Guidance for California’s Mandatory Greenhouse Gas Emissions Reporting
California Air Resources Board 12 April 11, 2024
and Tacoma can do both. Powerex and Tacoma can sell power from multiple sources,
including specified, unspecified, or ACS power.
Although Bonneville considers all of its sales as sourced from the BPA system, CARB
differentiates between Bonneville sales from two sources based on e-Tags: BPA ACS
power and path out power. Bonneville tags power from either BPA Power or BPA Slice
(both of which are ACS power), or from non-BPA power sources (that were originally
procured for use by the BPA system). Bonneville sales tagged from a non-BPA source,
but sold by Bonneville as BPA power are referred to as path outs, or path out power.
Thus, buyers of BPA power may end up receiving e-Tags sourced as BPA Power, BPA
Slice, or as path out power. Transactions tagged as BPA path out power, where BPA is
the seller, but the source is not the BPA ACS system, are not eligible to be claimed as
specified source power, and therefore may not use the ACS emission factor for BPA.
A specified source contract is also required to claim ACS power, including from BPA. In
contrast, path out power tags received as part of a BPA purchase must be claimed as
unspecified for calendar year 2013 and beyond. Entities that transact directly with BPA
must claim specified ACS power when tagged with the source as either “BPA Power” or
“BPA Slice.” For questions on how to report BPA ACS power, please contact CARB.
Powerex has withdrawn their 2020 ACS application and will no longer transact power as
an ACS effective January 2021.
1.4.6 What power purchases made by an ACS will be included in its system
emission factor calculation, and will thus be considered part of its ACS
system footprint?
The ACS system emission factor calculation includes components for purchased
electricity from specified and unspecified sources. Power purchases that sink to serve
load or to maintain reliability of the ACSs system are included in the system emission
factor calculation. Purchases intended to serve load or maintain system reliability that
were sold as path outs will not be included in the system emission factor calculation.
1.4.7 When buying BPA Slice power, what documentation should be made
available to a verifier to meet the seller warranty requirements?
For short-term and long-term transactions, EPEs must comply with the specified source
requirements in MRR. In general, the importer must establish evidence of seller
warranty for the transaction, meaning that the seller has specified source rights to the
BPA Slice power. For instance, for a transaction between an entity that has specified
source rights to BPA Slice power and an entity that imports the power to California,
evidence of seller warranty can be established through the following:
1. A confirmation between the BPA Slice holder and the importer. For long-term
transactions, the reporter could provide a written confirmation between the BPA