III. Overview of Tracking of GHG Emissions in the Electricity Sector under a Load-based Regulatory System
This section provides a general description of the method that we recommend to ARB for verifying GHG emissions in the electricity sector if a load-based regulatory approach is adopted for the electricity sector. Subsequent sections address the needed reporting and verification provisions in more detail.
ARB plans to collect net generation, fuel consumption, and GHG emissions data from all generating facilities in California with a nameplate generation capacity of one or more megawatts (MW). The reporting and verification protocol we recommend for the electricity sector would complement ARB's source-based protocol. As the regulatory framework for the electric sector has yet to be determined, our current objective is simply to ensure that the initial reporting protocol yields data that will support alternative approaches. We take no position at this time on whether a load-based, first-seller, or some other approach should ultimately provide the framework for the electricity sector regulatory approach under AB 32.
A load-based tracking approach would assign responsibility to each electricity retail provider for the GHG emissions associated with the electricity generated to serve its load. Consistent with this approach, the retail providers would report information regarding their procurement of electricity from various types of sources, including the following:
o Owned generation, which includes partial ownership (in-state or out-of-state),
o Contracts for power purchases tied to specific power plants,
o Contracts for power purchases tied to specific fleets of power plants,
o Contracts for power purchases that do not specify the generation source(s), and
o Purchases from the real-time market and the planned Integrated Forward Market of the California Independent System Operator (CAISO).
ARB would then attribute GHG emissions to the power procured by the retail provider, based on emissions information from a variety of sources:
o For owned in-state generation and power contracts with specified in-state sources, emissions information would be available from ARB's source-based reporting regulations.
o ARB would obtain emissions information regarding other specified sources from reports that those plants may submit voluntarily, or from power plant data submitted to federal agencies.
o For procurements from unspecified sources, ARB would develop default emission factors and/or supplier-based emission factors, as detailed in Section V.C of this order.
o ARB may need to make certain adjustments to ensure that attributed emissions are accurate and that reported emission reductions are real, as discussed in Section V.A of this order.
To allow assessment of emissions due to electricity generated in California and exported from the state, retail providers would be required to report information regarding their wholesale power sales, including exports. Marketers would similarly be required to report information regarding their exports from California.
Multi-jurisdictional utilities would be required to report information for their operations that provide electricity to service territories that include end use customers in California. ARB would attribute GHG emissions to their California operations based on the proportional share of their electricity sales in California.
Lastly, marketers would be required to submit information regarding imports of electricity into California, which would be needed if a deliverer/first-seller approach is adopted.
