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Thirty-eight percent of EBCE's Bright Choice power mix originates from "Unspecified <br />Sources of Power". The California Energy Commission refers to unspecified sources of <br />power as "electricity that is not traceable to a specific generating facility, such as <br />electricity traded through open market transactions. Unspecified sources of power are <br />typically a mix of all resource types and may include renewables." Bright Choice <br />receives unspecified power from the Asset Controlling Supplier, BC Hydro System, <br />which procures large hydroelectric energy. Of Bright Choice's 705,638 Megawatt hours <br />(MWh) of unspecified sources of power, BC Hydro System generates 535,768 MWh <br />(29%), and the other 9% comes from other unspecified sources. This means Bright <br />Choice's carbon -free makeup is really significantly greater than 85%, as explained in <br />more detail later in this section. <br />Large hydropower has its pros and cons. One potential issue with such a bulk of <br />EBCE's energy portfolio relying on large hydropower is the possibility of drought. A <br />drought can affect electricity generation, which ultimately can cause a fluctuation in <br />supply and price. <br />Unbundled Renewable Energy Certificates (RECs) are a type of electricity source <br />energy providers can purchase. Unbundled RECs allow for CCAs or IOUs to purchase <br />the credit for renewable energy, without actually purchasing the renewable energy itself. <br />Unbundled RECs give utilities the credit, but they are not actually injecting renewable <br />energy onto the grid. This is one way to comply with the state's Renewable Portfolio <br />Standards, albeit a controversial way. Currently, California's RPS allows electricity <br />providers to use up to 10% unbundled RECs in their portfolio. EBCE's own rule in its <br />JPA document limits the CCA to no more than half of the unbundled RECs allowed in <br />California's RPS program. This means EBCE's energy portfolio can include a maximum <br />of 5% unbundled RECs. EBCE is currently below this threshold and less than 2% of <br />EBCE's load is from unbundled RECs. <br />California's RPS requires an electricity procurer's energy portfolio to contain at least <br />50% renewable energy by 2030, with an interim target of 33% renewable by 2020. The <br />basic packages from the following CCAs have different renewable energy mixes: MCE, <br />61 %; Silicon Valley Clean Energy, 54%; Peninsula Clean Energy, 50%; and <br />CleanPowerSF, 48%. EBCE's Bright Choice and Brilliant 100 programs are 38% and <br />40% renewable, respectively. While EBCE has already exceeded the 2020 interim <br />target of 33%, it lags behind the other Bay Area CCAs. However, they have the <br />potential to increase their renewable energy percentages with their new Power <br />Purchasing Agreements (PPAs). <br />Alternatively, PG&E's 2018 electric power generation mix is 86% carbon -free, with 39% <br />coming from renewable energy sources. PG&E's electric renewable energy mix comes <br />from a mix of mostly solar and wind, with smaller amounts of biomass/biowaste, <br />geothermal, and small hydroelectric energies. PG&E's 2018 standard electricity mix <br />would appear to derive slightly more energy from renewable sources than EBCE's <br />Bright Choice. In addition, PG&E has improved its renewable and carbon -free portfolio <br />by six percentage points from 2017 to 2018. Similar to EBCE and all the other CCAs in <br />Page 10 of 20 <br />