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We're coming down to the final wire on the Green-eT-RECs standard. Below i=
s a synopsis of the outstanding issues. I wanted to get your thought about= the following the options. I agree with staff that choice #1 is ideal. M= y second choice is #3. The issue is this: Each of the regions has slightly= different to dramatically different definitions for eligible resources for= a Green-e certified electricity product. In order to have a national stan= dard whereby a marketer can market the same product across the states, staf= f has proposed certifying generators per region. These generators would be= certified according to that region's standard. The T-RECS could then be m= arketed anywhere. Some folks want to control not only the generators that = are certified, but the products that are sold in their region. Thus the op= tion for the highest common denominator (choice #2). I think we need to go= with the most administratively simple method that will promote the most li= quidity. Certifying generator or creating a separate T-RECs standard seem = to be the easiest. Let me know your thoughts. I'd like to get back with Meredith today. Also= , these issues are pretty nebulous -- so call if you have ?s. Stacey Bolton Environmental Strategies Enron Corp 713-853-9916 direct=20 713-303-2632 cell=20 stacey.bolton@enron.com <mailto:stacey.bolton@enron.com< =20 -----Original Message----- From: =09"Meredith Wingate" <mwingate@resource-solutions.org<@ENRON =20 Sent:=09Tuesday, November 06, 2001 4:34 PM To:=09Anne Marie McShea; Barbara Atkinson \(LBNL\); Brenna Herpmann; Brent = Beerley; Jeff Schmidt; Kevin Porter; Liz Robinson; Maureen Mulligan; Mark C= rowdis; Matt Deluca; Peter Adels; Rich Travaglini; Roger Clark; Sam Swanson= ; Serpil Guran; Stacey Bolton; Maryanne Daniel Cc:=09Dan Lieberman; Andrew Altman; Kirk Brown Subject:=09Generator based sourcing standards Folks,=20 As you know, at our last meeting, I promised to circulate the different op= tions we discussed on generator -based sourcing standards. =20 =20 The problem we are trying to solve is this: We'd like to develop a nation= al definition for "eligible" renewables for certification of T-RECs pro= ducts under Green-e. The problem is that if we did a highest common denom= inator standard, some renewables, namely biomass would be excluded. We fe= el that this would be a somewhat arbitrary exclusion because biomass has b= een excluded from some regional standards because of specific regional cir= cumstances and that it would not be fair to penalize the entire biomass in= dustry by eliminating it from the T-RECs - Green-e market. =20 So staff have proposed a generator based sourcing standard. Eligibility w= ould thus apply to renewable generators, not marketers. So if a generator= qualified, they would-be able to market their T-RECs anywhere in the US. = The general feedback I got from you was that people didn't like this idea= because (1) it wasn't clear for the consumer what types of eligible are a= llowed under Green-e cert. (e.g. Georgia biomass excluded, but PA biomass = allowed) and (2) effectively gave marketers the ability to sell a type of = power into a market that might not meet the regional definition of eligibl= e, (e.g. you could sell forestry-derived biomass generated in New England = into the PA market - the generator would meet the new England definition f= or eligible and therefore would be able to sell that power anywhere.) =20 We discussed a couple of different options for handling this dilemma. Her= e are a few of the major pros an cons. =20 1. Adopt a single generator-based sourcing standard for electricity = and T-RECs (this was the proposal by staff) pros: it is consistent b/t electricity and T-RECs products, and it allows= for regional definitions of eligibility;=20 cons: not clear for the consumer what types of eligible are allowed under = Green-e cert.; effectively gives marketers the ability to sell a type of = power into a market that might not meet the regional definition of eligibl= e =20 2. Don't change electricity standards (keep definition of "eligible"= renewable as regional product standard) but have a T-RECs standard that = is based on the highest common denominator of all regional Green-e/Green p= ricing standards. A highest common denominator standard would include sola= r, wind, digester gas, and possibly LIHI hydro, geothermal landfill methan= e with some NOx limits. I say "possibly" because these things aren't incl= uded in green pricing eligibility criteria but we think we might be able t= o convince stakeholders there to accept them. Pros: Meets both regional definitions for what is generated in a state and= what is marketed in a state Cons: inconsistent standard b/t electricity products and T-RECs products; = eliminates biomass and possibly other renewables from eligibility for T-R= ECs =20 3. Don't change electricity standard but develop a new national defi= nition for what T-RECs are "eligible" (this would not necessarily be a hig= hest common denominator standard, but more of a "generally accepted renewa= ble" standard) Pros: Doesn't change electricity standard; makes it clear for consumers wh= at's in a Green-e certified product Cons: potentially inconsistent standard b/t electricity products and T-REC= s products; could undermine regional standards if something is approved as= eligible for T-RECs but it is not eligible for electricity. =20 4. keep product standard for both electricity and for T-RECs; requir= e both electricity providers and T-RECs providers to meet the regional de= finitions. Pros: Meets both regional definitions for what is generated in a state and= what is marketed in a state Cons: requires T-RECs marketers to market different products for different= regions- could prevent them from seeking certification; inconsistent stan= dard b/t electricity products and T-RECs products Please send me your feedback on these different options. We did have an op= tion 5, but upon reflection, it appeared to me to be the same as one of th= e other options. if this isn't enough selection for you, feel free to add= you own option too! =20 Thanks, Meredith=20 =20 =20 Meredith Wingate Center for Resource Solutions Presidio Building 49 PO Box 29512 San Francisco, CA 94134 415-561-2100 _________________________ Information about CRS programs is available at www.resource-solutions.org= =20 Curious about Green-e and green power? Check out www.green-e.org
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