> ## Content Index > Fetch the complete content index at: https://www.etrminsider.com/llms.txt > Use this file to discover other available public pages before exploring further. # California PCC 101 for CCA ops teams: what actually gets checked - URL: https://www.etrminsider.com/california-pcc-101-for-cca-ops-teams/ - Published: 2026-10-14T10:02:55.000Z - Updated: 2026-10-14T14:02:57.000Z - Description: A plain-English walk-through of California's portfolio content categories, portfolio balance limits, long-term contracting rule, and how WREGIS data reaches the CPUC, with every number linked to a CPUC or CEC source. - Author: Emmanuel Gonzalez - Tags: RECs & Compliance **Independence:** ETRM Insider is vendor-independent. This article names no preferred products, and no vendor sponsored, paid for, or reviewed it. [Our standards →](https://www.etrminsider.com/standards/) If you run RPS compliance at a California CCA, most of your year is spent proving things you already know: that a REC came from where you said, under the contract you said, and counts in the category you claimed. This is the plain-English version I'd hand a new analyst. Every number links to a CPUC or CEC source. Rules change, so check those sources before you rely on any of this for a filing. ## Who does what California's RPS is run by two agencies. The [CPUC](https://www.cpuc.ca.gov/rps?ref=etrminsider.com) sets and enforces compliance rules for retail sellers, which include investor-owned utilities, electric service providers, and CCAs. The CEC certifies generating facilities as RPS-eligible, verifies procurement claims, and handles compliance for publicly owned utilities. The CPUC makes its compliance determination after the CEC verifies your claims. Compliance is counted in RECs, where [1 REC equals 1 MWh](https://www.cpuc.ca.gov/rps?ref=etrminsider.com), and it's assessed over multi-year compliance periods, not single years. Under SB 100, the CPUC's [60% RPS procurement rules](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/rps/rps-compliance-rules-and-process/60-percent-rps-procurement-rules?ref=etrminsider.com) set targets of 52% by December 31, 2027 and 60% by December 31, 2030, with requirements in between following a linear trend. Later three-year periods stay at a minimum of 60%. We're in Compliance Period 5, 2025 through 2027, according to the CPUC's [onboarding guide for new retail sellers](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com). Your procurement quantity requirement (PQR) for a period is the statutory percentage for each year multiplied by that year's retail sales, summed across the period. Take the year-by-year percentages from the onboarding guide rather than rebuilding them. ## The three portfolio content categories PCCs apply to procurement from contracts executed after June 1, 2010\. The [CPUC's definitions](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/rps/rps-compliance-rules-and-process/60-percent-rps-procurement-rules?ref=etrminsider.com), in short: - **PCC 1:** energy and RECs from a facility whose first point of interconnection is within a California balancing authority, or from a facility that schedules its electricity into a California balancing authority hourly or sub-hourly without substituting electricity from another source. Dynamic transfers also qualify. - **PCC 2:** energy and RECs from outside a California balancing authority, paired with incremental or substitute energy (often called "firmed and shaped"). The contract buys the energy and RECs at the same time, and substitute energy is arranged under a separate agreement. - **PCC 3:** unbundled RECs, and any eligible procurement that doesn't meet PCC 1 or PCC 2. There's also **PCC 0** for contracts executed before June 1, 2010 (January 13, 2011 for ESPs). The [onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) notes that an amendment that increases nameplate capacity or expected annual generation can cost a contract its PCC 0 status. Two things trip people up. First, **you don't decide the category.** The CPUC's [compliance FAQ](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/rps-compliance-faq%5F2020.pdf?ref=etrminsider.com) is explicit: you claim a category, and CPUC staff determine whether the procurement meets it. Second, the classification is made at the end of each compliance period, so a mistake made early in a period can sit unnoticed for years. ## Portfolio balance: the limits Starting with Compliance Period 3 (2017-2020), and for every period after it, the [onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) puts the portfolio balance requirement at: - **at least 75%** PCC 1, and - **no more than 10%** PCC 3, with PCC 2 making up the rest. Per the CPUC's [procurement rules page](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/rps/rps-compliance-rules-and-process/60-percent-rps-procurement-rules?ref=etrminsider.com), these balance requirements apply to most retail sellers and cover procurement from contracts executed after June 1, 2010. ## Long-term contracting: the 65% rule Beginning with the 2021-2024 period, each retail seller must show that **at least 65%** of the RECs it counts toward its PQR come from long-term contracts. The [onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) lists three ways a contract qualifies: - a contract of 10 years or more; - a contract initially 10 years or more that may be extended for any period; or - a contract with an initial term under 10 years that's amended to extend it by at least 10 continuous years. A contract's term, as written and as amended, has to live in your system as data, not in a PDF someone rereads every August. **Banking** works differently from earlier periods. For 2021-2024 and later, the [compliance FAQ](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/rps-compliance-faq%5F2020.pdf?ref=etrminsider.com) says all excess PCC 1 RECs can be banked whether they come from short- or long-term contracts, and no PCC 2 or PCC 3 RECs can be banked. ## How WREGIS data reaches the CPUC The chain looks like this: 1. **Retire in WREGIS.** Retail sellers must track RECs in WREGIS for them to count. The CEC's [WREGIS Reporting Guidance](https://www.energy.ca.gov/sites/default/files/2026-04/WREGIS%5FReporting%5FGuidance%5Fada.pdf?ref=etrminsider.com) says retail sellers retire into a reporting-year account named in the form "202X CA RPS RTSL." Retire RECs from facilities inside and outside a California balancing authority in separate transactions, and finish e-Tag matching *before* you retire, because e-Tags can't be unmatched afterward. 2. **Report to the CEC by July 1.** Authorize WREGIS to send your retirement report to the CEC and, as a retail seller, to the CPUC as well. Then submit the attestation in the CEC's RPS Online System. 3. **File with the CPUC by August 1.** The [annual RPS compliance report](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/rps/rps-compliance-rules-and-process/rps-compliance-and-reporting?ref=etrminsider.com) is due each August 1\. For RECs from facilities outside a California balancing authority, the [onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) says you also submit an hourly e-Tag summary report so staff can determine the right PCC. 4. **CEC verification, then the final report.** After a compliance period, the CEC verifies claims against WREGIS data. Final compliance reports are due to the CPUC 30 days after the CEC's verification report is issued. ## Common mistakes - **Claiming PCC 1 on imports without the scheduling evidence.** The [onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) warns that RECs not meeting PCC 1 or PCC 2 delivery requirements may end up as PCC 3\. That can quietly break your portfolio balance. - **Miscounting contract length.** Counting from first delivery instead of the contract term, or losing track of amendments. This affects the 65% test. - **Retiring before matching.** Once RECs are retired, the e-Tag match is locked in. - **Missing the retirement window.** The CEC's [RPS Eligibility Guidebook, Tenth Edition](https://efiling.energy.ca.gov/GetDocument.aspx?DocumentContentId=105048&tn=268036&ref=etrminsider.com) refers to a 36-month REC retirement rule, and it limits un-retiring to one year after the retirement date or before the final eligibility determination, whichever comes first. - **Treating the August report as the final word.** It's preliminary. The real test is period-end verification. The cost of getting it wrong is concrete. The [onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) lists the penalty as $50 per REC of shortfall against either the PQR or the portfolio balance requirement. ## A compliance calendar for the rest of Compliance Period 5 | Date | What | Source | | ------------------------------------- | ---------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | July 1, 2027 | CEC annual report and WREGIS retirement report for reporting year 2026 | [CEC CP5 Annual Reporting Instructions](https://www.energy.ca.gov/sites/default/files/2026-04/Compliance%5FPeriod%5F5%5FAnnual%5FReporting%5FInstructions%5Fada.pdf?ref=etrminsider.com) | | August 1 (each year) | CPUC Annual RPS Compliance Report | [CPUC RPS Compliance and Reporting](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/rps/rps-compliance-rules-and-process/rps-compliance-and-reporting?ref=etrminsider.com) | | December 31, 2027 | Compliance Period 5 ends (52% target) | [CPUC 60% RPS Procurement Rules](https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/rps/rps-compliance-rules-and-process/60-percent-rps-procurement-rules?ref=etrminsider.com) | | July 3, 2028 | CEC report for reporting year 2027 | [CEC CP5 Annual Reporting Instructions](https://www.energy.ca.gov/sites/default/files/2026-04/Compliance%5FPeriod%5F5%5FAnnual%5FReporting%5FInstructions%5Fada.pdf?ref=etrminsider.com) | | 30 days after CEC verification report | CPUC Final Compliance Report for the period | [CPUC onboarding guide](https://www.cpuc.ca.gov/-/media/cpuc-website/industries-and-topics/documents/energy/rps/2024/rps-onboarding-for-new-ca-retail-sellers-2024.pdf?ref=etrminsider.com) | Per the CEC, if a due date falls on a weekend or state holiday, it moves to the next business day. ## Use it this week Pull every contract you're counting toward the 65% test. For each one, write down the executed date, the original term, any amendments, and the PCC you're claiming. If any of those lives only in a PDF, that's your first fix. --- *Drafted with AI assistance from my research notes and outline; reviewed, edited, and fact-checked by me. The opinions are mine.*