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:

• The Green-e Energy National Standard, which covers renewable resource eligibility and product specifications
• The Code of Conduct and Customer Disclosure Requirements, which ensures that providers of certified renewable energy abide by consumer protection and environmental standards, and requires providers to disclose clear product information to all customers prior to their purchase and to use the Green-e logo correctly
• The Green-e Logo Use Guidelines, which provides information on appropriate display of the Green-e logo by seller of renewable energy
• Guidelines for Use of Green-e Marks by Renewable Energy Purchasers, which discusses how the trademarked Green-e logo and the term "Green-e" may and may not be used by purchasers of Green-e Energy Certified renewables.

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 2.3. This version contains substaintial revisions to eligibility of biomass resources used as electricity fuels, as well as new treatment of hydropwer repowering and efficiency upgrades. Non-substantive typographical and wording changes were also made in limited locations. A redlined version of the National Standard, highlighting changes made between Versions 2.2 and 2.3, can be downloaded here.

For companies that sign up to sell their first Green-e Energy certified product on or after April 23, 2013, Version 2.3 must be followed for all generation used for all certified sales. For companies participating in Green-e Energy prior to April 23, 2013, Version 2.3 is effective with generation occurring on July 1, 2014 and later; for thse companies, generation occurring between the April 23, 2013 release date and June 30, 2014 must be eligible under either Version 2.2. or Version 2.3 of the National Standard.

Hardcopies and Translations. Hardcopies of all Green-e standards and translated copies of those standards are available upon request.

Repowered and Cofiring Facilities. Worksheets are available for facilities applying as eligible sources of supply that have been repowered (Section II.E.2 of the Standard) or are cofiring biomass with non-renewable fuels (Section II.B.3). See the Green-e Energy Repowering Worksheet or the Green-e Energy Co-firing Methodology Worksheets.

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:

1. Stakeholders will be solicited in advance of Green-e Governance Board meetings for input on substantive policy change issues; and
2. 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.

Guidance on Generator Claims (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 documents on green marketing claims put together by Center for Resource Solutions: Best Practices in Public Claims for Green Power Purchases and Sales, with particular attention to Claim Example 5-A: Utility claim on page 9; and Best Practices in Public Claims for Solar Photovoltaic Systems.. Both are available on our website.

Guidance for Companies Participating in Cap and Trade Programs (III.E – footnote 7)

This footnote describes eligibility of renewable MWh generated by companies participating in cap-and-trade programs, including the Chicago Climate Exchange (CCX). Because the last phase of CCX participation and reporting ended at the close of 2010, Green-e Energy encourages its program participants to check that any generation they are planning to use toward RY2010 verification reporting complies with these rules, as facilities owned by companies participating in a cap-and-trade program are otherwise ineligible. Generation that was produced before 2011 by facilities owned by members of CCX will be affected by these rules. Green-e Energy participants are advised to check if the owners of facilities from which they are sourcing are listed as Members on the CCX website and to contact Green-e Energy staff if such companies are listed.

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

Download the Code of Conduct and Customer Disclosure Requirements The 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 review.

Green-e Logo Use Guidelines

The Green-e 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.