Description and Frequently Asked Questions
Generation from facilities that have approved CRS Listed™ Tracking Attestations on file with Center for Resource Solutions (CRS) may be used by Green-e® Energy participants to expedite the annual verification and certification process. This is because CRS has already confirmed for CRS Listed™ facilities that the information provided in Section IV of the Tracking Attestation is accurate and in accordance with selected elements of the Green-e® Renewable Energy Standard for Canada and the U.S., and there are no unresolved double-counting issues per the Green-e® Energy Double Claims Policy.
Tracking Attestation submission and approval does not mean that the facility, facility owner, facility's output, or sale of facility's output are, in fact, Green-e® Energy Certified.
It simply means that a Tracking Attestation form for the facility has been submitted to and approved by CRS, and the facility's output may be used by participants in the Green-e® Energy program to streamline Green-e® Energy verification and certification. For convenience to Green-e® Energy participants, CRS maintains a confidential and proprietary list of electricity generation facilities that have been recognized by CRS as meeting these criteria.
The term "Green-e® Energy eligible" has in the past been used to describe generation facilities that have had active Tracking Attestations on file with CRS. CRS has discontinued any allowance of such designations because such review was not a guarantee that a facility's output may be used in a Green-e® Energy certified sale and CRS seeks to avoid confusion with certified products. CRS does not endorse the use of the term "Green-e® Eligible" in any circumstance, including in wholesale and retail transactions. In cases where an alternative to "Green-e Eligible" is required (in supply contracts, for example), the terms "Approved Tracking Attestation on File with CRS" or "CRS Listed" may be used.
The approval of a Tracking Attestation does not confer any consumer protection benefits associated with Green-e® Energy certification and should never be treated as equivalent to Green-e® Energy certification by retailers or end-use customers. This is because generation from a facility with an approved Tracking Attestation on file has not been certified by CRS. In other words, CRS has not tracked chain of custody, confirmed retirement, or provided any other assurance that would come as a part of certification. Even if a generating facility has an approved Tracking Attestation on file with CRS, marketing its generation as "Green-e® eligible" or "Green-e® certifiable" without a license to use the Green-e® trademark is strictly prohibited.
CRS Listed Tracking Attestation Form Frequently Asked Questions
What Is a CRS Listed Tracking Attestation?
The CRS Listed Tracking Attestation is a form that must be completed and accepted by CRS for generating facilities to have their renewable energy claimed within the supply chain of a Green-e® Energy Certified product, or, or that wish to be identified as CRS Listed. If accepted, Tracking Attestations are in effect for a year and must be renewed annually in order to remain CRS Listed. Tracking Attestation forms may be filled out here.
Who Can Submit Tracking Attestations?
Tracking attestations may be submitted on behalf of generating facilities that are registered with a renewable energy tracking system in the United States or Canada. There are several regional tracking systems in operation in the U.S., and more under development, including: ERCOT, M-RETS, MIRECS, NAR, NEPOOL-GIS, NC-RETS, NYGATS, PJM-GATS and WREGIS.
Tracking attestations are submitted by the generator owner or someone who has the legal authority to act on behalf of the generator owner. In some cases, generators may be registered in tracking systems by persons other than the generator owner, in which case that account manager may be authorized to submit the attestation. In order for a tracking system account manager to submit a tracking attestation to CRS on behalf of a generator, they must submit to CRS the documentation approved by the relevant tracking system giving them legal authority to register the generator in a tracking system.
What is the Cost to be CRS Listed?
The cost to submit an attestation is a $150 annual flat fee, and free for generators with less than 1 Megawatt in capacity. The fee must be paid when the tracking attestation is submitted. CRS’s products and services may incur fee increases year over year. The Tracking Attestation applies to the current one-year term and license and does not guarantee the current rate for any renewals.
What Information Is Needed to Complete the Form?
The person completing the form will need: the facility’s NERC Region, EIA or QF number; the name of the tracking system the facility uses; the facility’s tracking system ID number; its nameplate capacity (MW); and the date the facility was first operational. CRS also requires a contact for the facility, who will then receive notice if the attestation has been accepted by CRS and notice to renew an accepted attestation prior to its annual expiration. Additional information may be required depending on the facility’s resource type, location, and repowering or co-firing status, or if questions arise during the tracking attestation review, described below.
How Are Tracking Attestations Approved?
Tracking Attestations are received and reviewed through a three-step process:
- Submission of the Tracking Attestation Form. The Tracking Attestation is subject to certain terms and conditions that must be reviewed and accepted by the facility in order to submit the form. It is also at this point that a fee will be charged for form submitted after July 1.
- CRS Review of the Tracking Attestation. CRS evaluates the information provided in the form and performs a review of any public statements concerning the use of renewable electricity or any of the environmental attributes within the Renewable Energy Certificate (REC), including avoided emissions, to a party who is not the REC owner. CRS will engage with the submitter of the Attestation to suitably resolve any potential double claim issues before approval. The review process can take up to two weeks from the date payment is received. CRS reserves the right to reject the Attestation if not completed fully and accurately.
- Notification of Approval. CRS will notify generators of their Tracking Attestation approval status after it has completed its review. Reasons CRS may reject a Tracking Attestation are listed below.
Is a Facility With an Approved Tracking Attestation Supplying Green-e® Certified Renewable Energy?
No. CRS’s acceptance of a Tracking Attestation does not mean that the facility, facility owner, facility's output, or sale of facility's output are Green‑e® Energy Certified. CRS’s Green-e® certification programs have additional requirements that CRS Listed facilities do not have to meet. Most notably, CRS has not tracked chain of custody, confirmed retirement, or provided any other assurance that would come as a part of certification. As a result, the approval of a Tracking Attestation does not confer any consumer protection benefits associated with Green-e® Energy certification and should never be treated as equivalent to Green-e® Energy certification by retailers or end-use customers. CRS also cautions that retail sales of supposedly "eligible" renewable energy could be deceptive or misleading. The only way to ensure that renewable energy purchase meets all applicable sustainability and consumer protection criteria in the Standard and Code of Conduct is for it to be Green-e® Energy Certified. However, Green-e® Energy certification program participants are encouraged to use output from facilities that already have Tracking Attestations on file with CRS to streamline aspects of Green-e® Energy verification and certification.
Are There Restrictions on Representing Generation as “Green-e® eligible”?
Yes. CRS expressly prohibits use of the phrase “Green-e® eligible” in any context, including wholesale transactions. CRS does not permit use of this description, in part because of its potential to mislead consumers, as no generation is guaranteed to be usable in a Green-e® Energy Certified product. Furthermore, the word “Green-e” is a registered certification mark of CRS and may only be used in reference to certified products; other uses may violate CRS’s intellectual or other property rights.
Can a Facility’s Attestation be rejected or can it lose Its CRS Listed status?
Yes, for a few reasons:
- The Tracking Attestation is not renewed when it expires
- Information provided on the Tracking Attestation is found to be inaccurate or false, or the information changes and CRS is not notified
- The facility is no longer actively registered in a tracking system, or is out of compliance with the tracking system’s rules
- The facility doesn’t pay the required fee;
- The facility is represented as being Green-e® Certified or otherwise wrongly connected to Green-e® certification
- The facility’s generation is subject to multiple (“double”) end-use claims that cannot be resolved
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