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In This Issue
Double-Counting in the Northeast | Renewable Energy Markets 2014 | Just Published | Green-e Staff on the Road | Upcoming Webinar | Green-e Events Spotlight: Greenbuild | The Growing EV Opportunity | Green-e News | Staff News

A serious case of double-counting in the Northeast

A recent petition filed by environmentalists from Vermont Law School claims that the state's largest utility, Green Mountain Power, is double counting renewable energy generated in state by applying it toward statewide renewable energy targets while selling it outside the state and telling customers that they are using renewable energy. At issue is the fundamental understanding of how renewable energy certificates (RECs) convey ownership of the underlying generation.

A Green Mountain Power spokesman claimed that "the electrons and the power stays in Vermont. The environmental attributes go elsewhere, and they're claimed by the organizations we sell them to." This, coupled with Green Mountain Power statements about delivering renewable energy to customers, is a direct violation not only of how RECs are tracked, traded, and accounted for in the U.S., but the recent "Guides for the Use of Environmental Marketing Claims" ("Green Guides") released by the U.S. Federal Trade Commission (FTC).

The petition, filed in early September by the Environmental and Natural Resources Law Clinic at Vermont Law School, asks the FTC to investigate what they consider deceptive trade practices in the marketing of renewable energy to Vermont ratepayers. Specifically, the petition alleges a violation of Section 5(a) of the Federal Trade Commission Act, cites marketing contrary to the Green Guides, and alleges deceptive trade practices by Green Mountain Power.

Green-e Energy does not certify RECs that have already been used to meet a state's delivery-based renewable energy goals, and if a state mandate allows RECs to be sold from generation while still counting the null electricity toward the RPS, those RECs are not eligible for use in a Green-e Energy certified sale. Vermont's Sustainably Priced Energy Enterprise Development (SPEED) feed-in tariff program is presented as a voluntary target, but becomes mandatory if it is not met, and so Green-e disallows use of Vermont RECs where the associated electricity is being used toward the SPEED program.

Vermont's SPEED program is a clear example of double counting, with the state counting energy used in-state towards its renewable energy goals and utilities telling ratepayers they are getting renewable energy, while the RECs are stripped off and sold elsewhere.

In January, the State of Connecticut banned the use of Vermont's double-counted RECs toward its renewable portfolio standard, and in May, NextEra Energy announced that it will no longer trade Vermont RECs.

—Lead Staff: Robin Quarrier



Renewable Energy Markets 2014

REM 2014

Renewable Energy Markets 2014 is just around the corner, taking place in Sacramento, CA from December 2–4. Register now for this year's conference, which will be the biggest and best conference we've ever held, with hundreds of participants from across the country and around the globe sharing best practices for buying, generating, selling, trading, and marketing clean energy.

The discounted hotel rate is ending soon—on Friday, November 7. This will be the last opportunity to save $70 (nearly 30%!) off the average daily rate. To book your room, see the Location page for details.

Special thanks to our Presenting Sponsor, NextEra Energy Resources, and our City Sponsor, Sacramento Municipal Utility District (SMUD). If you are interested in sponsorship opportunities, please download our Sponsorship Guide.

For more information and to sign up for email updates about REM, visit



Just Published

Protecting Carbon Markets From Boiler Room Activities: Overview and Recommendations for Market Participants

In 2010, reports of boiler rooms operating in carbon markets and selling emissions reduction credits (carbon offsets) as investments began to emerge out of the U.K. In 2013, CRS began work examining what investor protections are needed in carbon markets, particularly in voluntary OTC markets, and what practices market participants could adopt to regulate carbon investments and enhance protection against deceptive sales tactics. This report, by Todd Jones, Green-e Climate Manager, summarizes our recommendations, which are aimed at increasing consumer and investor protection, with broader climate policy and market-stability benefits. Read the Report »


Green-e Staff on the Road

Green-e staff has been on the road a lot recently, speaking at conferences and meeting with stakeholders around the country.

Green-e Climate Manager Todd Jones recently returned from Washington, D.C., where he attended the State-Federal RPS Collaborative's National Summit on RPS, New York and Climate Week NYC, where he attended the International Emissions Trading Association's Carbon Forum North America, and beautiful Napa Valley, where he presented at the Argus California Carbon and LCFS Summit.

In DC, state regulators were abuzz discussing the changing landscape of state RPS programs and their new potential role in compliance with the EPA's proposed Clean Power Plan. The most anticipated session of the day was on precisely this topic and led by CRS Executive Director Jennifer Martin. Jennifer moderated a fascinating discussion of renewable energy under the Plan and how RPS policies in particular can be integrated into state plans. The EPA was on hand to answer questions while analysts and academics and probed the details of Plan, presented potential outcomes of various interstate trading scenarios, and explored different alternatives for states.

In NYC, amid the excitement of the People's Climate March and the UN Climate Summit, a different group of stakeholders working in carbon markets around the world met at the IETA Carbon Forum North America. Though the agenda also included discussions about this year's Conference of Parties in Lima and the road to the decisive COP in Paris in 2015, new emissions trading schemes and linkages in North America, and new methane initiatives, all eyes were once again focused on EPA's Clean Power Plan, with roundtables of analysts, state representatives, and industry representatives offering perspectives and cost scenarios. Here there seemed to be strong support for regional cooperation and mass-based targets and trading.

At the end of September, Todd Jones spoke at the Argus California Carbon and LCFS Summit in Napa Valley, where the focus was on California's programs and environmental markets in the west. There was a great deal of discussion in anticipation of the expansion of California's cap in 2015 to encompass transportation and heating fuels, and potential impacts on power and fuel markets. California carbon offsets were also a hot topic with the Air Resources Board's recent invalidation of 4.4 million offset credits earlier this year. And finally, the EPA's Clean Power Plan was again unavoidable, as CARB and California market players examined how the proposed rules interact with California's programs. Todd spoke on a panel about REC markets in the West, where he presented Green-e activity in the west, previewing 2013 voluntary market data, and on how carbon regulation has affected voluntary activity, the importance of voluntary renewable energy set-asides in cap-and-trade programs, and finally how the EPA's Clean Power Plan will likely impact the voluntary market and what EPA can do to protect it.

At the beginning of October, CRS Senior Project Manager Rachael Terada spoke on "Implementing Clean Technology and Green Purchasing" at California Minority Enterprise Development Week (MEDWeek) – Clean Tech, Advanced Manufacturing and Life Sciences Summit, in San Jose, CA. She then traveled to Chicago to address the M-RETS Subscriber Group meeting about the Clean Air Act Section 111(d). On October 20th, she presented a poster on "REC Best Practices and Claims" at Solar Power International (SPI) in Las Vegas.



Upcoming Webinar

Highlights of the 2013 Green-e Verification Report (Free)
Thursday, November 13, 2014 at 11:00 am PT. A sneak peak at how the Green-e certification programs performed in 2013, including trends in voluntary renewable energy and carbon offset markets, and how top companies communicated their commitments to clean energy by using the Green-e logo. Join us for an early look at the report, which is scheduled to be released on December 2, 2014 at Renewable Energy Markets 2014. Register Now »

Missed Any?
If you missed any webinars, we record many of them and make them available for free. Check out our Videos page on Vimeo to see any webinars you might have missed (or watch them again!).


Green-e Events Spotlight: Greenbuild 2014

Greenbuild is the nation's largest conference and expo dedicated to green building design and construction, and this year it went all-in on sustainability by reducing its environmental footprint through Green-e's event certification program. Working with carbon offset and REC provider Terrapass, the U.S. Green Building Council sourced carbon offsets and RECs to cover all emissions from the conference's energy sources, transportation, hotel, and travel. It was the biggest Green-e certified event ever. "Green-e was pleased to partner with the Greenbuild and TerraPass on reducing the impact of Greenbuild, the largest event to receive our certification,” said CRS Executive Director Jennifer Martin. “Their leadership in offsetting the total greenhouse gas and electricity impact is an example we believe is the future for sustainable events." You can read the release here.

Learn more about Green-e certified events at

The Growing EV Opportunity

It's no secret: electric vehicles (EVs) are the cleanest way to drive, and one of the most promising ways to reduce greenhouse gas emissions from the transportation sector (other than driving less and taking public transportation, of course). The only drawback is that EVs often rely on grid power to charge, and depending on where you live, this can mean some percentage of brown power. Enter a significant opportunity for clean energy. We put together some recent data about the incredible adoption rate of EVs (Over 9,000 are sold a month in the U.S.!) and the amazing opportunity for the renewable energy industry to green up grid-powered EVs. Check out our Electric Vehicles Are Driving Renewable Energy Adoption infographic. For more information on our ongoing campaign to link clean energy with EVs, contact Brendan Cook, Green-e Marketplace senior analyst, at or 415-568-4280.

Green-e News


Green-e Climate

Green‐e Climate has introduced new certification options for utilities offering gas offset programs to their customers. In response to increasing customer demand, many gas utilities have begun offering options that bundle natural gas with high-quality carbon offsets in order to neutralize the greenhouse gas emissions associated with that energy use. Green-e certification of gas offset products is important for consumer protection and as a way to demonstrate overall product quality. Read Green-e Certification for Gas Offset Products for more.

Verification of Green-e certified offset sales for reporting year 2013 indicate a dip in overall certified sales from 2012 but substantial growth in sales sourcing from current Endorsed Programs from 2011 and previous years.


Green-e Energy

Open for Comment: Long-Term Energy Purchasing. Green-e Energy is now taking comments on draft language that would allow customers to buy certified renewables from specific generators for more than 15 years. We are also asking for feedback on language that could allow certain tidal and wave power generators. This is second comment period on these topics, and all comments are due by November 20th. See "Comment Period Open through November 20, 2014" on the Green-e Energy National Standard and Governing Documents page to learn more. Thank you to the 100+ commenters who offered their thoughts during the first stakeholder comment period over the summer!


Green-e Marketplace

Aromafloria creates finely crafted, artisanal quality body care and aromatherapy products with a sustainable message. Aromafloria's manufacturing facility is powered with 100% Green-e certified wind energy.

To find out more about Aromafloria's commitment to renewable energy and personal care products, visit Learn more about Green‑e Marketplace.



Staff News

Recent Additions

Togzhan IbrayevaTogzhan Ibrayeva
Legal Volunteer

Togzhan joined CRS in October 2014 as a Legal Volunteer. She is assisting the Chief Counsel with legal research and revision of contracts. She graduated from UC Berkeley, School of Law, in 2014 with a LL.M degree, where she focused her studies on renewable energy and intellectual property law. She has practiced law in law firms in Kazakhstan, and advised energy companies on all matters related to extraction of natural resources. Togzhan is interested in environmental sustainability issues and wants to continue working in renewable energy-related fields.

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