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HomeMy WebLinkAboutStaff Report 2509-5220CITY OF PALO ALTO CITY COUNCIL Monday, December 15, 2025 Council Chambers & Hybrid 4:30 PM     Agenda Item     6.Adoption of a Resolution Approving and Attesting to the Veracity of the City's 2024 Power Source Disclosure and Power Content Label Reports. CEQA Status: Not a project City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Utilities Meeting Date: December 15, 2025 Report #:2509-5220 TITLE Adoption of a Resolution Approving and Attesting to the Veracity of the City's 2024 Power Source Disclosure and Power Content Label Reports. CEQA Status: Not a project RECOMMENDATION Staff recommends that the City Council adopt a resolution (Attachment A) approving and attesting to the veracity of the City’s Power Source Disclosure reports and Power Content Labels for 2024. BACKGROUND Senate Bill 13051 was approved in 1997 to ensure that all retail suppliers of electricity disclose to consumers the sources of energy used to provide the electric service in an accurate, consistent, and easy to understand manner. The SB 1305 Report is commonly referred to as the Power Source Disclosure (PSD) report. The City of Palo Alto is required to submit an annual PSD report to the California Energy Commission (CEC) by June 1st of each year. The information contained in this report is used to prepare the annual Power Content Label (PCL), which is mailed to City of Palo Alto Utilities customers and posted on the City’s website each year at www.cityofpaloalto.org/powercontentlabel and on the CEC’s website at energy.ca.gov/power- content-label. ANALYSIS CEC regulations governing the Power Source Disclosure Program2 require retail electricity sellers 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.3 However, publicly owned 1 Senate Bill 1305: http://www.leginfo.ca.gov/pub/97-98/bill/sen/sb_1301- 1350/sb_1305_bill_19971009_chaptered.html 2 California Code of Regulations, Title 20, Sections 1391-1394. 3 California Code of Regulations Title 20, Section 1394(a)(2). electric utilities are exempt from the audit requirement if the governing board of the utility “submits to the Energy Commission an attestation of the veracity of each annual resource report for the previous year.”7 8 Although the power sourced out-of-state remains renewable and carbon-neutral, the CEC categorizes such power as “unspecified power” on the PSD and PCL documents. 9. Of this amount, $2.83 million was attributable to the REC Exchange Program, and per Council’s direction in 2022, an amount equivalent to this level of net revenue will be set aside in the City’s Cap and Trade Program Reserve and used to fund investments in local decarbonization initiatives (Staff Report 14735). 10), and the City remained in compliance with the state’s Renewable Portfolio Standard (RPS) mandate. 7 California Code of Regulations Title 20, Section 1394(a)(2). 8 The City Council approved the REC Exchange Program in August 2020 (Staff Report 11556): https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports- cmrs/year-archive/2020-2/id-11566.pdf. 9 There is typically a lag of up to 12 months before the City receives the funds from these transactions, due to the time required for the RECs to be registered and transferred, as well as the time required for the billing and settlements process to transpire. 10 Staff Report 11556: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/reports/city- manager-reports-cmrs/year-archive/2020-2/id-11566.pdf A to Attachment A) to the CEC in May 2025, along with the associated attestation form. The City’s 2024 PCLs (Exhibit B to Attachment A) were mailed to each electric utility customer as a bill insert in November 2025, in accordance with the Power Source Disclosure Program regulations.15 They are also posted on the City’s website. The attached resolution (Attachment A) approves the annual PSD reports and PCLs for both the standard power mix and the PaloAltoGreen product and provides for Council’s attestation to the veracity of these four documents as required for exemption from the third-party audit requirement. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: 15 California Code of Regulations Title 20, Section 1393.1: “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.” *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 1393.1(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 distributed to Utilities customers as an insert in their November Utilities bills. SECTION 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 PSDprogram@energy.ca.gov. Remember to complete the Retail Supplier Name and contact information above. California Energy Commission's website. If you have questions, contact Power Source Disclosure (PSD) staff at PSDprogram@energy.ca.gov 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 james.stack@paloalto.gov 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. Facility Name Fuel Type State or Province WREGIS ID of REC source 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 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 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 Procured Firmed & Shaped Resource? 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 0 0 Eligible Hydroelectric 9390 Solar 316075 Wind 5408 Large Hydroelectric 512586 Nuclear 0 Emerging Technologies 0 Other 0 Natural Gas 0 Coal & Petroleum 0 Unspecified Power - ACS 0 Unspecified Power - Spot Market 19656 Unspecified Power - Total 19656 Total PCL GHGs (MT CO2e)8412.8 Emissions intensity (MT CO2e/MWh)0.010 PCL GHG Intensity (lbs CO2e/MWh) 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 Solar 34253 0 ELEVATION SOLAR Solar 92129 0 Solar 40708 0 Solar 132 0 HP INC.Solar 2002 0 445 BRYANT ST. PARKING GARAGE Solar 327 0 520 Webster St. Parking Garage Solar 560 0 Solar 322 0 Solar 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 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 Stack Representing: City of Palo Alto Utilities Signature: __________________ Dated: 5/28/2025 Executed at: Palo Alto, CA C O M M E R C I A L P O W E R C O N T E N T L A B E L 2 0 2 4 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 ADA@paloalto.gov.org. 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’s a Prospective Product Content Label b for 2025 Consists of 100% Wind Energy c 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 C E R T I F I E D 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 C H E C K O U T PA LO A LTO ’ S P OW E R C O N T E N T L A B E L F O R 2 0 2 4 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 ADA@cityofpaloalto.org. 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.