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The Tracking Attestation Form

Generation from facilities that have approved 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 each June.

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.

SUBMIT TRACKING ATTESTATION FORM

 

Green-e® Energy Tracking Attestation Form Frequently Asked Questions

What is the Green-e® Energy Tracking Attestation Form?

The Green-e® Energy Tracking Attestation is a form to be completed by generating facilities that are registered in an approved tracking system and intend to supply generation to be used in a Green-e® certified sale. All generating facilities that submit Tracking Attestations to CRS must be registered in and compliant with a tracking system, remain in compliance with that tracking system's rules, not have any other end-user claiming its renewable attributes, and have its output be used in Green-e® Energy certified products. Renewable generation facilities must also abide by double counting and double claiming restrictions in Section II.E of the Green-e® Renewable Energy Standard for Canada and the United States (the "Standard").

Approval of a Tracking Attestation 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 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 approved Tracking Attestations on file with CRS. However, renewable generating facilities do not need to submit Tracking Attestations prior to use toward a certified sale, as participants remain free to procure supply from any generating facility they choose, subject to subsequent audit and verification by CRS against the Standard.

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. The term “Green-e® Energy Eligible” has in the past been used to describe generation facilities that (a) were registered in a renewable energy tracking system, (b) had signed a Tracking Attestation submitted to CRS; and (c) reviewed by CRS against certain limited portions of the Standard. 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. 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, among other issues. 

Why Submit a Tracking Attestation?

Generators may wish to submit a Tracking Attestation to identify themselves as CRS Listed to Green-e® Energy participants, which may elect to purchase RECs or renewable electricity generated from these facilities for use toward Green-e® Energy Certified retail and wholesale product(s). However, 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 only 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. CRS cautions that retail sales of "eligible" renewable energy could be deceptive, misleading customers about quality assurance by presenting a product as equivalent or similar to Green-e® Energy Certified. 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.

What is the Tracking Attestation Approval Process?

Tracking Attestations are received and reviewed through a three-step process:

1. Submission of the Tracking Attestation Form. Currently, only generating facilities that are registered with a renewable energy tracking system in the United States or Canada may submit a Tracking Attestation Form. 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. Completion of this form is required for any such generating facility that either (a) wishes to be identified as producing renewable energy that may be used in a Green-e® Energy Certified product, or (b) whose renewable energy is claimed to be within the supply chain of a product that is subject to an annual sales and supply audit for Green-e® Energy certification. The Tracking Attestation is subject to certain terms and conditions that must be reviewed and acknowledged by the facility before the form may be submitted. The Tracking Attestation is available on the Green-e Energy Documents webpage. CRS reserves the right to reject the Attestation if not completed fully and accurately.

2. CRS Review of the Tracking Attestation. CRS evaluates the information provided in Tracking Attestations against the Standard to determine if the generation meets certain criteria for Green-e® Energy Certified supply. Due to the large number of Tracking Attestations submitted, the review process can take approximately 45 days. CRS encourages facilities to submit the Tracking Attestation as soon as possible.

3. Notification of Approval. CRS will notify generators of their Tracking Attestation approval status after it has completed review of the Tracking Attestation. If a generator is found to satisfy the criteria laid out in the Standard, it will be added to the confidential and proprietary list of facilities with approved Tracking Attestations on file that CRS makes available to Green-e® Energy participants.