US EPA
MCE's stunning volumes of brown power and a class action (part I)
A review of MCE's brown power volumes from 2011 through 2016 (last year available) reveals an altogether stunning and troubling picture that calls into question everything about the clean energy agency.
If leadership is aware of what is happening, how can it idly stand by? More to the point -- how can MCE, which advertises it's so clean be delivering so much dirty power?
Click to enlarge image
This chart is not an opinion -- this is what is in MCE’s and PG&E's complete regulatory filings.
This is the first in a series that will enable you to verify brown power volumes and GHG claims independently of advertising, salespeople, or even this writer’s observations. This is necessary for addressing what MCE's P.R. department releases for public consumption (20 of MCE's total staff of 58 works in public affairs / public relations).
Starting Point -- you have to know this
One term in the renewable energy industry with which familiarity is required is “REC,” or renewable energy certificate. RECs are the basis of tracking clean energy and are at the heart of clean energy accounting.
RECs are little more than a receipt, akin to a sales slip you receive from a grocery store for a loaf of bread or carton of milk. Unlike a grocery store receipt, a REC is an electronic file that shows (i) name & location of renewable energy resource , (ii) renewable energy type (solar, wind, etc), (iii) date of generation, and (iv) amount of energy created in megawatt-hours (MWhs). (An average residence in MCE’s service area consumes about 6 MWhs per year).
When a REC is used -- technically “retired” -- it is cataloged by WREGIS, Western Renewable Energy Generation Information System. WREGIS issues, tracks, and transfers RECs. Creation of a REC ties to production reported from the renewable resource (wind farm, etc).
RECs are required by MCE and PG&E to authenticate to regulators the delivery of renewable energy in their respective portfolios to ratepayers.
The three sources of MCE’s brown power... and a class action lawsuit
1-- Gas-fired generation. Emissions from combined-cycle gas fired generation range from 850 to 900 pounds of greenhouse gas (GHG) per MWh, depending on the power plant. Gas-fired generation only appears in annual regulatory filings if MCE purchases energy from a named gas-fired resource (example Delta Energy Center).
2—“Unspecified power.” This is bulk brown power, also known as “system power.” This energy occupies California’s electric grid -- those large wires and transmission towers that crisscross California. “Unspecified power” is created mostly from gas-fired generation and includes coal-fired energy and nuclear energy. The emission rate for unspecified power, as established by California Air Resources Board, is 943.58 pounds of GHG per MWh.
3—MCE’s clean energy. Within California's eligible renewable energy statute, known as the Renewable Portfolio Standard or RPS, California also has different classes of renewable energy, as diagrammed below:
- PCC 1 (Portfolio Content Category 1, aka Cat 1 or Bucket 1). Many consumers are under the mistaken impression that all of their delivered renewable energy is PCC1.
- PCC 2 (Portfolio Content Category 2, aka firm-and-shape energy, Cat 2 or Bucket 2).
- PCC 3 (Portfolio Content Category 3, aka “RECs,” unbundled RECs, Cat 3 or Bucket 3).
There is another group known as PCC 0. This is a separate grouping of contracts or ownership agreements that are governed by special rules for contracts executed before June 2010. These contracts are grandfathered in to California's renewable energy statutes. MCE treats all of its (non-transparent) PCC 0 contracts, provided by Shell Oil, as zero-GHG emissions.
After reviewing the above diagrams, you might conclude that MCE appears to deliver “Unspecified power” (dirty power) in place of much of its advertised clean energy.
Your conclusion would be correct. Much of MCE’s clean energy has an emission rate of 943.58 pounds of GHG per MWh, not zero.
MCE exceeded California limits on using PCC2-type instruments by 600% -- most of them were surreptitiously retired as "voluntary" energy that MCE advertised as "voluntarily exceeding California's clean energy requirements" -- in one of its most misleading years on record (203,029 of the instruments used; 28,500 allowed).
MCE's continuing abuses triggered a class action lawsuit. The suit was ultimately dropped because the law firm presenting the class action also wanted a Deep Green claimant and was unable to locate a party willing to stand in the public arena.
In summary, MCE’s delivered total brown power = MCE’s gas-fired energy + MCE’s disclosed “unspecified power” + MCE’s undisclosed “unspecified power” that MCE advertises as clean energy.
Stealth Brown Power at PG&E?
PG&E’s regulatory filings show zero PCC2 energy volumes. The filings identify one PCC3 energy volume -- that volume was reported to regulators along with an equal volume of “unspecified power.” Unlike MCE's practice, PG&E discloses and reports this corresponding delivery of brown power.
Why are these PCC1, PCC2, and PCC3 classifications even needed?
California regulators acknowledged no one could comply with the state’s governing clean energy law – the RPS. There simply was not enough clean energy in California to satisfy the law. The availability problem was compounded by an over-stressed electric transmission system from the Pacific Northwest that did not have the capacity to deliver wind energy and hydroelectric power to satisfy California's demand.
Thus, low cost PCC2 and cheap PCC3 instruments were created as a workaround – basically a hall pass -- until enough PCC1 energy was constructed to meet California’s entire RPS obligation. Regulators allowed entities such as MCE to add PCC2 and PCC3 to their reported renewable energy volumes and thereby satisfy their annual RPS mandate.
However, the state’s hall passes did not grant MCE (and other CCAs) the right to advertise those PCC2 and PCC3 volumes as zero-GHG, delivered renewable energy.
In essence, MCE took its hall pass and advertised it got an “A” on its final exam.
While MCE was advertising an impressively clean energy portfolio (few pounds of CO2 per megawatt-hour), it was also accruing a substantial cash windfall through its relabeling scheme. According to MCE’s 2018 & 2017 Financial Statements, the not-for-profit agency now holds $34 million in cash and cash equivalents.
While emitting millions of pounds of stealth GHGs, MCE saves a typical household $2.95 per month compared to PG&E. That's enough to purchase a package of ho-hos.
Part II of this series will cover:
MCE's move to bury its brown power disclosures and its invention of "voluntary" energy to circumvent California statutes;
Where to find regulatory filings and brown power;
Organizing a GHG worksheet (Excel);
MCE's attempt to quash California's new truth-in-advertising energy law.
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