Green-e Energy National Standard Open Comment Period 1

Transcription

1 Green-e Energy National Standard Open Comment Period 1 Green-e Energy seeks feedback on current and potential future provisions of the Green-e Energy National Standard (the "Standard"). Feedback will be accepted until Saturday, April 30, CRS will conduct a second comment period, incorporating feedback from this first comment period. To comment, go to: To review the current Standard, go to: Posted on February 29, 2016 Center for Resource Solutions 1012 Torney Ave. 2 nd Floor San Francisco, CA

2 Green-e Energy Call for Comments: National Standard version 3.0 Green-e Energy seeks feedback on current and potential future provisions of the Green-e Energy National Standard (the "Standard"), specifically regarding: Product Specifications: Allowing Variability for RPS-affected Products and Among Huband-Spoke Utilities Geographic Eligibility for Electricity Products Eligible Generation Locations: Guam, the U.S. Virgin Islands, the Northern Mariana Islands, and associated territorial waters and airspace Eligible Sources of Supply: o Fuel Cells o Biofuels o Biogas o Organic Waste Hub-and-Spoke Utilities: Marketing Compliance Responsibilities Newer Product Types o Community Renewables o Community Choice Aggregation o Direct Purchase Agreements (PPAs and On-site) Minimum Purchase Quantity New Renewables: New Date Geographic Source Reporting: RECs + Electricity Products Increased Granularity in Reporting: All Products Eligibility of Generation Dates: All Products Requiring Tracking System Use Regional Greenhouse Gas Initiative (RGGI): Applicability of Certain Supply Feedback will be accepted until Saturday, April 30, CRS will conduct a second comment period, incorporating feedback from this first comment period. The current Standard and a PDF summary of all potential changes are available at Green-e Energy National Standard and Governing Documents (opens in a new window) for you to view before completing the survey. Green-e Energy is North America s leading certification program for sales of renewable electricity and renewable energy certificates (RECs) made in the voluntary market for renewable energy. Created in 1997, Green-e Energy provides oversight to voluntary renewable energy sales, certifying the majority of all retail voluntary renewable energy sales in the U.S. The Green-e Energy National Standard was developed through an open stakeholder process in 2004 and 2005, and grew out of regional program standards in place between 1997 and Periodically, the Standard is assessed to determine if any changes should be made to adapt it to the evolution of the voluntary renewable energy market. 2

3 This survey may take up to 30 minutes to complete--depending on your responses, it may take less time. If you need to pause while taking the survey (for example, to look up information), you may resume at any time prior to midnight Pacific on Saturday, April 30, by using the link that directed you to this page, provided you do so from the same computer and browser. You may also go back and change your answers at any time prior to clicking "Submit Survey Responses" at the end of the survey. Thank you for your time and consideration as you complete this survey. NOTE: Although contact information is requested in this survey, it is not required to complete the survey. However, we would appreciate your contact information, as it will help us if we have follow up questions for you. We will not distribute your contact information; it will only be used for follow-up related to the Standard. Throughout the questions, text additions to Standard language are underlined; Deletions are designated by strikethrough. Take the Survey: 3

4 1. Product Specifications: Allowing Variability for RPS-affected Products and Among Hub-and- Spoke Utilities On October 18th, 2015, Green-e Governance Board members considered and passed a 1-year exception that allows Participants selling electricity products with a wide geographic service area to provide customers with facility-specific or state-specific generation without having to offer multiple Green-e Energy certified products. This allows for more flexibility in community renewables offerings and accommodates state-specific RPS requirements. The exception also permitted utility participants within the hub-and-spoke model to offer generation from various local renewable energy facilities within a residential single-mix product offered by their retail spoke utilities. To this end, the Green-e Governance Board adopted the following resolution: "Green-e will allow companies selling a residential single-mix electricity product(s) to vary the generation location within a resource type among the customers of the product(s) while maintaining a single approved product mix for all customers of the product, and abiding by all other program requirements, without violating Section III.D. and V.E. of the Green-e Energy National Standard, through December 31, 2016." To become permanent, the following changes would be made to the Green-e Energy National Standard: Change 1: Section III.D.: D. Renewable Portfolio Standard (RPS) Renewables, Other Mandated Renewables, and Financial Incentives Only for a certified renewable electricity product that meets 100% of a customer s load, Greene Energy allows a percentage of the product content to be satisfied with renewables reported toward a renewable portfolio standard (RPS) or other similar state policy, up to the amount that is attributable to the customer of the voluntary product.15 All such resources must also go through the Green-e Energy verification process, and meet all other applicable Green-e Energy eligibility and disclosure requirements. Distribution of renewables reported toward a RPS or similar policy must be consistent across the load on which the policy s obligation calculations are based, and allocating all such renewables to one customer type or group of customers is not allowed. However, variability of geographic location of generation (not renewable resource type) is allowed to the extent required by Participant's RPS obligations under the laws of said state." 4

5 Change 2: Section V.E.: E. Programs Serving Multiple Utilities (Hub and Spoke) 1) In order to qualify for Green-e Energy certification using the hub and spoke model, the product must: a) Contain exactly the same proportional mix of resources for each participating spoke vendor. Each participating spoke may vary the generation location within a resource type but all participating spokes must offer the same overall mix of resource types. The same facilities must be used and shared equally among customers. In other words, if the customers of one utility in the Midwest are purchasing 50% wind from Minnesota and 50% biomass from Wisconsin, then all participating vendors must sell the same mix of renewables from the same resource. That way Green-e Energy can do a single verification audit. All of the renewable energy supply for the product must be sourced from the hub. 2) Obligations of the Hub and Spoke Facilitator (the Hub): a) Offer the exact same product to all participating vendors retail distribution utilities (the Spokes). 1. Should the change to the Standard's "exact mix" rules for certain single-mix electricity products be changed as described above? -Yes -No -Neutral If no, please state alternate preferences: 5

6 2. Geographic Eligibility for Electricity Products Green-e Energy allows electricity products to be sourced from the customer s NERC region, and/or the customer s ISO/RTO, and/or the state where the customer is located. Particularly in the west and mid-west, this allows for a broad range of sources for many consumers. In some areas throughout the nation, particularly in the Mid-Atlantic, geographic boundaries for these electrical power systems may include a portion of a state. Green-e staff have received questions regarding the definition of eligible geographic sourcing from program participants. This change is proposed to clarify how sellers must define a state and to add the possible boundary of supply to include the entire service territory of a utility Participant. These clarifications will support better understanding of Green-e s existing rules by Participants. Proposed Standard language reads: Section IV A.: A. Geographic Eligibility for Electricity Products For electricity products (i.e. products used to meet a customer s electricity needs), provider can source from one or more of the following geographic boundaries: a) The single state where all of the product s customers is are located; and/or b) The North American Electric Reliability Corporation (NERC) region, Independent System Operator (ISO), Regional Transmission Organization (RTO); or Balancing Authority Area of the customer being served; and/or Participant s regulated electric service territory; and/or c) An adjacent NERC, ISO, RTO or Balancing Authority Area region where the electricity, bundled with a REC, is wheeled into the respective region of the customer being served. 1. Do you think this language clarification is appropriate? If not, how would you change it? -Yes -No -Neutral 6

7 3. Eligible Generation Locations: Guam, the U.S. Virgin Islands, the Northern Mariana Islands, and associated territorial waters and airspace In March 2015, the President issued Executive Order 13693, which described the acceptable geographical locations of generation that may be used to source renewable energy that meets requirements established for federal agencies and departments. It describes "the fifty States, the District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, the United States Virgin Islands, the Northern Mariana Islands, and associated territorial waters and airspace" as eligible. Currently the Standard includes generation from all of those regions, except Guam, the U.S. Virgin Islands, the Northern Mariana Islands, and associated territorial waters and airspace, only because generation from those regions has not yet been presented for certification. In our research, staff has found no compelling reason to exclude these regions, as long as the supply meets all other provisions of the Standard. Should Green-e Energy include Guam, the United States Virgin Islands, the Northern Mariana Islands, and associated territorial waters and airspace among the allowed geographical sources of generation, and in so doing, align with federal requirements? Yes No Neutral Comments: 7

8 4. Eligible Sources of Supply: Fuel Cells Green-e Energy describes the types of energy technologies that are eligible to be included in certified products. One type is fuel cells. A slight edit to the Standard will explicitly allow fuel cells to be powered by all eligible fuel sources: Section II.A.7: 7) Fuel cells are eligible only if powered by hydrogen or other fuels1, derived from any of the above eligible renewable resources. (See section II.E.7) SectionII.E.7: 7) A fuel cell that began generating electricity on or after the applicable New Date. The hydrogen or other fuels powering the fuel cell must be derived from a facility that meets the resource eligibility requirements described in section II.A. above. The renewable resource facility that produces the fuel from which the hydrogen is derived does not need to meet the new date criteria but does need to meet Green-e Energy resource definitions (section II.A) and/or FOOTNOTE: 1 Biogas from a shared pipeline is eligible only if it can be demonstrated that all environmental attributes are appropriately transferred along the chain of custody. 1. Should Sections II.A.7 and II.E.7 be changed to allow "other fuel types" derived solely from renewable sources eligible under the National Standard? Yes No; Neutral If "yes" or if "no", please state your reasoning: 8

9 5. Eligible Sources of Supply: Biofuels Green-e Energy responds to changes in technology and fuels available to the energy markets by updating the definitions of eligible supply. Advances in liquid fuels allow the Standard to be more descriptive about what is included in the definition of allowable biofuels. A proposed change to the Standard that would accomplish that would read: Section II.A.5 5) Solid, liquid and gaseous forms of Biomass from the following fuels: FOOTNOTE: 3 Including liquid biofuels made entirely of eligible resource noted in Section 2.A.5 (for example biomethane, biogas, or bioethanol). Do you support expanding the definition of liquid fuels to specify other biofuels as described above? Yes No Neutral If "yes" or if "no", please state your reasoning: 9

10 6. Eligible Sources of Supply: Biogas Staff has received questions about the production date of eligible biogas fuels used for electricity generation. The Green-e Energy National Standard currently does not restrict the production date of biogas, but only has requirements related to the date the fuel is used for electricity generation. Some stakeholders have asked for rules addressing the production date of biogas to be made explicit. A proposed change to the Standard that would clarify the current treatment of fuel production date reads: Section II.A 5. Solid, liquid, and gaseous forms of Biomass from the following fuels: 1,2,3,4 4 Biogas used to supply electricity generators may be produced at any time, but any renewable MWh generated from such fuels must meet the requirements in Section III.B Vintage of Eligible Renewables. Do you support the proposed changes to the Standard to clarify eligible production dates for biogas fuel? Yes No; Neutral If "no", please state your reasoning, and whether you think that this fuel type should be treated differently than others: 10

11 7. Eligible Sources of Supply: Organic waste The following section of the Standard refers to "organic waste" without defining it, which may lead to confusion as other sections of the Standard address specific kinds of organic waste. See below for the current use of the term. SECTION II.A.5.c: 5) Solid, liquid, and gaseous forms of Biomass from the following fuels: c) All animal and other organic waste 8 FOOTNOTE: 8 In the case that a biogenic methane capture and destruction project (such as a dairy burning biogas produced by an animal waste digester) is receiving carbon offsets for the destruction of methane, renewable electricity and RECs generated using the heat of combustion of such methane are eligible under this Standard so long as the calculation of carbon offsets does not include the environmental benefits arising from generation of renewable electricity or of backing down generation elsewhere on the grid. Green-e Energy staff reserve the right to request offset calculation methodologies of such projects. Should Green-e Energy specify the meaning of "other organic waste" in more detail? Yes / No / Neutral Comments If yes, how should organic waste be defined and what types of organic wastes would be appropriate to include in this section? Are there existing definitions or resources with which the Standard should align? 11

12 8. Hub-and-Spoke Utilities: Marketing Compliance Responsibilities Green-e currently requires Hub-and-Spoke utilities to use similar marketing among its Spokes. If changes requested for comment in Question 1 (permission for variation in the mix of resources delivered among the Spokes) are allowed, corresponding changes to the marketing requirements for Spokes would have to be made as well. Specifically, this change would allow Spokes to uniquely market their product as appropriate to the resources used, while following all rules and regulations of the Green-e Energy Code of Conduct. The choice by a Spoke to vary their product marketing from the Hub s will result in a separate marketing compliance review of that Spoke, and additional certification fees may be billed to the Hub utility. A proposed change to the Standard that would accomplish this would read: Section V.E.1 c) UseUtilize the same marketing materials for each participating vendor Spoke, unless a Spoke is approved by Hub to participate in a separate marketing compliance review and Green-e is notified (additional certification fees may apply). All participating vendors must use the same marketing materials. Any Iindividual utility vendors Spoke may brand the marketing materials without triggering a separate marketing compliance review so long as there are no other variations from the marketing materials provided by the Hub. However, marketing materials must be consistent across the product service territory so Green-e Energy can do a single marketing compliance review. Limited exceptions to this rule will be tolerated so long as Green-e Energy is notified. Section V.E.2 d) Undergo single marketing compliance reviews. If a Spoke has been approved by the Hub and Green-e has been notified of its intent to use customized marketing, individual marketing compliance reviews for each Spoke will be required and additional certification fees may apply. Last sentence of Section V.E There is a single annual fee assessed per product regardless of the number of participating Spokesvendors. The choice of a Spoke to conduct Spoke-specific marketing may incur additional certification fees for the Hub. 1. Should Green-e Energy change Hub-and-Spoke rules such that Spokes are allowed to choose, with Hub s approval, Spoke-specific marketing compliance review? (Note: This change will lead to an adjusted billing structure for affected Hub-and-Spoke utilities) Yes No Neutral Comments: 12

13 9. Newer Product Types: Community Renewables, Community Choice Aggregation, Brokers, and Direct Purchase Agreements (PPAs and On-site) Green-e Energy staff seeks comment on the need to add specific criteria in the Standard for product types that are currently eligible for certification, including community renewables, community choice aggregation, and direct purchase agreements (whether off-site or on-site). COMMUNITY RENEWABLES 1. Do you support creating a separate section of the Standard to address community renewables? Yes No Neutral Comments (requested if answering "yes" or "no") 2. How should the Standard define community or local in terms of geographical restrictions? Comments 3. What types of community renewables projects/programs/structures should be allowed? Comments 4. Are the block size / percent of use thresholds currently in the Standard (see Section III.A.) still appropriate when applied to community renewables? Yes / No / Neutral Comments (requested if answering "yes" or "no") COMMUNITY CHOICE AGGREGATION (CCAs) / MUNICIPAL AGGREGATION 1. Do you support including specific criteria for community choice aggregation (CCAs), also known as municipal aggregation? Yes No Neutral Comments (if Yes, please elaborate what type of criteria would be appropriate) DIRECTLY CONTRACTED AND ON-SITE SOURCED GENERATION 1. Do you support including specific criteria for direct sales of renewable electricity and/or RECs from generation facilities to end-use customers, such as PPAs of all kinds and direct REC sales (for either off-site and/or on-site projects)? Yes No Neutral Comments (if Yes, please elaborate what type of criteria would be appropriate") 13

14 10. Minimum Purchase Quantity In 2014, the Green-e Governance Board approved an edit to the Standard allowing Participants to sell certified capacity-based electricity products to residential customers. This change interpreted how the Standard s minimum purchase size rule (shown below) applies to electricity programs sold as shares or portions of a facility, such as a solar shares program. To formalize this rule change, we seek comment on its applicability and seek to move it up from a footnote level to its own section (to be III.A.3): Section III.A: III. PRODUCT SPECIFICATIONS A. Minimum Purchase Quantity Green-e Energy certified products sold to residential customers must contain at least the minimum amounts of Green-e Energy eligible renewable energy described below. 1) Percentage-of-Use Products: Retail electricity offerings must match at least 25% of a residential customer s electricity usage with new renewables above and beyond any state mandated Renewable Portfolio Standard (RPS) renewable amount. If a marketer or utility offers the option to match less than 50% of a residential customer s electricity use, they must also offer a 100% option to residential customers. 2) Block Products: Electricity and REC products sold as block products must be 100% Green-e Energy eligible renewables in a minimum size of 100 kwh/month. 12 3) Capacity-Based Products: Electricity or REC products sold as kw of capacity from or shares of a facility must deliver a minimum of 100 kwh a month averaged over a calendar year, or, if such products are supplied by community renewables facilities, they may instead deliver a minimum of 25% of the customer s monthly electricity use averaged over a calendar year. FOOTNOTE: 12 When RECs are sold on a one-time basis to a residential customer, the minimum purchase quantity shall be 100 kwh. Electricity products sold as kw of capacity from or shares of a facility must deliver a minimum of 100 kwh a month averaged over a calendar year, or, if such products are supplied by community renewables facilities, they may instead deliver a minimum of 25% of the customer s monthly electricity use averaged over a calendar year. Should current Standard language allowing capacity-based program options to qualify under Green-e Energy s Minimum Purchase Quantity be moved to new Section III.A.3? Yes No Neutral Comments (requested if answering "yes" or "no") 14

15 11. New Renewables: New Date The new date refers to the commercial online date or repowering date of the eligible renewable energy facility. The Standard requires that certified products are supplied with generation from facilities that are no more than 15 years old. The new date adjusts each year, which supports the development of new renewable energy facilities. Last year, Presidential Executive Order established a 10-year new date for acceptable renewable generation sourced by federal agencies and department seeking to comply with minimum renewable procurement goals. Green-e Energy has also fielded proposals requesting a shorter new date. Other proposals have suggested Green-e should define a longer or unlimited new date for long-term contracts or wholly-owned, on-site generation. 1. Should Green-e Energy consider modifying its current new date of 15 years? Yes / No / Neural If yes, what should the new date be select a numerical answer: -5 years -7 years -10 years -20 years -other 2. Do you support having different new dates for different types of renewable energy supply contracts (between the Participant and the generator) or for an owned generator? Yes No Neutral 3. Matrix question: If supportive of differentiating new dates, please indicate what new date (number of years or unlimited) you recommend for these options: 1) long-term procurement contract between Participant and generator; 2) Participant owned onsite generation; 3) Participant owned offsite generation; 4) all other procurement types. 4. If changes to the new date are adopted, when should these become effective, and should existing facilities or contracts be subject to the new requirements? 5. Please provide any additional comments you would like to submit regarding the New Date requirements. 15

16 12. Electricity Source Reporting: RECs + Electricity Products The Standard currently contains the following rules regarding the use of RECs in certified electricity products. Section IV.B: B. Use of Renewable Energy Certificates in an Electricity Product Renewable Energy Certificates (RECs) can be combined with nonrenewable power to serve green electricity customers under the following conditions: a) The Renewable Energy Certificates must come from the defined geographic boundary of the customer being served as noted above if they are to be marketed as an electricity product; b) The emission rates per kwh for SO2, NOx, and CO2 for the underlying electricity must be at or below the customer s average utility, state or regional power emissions rates; and c) The underlying electricity cannot include any specific purchases of nuclear power in the non-renewable portion of the product other than what is contained in any system power purchase (e.g. the product may not include differentiated nuclear power). If the RECs are sourced from outside the defined geographic boundary defined in Section IV.A. (Geographic Eligibility for Electricity Products), the product will need to be marketed as a REC product and contain the appropriate disclosure language (see Green-e Energy Code of Conduct). In your experience, do customers want to know or need to know whether their renewable electricity provider also sourced electricity from the same facility as the RECs? If so, what value do customers get and what suggestions do you have for Green-e to help customers realize that value? Yes No Neutral Comments (requested if answering "yes" or "no") 16

17 13. Increased Granularity in Reporting: All Products In some cases, depending on the Participant s marketing disclosure choices, the specific dates of the generation of a buyer s product are not disclosed. The customer would always know at a minimum that their renewable energy generation happened within the 21-month vintage period applicable to the year they bought the certified product. For Green-e Energy Federal Option products, Green-e requires the disclosure of year and quarter of generation, specifically to allow the buyer (in this case federal agencies), to accurately report their purchasing under federal regulations. Other non-federal Option buyers may benefit from having this detail provided to them when reporting on their own renewable energy purchasing activities in Sustainability Reports, Scope 2 reporting, or in statements to other stakeholders. As Green-e is interested in providing buyers with the ability to properly market the beneficial results of their purchases, requiring retrospective disclosure of a product s year and quarter of generation supports an added granularity within those marketing statements. Do you support requiring that all sellers retrospectively disclose to non-residential customers the dates/quarters of generation of their certified products? Yes No Neutral Comments (requested if answering "yes" or "no") 17

18 14. Eligibility of Generation Dates: All Products When Green-e released Version 1.0 of the Standard in 2006, a generation vintage window of 21 months was created to allow the greatest flexibility in sourcing of supply as related to (then) current supply trends, especially due to the seasonality of certain renewable generation. This window has not been adjusted in the 10 years that followed. Current market forces lead us to ask if there is support for an adjustment to a 15-month window to better reflect current supply conditions and customer needs. The current supply eligibility window of 21 months consists of these three periods: REPORTING YEAR 2016 WINDOW OF GENERATION ELIGIBILITY <---JUNE DEC.---> < JANUARY DECEMBER > <-JAN MAR-> A change to the Standard as written below would require the seller to procure most of the required supply within the Reporting Year, and allow them to supplement as needed in the following three months. Section III.B: B. Vintage of Eligible Renewables A Green-e Energy certified product may include only renewables that are generated in the calendar year in which the product is sold, and the first three months of the following calendar year, or the last six months of the prior calendar year. 1. Do you support reducing the generation eligibility window by 6 months, requiring that all sellers secure supply within the Reporting Year and/or the first 3 months of the following year? 2. Do you have other suggestions for limiting or expanding the eligible supply window for sellers? 18

19 15. Requiring Tracking System Use Currently, electronic tracking systems are available throughout the U.S. and in Canada. These systems track data on renewable electricity generation, acting similarly to bank accounts for RECs, and are used by Green-e Energy to aid in annual verification of certified renewable energy sales. When generators are registered in tracking systems, tracking system data related to certified sales must be supplied to Green-e Energy, but many facilities are not registered in tracking systems, and tracking system registration is not currently a requirement for eligibility under the Standard. During a prior Standard survey, respondents were asked whether they generally supported requiring the use of tracking systems for generator eligibility. Nearly 80% did, with somewhat differing comments on when to implement the requirement, which facility types to omit, how to limit costs, and the like. Based on these responses, Green-e Energy has entered into conversations with the various tracking systems noted below, that together cover the entire eligible territory for Green-e Energy certification, to address stakeholder concerns such as cost implications and functionality. Those discussions currently show support for a Green-e Energy requirement for use of tracking systems and a willingness to work with energy sellers to keeps costs within reasonable bounds. Green-e Energy is seeking feedback on the proposed change and language below. Proposed language to include in a new section (likely to be Section III.H. Tracking System Use ) of the Standard: In all but a few specific cases listed in this section, Green-e Energy certified products must be supplied and substantiated by renewable MWh tracked in a renewable energy tracking system that are approved by Green-e Energy and that meet the following criteria: a. Is managed by or coordinates with a government agency(ies) that oversee relevant state RPS policies, electricity resource disclosure and/or carbon accounting; b. Has the ability to indicate that RECs are retired specifically for Green-e Energy certified sales; and c. Has the ability to provide information directly to Green-e Energy on retirements that are marked as Green-e Energy certified in the tracking system. As of [Standard publication date], approved tracking systems meeting the above criteria are: 1. Electric Reliability Council of Texas (ERCOT) 19

20 2. Michigan Renewable Energy Certification System (MIRECS) 3. Midwest Renewable Energy Tracking System (MRETS) 4. North American Renewables Registry (NAR) 5. North Carolina Renewable Energy Tracking System (NCRETS) 6. New York Generation Attribute Tracking System (NYGATS) in development 7. NEPOOL Generation Information System (NEPOOL-GIS) 8. PJM Generation Attribute Tracking System (PJM-GATS) 9. Western Renewable Energy Generation Information System (WREGIS) This requirement will go into effect for all generation supplying certified sales occurring on or after January 1, Only in the following cases is the use of tracking systems not required for Green-e Energy certified products and participants: a. The facility has a nameplate capacity less than 10 MW, or b. The facility is located on property owned by the retail electricity user claiming the RECs/renewable energy, and located at the site of use, and that user is claiming all RECs generated in the calendar year by the facility, or c. The participant s total certified sales volume is less than 10,000 MWh for that reporting year. In this case another tracking system accountholder must retire supply on behalf of the participant s certified sales (in addition to all other required verification procedures) or the facilities used must meet a. or b. above. Each Green-e Energy participant, if not exempted by an exception a.-c. above, must have and use its own account in each tracking system used to substantiate the participant s certified sales in a given calendar year. Details of how to use tracking systems, for example, which retirement reasons to use, are provided in the Green-e Energy verification protocols. 1. Do you support language above that would require all supply used in certified sales (with the exceptions noted in parts a.-c.) to go through a recognized tracking system? Yes No Neutral Comments: 2. Is the 10MW cutoff in exception a. appropriate to all resource types, or should it vary by resource type? Yes / No / Neutral Comments: 3. Is 10,000 MWh the appropriate cut-off in situations such as those outlined in exception c.? Yes / No / Neutral 20

21 Comments: 4. If adopted, should Green-e Energy schedule the rule change that affects current Participants to go into effect on January 1, 2018, or July 1, 2018? 1/1/18 7/1/18 21

22 16. Regional Greenhouse Gas Initiative (RGGI): Applicability of Certain Supply The RGGI is the greenhouse gas emissions cap-and-trade program implemented by 9 northeastern and mid-atlantic states. As part of the RGGI program, 8 of the 9 states have adopted set-aside programs that allow voluntary renewable energy purchasers to have allowances retired on their behalf, thereby maintaining the carbon reduction impacts of voluntary renewable energy purchasing under the program. Currently, only renewable energy transactions that meet certain criteria specified by each of these states are eligible for the set aside programs, and Green-e Energy has limited certification only to those eligible transactions. Green-e seeks stakeholder feedback on the use of RGGI allowance retirements for voluntary renewable energy transactions sourced from renewable energy facilities within RGGI states that are not currently eligible to use the set aside programs operated by the states. For example, should generation sourced from RGGI states be allowed to be sold to customers located outside the RGGI footprint, with the purchase and retirement of applicable allowances in COATS? Should Green-e change the Standard to allow the purchase and retirement of allowances for generation located in RGGI states that is not eligible for the state voluntary set-aside programs, but that otherwise meet all other Green-e Energy eligibility criteria, so that that generation can be included in Green-e Energy certified products? Yes / No / Neutral Comments: 22

23 17. Suggestions for Other Changes Green-e Energy periodically conducts a stakeholder review process of the Standard which includes a minimum of two (2) open comments periods. You are participating in the first of two (2). If there is significant desire among stakeholders for open review of additional areas for change within the Standard, those issues will be raised in the second open comment period, scheduled for mid-summer Please make use of the following section to introduce your additional comments, not related to comments previously made: 1. Additional Comment 1 2. Additional Comment 2 3. Additional Comment 3 4. Additional Comment 4 23

24 18. Conclusion Thank you for your comments. Green-e Energy will compile your responses for the consideration of the Green-e Governance Board, who will discuss and vote on whether to support edits to the Green-e Energy National Standard. Thank you for your participation. If you would like to reach us directly with questions or additional comments, please write to 24