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City of Pleasanton GHG Inventory, Forecast, and Targets Methodology and Calculations 10 The following discussion outlines the changes made to the EBEW inventories for consistency with the ICLEI Community Protocol29 and inventory years. Direct Access Electricity Direct access electricity30 was not reported by PG&E for the 2005 and 2010 reporting year due to California privacy rules, specifically what is known as the 15-15 rule31. It was determined by examining the available PG&E data for Pleasanton (obtained via PG&E’s Green Communities portal) that direct access electricity users triggered the 15-15 rule for years before 2011. This prevented PG&E from reporting 2005 and 2010 direct access electricity activity data as a part of the data request for Pleasanton’s energy data, which was listed as ‘ZZZZZ’. This direct access electricity data was reported in all years between 2011 and 2017. To allow for accurate comparison of energy sector emissions between inventory years, direct access electricity usage and emissions were estimated for 2005 and 2010. This was done by using the average rate of direct access electricity usage for Alameda County in 2005, which was 13.9 percent of nonresidential electricity.32 The rate of 13.9 percent is lower than that seen in 2017 and therefore, may underestimate the use of direct access electricity in the baseline year. Therefore, this is considered a conservative estimate which would require additional reductions to meet the 40% reduction from 1990 levels. Direct access electricity usage was estimated in this way for 2005 and 2010, so direct access electricity emissions are accounted for across all four inventory years. Natural Gas When examining the available PG&E natural gas data for Pleasanton (obtained via PG&E’s Green Communities portal) it was determined that large industrial natural gas users triggered the 15-15 rule in 2015. This prevented PG&E from reporting 2015 industrial natural gas activity data as a part of the data request for Pleasanton’s energy data, which was listed as ‘Fail-Dropped’. In other years, industrial natural gas emissions were included with commercial emissions. To allow for accurate comparison of energy sector emissions between inventory years, industrial natural gas usage and emissions were estimated for 2015. This was done by calculating the ratio of commercial natural gas usage to residential natural gas usage in other reporting years (where industrial was included with commercial), and then the average ratio was applied to 2015 to estimate industrial natural gas usage in that year. The years 2013, 2014, 2016, and 2017 were used to calculate the average commercial/residential natural gas usage ratio, as these were the closest reporting years to 2015, and there was a clear upward trend in combined commercial and industrial natural gas usage after 2013. After applying this average to 2015, the estimated activity data for combined commercial and industrial natural gas usage was used to calculate emissions from the nonresidential natural gas sector in 2015 so industrial natural gas emissions are accounted for across all four EBEW inventory years. 29 ICLEI. 2013. U.S. Community Protocol for Accounting and Reporting of Greenhouse Gas Emissions, Version 1.1 30 Direct access electricity is retail electric service where customers purchase electricity from a competitive provider called an Electric Service Provider (ESP), instead of from a regulated electric utility. An ESP is a non-utility entity that offers electric service to customers within the service territory of an electric utility. The utility delivers electricity that the customer purchases from the ESP to the customer over its distribution system. 31 The 15/15 rule states no data can be provided if there are less than 15 users in any sector or if one user makes up more than 15 percent of the total usage. This applies to natural gas and electricity consumption. 32 Average rate of direct access electricity in Alameda County, as cited in Appendix A of 2012 City of Pleasanton Climate Action Plan 1.0.