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Tracking Attestations and Eligibility

 

What is Green-e® "Eligibility"?

"Eligibility" under the Green-e® Energy certification program refers to whether renewable energy or renewable energy certificates (RECs) generated from a specific facility meet certain criteria in the Green-e® Renewable Energy Standard for Canada and the United States (the "Standard") and therefore are "eligible" to satisfy the supply requirements for participants in the Green-e® Energy certification program. It also means that the facility has completed the process to be recognized as eligible by CRS. For example, a generating facility must submit a tracking attestation form to CRS, be registered 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 Standard to be recognized as Green-e® Energy eligible.

Eligibility under the Green-e® Energy program 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 been recognized by CRS as meeting these criteria. However, renewable generation does not need to be recognized as Green-e® Energy eligible 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 Any Restrictions on Representing Generation as Green-e® Energy Eligible?

Yes. A generator must be recognized as eligible by CRS through a three-step process described below. Furthermore, Green-e® is a registered trademark of CRS and only available to licensed users. In addition, the designation "Green-e® Energy eligible" is onlyauthorized for wholesale transactions, where the buyer is not the end-user of the renewable electricity or REC; in those cases, it is used to indicate that the counterparty will deliver supply that meets specific eligibility requirements in the Standard. Once again, this does not mean that the facility, facility owner, facility's output, or sale of facility's output is Green-e® Energy Certified. And, of course, only participants in the Green-e® Energy program are permitted to represent their products as "Green-e® Energy Certified." CRS also reserves the right to remove the Green‑e® Energy eligibility designation at any time at its sole discretion.

 

Why Be Recognized as "Eligible"?

Generators may wish to be recognized as "eligible" to identify themselves to Green-e® Energy participants, who may elect to purchase these RECs or renewable electricity for use toward Green-e® Energy Certified retail and wholesale product(s). However, outside of Green-e® Energy verification, Green-e® "eligible" renewable energy or RECs hold no additional Green-e®-related value. This is because Green-e® Energy "eligible" renewable energy has not been certified by CRS. For example, CRS has not tracked chain of custody, confirmed retirement, or provided any other assurance that would come as a part of certification. End-use customers therefore are not protected when they purchase Green-e® Energy eligible or "certifiable" renewable energy. 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.

 

How Does a Generator Become Recognized as "Eligible" under Green-e® Energy?

There are three steps to be recognized by CRS as generating "eligible" renewable energy or RECs under Green-e® Energy criteria:

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, NARR, 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 at Green-e Energy Documents. 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 currently takes approximately 45 days, though CRS tries to complete review sooner. CRS encourages any facility requiring designation as Green‑e® Energy eligible to submit the Tracking Attestation as soon as possible.

3. Notification of Eligibility

CRS will notify generators of its eligibility determination 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 eligible facilities that CRS makes available to Green-e® Energy participants.