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EPA’s Green Power Partnership
               The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily
               Discussion Draft




D                                                                                       The Role of RECs in the Renewable Energy
         ramatically increasing the use of renewable energy in the
         nation’s electricity generation portfolio is essential to re-                  Marketplace
         ducing U.S. greenhouse gas (GHG) emissions. For most                           RECs were introduced in the late 1990s to verify consumer
organizations, the use of electricity might be the largest single                       electricity labels and renewable portfolio standards (RPS)
source of GHG emissions for which they have responsibility.                             compliance, and to provide flexibility for RPS compliance.
Therefore, the purchase of zero-emission, renewable electricity is                      Today, they stimulate renewable energy development by giving
an excellent way to help make the transition to more renewable                          generators and consumers access to broader markets than just
energy and a reduced carbon footprint. Thousands of organiza-                           their interconnected utilities.
tions are leading this effort by installing their own renewable
energy systems or purchasing renewable electricity. Among these                         RECs are market-based instruments that convey the environ-
organizations, many have found that purchasing renewable en-                            mental value of renewable energy between buyers and sellers.
ergy certificates (RECs) is one of the simplest and most effective                      Each REC provides exclusive proof that 1 megawatt-hour
ways to reduce their carbon footprint.                                                  (MWh) of renewable energy has been generated.2 RECs are
                                                                                        widely used to verify compliance with state renewable portfolio
RECs are critical, effective, and valuable instruments for                              standards and to establish environmental claims in the volun-
expanding renewable energy across the United States. With                               tary market. As such, they are the common currency in both
RECs, electricity customers anywhere in the United States can                           compliance and voluntary markets.
buy renewable electricity regardless of whether it is offered by
their local electricity provider. RECs’ flexibility is a key factor                     REC trading enables a national voluntary market for renewable
in the emergence of a commercial and institutional customer-                            energy that facilitates both supply-side efficiency—develop-
driven national voluntary market for renewable energy. Volun-                           ers can site renewable energy facilities where the resource is
tary market sales grew four-fold in four years—from 6 billion                           most cost-effective—and customer choices—organizations can
kilowatt-hours (kWh) in 2004 to 24 billion kWh in 2008—                                 design a green power purchase that meets their specific criteria
largely because of organizational demand for RECs. Of the                               mix of geographic location, technology type, supplier, facility
total voluntary market sales in 2008, two-thirds were RECs                              vintage, and price. Many of EPA’s Green Power Partners make
(the remainder were utility green power products).1                                     sophisticated purchasing decisions with RECs, accessing desir-
                                                                                        able projects and satisfying cost and technology objectives.
The purpose of this paper is to educate U.S. Environmental
Protection Agency’s Green Power Partners and prospective                                EPA regards REC purchasing as the simplest way for organiza-
Partners about the environmental value of purchasing RECs                               tions and institutions to affect the United States’ electricity
voluntarily. To clarify the basis for this environmental value,                         generation mix at a national scale. These voluntary purchases
this paper addresses: the role of RECs in the renewable energy                          create demand that is over and above the demand created by
marketplace, their role in reducing emissions, and the manner                           the compliance requirements of state RPSs and allow organiza-
in which a corporate GHG inventory accounts for the environ-                            tions of all sizes to leverage their collective purchasing power
mental value of a voluntary REC purchase.                                               to positively influence utility-scale generation.3 As a result of
                                                                                        this flexibility, voluntary demand for new renewable energy
                                                                                        is currently roughly equivalent in size to the demand for new
                                                                                        generation created by the compliance requirements of existing
                                                                                        state RPSs.4




1 Bird, Lori, Claire Kreycik, and Barry Friedman, Green Power Marketing in the United States: A Status Report (2008 Data), National Renewable Energy Laboratory,
  United States, 2009, p. 4, http://www.nrel.gov/docs/fy09osti/ 46581.pdf.
2 A certificate tracking system issues a uniquely numbered certificate for each MWh of electricity generated by a generation facility registered in the system, tracks the
  ownership of certificates as they are traded, and retires the certificates once they are used or claims are made based on their attributes or characteristics. For more
  information, see the EPA Green Power Partnership’s REC Tracking Web page (August 2010): http://www.epa.gov/greenpower/gpmarket/tracking.htm.
3 RECs sold into the voluntary market cannot also be used in the compliance market. If the voluntary market buys all of the RECs intended for a state’s RPS, new sup-
  ply will have to be created to meet the mandates. This gives the voluntary market an inherent degree of additionality.
4 Bird, et al., 2009, pp. 6–7.
                                                                                    1                                                                  October 2010
EPA’s Green Power Partnership: The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily
Discussion Draft

It is worth noting that RECs and utility green power are fun-                           saleable products—electrons and RECs. This added revenue
damentally equivalent environmental products. Utility green                             helps developers recover costs, pay off debt, and reduce project
power is a type of product offered by many electric service                             risk. Increased demand for RECs will help developers to pay
providers that combines electricity with RECs. It is function-                          for new projects, which influences the mix of resources used to
ally the same as buying RECs separately. A customer purchas-                            generate electricity. Purchasing RECs through long-term con-
ing green power from a utility-owned wind farm is unlikely                              tracts is even more desirable for project developers because such
to receive the electrons that were generated at the wind farm                           contracts further reduce risk and uncertainty.
because electrons flow to the nearest point of use. The customer
                                                                                        Generally speaking, new renewable electricity facilities deliver
in this example is receiving RECs, albeit from a specific and, in
                                                                                        electricity that affects the order in which existing facilities
some circumstances, proximate facility.
                                                                                        generate electricity for the grid and the future plans for fossil-
When RECs are sold separately from electricity, then the                                fueled generators. As a result of bringing new renewable elec-
underlying electricity is no longer considered “renewable” or                           tricity facilities online, the electricity sector emits fewer tons of
“green.”5 Users of that electricity cannot claim to be buying                           carbon dioxide emissions than it would have if these renewable
or using green power in the absence of owning the REC. This                             energy sources had not been operating or built.
prevents double-counting of environmental benefits.6
                                                                                        EPA periodically updates regional grid emission factors to
While RECs convey the environmental value of renewable ener-                            account for these changes in the generation resource mix. At
gy between buyers and sellers, REC prices are not based solely on                       present and in spite of significant voluntary market growth,
cost. The prices vary over time based on supply and demand—                             renewable energy growth attributable to voluntary purchases
including mandated RPS demand—and other dynamic factors                                 still represents a small percentage of the total supply portfolio.
such as wholesale power prices, capital costs, and the availability                     EPA anticipates future updates when emission factors will have
of credit and government incentives. As a result, a REC’s price is                      to be adjusted to account for such growth.7
not a true or accurate reflection of its environmental value.

                                                                                        RECs and Corporate GHG Accounting
The Role of RECs in Reducing GHG Emissions                                              An organization buying RECs can claim to be buying zero-
RECs have historically been thought of as an important ad-                              emission, renewable electricity, which reduces or avoids its
ditional incentive, often necessary to turn an uneconomical                             indirect emissions from purchased electricity.8 Another way to
project into a viable one. Recently, questions have arisen as to                        express the benefit is as a reduction in the organization’s carbon
whether RECs are truly an integral component of project eco-                            footprint.9 EPA guidance and existing voluntary corporate
nomics. For project developers, RECs represent an additional                            GHG accounting rules support these claims.10
revenue source: a wind farm, for instance, will produce two




5 Electricity without its environmental attributes is commonly called null power, which conveys no contractual rights or claims. See: Environmental Tracking Network
   of North America, The Intersection between Carbon, RECs, and Tracking: Accounting and Tracking the Carbon Attributes of Renewable Energy, February 2010, http://
   etnna.org/images/PDFs/Intersection%20btwn%20Carbon%20RECs%20and%20Tracking.pdf.
6 For more information about RECs and other green power product options, see: U.S. Environmental Protection Agency, U.S. Department of Energy, World Resources
   Institute, and Center for Resource Solutions, Guide to Purchasing Green Power, http://www.epa.gov/greenpower/documents/purchasing_guide_for_web.pdf.
7 According to Bird, et al. (2009, p. 3), retail sales of renewable energy in voluntary purchase markets exceeded 24 billion kWh in 2008, or about 0.6 percent of total
   U.S. electricity sales. This includes sales of renewable energy derived from both “new” and “existing” renewable energy sources, consistent with the generally accepted
   market definition with most sales supplied from new sources.
8 Indirect emissions come from sources that an organization does not own but that are associated with its activities. This is distinguished from reducing direct emissions
   that result in reducing global or total atmospheric emissions. See Table 1.
9 Some GHG voluntary reporting programs use the terminology of “using zero-emission electricity” rather than “reducing or avoiding indirect emissions.” Either way,
   both result in adjustments to the purchasing organization’s scope 2 emissions.
10 These claims are supported by the World Resources Institute and World Business Council for Sustainable Development (Greenhouse Gas Protocol: A Corporate Ac-
   counting and Reporting Standard [Revised Edition], p. 61, http://www.ghgprotocol.org/standards/corporate-standard), as well as EPA’s voluntary GHG reporting and
   goal-setting guidance and the U.S. Council on Environmental Quality (Federal Greenhouse Gas Accounting and Reporting Guidance, http://www.whitehouse.gov/sites/
   default/files/microsites/ceq/ GHG%20Guidance%20Document_0.pdf). The Climate Registry (http://www.theclimateregistry.org/downloads/ 2010/08/Draft-Cli-
   mate-Registered-Leadership-Program-Reporting-Requirements.pdf) has a draft policy for its Climate Registered Leadership program that is also consistent with these
   claims, but it has not been finalized at this time.


                                                                                    2                                                                 October 2010
EPA’s Green Power Partnership: The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily
Discussion Draft

Most leading organizations and businesses that are tracking the                          actions to reduce them. According to accounting rules, the same
GHG emissions associated with their operations are doing so                              emissions may be claimed by more than one entity as long as the
through established voluntary GHG reporting programs. While                              emissions are claimed in different scopes. Double counting of
accounting methodologies might vary slightly, most programs                              emissions would occur only if more than one entity claimed the
follow the framework provided by the internationally accepted                            same emissions in the same scope.
World Resources Institute and World Business Council for
                                                                                         Voluntary RECs might be confused with voluntary carbon
Sustainable Development Greenhouse Gas Protocol Corporate
                                                                                         offsets.12 RECs are not offsets. The differences between the two
Standard. According to this standard, when reporting emis-
                                                                                         environmental instruments prevent them from being used inter-
sions to a GHG inventory, organizations classify emissions into
                                                                                         changeably,13 though both may be useful in achieving organiza-
three scopes, as shown in the first two columns of Table 1. The
                                                                                         tions’ net GHG reduction goals.
remainder of Table 1 is EPA’s interpretation of how these scopes
may be used.                                                                             The purchase of RECs or green power is reflected as an adjust-
                                                                                         ment to scope 2 emissions. Scope 2 accounts for the GHG
This classification recognizes that emissions (and emission
                                                                                         emissions from the mix of regional generation resources used
reductions) are rarely the responsibility of just one entity’s opera-
                                                                                         to generate the MWh of purchased electricity. The adjustment
tions. The different scopes enable all of the entities involved to
                                                                                         methodology depends on the specific GHG voluntary reporting
report the emissions associated with their operations and to take
                                                                                         program. In EPA’s voluntary GHG reporting and goal-setting




            Table 1. Scopes for Corporate GHG Accounting and EPA’s
                           Interpretation of Their Use
                                                                                                            Applicability
                                                                                                                                           Allowable
 Scope                                Description
                                                                                                                                           Reduction Claims
                                                                                                        RECs               Offset

                            Emissions from sources that the organization
                                                                                                                                           Total GHG emission
                            owns or controls, such as industrial processes,
 Scope 1 (Direct Emissions)                                                                                No                 Yes          reductions; direct
                            natural gas consumption in buildings, owned
                                                                                                                                           emission reductions
                            vehicles, and owned energy generators11
                                      Emissions associated with the generation of
                                                                                                                                           Carbon footprint
 Scope 2 (Indirect                    electricity, steam, or heat—from sources that the
                                                                                                           Yes                Yes          reductions; indirect
 Emissions)                           organization does not own—that is purchased
                                                                                                                                           emission reductions
                                      and consumed by the organization
                                      Emissions from other sources the organization
                                                                                                                                           Carbon footprint
 Scope 3 (Other Indirect              does not own or control; examples include waste
                                                                                                           No                 Yes          reductions; indirect
 Emissions)                           disposal, leased/outsourced activities, business
                                                                                                                                           emission reductions
                                      travel, and employee commuting



11 On-site generators owned by the reporting entity should report direct emissions in scope 1. The owners of such on-site generators that displace purchased electricity
   should also report the emission reductions as an adjustment to scope 2 emissions.
12 A GHG or “carbon” offset is a unit of carbon dioxide-equivalent (CO2e) that is reduced, avoided, or sequestered to compensate for emissions occurring elsewhere.
   Goodward, Jenna, and Alexia Kelly, Bottom Line on Offsets, World Resources Institute, August 2010, http://www.wri.org/publication/bottom-line-offsets. Offsets
   are generated by investing in projects that result in verifiable emission reductions or in removing GHGs from the atmosphere. U.S. Environmental Protection Agency,
   Climate Leaders Greenhouse Gas Inventory Protocol Design Principles, 2005, p. 45, http://www.epa.gov/climateleaders/documents/resources/design-principles.pdf.
13 Direct emission reductions resulting from voluntary REC purchases are typically realized at conventional power generation facilities owned by entities other than
   the REC owner or generator. However, REC purchasers do not have clear title to direct emission reductions because green power or REC contracts typically do not
   include conventional power generation facilities displaced by renewable energy generators as a third party to the agreement. As a result, the role of RECs in reducing an
   organization’s GHGs is limited to indirect emissions (i.e., scope 2). U.S. Environmental Protection Agency, Climate Leaders Greenhouse Gas Inventory Protocol Optional
   Modules Methodology for Green Power and Renewable Energy Certificates, 2008, p. 4, http://www.epa.gov/climateleaders/documents/greenpower_guidance.pdf.




                                                                                     3                                                                 October 2010
EPA’s Green Power Partnership: The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily
Discussion Draft

guidance, an organization purchasing RECs calculates its net                         Conclusion
emissions by estimating the avoided emissions associated with                        Voluntary RECs offer critical environmental value because
its green power purchase14 using regional marginal emission                          they capture and enable the trade of the specific environmental
factors, which is advised by most GHG registries when facility-                      benefits associated with renewable energy generation. RECs
specific emission information is not available.15                                    create an accessible and more efficient national voluntary market
It is worth emphasizing that using RECs to adjust scope 2 emis-                      for renewable energy and provide an additional revenue stream
sion levels is consistent with, not an exception to, general scope                   for renewable energy project developers. Deploying renewable
2 accounting rules. Scope 2 was specifically designed to recog-                      sources of energy is critical for reducing our nation’s carbon
nize the importance of demand-side actions in reducing electric-                     emissions. The voluntary purchase of RECs allows businesses
ity sector emissions (as well as emissions related to purchased or                   and individuals to help grow U.S. renewable energy capacity in
imported steam or heat).                                                             a way that is most cost-effective and efficient for the economy
                                                                                     and offers a compelling, verifiable, and transparent way for an
The enactment of climate regulations might necessitate changes                       organization to meet its environmental goals.
to voluntary REC definitions and to corporate GHG account-
ing rules, but any changes would depend on the details of the                        EPA supports organizations purchasing RECs that meet the
specific regulations adopted. EPA and other experts agree that it                    Green Power Partnership eligibility criteria16 and encourages
will still be valuable for organizations to take actions to reduce                   them to use their purchases to adjust their indirect GHG emis-
the emissions associated with their purchased electricity, and it                    sions and to claim a smaller carbon footprint.
is possible that voluntary RECs would continue to offer organi-
zations a means to reduce their carbon footprint over and above
a regulatory baseline.




14 To learn how emission reduction claims are quantified, see Greenhouse Gas Protocol Initiative, Indirect CO2 Emissions from the Consumption of Purchased
   Electricity, Heat, and/or Steam: Guide to Calculation Worksheets (v. 1.2), January 2007, http://www.ghgprotocol.org/calculation-tools/downloads/ downloads-
   registration?referred_from=/downloads/ calcs/ElectricityHeatSteamPurchase_guidance1.2.pdf/; and U.S. Environmental Protection Agency, Climate Leaders Green-
   house Gas Inventory Protocol Optional Modules Methodology for Green Power and Renewable Energy Certificates. 2008. http://www.epa.gov/climateleaders/documents/
   greenpower_guidance.pdf.
15 U.S. Environmental Protection Agency, 2008, p. 4.
16 For more information, see: U.S. Environmental Protection Agency, EPA’s Green Power Partnership’s Partnership Requirements, May 2010, http://www.epa.gov/green-
   power/documents/gpp_partnership_reqs.pdf.

                                                                                 4                                                               October 2010

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The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily

  • 1. EPA’s Green Power Partnership The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily Discussion Draft D The Role of RECs in the Renewable Energy ramatically increasing the use of renewable energy in the nation’s electricity generation portfolio is essential to re- Marketplace ducing U.S. greenhouse gas (GHG) emissions. For most RECs were introduced in the late 1990s to verify consumer organizations, the use of electricity might be the largest single electricity labels and renewable portfolio standards (RPS) source of GHG emissions for which they have responsibility. compliance, and to provide flexibility for RPS compliance. Therefore, the purchase of zero-emission, renewable electricity is Today, they stimulate renewable energy development by giving an excellent way to help make the transition to more renewable generators and consumers access to broader markets than just energy and a reduced carbon footprint. Thousands of organiza- their interconnected utilities. tions are leading this effort by installing their own renewable energy systems or purchasing renewable electricity. Among these RECs are market-based instruments that convey the environ- organizations, many have found that purchasing renewable en- mental value of renewable energy between buyers and sellers. ergy certificates (RECs) is one of the simplest and most effective Each REC provides exclusive proof that 1 megawatt-hour ways to reduce their carbon footprint. (MWh) of renewable energy has been generated.2 RECs are widely used to verify compliance with state renewable portfolio RECs are critical, effective, and valuable instruments for standards and to establish environmental claims in the volun- expanding renewable energy across the United States. With tary market. As such, they are the common currency in both RECs, electricity customers anywhere in the United States can compliance and voluntary markets. buy renewable electricity regardless of whether it is offered by their local electricity provider. RECs’ flexibility is a key factor REC trading enables a national voluntary market for renewable in the emergence of a commercial and institutional customer- energy that facilitates both supply-side efficiency—develop- driven national voluntary market for renewable energy. Volun- ers can site renewable energy facilities where the resource is tary market sales grew four-fold in four years—from 6 billion most cost-effective—and customer choices—organizations can kilowatt-hours (kWh) in 2004 to 24 billion kWh in 2008— design a green power purchase that meets their specific criteria largely because of organizational demand for RECs. Of the mix of geographic location, technology type, supplier, facility total voluntary market sales in 2008, two-thirds were RECs vintage, and price. Many of EPA’s Green Power Partners make (the remainder were utility green power products).1 sophisticated purchasing decisions with RECs, accessing desir- able projects and satisfying cost and technology objectives. The purpose of this paper is to educate U.S. Environmental Protection Agency’s Green Power Partners and prospective EPA regards REC purchasing as the simplest way for organiza- Partners about the environmental value of purchasing RECs tions and institutions to affect the United States’ electricity voluntarily. To clarify the basis for this environmental value, generation mix at a national scale. These voluntary purchases this paper addresses: the role of RECs in the renewable energy create demand that is over and above the demand created by marketplace, their role in reducing emissions, and the manner the compliance requirements of state RPSs and allow organiza- in which a corporate GHG inventory accounts for the environ- tions of all sizes to leverage their collective purchasing power mental value of a voluntary REC purchase. to positively influence utility-scale generation.3 As a result of this flexibility, voluntary demand for new renewable energy is currently roughly equivalent in size to the demand for new generation created by the compliance requirements of existing state RPSs.4 1 Bird, Lori, Claire Kreycik, and Barry Friedman, Green Power Marketing in the United States: A Status Report (2008 Data), National Renewable Energy Laboratory, United States, 2009, p. 4, http://www.nrel.gov/docs/fy09osti/ 46581.pdf. 2 A certificate tracking system issues a uniquely numbered certificate for each MWh of electricity generated by a generation facility registered in the system, tracks the ownership of certificates as they are traded, and retires the certificates once they are used or claims are made based on their attributes or characteristics. For more information, see the EPA Green Power Partnership’s REC Tracking Web page (August 2010): http://www.epa.gov/greenpower/gpmarket/tracking.htm. 3 RECs sold into the voluntary market cannot also be used in the compliance market. If the voluntary market buys all of the RECs intended for a state’s RPS, new sup- ply will have to be created to meet the mandates. This gives the voluntary market an inherent degree of additionality. 4 Bird, et al., 2009, pp. 6–7. 1 October 2010
  • 2. EPA’s Green Power Partnership: The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily Discussion Draft It is worth noting that RECs and utility green power are fun- saleable products—electrons and RECs. This added revenue damentally equivalent environmental products. Utility green helps developers recover costs, pay off debt, and reduce project power is a type of product offered by many electric service risk. Increased demand for RECs will help developers to pay providers that combines electricity with RECs. It is function- for new projects, which influences the mix of resources used to ally the same as buying RECs separately. A customer purchas- generate electricity. Purchasing RECs through long-term con- ing green power from a utility-owned wind farm is unlikely tracts is even more desirable for project developers because such to receive the electrons that were generated at the wind farm contracts further reduce risk and uncertainty. because electrons flow to the nearest point of use. The customer Generally speaking, new renewable electricity facilities deliver in this example is receiving RECs, albeit from a specific and, in electricity that affects the order in which existing facilities some circumstances, proximate facility. generate electricity for the grid and the future plans for fossil- When RECs are sold separately from electricity, then the fueled generators. As a result of bringing new renewable elec- underlying electricity is no longer considered “renewable” or tricity facilities online, the electricity sector emits fewer tons of “green.”5 Users of that electricity cannot claim to be buying carbon dioxide emissions than it would have if these renewable or using green power in the absence of owning the REC. This energy sources had not been operating or built. prevents double-counting of environmental benefits.6 EPA periodically updates regional grid emission factors to While RECs convey the environmental value of renewable ener- account for these changes in the generation resource mix. At gy between buyers and sellers, REC prices are not based solely on present and in spite of significant voluntary market growth, cost. The prices vary over time based on supply and demand— renewable energy growth attributable to voluntary purchases including mandated RPS demand—and other dynamic factors still represents a small percentage of the total supply portfolio. such as wholesale power prices, capital costs, and the availability EPA anticipates future updates when emission factors will have of credit and government incentives. As a result, a REC’s price is to be adjusted to account for such growth.7 not a true or accurate reflection of its environmental value. RECs and Corporate GHG Accounting The Role of RECs in Reducing GHG Emissions An organization buying RECs can claim to be buying zero- RECs have historically been thought of as an important ad- emission, renewable electricity, which reduces or avoids its ditional incentive, often necessary to turn an uneconomical indirect emissions from purchased electricity.8 Another way to project into a viable one. Recently, questions have arisen as to express the benefit is as a reduction in the organization’s carbon whether RECs are truly an integral component of project eco- footprint.9 EPA guidance and existing voluntary corporate nomics. For project developers, RECs represent an additional GHG accounting rules support these claims.10 revenue source: a wind farm, for instance, will produce two 5 Electricity without its environmental attributes is commonly called null power, which conveys no contractual rights or claims. See: Environmental Tracking Network of North America, The Intersection between Carbon, RECs, and Tracking: Accounting and Tracking the Carbon Attributes of Renewable Energy, February 2010, http:// etnna.org/images/PDFs/Intersection%20btwn%20Carbon%20RECs%20and%20Tracking.pdf. 6 For more information about RECs and other green power product options, see: U.S. Environmental Protection Agency, U.S. Department of Energy, World Resources Institute, and Center for Resource Solutions, Guide to Purchasing Green Power, http://www.epa.gov/greenpower/documents/purchasing_guide_for_web.pdf. 7 According to Bird, et al. (2009, p. 3), retail sales of renewable energy in voluntary purchase markets exceeded 24 billion kWh in 2008, or about 0.6 percent of total U.S. electricity sales. This includes sales of renewable energy derived from both “new” and “existing” renewable energy sources, consistent with the generally accepted market definition with most sales supplied from new sources. 8 Indirect emissions come from sources that an organization does not own but that are associated with its activities. This is distinguished from reducing direct emissions that result in reducing global or total atmospheric emissions. See Table 1. 9 Some GHG voluntary reporting programs use the terminology of “using zero-emission electricity” rather than “reducing or avoiding indirect emissions.” Either way, both result in adjustments to the purchasing organization’s scope 2 emissions. 10 These claims are supported by the World Resources Institute and World Business Council for Sustainable Development (Greenhouse Gas Protocol: A Corporate Ac- counting and Reporting Standard [Revised Edition], p. 61, http://www.ghgprotocol.org/standards/corporate-standard), as well as EPA’s voluntary GHG reporting and goal-setting guidance and the U.S. Council on Environmental Quality (Federal Greenhouse Gas Accounting and Reporting Guidance, http://www.whitehouse.gov/sites/ default/files/microsites/ceq/ GHG%20Guidance%20Document_0.pdf). The Climate Registry (http://www.theclimateregistry.org/downloads/ 2010/08/Draft-Cli- mate-Registered-Leadership-Program-Reporting-Requirements.pdf) has a draft policy for its Climate Registered Leadership program that is also consistent with these claims, but it has not been finalized at this time. 2 October 2010
  • 3. EPA’s Green Power Partnership: The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily Discussion Draft Most leading organizations and businesses that are tracking the actions to reduce them. According to accounting rules, the same GHG emissions associated with their operations are doing so emissions may be claimed by more than one entity as long as the through established voluntary GHG reporting programs. While emissions are claimed in different scopes. Double counting of accounting methodologies might vary slightly, most programs emissions would occur only if more than one entity claimed the follow the framework provided by the internationally accepted same emissions in the same scope. World Resources Institute and World Business Council for Voluntary RECs might be confused with voluntary carbon Sustainable Development Greenhouse Gas Protocol Corporate offsets.12 RECs are not offsets. The differences between the two Standard. According to this standard, when reporting emis- environmental instruments prevent them from being used inter- sions to a GHG inventory, organizations classify emissions into changeably,13 though both may be useful in achieving organiza- three scopes, as shown in the first two columns of Table 1. The tions’ net GHG reduction goals. remainder of Table 1 is EPA’s interpretation of how these scopes may be used. The purchase of RECs or green power is reflected as an adjust- ment to scope 2 emissions. Scope 2 accounts for the GHG This classification recognizes that emissions (and emission emissions from the mix of regional generation resources used reductions) are rarely the responsibility of just one entity’s opera- to generate the MWh of purchased electricity. The adjustment tions. The different scopes enable all of the entities involved to methodology depends on the specific GHG voluntary reporting report the emissions associated with their operations and to take program. In EPA’s voluntary GHG reporting and goal-setting Table 1. Scopes for Corporate GHG Accounting and EPA’s Interpretation of Their Use Applicability Allowable Scope Description Reduction Claims RECs Offset Emissions from sources that the organization Total GHG emission owns or controls, such as industrial processes, Scope 1 (Direct Emissions) No Yes reductions; direct natural gas consumption in buildings, owned emission reductions vehicles, and owned energy generators11 Emissions associated with the generation of Carbon footprint Scope 2 (Indirect electricity, steam, or heat—from sources that the Yes Yes reductions; indirect Emissions) organization does not own—that is purchased emission reductions and consumed by the organization Emissions from other sources the organization Carbon footprint Scope 3 (Other Indirect does not own or control; examples include waste No Yes reductions; indirect Emissions) disposal, leased/outsourced activities, business emission reductions travel, and employee commuting 11 On-site generators owned by the reporting entity should report direct emissions in scope 1. The owners of such on-site generators that displace purchased electricity should also report the emission reductions as an adjustment to scope 2 emissions. 12 A GHG or “carbon” offset is a unit of carbon dioxide-equivalent (CO2e) that is reduced, avoided, or sequestered to compensate for emissions occurring elsewhere. Goodward, Jenna, and Alexia Kelly, Bottom Line on Offsets, World Resources Institute, August 2010, http://www.wri.org/publication/bottom-line-offsets. Offsets are generated by investing in projects that result in verifiable emission reductions or in removing GHGs from the atmosphere. U.S. Environmental Protection Agency, Climate Leaders Greenhouse Gas Inventory Protocol Design Principles, 2005, p. 45, http://www.epa.gov/climateleaders/documents/resources/design-principles.pdf. 13 Direct emission reductions resulting from voluntary REC purchases are typically realized at conventional power generation facilities owned by entities other than the REC owner or generator. However, REC purchasers do not have clear title to direct emission reductions because green power or REC contracts typically do not include conventional power generation facilities displaced by renewable energy generators as a third party to the agreement. As a result, the role of RECs in reducing an organization’s GHGs is limited to indirect emissions (i.e., scope 2). U.S. Environmental Protection Agency, Climate Leaders Greenhouse Gas Inventory Protocol Optional Modules Methodology for Green Power and Renewable Energy Certificates, 2008, p. 4, http://www.epa.gov/climateleaders/documents/greenpower_guidance.pdf. 3 October 2010
  • 4. EPA’s Green Power Partnership: The Environmental Value of Purchasing Renewable Energy Certificates Voluntarily Discussion Draft guidance, an organization purchasing RECs calculates its net Conclusion emissions by estimating the avoided emissions associated with Voluntary RECs offer critical environmental value because its green power purchase14 using regional marginal emission they capture and enable the trade of the specific environmental factors, which is advised by most GHG registries when facility- benefits associated with renewable energy generation. RECs specific emission information is not available.15 create an accessible and more efficient national voluntary market It is worth emphasizing that using RECs to adjust scope 2 emis- for renewable energy and provide an additional revenue stream sion levels is consistent with, not an exception to, general scope for renewable energy project developers. Deploying renewable 2 accounting rules. Scope 2 was specifically designed to recog- sources of energy is critical for reducing our nation’s carbon nize the importance of demand-side actions in reducing electric- emissions. The voluntary purchase of RECs allows businesses ity sector emissions (as well as emissions related to purchased or and individuals to help grow U.S. renewable energy capacity in imported steam or heat). a way that is most cost-effective and efficient for the economy and offers a compelling, verifiable, and transparent way for an The enactment of climate regulations might necessitate changes organization to meet its environmental goals. to voluntary REC definitions and to corporate GHG account- ing rules, but any changes would depend on the details of the EPA supports organizations purchasing RECs that meet the specific regulations adopted. EPA and other experts agree that it Green Power Partnership eligibility criteria16 and encourages will still be valuable for organizations to take actions to reduce them to use their purchases to adjust their indirect GHG emis- the emissions associated with their purchased electricity, and it sions and to claim a smaller carbon footprint. is possible that voluntary RECs would continue to offer organi- zations a means to reduce their carbon footprint over and above a regulatory baseline. 14 To learn how emission reduction claims are quantified, see Greenhouse Gas Protocol Initiative, Indirect CO2 Emissions from the Consumption of Purchased Electricity, Heat, and/or Steam: Guide to Calculation Worksheets (v. 1.2), January 2007, http://www.ghgprotocol.org/calculation-tools/downloads/ downloads- registration?referred_from=/downloads/ calcs/ElectricityHeatSteamPurchase_guidance1.2.pdf/; and U.S. Environmental Protection Agency, Climate Leaders Green- house Gas Inventory Protocol Optional Modules Methodology for Green Power and Renewable Energy Certificates. 2008. http://www.epa.gov/climateleaders/documents/ greenpower_guidance.pdf. 15 U.S. Environmental Protection Agency, 2008, p. 4. 16 For more information, see: U.S. Environmental Protection Agency, EPA’s Green Power Partnership’s Partnership Requirements, May 2010, http://www.epa.gov/green- power/documents/gpp_partnership_reqs.pdf. 4 October 2010