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Home My WebLink About2020-09-28 City Council Agendas (6) City of Palo Alto (ID # 11562) City Council Staff Report Report Type: Consent Calendar Meeting Date: 9/28/2020 City of Palo Alto Page 1 Council Priority: Climate/Sustainability and Climate Action Plan Summary Title: Approval of the 2019 Annual Power Source Disclosure Reports Title: Adoption of a Resolution Approving and Attesting to the Veracity of the City's 2019 Annual Power Source Disclosure and Power Content Label Reports From: City Manager Lead Department: Utilities Recommendation Staff recommends that the City Council adopt a resolution (Attachment A) approving the City’s two Power Source Disclosure reports for 2019 (attached as Exhibit A in Attachment A) and attesting to their veracity. Background Senate Bill 1305 (SB 1305) was approved in 1997 to ensure that all retail suppliers of electricity disclose to consumers the sources of energy used to provide electric service in an accurate, reliable and easy to understand manner. 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. The City of Palo Alto normally submits an annual PSD Report to the California Energy Commission (CEC) by June 1st of each year; however, due to the Covid-19 pandemic, in 2020 the CEC extended the PSD Report deadline (for all retail electricity suppliers) to July 20th. The information contained in the PSD report also contains the fuel mix for the City’s retail electricity sales for the prior year, which is used to prepare the City’s annual Power Content Label (PCL). The City mails the PCL to the City’s customers, and posts it on the City’s website by October 1st of each year at https://www.cityofpaloalto.org/gov/depts/utl/residents/resources/pcm/power_content_label. asp and on the CEC’s website at https://www.energy.ca.gov/programs-and- topics/programs/power-source-disclosure/power-content-label. CITY OF PALO ALTO City of Palo Alto Page 2 Discussion In 2017, the CEC updated the regulation1 implementing SB 1305, making the changes retroactively effective in October 2016. One of the changes required utilities to engage a third- party certified public accountant to perform an audit to verify the specific purchases, resales, and self-consumption of energy by fuel type, but included an exemption for publicly owned electric utilities, if the Council formally attested to the veracity of the annual report. In Palo Alto’s case, this meant that the PSD report for the City’s standard power mix could be approved by the City Council, as described above. However, the City’s voluntary PaloAltoGreen product, which is available to all commercial customers and allows them to pay a small premium in order to receive a power supply comprising only wind and solar generation, was subject to the audit requirement. (The third-party certified public accountant that the City hired to perform the audit, Lakeshore Global, approved the City’s PSD report for the 2018 PaloAltoGreen program in November 2019.) A May 2020 update to the CEC regulation2 implementing SB 1305 now allows the City Council to attest to the veracity of each PSD report and PCL for the previous year, and avoid having to hire a third-party auditor to review the PSD report for the 2019 PaloAltoGreen product. The PSD report submissions for both the standard Carbon Neutral product and the 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 multiple City staff members 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 the program. In 2019, CPAU’s hydroelectric generation was above long-term average levels, after the state experienced relatively wet years in 2017 and 2018. Because of this, along with steady declines in the City’s annual load in recent years, and with five new utility-scale solar projects that came online in the past few years, Palo Alto had a significant overall surplus of energy. Utilities Department staff sold this excess generation (216,000 MWh) as renewable energy to other utilities, yielding over $3.5 million in revenue to offset other supply purchase costs. As a result of these renewable energy sales, the share of the City’s standard power mix that comes from eligible renewables sources was lower in 2019 (36.3%) than in 2018 (65%). However, as noted earlier, the City’s power supply remained carbon neutral in 2019 in accordance with the City’s Council-adopted Carbon Neutral Plan (Staff Report 11556). (Note that the power mix percentages listed in the PSD reports to the CEC reflect the total energy the City purchased during the prior calendar year, as opposed to the information on the PCL for consumers, which 1 “Power Source Disclosure Program Regulations,” California Energy Commission, CEC-300-2017-048, October 2016. http://docketpublic.energy.ca.gov/PublicDocuments/14-OIR- 01/TN216978_20170412T103905_Power_Source_Disclosure_Program_Amended_Regulations.pdf. 2 California Code of Regulations Title 20, Sections 1394.2(a)(2). https://efiling.energy.ca.gov/GetDocument.aspx?tn=232986&DocumentContentId=65451. City of Palo Alto Page 3 displays the City’s retail electricity sales during the prior calendar year.) Utilities Department staff submitted the City’s annual PSD report for calendar year 2019 (attached as Exhibit A in Attachment A) to the CEC in July 2020, along with the associated staff attestation form. Staff subsequently submitted an updated set of annual PSD reports to the CEC after Utilities staff discovered a minor clerical error with the original submission. The 2019 PCL will be mailed to each electric utility customer as a bill insert and posted on the City’s website in October 2020, in accordance with the regulation. The attached resolution (Attachment A) approves the annual PSD reports for both the standard power mix and the PaloAltoGreen product and provides the attestation to the veracity of all of the reports as required for exemption from the third-party audit requirement. Staff anticipates submitting the City’s annual PSD report for calendar year 2020 to the CEC around June 2021 and providing the 2021 PCL to electric customers around September 2021. Resource Impact Adoption of the attached resolution will not result in a financial impact to the City. Policy Implications Adoption of the attached resolution will enable the City to comply with the CEC regulation implementing SB 1305 (California Code of Regulations, title 20, sections 1391 to 1394). Environmental Review Adoption of the attached resolution is not subject to California Environmental Quality Act (CEQA) review as an administrative government activity that will not result in any direct or indirect physical change to the environment as a result (CEQA Guidelines section 15378(b)(5)). Attachments: • Attachment A: Resolution Approving 2019 Power Source Disclosure Reports *NOT YET APPROVED* 6055424 Resolution No. _______ Resolution of the Council of the City of Palo Alto Approving and Attesting to the Veracity of the City’s 2019 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 October. D.California Code of Regs., title 20, sections 1394.2(a)(2), updated by the California Energy Commission effective May 2020, allows the City Council to attest to the veracity of each PSD report and PCL 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 July 2020, Utilities Department staff submitted the 2019 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. Staff submitted an updated set of 2019 Annual PSD reports to the Energy Commission in August 2020. Attachment A *NOT YET APPROVED* 6055424 The Council of the City of Palo Alto (“City”) RESOLVES as follows: SECTION 1. The City Council approves the submission and attests to the veracity of the 2019 Annual Power Source Disclosure and Power Content Label Reports for the City’s standard carbon neutral portfolio, and for the City’s voluntary PaloAltoGreen program (attached as Exhibit A to this resolution) which staff submitted to the California Energy Commission in August 2020. SECTION 2. 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: ___________________________ _______________________ Assistant City Attorney City Manager ___________________________ Director of Utilities ___________________________ Director of Administrative Services Version: May 8, 2020 Name James Stack Title Senior Resource Planner Mailing Address 250 Hamilton Ave., 3rd Floor City, State, Zip Palo Alto, CA 94301 Phone (650) 329-2314 E-mail james.stack@cityofpaloalto.org Website URL for PCL Posting www.cityofpaloalto.org/PowerContentLabel Submit the Annual Report and signed Attestation in PDF format with the Excel version of the Annual Report to PSDprogram@energy.ca.gov. 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. 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. If you have questions, contact Power Source Disclosure (PSD) staff at PSDprogram@energy.ca.gov or (916) 654-3954. ELECTRICITY PORTFOLIO NAME Standard Rate CONTACT INFORMATION City of Palo Alto Utilities ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source Disclosure For the Year Ending December 31, 2019 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 Exhibit A Version: May 8, 2020 861,561 880,044 - 18,483 8 - 880,035 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 N/A Half Moon Bay (Ox Mountain) Biomass & biowaste CA W 2033 60022A 56895 43,474 19,424 24,050 23,545 Johnson Canyon LFG Biomass & biowaste CA W 3397 61353A 58397 10,422 4,589 5,833 5,711 Keller Canyon Biomass & biowaste CA W 2071 61298A 56897 14,939 6,502 8,437 8,260 San Joaquin LFG Biomass & biowaste CA W 3883 62433A 58436 30,653 13,872 16,781 16,429 Santa Cruz LFG Biomass & biowaste CA W 2014 61297A 56428 9,348 3,865 5,483 5,368 New Spicer Meadows Eligible hydro CA W 1260 61580A 54554 5,623 2,451 3,172 3,105 WAPA - Lewiston Eligible hydro CA W 1108 61044A 485 485 475 WAPA - Nimbus Eligible hydro CA W 1161 61045A 444 5,747 5,747 5,626 WAPA - Stampede Eligible hydro CA W 1177 61046A 7066 1,595 1,595 1,562 275 Cambridge Ave Parking Garage Solar CA W 5649 63982A 463 463 453 445 Bryant St. Parking Garage Solar CA W 5647 63610A 383 383 375 475 Campridge Ave Parking Garage Solar CA W 5650 63981A 491 491 481 520 Webster St. Parking Garage Solar CA W 5648 63611A 583 583 571 Crow Creek Solar (Frontier) Solar CA W 4962 62248A 60039 52,091 18,818 33,273 32,575 EE Kettleman - Land - Centaurus Solar CA W 4695 62422A 59633 53,502 18,635 34,867 34,135 Elevation Solar C (Big Sky 2) Solar CA W 5298 63192A 59964 110,990 44,962 66,028 64,642 Hayworth Solar (Lamont) Solar CA W 4719 62744A 59009 64,546 23,626 40,920 40,061 HP Inc - Palo Alto HQ Solar CA W 7686 64036A 355 355 348 Hydro Solar Solar CA W 1266 62543A 3 3 3 UUCPA (505 E. Charlestom Rd)Solar CA W 7382 63983A 218 218 213 Western Antelope Blue Sky Ranch B (Big Sky 4) Solar CA W 5300 61518A 59961 55,145 20,172 34,973 34,239 High Winds Wind CA W 229 60726A 56075 36,627 14,157 22,470 21,998 Shiloh Wind CA W 231 60488A 56362 37,460 25,035 12,425 12,164 ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source Disclosure SCHEDULE 1: PROCUREMENTS AND RETAIL SALES For the Year Ending December 31, 2019 City of Palo Alto Utilities Standard Rate Net Nuclear, Large Hydro & Renewables Retail Sales (MWh) Unspecified Power (MWh) Procurement to be adjusted Net Natural Gas Net Coal & Other Fossil Fuels Net Specified Procurement (MWh) 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 firmed-and-shaped imports, provide the EIA ID of the substitute power, not the generator ID of the RECs. For EIA IDs for unspecified power or specified system mixes from asset-controlling suppliers, enter "unspecified", "BPA," "Powerex,", or "Tacoma" 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 L9. Unbundled RECs must not be entered on Schedule 1 ; these products must be entered on Schedule 2. At the bottom portion of the schedule, provide the other electricity end-uses that are not retail sales including, but not limited to transmission and distribution losses or municipal street lighting. Amounts should be in megawatt-hours. Version: May 8, 2020 FIRMED-AND-SHAPED IMPORTS Facility Name Fuel Type Province WREGIS ID RPS ID REC Substitute Procured MWh Resold Procured MWh N/A - - - - - - - - - - - - - - - - - - - - - - SPECIFIED NON-RENEWABLE PROCUREMENTS Facility Name Fuel Type Province WREGIS ID RPS ID REC EIA ID Procured MWh Resold Procured MWh N/A Collierville Large hydro CA W 1258, W 1259 54555 209,381 209,381 204,986 Gianelli Powerplant (units 2 and 6)Large hydro CA W 1162, W 1288 448 - - WAPA - Folsom Large hydro CA W 1156 thru W 1158 441 52,091 52,091 50,997 WAPA - J.F.Carr Large hydro CA W 1164 442 17,176 17,176 16,815 WAPA - Keswick Large hydro CA W 1165 443 23,511 23,511 23,017 WAPA - New Melones Large hydro CA W 1159, W 1160 6158 54,059 54,059 52,924 WAPA - O'Neill Large hydro CA W 1167, W 1186 446 321 321 315 WAPA - Shasta Large hydro CA W 1168 thru W 1172 445 161,665 161,665 158,271 WAPA - Spring Creek Large hydro CA W 1174 450 24,339 24,339 23,828 WAPA - Trinity Large hydro CA W 1175, W 1176 451 18,457 18,457 18,069 City of Palo Alto COBUG Natural gas CA 57714 8 8 - - - - - - - - - - - - - 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 N/A - - - - - - - - - - - Version: May 8, 2020 Adjusted Net Procured (MWh) Percent of Total Retail Sales Renewable Procurements 312,338 36.3% Biomass & Biowaste 59,312 6.9% Geothermal - 0.0% Eligible Hydroelectric 10,768 1.2% Solar 208,096 24.2% Wind 34,162 4.0% Coal - 0.0% Large Hydroelectric 549,223 63.7% Natural gas - 0.0% Nuclear - 0.0% Other - 0.0% Unspecified Power - 0.0% Total 861,561 100.0% 861,561 0.0% ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source for the year ending December 31, 2019 Standard Rate Total Retail Sales (MWh) Percentage of Retail Sales Covered by Retired Unbundled RECs City of Palo Alto Utilities SCHEDULE 3: ANNUAL POWER CONTENT LABEL DATA Instructions: No data input is needed on this schedule. Retail suppliers should use these auto-populated calculations to fill out their Power Content Labels. Version: May 8, 2020 ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source Disclosure ATTESTATION FORM for the year ending December 31, 2019 City of Palo Alto Utilities Standard Rate I, James A. Stack, Senior Resource Planner, declare under penalty of perjury, that the statements contained in this report including Schedules 1, 2, and 3 are true and correct and that I, as an authorized agent of City of Palo Alto Utilities, have authority to submit this report on the company's behalf. I further declare that the megawatt-hours claimed as specified purchases as shown in these Schedules were, to the best of my knowledge, sold once and only once to retail customers. Name: James A. Stack Representing (Retail Supplier): City of Palo Alto Utilities Signature: __________________________________________________________ Dated: August 19, 2020 Executed at: Palo Alto, CA Version: May 8, 2020 Name James Stack Title Senior Resource Planner Mailing Address 250 Hamilton Ave., 3rd Floor City, State, Zip Palo Alto, CA 94301 Phone (650) 329-2314 E-mail james.stack@cityofpaloalto.org Website URL for PCL Posting www.cityofpaloalto.org/PowerContentLabel Submit the Annual Report and signed Attestation in PDF format with the Excel version of the Annual Report to PSDprogram@energy.ca.gov. 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. 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. If you have questions, contact Power Source Disclosure (PSD) staff at PSDprogram@energy.ca.gov or (916) 654-3954. ELECTRICITY PORTFOLIO NAME Palo Alto Green CONTACT INFORMATION City of Palo Alto Utilities ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source Disclosure For the Year Ending December 31, 2019 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 Version: May 8, 2020 26,565 26,565 - - - - 26,565 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 N/A HP Inc - Palo Alto HQ Solar CA W 7686 64036A 260 260 260 445 Bryant St. Parking Garage Solar CA W 5647 63610A 5 5 5 Shiloh Wind CA W 231 60488A 56362 26,300 26,300 26,300 - - - - FIRMED-AND-SHAPED IMPORTS Facility Name Fuel Type Province WREGIS ID RPS ID REC Substitute Procured MWh Resold Procured MWh Grandfathered - - - - - - - - - - - - - - - - - - - - - - SPECIFIED NON-RENEWABLE PROCUREMENTS Facility Name Fuel Type Province N/A N/A N/A EIA ID Procured MWh Resold Procured MWh N/A - - Net Nuclear, Large Hydro & Renewables ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source Disclosure SCHEDULE 1: PROCUREMENTS AND RETAIL SALES For the Year Ending December 31, 2019 City of Palo Alto Utilities Palo Alto Green Retail Sales (MWh) Net Specified Procurement (MWh) Unspecified Power (MWh) Procurement to be adjusted Net Natural Gas Net Coal & Other Fossil Fuels 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 firmed-and-shaped imports, provide the EIA ID of the substitute power, not the generator ID of the RECs. For EIA IDs for unspecified power or specified system mixes from asset-controlling suppliers, enter "unspecified", "BPA," "Powerex,", or "Tacoma" 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 L9. Unbundled RECs must not be entered on Schedule 1 ; these products must be entered on Schedule 2. At the bottom portion of the schedule, provide the other electricity end-uses that are not retail sales including, but not limited to transmission and distribution losses or municipal street lighting. Amounts should be in megawatt-hours. Version: May 8, 2020 Adjusted Net Procured (MWh) Percent of Total Retail Sales Renewable Procurements 26,565 100.0% Biomass & Biowaste - 0.0% Geothermal - 0.0% Eligible Hydroelectric - 0.0% Solar 265 1.0% Wind 26,300 99.0% Coal - 0.0% Large Hydroelectric - 0.0% Natural gas - 0.0% Nuclear - 0.0% Other - 0.0% Unspecified Power - 0.0% Total 26,565 100.0% 26,565 0.0%Percentage of Retail Sales Covered by Retired Unbundled RECs ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source SCHEDULE 3: ANNUAL POWER CONTENT LABEL DATA for the year ending December 31, 2019 City of Palo Alto Utilities Palo Alto Green Total Retail Sales (MWh) Instructions: No data input is needed on this schedule. Retail suppliers should use these auto-populated calculations to fill out their Power Content Labels. Version: May 8, 2020 ANNUAL REPORT TO THE CALIFORNIA ENERGY COMMISSION: Power Source Disclosure ATTESTATION FORM for the year ending December 31, 2019 City of Palo Alto Utilities Palo Alto Green I, James A. Stack, Senior Resource Planner, declare under penalty of perjury, that the statements contained in this report including Schedules 1, 2, and 3 are true and correct and that I, as an authorized agent of City of Palo Alto Utilities, have authority to submit this report on the company's behalf. I further declare that the megawatt-hours claimed as specified purchases as shown in these Schedules were, to the best of my knowledge, sold once and only once to retail customers. Name: James A. Stack Representing (Retail Supplier): City of Palo Alto Utilities Signature: __________________________________________________________ Dated: August 19, 2020 Executed at: Palo Alto, CA