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Kate Sears' and MCE's "Green New Deal" - Part II
As discussed in Part I, Community Choice Aggregators (CCAs) and specifically Marin Clean Energy (MCE) are delivering a stripped down version of the "Green New Deal" under the guise of “carbon-free” energy that is nothing of the sort [Footnote 1].
The scheme is now spreading into Southern California through Los Angeles' Clean Power Alliance and Riverside County's Western Community Energy, and is largely based upon representations of clean energy deliveries to customers that are actually dirty system power (coal and natural gas) [Footnote 2].
Separately, other system power deliveries by CCAs occur during the night when CCAs' renewable resource production declines. CCAs fail to disclose much of this system power consumption and the associated greenhouse gas (GHG) emissions.
All of this occurs independently of CCAs repackaging other parts of their energy portfolios and branding them ultra-clean -- such as MCE's Deep Green -- which is a marketing ploy that is used to charge municipalities, water agencies, and other ratepayers more money for feeling good about receiving the exact same energy mix as non-Deep Green customers.
Part I of this series identified the three classes of renewable energy that are used to meet statutory requirements of California’s annual Renewable Portfolio Standard (RPS) mandate. These sources are technically known as PCC 1, PCC 2, and PCC 3.
The latter two are actually delivering dirty energy that a CCA advertises is "clean."
For global warming purposes, it is worth considering that PG&E's regulatory filing (and SCE's filing) shows it uses no PCC 2 or PCC 3 (dirty) energy. That is contrary to the practices of MCE, which, according to its regulatory filings, has delivered far less carbon-free energy to its customers than PG&E has to its ratepayers.
Ironically, much of MCE's carbon-free energy is nuclear power that is imported from Arizona's Palo Verde Nuclear Power Plant as a component of MCE's generic "system power" consumption. Remarkably, MCE does this while simultaneously criticizing PG&E for its reliance on the Diablo Canyon Nuclear Power Plant.
Washing Itself with Oil
MCE’s carbon accounting abuses involving unbundled RECs (PCC 3) are well-documented. MCE’s CEO, Dawn Weisz, claims MCE's activities are merely "true-ups." This so-called true-up was nothing more than manipulated accounting that MCE used (and uses) to magically transform its energy portfolio into a cleaner appearing energy mix than what PG&E advertised -- MCE delivered a given amount of dirty system power (fossil-fired), but represented to consumers that the same system power was suddenly & instantly carbon-free energy from a Montana hydroelectric dam, as was printed on some paper records from a San Francisco broker's office that MCE purchased 15 months after-the-fact.
The transaction circumvented California's governing Renewable Portfolio Standard while MCE represented it was in compliance with the law.
MCE's on-going manipulations are largely responsible for California passing truth-in-advertising legislation, AB 1110, which is currently being implemented.
Subsequent to public alert of MCE's doctored GHG emission numbers, MCE crafted new language in its annual "Understanding MCE's GHG Emission Factors" document for its naive board's consumption. This added text says MCE now requires a time delay in publishing its annual GHG emission rate to allow sufficient time for data computation and review [of PG&E's emission rate] before releasing such information to the public.
In other words, MCE will do whatever is necessary to ensure that its GHG emission rate never appears higher than PG&E's, and that MCE will wait for PG&E to publish its energy mix's GHG emission rate before publishing its own.
This continued doctoring is also confirmed by MCE's note at the bottom of its Price Comparison page where the CCA states its annual GHG emission factor "will be updated once PG&E's updates."
MCE's difficulty in cleaning up its behavior resides in its staff and extremely weak board leadership, which is typified by MCE's inability to jettison Shell Oil after claiming to do so in 2017. Over the past five months MCE has executed nearly $50 million in contracts with Shell, adding to the more than one-half billion dollars exported to the oil giant since 2010.
AB 1110 to the rescue, or an eviscerated casualty of political correctness?
Assembly Bill 1110 is supposed to correct GHG emission accounting abuses and bring transparency to the entire clean energy disclosure process. To get ahead of this inevitability CCAs throughout California, including MCE, claim they are weaning themselves off of PCC 3 (commonly referred to as “RECs" for unbundled Renewable Energy Certificates).
Yet, behind the scenes CCAs are lobbying California's AB 1110 implementation team to allow their continued reporting of PCC 3 and PCC 2 as zero-carbon energy even though both are nothing but the delivery of inexpensive dirty “system power” [Footnote 3].
CCAs prefer no transparency. Why? Because CCA staff, whose incomes depend on consumer participation, are afraid if consumers learn how dirty their CCA energy is, they will Opt Out of their so-called “clean energy” programs.
How dirty are they?
Independent Confirmation of Actual GHG Emission Rate is not easy for non-energy professionals. But it is doable.
Here are the steps that enable you to determine how much GHG is not disclosed by CCA (MCE). I suggest using a computer with a sizable monitor. Do not attempt this on a cell phone because you will need to magnify data tables in the source documents (PDFs).
STEP 1:
Collect these two source documents:
1. The annual Power Source Disclosure (PSD) report for calendar year in question. This must be requested from the California Energy Commission (CEC) at psdprogram@energy.ca.gov. It is available as PDF and Excel; request both from CEC. I suggest printing a copy so that you can make notes on it;
2. The Annual 33% RPS Compliance Report from the California Public Utilities Commission (CPUC). Click here for latest Preliminary RPS Compliance Reports (do not use Safari browser or you may have problems with CPUC site). Select folder titled "2017 Public Compliance Reports.zip." Save the desired CCA Compliance Report to your computer. Note the year to be sure it coincides with PSD Schedule 1 that should be in your possession.
STEP 2:
Construct an Excel spreadsheet that looks like this.
This spreadsheet is specific to MCE. The numbers that populate this sheet are linked to each of MCE's annual “Understanding MCE's GHG Emission Factors," discussed below. Do not worry about the "Understanding" document now.
STEP 3:
Identify PCC 3 (listed as "REC" or "REC only").
The annual Power Source Disclosure (PSD), Schedule 1, shows the annual energy volumes. These volumes may be listed as kilowatt-hours (KWh) or megawatt-hours (MWh) from each resource in MCE's annual portfolio. Be sure you are working with MWh. You can change KWh to MWh; divide KWh by 1,000.
Now locate and identify the "REC only" (aka "REC") volumes, identified on Schedule 1. Highlight these on the PSD report, as was done on MCE’s 2015 report here (a few of the "REC Only" are circled to be sure you see that text). You can see that the total-annual PCC3 megawatt-hour volume of 256,108 for 2015 was entered onto the worksheet here.
MCE's use of "PCC 3" was limited to 59,250 in 2015 by the RPS formula. So MCE invented "voluntary" RECs, and then retired another 196,858 of these instruments and told consumers its energy was extra clean.
STEP 4:
Identify PCC 2 (firm-and-shape RECs).
Identification of PCC 2 requires patience -- this can be an iterative and time consuming process. For illustrative purposes, I pasted the Annual RPS Compliance Report, behind Schedule 1 of the PSD report (I listed those resource names such as "Cedar Creek Wind" and associated PCC 2 MWh volumes for easy reference, per steps below).
Again, your objective is simply to identify all PCC 2 energy volumes in the RPS Compliance Report that correlate to Schedule 1 in the PSD, and highlight them – in red on the PSD report so that you can track / check them later, as needed or desired.
The mechanics of identifying PCC 2 are as follows:
- In the RPS Compliance Report, look for “Category 2 RECs” (or “PCC 2 RECs”) MWh volume for the year desired – typically identified within first five pages of a RPS Compliance Report. Make note that megawatt-hour (MWh) volume. You will likely have to enlarge the PDF document's view because the tables can be very small.
- Now, look at each resource name listed on the PSD Schedule 1, and then use the search feature on your PDF editor to locate that resource in the RPS Compliance Report. Most PCC 2 energy is "wind," so focus on those listed resources first. You may find the resource has no associated PCC 2 -- that is okay. This means the resource, in this instance, is not involved in a PCC 2 transaction.
- Scroll down through the RPS Compliance Report to the “Contract Detail” table (zoom to 300% or 400% as needed). Look for “PCC2” in the detail, then horizontally scroll to year in question. Underline the entire line in the Compliance Report, including resource name, so that you can return to the data line as you progress through this audit process. Write the resource name and MWh on the reverse side of your Schedule 1.
- Next, scroll through RPS Compliance Report's "36 Month Retirement.” Look for “PCC2” under the “Expected PCC Classification.” With the PSD report in hand, you are looking at the RPS Compliance Report’s header “Facility Name.”
- Each time you locate “PCC 2” for a facility name that is also listed on PSD Schedule 1 (example: Cedar Creek, Harvest Wind, Klondike III, White Creek Wind 1, Seneca), scroll to the far-right column of the RPS Compliance Report (under header “MWh REC Quantity Retired”) and note the megawatt-hours.
Write the resource name and MWh, on reverse side of Schedule 1, if that is easiest for you. There may be multiple lines in the RPS Compliance Report that correspond to a given resource name. That is okay. Again, your task is to identify -- by simple addition in easiest case, or iterative trial-and-error addition in more time consuming cases -- the cumulative MWh volumes in the RPS Compliance Report that match MWh volume identified on the PSD Schedule 1 for a given resource.
Be aware that sometimes a resource's MWh on the PSD Schedule 1 can reflect a combination of PCC 1 and PCC 2 volumes that are listed in the RPS Compliance Report. This is illustrated here on Schedule 1 where White Creek Wind 1 shows 71,163 MWh, but according to the RPS Compliance Report 50,000 MWh were PCC 2, while 21,163 MWh were PCC 1 (PCC 1 is the "good stuff" -- genuine delivered renewable energy).
- When this process is complete your sum MWh quantities for PCC 2 energy (highlighted in red on Schedule 1) will equal the initially noted “Category 2 RECs” or “PCC 2 RECs” MWh volume identified in the Preliminary RPS Compliance Report.
STEP 5:
Your completed and marked PSD Schedule 1 should now show all PCC 2 and PCC 3 volumes, and should look like this (yellow and red highlights, PCC 3 and PCC 2, respectively). I sorted this Schedule 1 for presentation purposes so that all PCC 2 and all PCC 3 were grouped together. You will find that your yellow and red highlighted lines are separated throughout Schedule 1.
STEP 6:
Enter all PCC 2 and PCC 3 MWh volumes for the year in question into your worksheet. The corresponding pounds of GHG are calculated at a California standard rate of 943.58 lbs per MWh, which is California Air Resources Board's factor for system power (aka Unspecified Power, or Generic Purchase).
STEP 7:
Add the associated GHGs for PCC2 + PCC3 to the GHGs that MCE discloses. The total pounds of GHG can then be divided by total annual MWh sales to determine the actual annual emission rate for MCE's overall energy portfolio. Footnotes in the table explain background on factors in the table.
This analysis gives the benefit of the doubt to MCE by assuming: (i) MCE's renewable energy volumes are, in fact, real, (ii) its renewable energy volumes satisfy the CPUC's RPS Compliance Period audit and content category, (iii) MCE disclosed all of its nighttime system power purchases and associated GHGs, and (iv) all of MCE's large hydro electric imports are legitimate deliveries into California and are not substituted with fossil-based system power [Footnote 4].
Keep in mind that you are embarking on an audit journey that requires a lot of expertise. However, if you are persistent, determining undisclosed GHGs in CCAs' portfolios is achievable [Footnote 5].
CONCLUSION
MCE and other CCAs are dramatically increasing global warming while misleading California consumers about the GHG emission reductions associated with their "clean" energy.
Audit of MCE's regulatory filings show that MCE's actual GHG emission rate is as much as twice what it advertises, as viewed in the summary table here. Actual annual GHG emissions cannot be massaged or rationalized away by lobbying governmental bodies or relabeling the truth. The atmosphere receives these emissions as the global warming gases that they are.
This is MCE's and all other CCAs' version of a Green New Deal.
Footnotes
[1] CCA failure of bringing required net-new renewable resources to California caused the California Public Utilities Commission (CPUC) to recently (unanimously) pass planning regulations that address California's renewable energy needs versus CCAs' "we're in control" attitudes where they reject CPUC's integrated oversight of California's electric system, deferring to their own boards that are comprised of city and town council members who are not energy professionals.
[2] CCA Western Community Energy (WCE) in Riverside County posts videos on its website stating that the "same energy" it purchases is delivered to its customers' homes.
However, the language in Western's draft Implementation Plan reveals a different reality. The Plan states that PCC 2 energy is used in its renewable energy mix. PCC2 is not the "same energy" -- it is substitute energy, typically system power. PCC 2 is used by CCA to save money and to appear clean.
The CCA consultant, EES Consulting (Kirkland, WA), who authored the original business plan for WCE (formerly known as Inland Choice Power CCA) is the same consultant who authored the original business plan for Los Angeles' Clean Power Alliance (formerly known as Los Angeles Community Choice Energy). In both business plans EES Consulting identifies that PCC 2 (Bucket 2) constitutes 100% of each CCA's RPS energy (Inland Choice (WCE) CCA Business Plan, 12-08-2016, page 26, Exhibit 14. LA CCE Business Plan, 06-30-2016, page 21, Exhibit 15).
Attempting to satisfy California's RPS energy mandate by exclusively using Bucket 2 (PCC 2) is not allowable, per RPS law.
[3] System power is the biggest resident on California’s electric grid and is produced by a mix of gas-fired and coal fired power plants, with some miscellaneous excess-production from other resources. California Air Resources Board stipulates that system power (aka "unspecified sources" or "generic purchase") has an emission rate of 943.58 lbs per MWh. System power energy sources are delivered as MCE’s PCC 2 and PCC 3 renewable energy. MCE then advertises this dirty power is zero-emission renewable energy [Source: MCE’s 2014 RPS Compliance Report, beginning p. 20 of 34]. Another example of delivered clean energy misrepresentation can be viewed at MCE’s sister CCA -- Silicon Valley Clean Energy (SVCE). Like MCE and other CCAs, SVCE claims PCC 2 renewable energy (and PCC 3) is delivered zero-emission renewable energy [Source: SVCE’s 2017 RPS Compliance Report, p. 339-341 of 344].
[4] Authenticity of CCA "large hydroelectric" imports remain a concern for energy professionals and regulators because large hydro is not classified as a renewable energy in California, and so it is not carefully tracked, audited, and reconciled. Much of CCAs' "zero-carbon" large hydroelectric power may by substitute system power. For instance, in 2017 (latest year of available data) 60% of SVCE's green energy was imported large hydro. In 2016 (last year of available data) Redwood Coast CCA was 45%, Sonoma Clean Power was 42%, and Marin Clean Energy was 21%.
Thus, for example, that 21% of MCE's carbon-free energy may actually be system power ("Unspecified Sources"), not clean energy.
[5] If you are interested in compiling GHG emissions (pounds CO2e per MWh) for CCAs other than MCE, you may need to calculate GHGs for natural gas, geothermal, etc., if those GHG-emitting resources are listed on Schedule 1 for the year you are wanting to review. Per above, use Schedule 1 as your roadmap. Then, in addition to the PCC 2 and PCC 3 steps above, determine GHGs for other emitting resources, including listed "Unspecified Power" (aka Generic Purchase).
You can find resource-specific CO2e (GHG) data at California Air Resources Board's website for 2016 or 2017 (select "GHG Data" tab at bottom). Be sure to convert "metric tons CO2e" to "pounds CO2e" (multiply metric tons x 2,204.62 to convert to pounds). Then divide those annual CO2e emissions for your specific resource by that resource's annual MWh production found in CEC’s annual database here for 2016 or, if you are working with 2017 then here for 2017, to determine the Pounds of CO2e per Megawatt-hour annual factor for the power generating resource in question. Once you determine this annual GHG emission factor, you can determine how many total GHGs for that single resource apply to your CCA by multiplying the annual GHG emission factor by the listed MWh for that power generating resource noted on your CCA's Power Source Disclosure, Schedule 1. If KWh are listed on Schedule 1 be sure to convert to MWh. This is achieved by dividing KWh by 1,000.
Generally speaking:
- Natural Gas (if combined cycle gas turbine) should not calculate to more than 900;
- Geothermal should not calculate to more than 135;
- "Unspecified Power" (aka Generic Sources, or system power) = 943.58.
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Jim Phelps is a consumer advocate, specializing in energy issues and CCAs. Before retiring he was a power contractor and utility rate analyst. He consults municipalities who are considering the merits of CCA and the accrued effects on municipal Climate Action Plans. He is a contributor to the California Energy Commission's AB 1110 Implementation Rulemaking.