We're coming down to the final wire on the Green-eT-RECs standard.  Below is 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.  My 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 standard whereby a marketer can market the same product across the states, staff has proposed certifying generators per region.  These generators would be certified according to that region's standard.  The T-RECS could then be marketed anywhere.  Some folks want to control not only the generators that are certified, but the products that are sold in their region.  Thus the option for the highest common denominator (choice #2).  I think we need to go with the most administratively simple method that will promote the most liquidity.  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 
713-303-2632 cell 
stacey.bolton@enron.com <mailto:stacey.bolton@enron.com>
 

 -----Original Message-----
From: 	"Meredith Wingate" <mwingate@resource-solutions.org>@ENRON  
Sent:	Tuesday, November 06, 2001 4:34 PM
To:	Anne Marie McShea; Barbara Atkinson \(LBNL\); Brenna Herpmann; Brent Beerley; Jeff Schmidt; Kevin Porter; Liz Robinson; Maureen Mulligan; Mark Crowdis; Matt Deluca; Peter Adels; Rich Travaglini; Roger Clark; Sam Swanson; Serpil Guran; Stacey Bolton; Maryanne Daniel
Cc:	Dan Lieberman; Andrew Altman; Kirk Brown
Subject:	Generator based sourcing standards


Folks, 
As you know, at our last meeting, I promised to circulate the different  options we discussed on generator -based sourcing standards.  
 
The  problem we are trying to solve is this:  We'd like to develop a national  definition for "eligible" renewables  for certification of   T-RECs products under Green-e.  The problem is that if we did a  highest common denominator standard, some renewables, namely biomass would be  excluded.  We feel that this would be a somewhat arbitrary exclusion  because biomass has been excluded from some regional standards because of  specific regional circumstances and that it would not be fair to penalize the  entire biomass industry by eliminating it from the T-RECs - Green-e  market.
 
So  staff have proposed a generator based sourcing standard.  Eligibility would 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 allowed 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 eligible, (e.g. you could sell forestry-derived  biomass generated in New England into the PA market - the generator would  meet the new England definition for eligible and therefore would be able to sell  that power anywhere.)
 
We discussed a couple of different  options for handling this dilemma.  Here are a few of the major pros an  cons.   
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; 
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 eligible
 
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 pricing standards. A highest common  denominator standard would include solar, wind, digester gas, and possibly LIHI  hydro, geothermal landfill methane with some NOx limits.  I say  "possibly" because these things aren't included in green  pricing eligibility criteria but we think we might be able to 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-RECs
 
3.       Don't change electricity  standard but develop a new national definition for what T-RECs are "eligible"  (this would not necessarily be a highest common denominator standard, but more  of a "generally accepted renewable" standard)
Pros: Doesn't change electricity standard; makes it clear for consumers  what's in a Green-e certified product
Cons: potentially inconsistent standard b/t electricity products  and T-RECs products; could undermine regional standards if something is  approved as eligible for T-RECs but it is not eligible for  electricity.
 
4.       keep product standard  for both electricity and for T-RECs; require both electricity providers and  T-RECs providers to meet the regional  definitions.
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 standard b/t electricity products and T-RECs  products
Please send me your  feedback on these different options. We did have an option 5, but upon  reflection, it appeared to me to be the same as one of the other options.   if this isn't enough selection for you, feel free to add you own option too!
 
Thanks,
Meredith 
 
 
Meredith Wingate
Center for Resource Solutions
Presidio Building  49
PO Box 29512
San Francisco, CA  94134
415-561-2100
_________________________
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