCL GHGs (MT CO2e) 8412.8
Emissions intensity (MT CO2e/MWh) 0.010
PCL GHG Intensity (lbs CO2e/MWh) 21
Unbundled REC % 15%
Standard Rate
Facility Name Fuel Type Net Procurement
Annual PCL
GHGs (MT
CO2e)
GOLDEN FIELDS SOLAR III Solar 66476 0
WAPA - NIMBUS Eligible Hydroelectric 8176 0
WAPA - STAMPEDE Eligible Hydroelectric 452 0
NEW SPICER MEADOWS Eligible Hydroelectric 762 0
HIGH WINDS WIND 5408 0
KETTLEMAN SOLAR Solar 36702 0
HAYWORTH SOLAR Solar 42003 0
FRONTIER SOLAR - CROW CREEK SOLAR ISolar 34253 0
ELEVATION SOLAR Solar 92129 0
WESTERN ANTELOPE BLUE SKY RANCH BSolar 40708 0
UNITARIAN UNIVERSALIST CHURCH OF PALO ALTOSolar 132 0
HP INC. Solar 2002 0
445 BRYANT ST. PARKING GARAGE Solar 327 0
520 Webster St. Parking Garage Solar 560 0
275 CAMBRIDGE AVE. PARKING GARAGESolar 322 0
475 CAMBRIDGE AVE. PARKING GARAGESolar 461 0
WAPA - FOLSOM Large Hydroelectric 47865 0
WAPA - GIANELLI Large Hydroelectric 9592 0
WAPA - J.F. CARR Large Hydroelectric 20318 0
WAPA - KESWICK Large Hydroelectric 28373 0
WAPA - NEW MELONES Large Hydroelectric 43083 0
WAPA - O'NEILL Large Hydroelectric 120 0
WAPA - SHASTA Large Hydroelectric 184106 0
WAPA - SPRING CREEK Large Hydroelectric 26242 0
WAPA - TRINITY Large Hydroelectric 31879 0
COLLIERVILLE Large Hydroelectric 121008 0
- - - 0
28,014

RETIRED UNBUNDLED RECS
Facility Name
Fuel
Type
State or
Province RPS ID
Total
Retired
(in MWh)
TB Flats Wind II Wind WY 64941 28014
Palo Alto Green
Unbundled RECs
130,000

RETIRED UNBUNDLED RECS
Facility Name
Fuel
Type
State or
Province RPS ID
Total
Retired
(in MWh)
Crossing Trails Wind CO 65038 35000
Dunlap I Wind WY 61188 19100
Elkhorn Valley Wind Farm Wind OR 61034 5880
Goodnoe Hills Wind WA 60819 6600
Cedar Creek Wind CO 60822 18000
Grand View 2 West Solar ID 61595 3312
Granite Mountain Solar East, LLC Solar UT 63670 21300
Project 10a Solar CA 64788 188
Project 3 Solar CA 64785 180
Townsite Project Solar NV 64813 20440
Standard Rate
Unbundled RECs
2024 POWER SOURCE DISCLOSURE ANNUAL REPORT

ATTESTATION FORM
For the Year Ending December 31, 2024
City of Palo Alto Utilities
I, James Stack, Senior Resource Planner, declare under penalty of perjury, that the information provided in this report is true and correct and that I, as an authorized agent of City of Palo Alto Utilities, 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: James StackRepresenting: City of Palo Alto UtilitiesSignature: __________________Dated: 5/28/2025Executed at: Palo Alto, CA

COMMERCIAL POWER CONTENT LABEL 2024
Persons with disabilities who require materials in an appropriate alternative format, auxiliary aids, or modifications to policies or procedures to access City meetings, programs, or services should contact the City’s ADA Coordinator George Hoyt at (650) 329-2550 or by emailing [email protected].
12/25
Printed on 100% post-consumer recycled paper, bleached without chlorine.

WHERE DOES OUR
ELECTRICITY COME FROM?
POWER SOURCES IN 2024 CPAU power sources include: six solar PV projects, one wind project, five landfill gas-fired projects, the Calaveras hydroelectric project, and the Western Area Power Administration contract, which is sourced from Central Valley Project hydroelectric facilities. All of these resources are located in California. Power supply percentages vary annually based on the available output from our contracted generators. In 2024, CPAU’s hydroelectric generation was significantly higher than long-term average levels due to favorable weather conditions, so CPAU had a large surplus of renewable generation that it was able to sell to other utilities, which helped lower CPAU’s rates.
100% CARBON NEUTRAL ELECTRICITY SINCE 2013 Carbon neutral electricity comes from a variety of sources, including renewable resources like solar, wind and small hydroelectric plants. Large hydroelectric sources are also carbon-free, but the state of California doesn’t consider them renewable.

PaloAltoGreen’sa Prospective Product Content
Labelb for 2025 Consists of 100% Wind Energyc
a PaloAltoGreen is a voluntary renewable energy
program from City of Palo Alto Utilities that matches up to 100% of your estimated monthly electricity usage with
Green-e
® certified Renewable Energy Credits (RECs)
from new renewable energy resources, specifically
from generation facilities that first began commercial
operation in the last 15 years.
b Prospective Product Content Label: These figures reflect the renewables that we have contracted to provide.

Actual figures may vary according to resource availability.

We will annually report to you before October 1st of next year in the form of a Historical Product Content Label the actual resource mix of the electricity you purchased.
c Sourced from wind energy RECs located in the western
U.S. (CA, OR, WA, ID, NV, UT, AZ, MT, WY, CO, or NM) or Canada (BC or AB).

Green-e
Energy

CERTIFIED
PaloAltoGreen™
PaloAltoGreen is Green-e®
Energy certified and meets the
environmental and consumer-
protection standards set forth
by the nonprofit Center for
Resource Solutions.

For more information
on Green-e®
Certified Energy, call
1-888-63-GREEN or
visit green-e.org
PaloAltoGreen 2024 Historical Product Content
Label (reflected in the “Palo Alto Green” column of
the table on page 2): These figures reflect the power
delivered to PaloAltoGreen’s customers in 2024.
‘Unspecified Power’ was sourced from wind energy
facilities in Montana and Wyoming.

Find more details at paloalto.gov/PowerContentLabel and paloalto.gov/CarbonNeutral ● LARGE HYDROELECTRIC—59%
● SOLAR—37%
● WIND—1%
● ELIGIBLE HYDROELECTRIC—1%
● UNSPECIFIED POWER—2%
Like a nutrition facts label that shows the ingredients in food, the Power Content Label shows the sources of electricity purchased by City of Palo Alto Utilities to power local homes and businesses.

Exhibit B

CHECK OUT PALO ALTO’S POWER CONTENT LABEL FOR 2024

WHERE DOES OUR
ELECTRICITY COME FROM?
Find more details at
paloalto.gov.org/PowerContentLabel
and paloalto.gov/CarbonNeutral
Persons with disabilities who require materials in an appropriate alternative format, auxiliary aids, or modifications to policies or procedures to access City meetings, programs, or services should contact the City’s ADA Coordinator George Hoyt at (650) 329-2550 or by emailing [email protected].
12/25 Printed on 100% post-consumer recycled paper, bleached without chlorine. ● LARGE HYDROELECTRIC—59%
● SOLAR—37%
● WIND—1%
● ELIGIBLE HYDROELECTRIC—1%
● UNSPECIFIED POWER—2%
Like a nutrition facts label that shows the ingredients in food, the Power Content Label shows the sources of electricity purchased by City of Palo Alto Utilities to power local homes and businesses.

POWER SOURCES IN 2024
CPAU power sources include: six solar PV projects, one wind project, five landfill gas-fired projects, the Calaveras hydroelectric project, and the Western Area Power Administration contract, which is sourced from Central Valley Project hydroelectric facilities. All of these resources are located in California.

Power supply percentages vary annually based on the available output from our contracted generators. In 2024, CPAU’s hydroelectric generation was significantly higher than long-term average levels due to favorable weather conditions, so CPAU had a large surplus of renewable generation that it was able to sell to other utilities, which helped lower CPAU’s rates. 100% CARBON NEUTRAL ELECTRICITY SINCE 2013
Carbon neutral electricity comes from a variety of sources, including renewable resources like solar, wind and small hydroelectric plants. Large hydroelectric sources are also carbon-free, but the state of California doesn’t consider them renewable.

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