PSD Frequently Asked Questions

The 2024 PCL will:

• Use color-coding and pie charts to distinguish between two supercategories of electricity sources: renewables and zero-carbon resources vs. fossil fuels and unspecified power
• Feature an updated statewide fuel mix that reflects the average fuel mix across all retail portfolios, rather than California Total System Electric Generation
• Exclude greenhouse gas (GHG) emissions associated with geothermal resources from the PCL
• Be produced by the Energy Commission for retail suppliers to share with their customers, rather than initially submitted by retail suppliers to the Energy Commission through a template
• No longer require a separate attestation from the governing boards of public agencies separate, who will only need to attest to the veracity of their submitted annual reports

The 2025 and subsequent PCLs will:

• Update the fuel mix supercategories to be either renewables and zero-carbon resources, or fossil fuels
• Display the percentage of unspecified power derived from either renewables and zero-carbon resources or from fossil fuels
• Feature a new “total” category that reflects the fuel mix and GHG emissions intensity of a retail supplier’s loss-adjusted load, which will include all retail sales, other electricity end uses, and transmission and distribution losses
• Update the state average fuel mix and GHG intensity to reflect the average of the loss-adjusted load data reported to the PSD program

This is a pollution rate that measures the mass of GHGs that are emitted into the atmosphere to generate one megawatt hour (MWh) of electricity from a particular generation resource or portfolio of resources.

An eligible renewable resource means a generator that is certified pursuant to the California Renewables Portfolio Standard (RPS) Program. Eligible renewables include biomass and biogas, geothermal, eligible hydroelectric, solar, wind, and other resources that the RPS Program may recognize in the future.

RECs are certificates of proof associated with the generation of electricity from an eligible renewable energy resource. Retail electricity suppliers buy and sell RECs for compliance with the RPS program, as well as for voluntary purposes. Under the PSD program, resources categorized as eligible renewables must include the associated RECs.

These are RECs bought or sold without any associated electricity. While they may be used to meet certain RPS requirements, unbundled RECs are not factored into the fuel mix or GHG emissions intensity of an electricity portfolio because they are not associated with electricity procurement. Instead, the PCL discloses unbundled RECs separately as a percentage of retail sales.

Unspecified power refers to electricity that is not traceable to specific generation sources by any auditable contract trail or equivalent.

For the 2020-2024 PCLs, the PSD program assigned all unspecified power a default emissions intensity of 944 lbs (0.428 metric tons) of CO2e/MWh. This is a similar emissions profile to a natural gas generator and reflects the emissions intensity that the California Air Resources Board (CARB) assigns to unspecified imports under the Mandatory Greenhouse Gas Reporting Regulation (MRR).

Starting with the 2025 PCL, the Energy Commission will calculate the GHG intensity of unspecified power based on the MWh and emissions from three data points:

• In-state gas generation that was not claimed as a specified purchase by retail suppliers.
• Unspecified imports.
• Oversupply, i.e. the excess generation from retail suppliers who procured more than their annual loss-adjusted loads.

The sum of all GHG emissions divided by the sum of all MWh across these three categories will determine the annual emissions factor of unspecified power.

Firmed-and-shaped products are a special class of electricity import, used primarily for RPS compliance, in which RECs are matched with imported substitute electricity. In the PSD program’s fuel mix accounting, firmed-and-shaped products are counted as eligible renewables and classified according to the fuel type of the REC source. In the PSD program’s GHG accounting, these products are assigned the emissions associated with the imported substitute electricity. This split accounting methodology reflects historical differences in fuel type and GHG emissions accounting practices established by other state programs such as the RPS and CARB’s MRR.

Retail suppliers can exclude GHG emissions associated with eligible firmed-and-shaped products from the PCL if they were procured under a purchase agreement executed prior to January 1, 2019. This provision provides good faith relief to retail suppliers that entered into firmed-and-shaped contracts prior to the development of retail GHG emissions accounting rules.

Neither biogenic carbon dioxide nor geothermal emissions have a compliance obligation under CARB’s Cap-and-Trade program, which means the state has not targeted them for decarbonization. The Energy Commission has chosen to exclude these emissions from the label to provide better alignment between the PCL and the emissions subject to the Cap-and-Trade program and to reflect the unique role that biogenic and geothermal resources play in California’s climate strategy.

However, this exclusion for biogenic and geothermal emissions is limited to the GHG emissions intensities displayed on the PCL. Information about all GHG emissions associated with retail suppliers’ electricity purchases, including from biogenic and geothermal sources, will be reported in the retail supplier’s Annual Report and made available on the Energy Commission’s website.

The PSD program serves a different purpose than the RPS program. RPS tracks the retirement of RECs across multi-year compliance periods, while PSD provides an annual snapshot of a retail supplier’s electricity sources serving retail customers. A further distinction between the programs is that PSD does not allow unbundled RECs to contribute to the fuel mix, even though those may be eligible products for use in RPS compliance.

SB 1158 established January 1, 2028, as the date on which hourly reporting takes effect. Calendar year 2027 data will be due to the PSD program by June 1, 2028.

All retail suppliers with greater than 60,000 customers and 1000 gigawatt hours (GWh) are required to report hourly data.

Public Utilities Code Section 398.6(l) allows the Energy Commission to modify or adjust the hourly reporting requirements for entities with 60,000 customers or fewer or with less than 1000 GWh of load. The Energy Commission has allowed these retail suppliers to report estimated data using hourly resource production profiles.

Public Utilities Code 398.6(j)(1-2) fully exempts publicly owned utilities and rural electric cooperatives with annual loads of less than 700 GWh (averaged over three years) from reporting hourly data.

No. Annual data will continue to be used for the information on the PCL. SB 1158 established an additional, separate hourly reporting requirement for some entities.

No, hourly data will not be separated into distinct portfolios. Instead, retail suppliers will report their total procurements and load across all end-uses at the hourly level.

Loss-adjusted load is the total amount of electricity that a retail supplier required in order to provide retail electric service, including its transmission and distribution losses. Under the PSD program, the total amount of electricity to provide for retail sales includes retail supplier self-consumption and other electricity end uses serving retail consumers.

Retail suppliers will be able to stack resources in the order of their preference using the template provided by the Energy Commission.

If a retail supplier did not procure enough specified resources to meet its hourly loss-adjusted load, the remaining generation required to cover its loss-adjusted load will be reported as unspecified power.

The Energy Commission will calculate the GHG intensity of hourly unspecified power based on the MWh and emissions from three data points:

• In-state gas generation that was not claimed as a specified purchase by retail suppliers.
• Unspecified imports.
• Oversupply, i.e. the excess generation from retail suppliers that procured more than their hourly loss-adjusted loads.

The sum of all GHG emissions divided by the sum of all MWh across these three categories will determine each hour’s unspecified power emissions factor.

Avoided GHG emissions measure a retail supplier’s oversupplied zero- or low-carbon electricity. These excess resources did not serve the procuring retail supplier’s hourly load, but that electricity did serve load somewhere on the California grid. A retail supplier is credited avoided GHG emissions to the extent that its hourly oversupply reduced the emissions associated with hourly unspecified power. However, SB 1158 stipulates that avoided emissions must be disclosed separately and cannot be included in a retail supplier’s overall GHG emissions total or emissions intensity.

Storage resources are not treated as individual specified resources under this methodology. Instead, storage is treated generically and in aggregate. Storage charging increases a retail supplier’s hourly load; this means a retail supplier must procure additional specified or unspecified resources (and claim the associated GHG emissions) to meet the added load from storage charging. Storage discharging, after accounting for round-trip storage losses, reduces the amount of resources need to meet hourly load.