Green-e Energy National Standard and Governing Documents
Green-e Energy certified renewable energy products must meet and abide by all criteria and rules put forth in the following Governing Documents:
Green-e Energy National Standard
Download the Green-e Energy National Standard
The Green-e Energy National Standard defines eligibility criteria for all Green-e Energy Certified renewable energy products: Renewable Energy Certificates, Utility Green Pricing Programs, and Competitive Market Electricity Products, in order to help promote high quality renewable electricity development and generation, and the environmental benefits of such generation in place of traditional fuels used for electricity.
The National Standard is currently in Version 2.4. This version provides clarifications to rules around double counting with RPS and other compliance markets in Section III.D, including: reference to capacity-based RPSs; properly calculating RPS compliance levels based on customer types covered by an RPS; and guidance on certified renewable electricity programs that meet 100% of a customer's electrical load. These clarifications are not considered to be a change and so Version 2.4 goes into effect immediately. A redlined version of the National Standard, highlighting changes made between Versions 2.3 and 2.4, can be downloaded here.
Hardcopies of all Green-e standards and translated copies of those standards are available upon request.
Comment Period Open through November 20, 2014
The National Standard is open for comment on two items, through midnight Thursday November 20, 2014
Pacific time. The items open for comment are:
- Allowing customers to buy a certified generator-specific renewable energy product under contracts that last more than 15 years
- Eligibility of electricity generation from certain types of ocean energy technologies
Prior to taking the survey, you may download and review a PDF of all survey questions
You may fill out the feedback survey at: www.surveymonkey.com/s/KBDB8GD
This is the second and final comment period for the two items above, which will be open for 30 days. These items were first raised in June 2014 for an initial 60-day comment period. Individual responses will only be used internally by staff and the Green-e Governance Board.
Updates to the Green-e Energy National Standard
The Green-e Energy National Standard is considered a dynamic document and may change
over time to accommodate changes in the renewable energy marketplace, policy
changes that affect renewable energy, and/or innovations in renewable energy
technology. For any substantial changes to the Green-e certification
criteria document, Green-e Energy commits that:
- Stakeholders will be solicited in advance of Green-e Governance Board meetings
for input on substantive policy change issues; and
- At least one year of notice (following the date of announcement of Board
approval) will be granted to utilities, green power marketers and other stakeholders
before the substantive changes go into effect, unless a more timely change
is necessary to respond to a significant and imminent problem threatening
the integrity of green power markets.
For more information on standard setting and revisions, please see the Standard Setting Procedures
Facilities Made Ineligible by Version 2.3
For certain facilities eligible under Version 2.2 of the National Standard but made otherwise ineligible by the change to Version 2.3 of the National Standard, the following form may be used to apply for extended use of the facility under Version 2.3: Extended Use Worksheet
Additional Guidance on Specific Sections of the National Standard
Green-e Energy provides clarifications, worksheets or additional information related to certain elements of the National Standard, broken down by section below.
Co-firing of Biomass with Non-Renewables (Section II.B.3)
A worksheet is available for facilities applying as eligible sources of supply that are cofiring biomass with non-renewable fuels (Section II.B.3): Green-e Energy Co-firing Methodology Worksheets
Repowering Generation Facilities, Including Hydropower (Section II.E.2)
A worksheet is available for facilities applying as eligible sources of supply that have been repowered: Green-e Energy Repowering Worksheet
For detailed information on treatment of hydropower facilities over 10MW in capacity that were approved as repowered under Version 2.2 of the National Standard that are no longer eligible under Version 2.3, Green-e staff is providing a Clarification on Treatment of Repowered Hydropower Facilities
Double Claims and Generator Claims (Section III.E)
Regarding double claims in materials published by a generator or other supplier providing renewable MWh to sellers of Green-e Energy Certified products, counting electricity from which RECs have been sold as ‘zero emissions’ when reporting electricity sales constitutes a double claim on those RECs. For example, if a utility sells RECs to another party and also counts the resulting null power as renewable when reporting electricity sales, this is a double claim resulting in RECs that are ineligible for use in a Green-e Energy Certified product. Likewise, there is a double claim if null power is disclosed as zero emissions for the purpose of informing electricity end users of the overall emissions from delivered electricity. This includes annual reports that display emissions from electricity supplied to end users. It is necessary to assign null power the emissions characteristics of system power for the purposes of reporting emissions linked to electricity sales.
Accurate statements by generators or generation owners about renewables in their generation portfolio are acceptable, but to ensure against double claims, statements about generation should be closely accompanied by the resource mix of actual sales. Such disclosure should account for RECs not being included with any null power delivered, and RECs and their zero-emissions attributes should be factored out of resource and emissions calculations. Such disclosure helps avoid misleading customers about the content of the electricity they are actually receiving.
Such an interpretation of the requirements of the Green-e Energy National Standard and Code of Conduct are directly in line with the FTC Green Guides
, which state on page 223, “If a marketer generates renewable electricity but sells renewable energy certificates for all of that electricity, it would be deceptive for the marketer to represent, directly or by implication, that it uses renewable energy.”
We strongly encourage marketers to investigate the statements being made by generators about the electricity they are selling before contracting for the sale of RECs. While these generators have to attest that they have not made claims on the RECs, a determination by Green-e Energy staff that the RECs are being claimed due to statements made by generators and / or null power buyers, users or sellers will render such RECs ineligible. To avoid this, it is in your best interest to proactively research counterparties’ statements that may affect eligibility and educating your suppliers about the impact of marketing statements that create unintentional claim on the RECs.
We encourage everyone to read the following documents on green marketing claims and the evaluation of statements for double claims, put together by Center for Resource Solutions, all of which are available on our REC Claims and Ownership
- Best Practices in Public Claims for Green Power Purchases and Sales (with particular attention to Claim Example 5-A: Utility claim on page 9);
- Best Practices in Public Claims for Solar Photovoltaic Systems; and
- Explanation of Green-e Energy Double Claims Policy
Wheeling Renewable Electricity from PJM into New York (Section IV.A.c)
To comply with Section IV.A.c of the National Standard, electric service providers supplying retail renewable electricitiy to New York state customers are able to coordinate with the New York Department of Environemntal Service by following the guidance provided in this document: Guidance on Wheeling Renewable Electricity into the State of New York from PJM-GATS
Federal Policy and the Green-e Energy National Standard
The Green-e Energy National Standard is a dynamic document, which strives to set rigorous environmental and consumer protection standards for the voluntary renewable energy market to ensure high quality products and processes. The Green-e Energy National Standard responds to changes in the marketplace for renewables, as is evident from Appendix A on State-Specific Requirements and Restrictions. In the event of policies on a national cap-and-trade program or a national renewable energy standard (RES), the Green-e Energy National Standard would necessarily be updated to reflect resulting changes in the renewable energy market.
In certain proposed national legislation, renewable electricity generation could be granted not only a REC, but potentially also a carbon allowance and/or a "Federal REC" (which would be issued exclusively by the federal government and used for compliance with a national RES). While Green-e Energy cannot state precisely how the National Standard would have to change to adapt to these new federal laws, it is worth noting previous treatment of similar state or regional laws by the National Standard.
The Green-e Energy National Standard requires that a REC / renewable MWh is "fully aggregated to the extent possible under law" and contains all environmental attributes that are linked to its generation. In the case of multiple kinds of RECs or attributes being created with each MWh of renewable electricity generation, all types of RECs and attributes associated with generation of a particular MWh must be retired for a voluntary retail purchase in order for the purchaser to have full and exclusive claim to that renewable MWh. For example, a 2008 law passed in Texas issued certain non-wind renewable MWh both a REC and a Compliance Premium, either of which could be used for RPS compliance; in response, Green-e Energy policy adapted by requiring an otherwise Green-e eligible Texas non-wind REC to be bundled with an associated Compliance Premium to remain eligible for Green-e Energy certification. This is analogous to what could be required if each renewable MWh generates both a REC as is currently known as well as a Federal REC.
In the case of a cap-and-trade program, Green-e Energy already has rules about treatment of renewable MWh generated and sold under the Regional Greenhouse Gas Initiative (RGGI). These rules require that RGGI RECs sold in RGGI states (except Delaware) cause a commensurate amount of CO2 emissions allowances to be retired along with the REC in a voluntary sale, so that the purchaser has the full claim to all available environmental benefits of the renewable electricity generation. This is similar to what could be required under a national cap-and-trade program.
If and when laws affecting the voluntary renewable energy market are passed, Green-e Energy will identify what, if any, types of changes are necessary to maintain the integrity and entirety of voluntary market claims on renewable MWh and will act in accordance with Section VI of the National Standard.
Code of Conduct and Customer Disclosure Requirements
the Code of Conduct and Customer Disclosure Requirements
Green-e Energy Code of Conduct and Customer Disclosure Requirements is one of the main governing documents of
Green-e Energy. It ensures that participating
marketers abide by the consumer protection and environmental standards
established by the Center
for Resource Solutions. Signatories
of the Code of Conduct and Customer Disclosure Requirements pledge to abide by the standard and cooperate
with the Green-e Governance Board, to ensure that these standards
are effective in providing customers information about environmentally
superior services in the renewable energy market.
The Code of Conduct and Customer Disclosure Requirements outlines the responsibilities
of a company offering a Green-e Energy certified product to disclose product
information to all customers prior to their purchase and in the case
that their purchase changes during the term of their purchase agreement. This
document also provides language
for describing Green-e Energy, language for describing a company?s
relationship with the Center for Resource Solutions and Green-e Energy, and logo use (see below). Additionally,
the Code of Conduct and Customer Disclosure Requirements outlines the process for CRS review
of marketing materials including the twice-annual marketing compliance
The Code of Conduct and Customer Disclosure Requirements underwent a minor update to Section VI.D.5 on November 6, 2013, summarized in this document: Green-e Energy Code of Conduct November 6, 2013 Revision Summary.
Green-e Logo Use Guidelines
Logo Use Guidelines
is specifically referenced within the Code of Conduct and
Customer Disclosure Requirements and provides detailed information on the appropriate
uses of the Green-e logo for all Green-e programs.
Guidelines for Use of Green-e Marks by Renewable Energy Purchasers
The Guidelines for Use of Green-e Marks by Renewable Energy Purchasers
offers clarity on the issue of under what circumstances a purchaser of Green-e Energy Certified renewables is able to use the trademarked
Green-e logo and the term "Green-e". For additional information on logo use by purchasers, see the Green-e Marketplace
section of this Web site as well.