This paper contains a survey of TRC issuing and tracking systems in the U.S., Europe and Australia. It provides recommendations for developing a network of TRC issuing bodies in the US and throughout North America.

This paper from the National Renewable Energy Laboratory (NREL), co-authored by Todd Jones and Orrin Cook from CRS, explores the policy and regulatory enabling environment for corporate sourcing of renewables. It was developed in support of the Corporate Sourcing of Renewables Campaign, which was launched at the Clean Energy Ministerial (CEM) meeting in June 2016. Through the campaign, a subset of CEM member governments collaborates with corporate and nongovernmental organization partners to facilitate increased corporate procurement of renewables and pursue supportive policies for corporate procurement.

Comments regarding preserving emission benefits of voluntary renewable energy (VRE) beyond 2020. The comments pertain specifically to continuing allocations to the VRE Reserve Account.

Comments regarding the Appendix G addition to the WREGIS Operating Rules specifically pertaining to issuance of TRECs and RECs.

Comments on Preliminary Scoping Questions for the February 21 Workshop on Updates to PSD Regulations.

CRS's comments focus on Section VII of the proposed rule, Generating RINs for Renewable Electricity—the proposal to include a pathway in the Renewable Fuel Standard (RFS) regulations that allows for Renewable Identification Number (RIN) generation for the use of renewable electricity generated from biogas as a transportation fuel.

Comments to the California Air Resources Board (ARB) regarding potential changes to how electricity used as a transportation fuel is treated in the ARB's Low Carbon Fuel Standard (LCFS) Program (pursuant to California Assembly Bill AB 32 and the Governor's Executive Order S-01-07). These comments pertain to the use of renewable electricity as a transportation fuel and the associated verification measures required to ensure exclusive use of renewable electricity. Specifically, these comments address topics and questions posed on slides 5 and 21 from the December 2, 2016 Workshop on Grid and Renewable Electricity and pages 4 and 13 of the November 23, 2016 Staff Discussion Paper.

This document focuses on Solarize Campaigns, a community solar option available to higher education institutions.

This document outlines best practices for developers marketing renewable energy products to customers, some of the risks and consequences associated with misleading marketing, and additional factors that solar developers need to consider when creating a marketing strategy and associated materials.

CRS's comments relate to Section "2.5.5 Environmental Value" of Staff's Report and Recommendations, and focus on the assignment of RECs from renewable energy distributed energy resource (DER) generation projects.

Comments on the California Public Utilities Commission (CPUC) Energy Division Staff's White Paper on Implementing GHG Planning Targets in the IRP Process. Comments are focused on Question for Parties no. 6, the methodologies for developing and reporting against GHG planning targets and the relevance of other methodologies/protocols developed for other state programs, and the treatment of voluntary renewable energy generation in GHG target reporting.

A fact sheet providing guidance on communicating the benefits of renewable energy purchases.

CRS comments regarding potential 2016 amendments to the California Cap-and-Trade Regulation discussed at the workshop held on October 21, 2016. Comments focus on post-2020 allowance allocation to Electrical Distribution Utilities (EDUs) and, in particular, on Staff's most recent proposal regarding the RPS Adjustment, included in the Post-2020 Electrical Distribution Utility Allocation Informal Proposal. Comments also provide a recommendation for how to administer the RPS Adjustment and avoid double counting with directly delivered renewable energy.

Comments to the U.S. EPA on the June 2016 Clean Energy Incentive Program (CEIP) Design Details ("CEIP Proposed Rule").

Comments in response to the 10 questions outlined in the RFI issued on September 23, 2016 on solutions to support the City of San Diego's Goal of 100% renewable energy.

Results and analysis of the 2015 reporting year for the Green‑e certification program. Green‐e Energy certified retail sales reached over 44 million megawatt‐hours (MWh) in 2015, the highest number of certified retail MWh in Green-e history and equivalent to over 1.2% of the total U.S. electricity mix.

This report examines the solar purchasing options available to higher education institutions, and the fundamental components of each deal that affect renewable energy certificate (REC) ownership, claims, and the environmental value of solar investments.

Comments on the New York State Energy Research and Development Authority's (NYSERDA's) petition requesting clarification regarding the status of attributes associated with NY-Sun and other Customer-Sited Tier (CST) projects in light of the Clean Energy Standard (CES) Order's filing requirements requesting NYSERDA to publish the number of Renewable Energy Credits (RECs) that will be available for sale for the 2017 compliance period by December 1, 2016.

Comments focusing on future allocations to the Voluntary Renewable Electricity (VRE) Reserve Account and the proposal to remove the requirement that Renewable Energy Credit (REC) serial numbers be reported with specified renewable energy (RE) imports.

A handout given out at the 2016 Solar Power International conference that offers guidance for developers marketing community solar programs to retail customers, including best practices, example marketing statements, and case studies.

An exploration of how mass-based states under the EPA's Clean Power Plan can avoid damaging the voluntary market for renewable energy through careful plan design that ensures the impact of voluntary demand for and private investment in renewable energy.

This report describes renewable energy certificates (RECs), why they are important, and what kinds of statements can be made depending on who owns them.

Comments submitted in response to the Request for Information issued on the SunShot Initiative's proposed Community Solar Challenge. Comments focus on the importance of accurate claims and Renewable Energy Certificate (REC) ownership in community solar projects and the benefits of Green-e certification.

CRS applauds the state of Washington for proposing such a comprehensive system for reducing greenhouse gas (GHG) emissions, and comments on the Clean Air Rule (CAR) draft proposal. Comments are focused on potential interactions with existing renewable energy (RE) markets and market instruments.

Comments to the California Energy Commission on the Additional 15-Day Language for Power Source Disclosure (PSD) Program Implementation Rulemaking ("June 2016 Additional 15-Day Language"), released for public comment on June 16, 2016.

Comments on the Maryland Public Service Commission's (PSC's) Proposed Action 16-104-P to adopt new regulations under Subtitle 62 Community Solar Energy Generation Systems (CSEGS), as described in the Maryland Register, Volume 43, Issue 9, Friday, April 29, 2016. Comments focus on Renewable Energy Credit (REC) ownership under the Pilot Program and consumer protection requirements for the Pilot Program.

Comments submitted in response to the April 6, 2016 Proposed Rulemaking I.D. No. PSC-14-16-00008-P Resetting Retail Markets for ESCO Mass Market Customers. Comments focus on providing information about the function and value of carbon offset natural gas programs offered by retail natural gas providers, and the benefits of Green-e certification.

Comments on the topics to be covered at the workshop focusing specifically on the consumer protection issues to be covered. Also a selection of materials developed by CRS to educate and inform solar consumers, suppliers, and other interested parties. And short responses to certain questions included in the Workshop Notice related to consumer protection.

CRS comments as part of the April 29, 2016 RGGI Stakeholder Meeting and 2016 Program Review. Comments focus on incorporating a mechanism for voluntary retirement of RGGI Allowances as a program design element and new functionality in the RGGI CO2 Allowance Tracking System (COATS).

"Making credible renewable electricity usage claims" from RE100 is a technical deep-dive into corporate transparency and credibility, and shows companies how to accurately describe their use of renewable electricity. It is authored by members of the RE100 Technical Advisory Group, which provides RE100 companies with best practice guidance on the use of renewable power, to help them progress their journeys to being 100% powered by renewable electricity.

This document summarizes information presented in a letter from CRS to California Assembly Member Phil Ting dated August 18, 2015 regarding AB 1110.

A fact sheet that explains the role of additionality in understanding the value of renewable energy certificate (REC) claims.

A fact sheet explaining the impacts and benefits of buying renewable energy through renewable energy certificates (RECs).

Information on the Green-e Energy Federal Option Product type, which allows certified sales to federal departments and agencies under Executive Order 13693.

Results and analysis of the 2014 reporting year for the Green-e certification program.

The U.S. Environmental Protection Agency (EPA) released the final Clean Power Plan (CPP) on August 3, 2015. In Part 2 of Renewable Energy in the EPA Clean Power Plan, we explore how the creation and trading of Emission Rate Credits (ERCs) may affect renewable energy certificate markets.

The U.S. Environmental Protection Agency (EPA) released the final Clean Power Plan (CPP) on August 3, 2015. In Part 1 of Renewable Energy in the EPA Clean Power Plan, we explain what the CPP says about Emission Rate Credits (ERCs).

A graphical illustration of the importance of renewable energy certificates to substantiating solar claims. Developed as a poster displayed at the 2015 Solar Power International conference.

Letter to CA Assembly Member Ting on Assembly Bill #1110.

CRS comments on the April 2015 Exposure Draft Standards for Public Comment for Consumption II sectors, including Apparel, Accessories & Footwear; Appliance Manufacturing; Building Products & Furnishings; Toys & Sporting Goods; Food Retailers & Distributors; Drug Retailers & Convenience Stores; Multiline and Specialty Retailers & Distributors; and E-commerce

CRS comments strongly support the Sustainability Tracking, Assessment & Rating System (STARS), and particularly the inclusion of criteria and points for measuring and reducing GHG emissions; generating, using, and/or purchasing clean and renewable energy; sustainable purchasing, and referencing Green-e.

This document is intended as a guide to resources that can help participants advise their customers on defensible carbon claims and comply with Green-e marketing compliance rules.

There is a strong legal basis for the use of renewable energy certificates (RECs) as instruments that represent the attributes of renewable electricity generation and are used to demonstrate renewable electricity purchasing, delivery, and use within the broader context of functioning voluntary and compliance renewable electricity markets. This document provides a summary of different selected sources on the definition and function of RECs in the U.S. Originally published January 31, 2014. Updated June 17, 2015.

CRS comments on the Power Source Disclosure (PSD) Program Pre-Rulemaking Draft Regulations, released by the California Energy Commission for public comment on May 14, 2015.

Comments on definitions, concepts in the National Green Building Standard.

CRS comments on the January 2015 Sustainability Accounting Standards Board (SASB) Exposure Draft Standards for Public Comment for Consumption I sectors, including Agricultural Products, Processed Foods, Non‐Alcoholic Beverages, Alcoholic Beverages, Household & Personal Care Products, and Meat, Poultry, and Dairy.

A description of how ownership of renewable energy attributes remains with the renewable energy certificate, and examples of claims issues between hosts, utilities, and owners.

CRS responds to the January 2015 U.S. Department of Energy Office of Energy Efficiency and Renewable Energy (EERE) RFI for the Definition of Zero Energy Buildings and the Public Comment Period Draft of the "A Common Definition for Zero Energy Buildings" report prepared by the National Institute of Building Sciences

In this paper, CRS and the Regulatory Assistance Project have collaborated to describe how the existing functionality of the regional renewable energy tracking systems can be used by states to track renewable energy and support compliance with the EPA Clean Power Plan, as well as to identify enhancements that may be needed to support state policy and reporting requirements.

In this paper, CRS and the Regulatory Assistance Project have collaborated to help readers to understand some of the ways in which states are using renewable energy today, and appreciate how existing renewable energy compliance practices provide well-established and suitable approaches for regulators to use as part of their efforts to demonstrate compliance under the EPA's Clean Power Plan.

This committee can put forth solutions that will make implementation of a regional or federal economy-wide cap more achievable by helping to meet greenhouse gas (GHG) reductions targets in each sector. Complementary policies can also produce low-cost reductions that cap-and-trade alone would miss. Therefore, a robust set of complementary policies in addition to cap-and-trade alone will be the most cost effective approach.

Comments in support of the proposed revisions clarifying that bundled or unbundled RECs must be used under all three methods for complying with the RPS and must be retired once they are claimed for compliance.

Guidance for accounting and reporting of renewable electricity in North America under the World Resources Institute's Corporate Accounting and Reporting Standard for reporting of Scope 2 greenhouse gas emissions.

CRS expresses support for several requirements proposed in the SNOPR, responds to DOE concerns, and responds to certain specific requests for comment. Specifically: RECs are required for any renewable electricity usage claim, Off‐site renewable electricity usage and low‐cost options should be available to federal agencies, concerns with federal agencies' lack of control over off‐site renewable energy and generation at facilities generating unbundled RECs, concerns with the additionality of off‐site renewable energy and generation of unbundled RECs, concerns on the impact of purchasing off‐site renewable energy and unbundled RECs with respect to reductions in fossil fuel generation, and concerns with tracking and accounting of RECs.

Comments by CRS on Oregon's HB 4126 - Voluntary Renewable Energy Tariff (VRET) proposal.

A graphic 1-page description of the Green-e Direct option.

In 2013 Green-e Energy certified retail sales of 33.5 million megawatt-hours (MWh), enough to power over a quarter of U.S. households for a month, or 1% of the total U.S. electricity mix. Over half of the installed wind capacity in the U.S. is participating in Green-e Energy certified transactions.

This document provides an overview of best practices and options for purchasing and using renewable electricity globally, as well as guidance for clear and accurate communication of renewable electricity claims within the context of national or regional renewable electricity markets.

CRS comments on the June 2014 Proposed Rule Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (the Clean Power Plan "Proposed Rule"). The comments focus on integrating renewable energy (RE) and existing RE markets, instruments, and tracking systems into 111(d) compliance and state plans; accounting and potential double counting of emissions and reductions; interstate tracking of electricity and challenges for state compliance; tracking RE and avoided emissions; and verification, monitoring, enforcement and recordkeeping for RE.

An illustration of how renewable energy certificates (RECs) work to track ownership, best practices for using and claiming RECs, and a series of example claims for solar panel owners or leaseholders.

In 2010, reports of boiler rooms operating in carbon markets and selling emissions reduction credits (carbon offsets) as investments began to emerge out of the U.K. In 2013, CRS began work examining what investor protections are needed in carbon markets, particularly in voluntary OTC markets, and what practices market participants could adopt to regulate carbon investments and enhance protection against deceptive sales tactics. This report summarizes our recommendations, which are aimed at increasing consumer and investor protection, with broader climate policy and market-stability benefits.

Existing renewable energy certificate (REC) tracking systems hold promise as an enabler of 111(d) compliance with renewable resources such as solar and wind generation. REC tracking systems, together with state policies designed to increase the production and use of renewable electricity, will provide one key to helping states reduce the carbon intensity of their power sector.

This document is intended to articulate Green-e Energy's standard approach to resolving questions and disputes regarding the eligibility of RECs for use in Green-e Energy certified transactions or products, when multiple parties have made statements related to the environmental attributes of the REC or underlying electricity.

CRS suggests changes to the proposed revision that will reduce the potential for double counting, including rejecting Track and Monitor and Track and Record, purchasing least cost RECs or kWh, creation of a maximum conventional energy requirement, the option of mandatory upfront incentives, and others

As environmental commodities, renewable energy certificates (RECs) may expose their owners and traders to potentially conflicting obligations and regulations from state and federal agencies. This article in the February, 2014 issue of the ABA's Renewable, Alternative, and Distributed Energy Resources Committee Newsletter looks at claims and marketing issues with RECs after the revised FTC Green Guides were released in October, 2012.

CRS provides comments to the Minnesota PUC on the "Notice of Comment Period on Commission Inquiry...In the Matter of Commission Inquiry Into Ownership of RECs Used to Meet Minnesota Requirements" These comments also provided a brief summary of the value of RECs in the voluntary market for renewable energy in Minnesota.

CRS comments in support of the Washington Department of Commerce's proposed addition to the Energy Independence Act (WAC 194-37-120) requiring the retirement of RECs in WREGIS, especially when they are used to comply with the Washington State renewable energy standard.

CRS submitted comments on the Draft Standards for the Technology & Communication Sector that recommended that renewable energy certificates be retained for all claims to the use of renewable energy. CRS also supports the inclusion of emissions from purchased electricity use (scope 2 emissions) to the proposed disclosure language and guidance in all applicable SASB standards.

A look back at the year's accomplishments for Center for Resource Solutions and its programs.

On April 9, 2012 the Green-e Governance Board approved changes to the Green-e Energy National Standard that modified the then-existing language defining the eligibility of biomass as a renewable fuel source under the Standard. The new language clarified the circumstances under which organic matter can be used for electricity generation and considered eligible for inclusion in a Green-e Energy certified renewable energy product. This document explains the changes and process.

In 2012 Green-e showed another year of impressive growth, with a remarkable 29% increase in Green-e Energy certified sales in 2012, reaching almost 36 million MWh. This is enough to power nearly a third of U.S. households for a month. Green‐e now certifies over 1% of the total U.S. electricity mix and approximately three‐quarters of the total voluntary market.

CRS submitted comments to the California Air Resources Board (CARB) regarding proposed changes to the California cap-and-trade program, as contained in a July 2013 Discussion Draft and presented at the July 18, 2012 Public Workshop.

This letter urges the Commission to reject Staff's proposal of "Track and Monitor" because of the impact on Arizona renewable energy generators and customers, and because it violates the requirements of the REST while raising issues with double counting.

CRS submitted comments to the Association of Climate Change Officers (ACCO) in response to their call for input on their Core Competencies for Climate Change Officers and Professionals.

CRS commented on the proposed revisions to the Energy Information Administration's (EIA) data collection practices, reiterating the need for continued data collection and the continued relevance of the data, as the EIA data collected on utility green electricity programs and renewable electricity is one of the few sources of hard information that can be used to demonstrate the growth and availability of such programs for American consumers.

In this paper RAP and CRS assess the suitability for tracking CO2 emissions associated with electricity imported into the RGGI region of two energy attribute tracking systems currently in use in the RGGI region.

Comments on a California Energy Commission (CEC) paper for the implementation of Assembly Bill 2196 for the California Renewable Portfolio Standard

The report highlights Green-e Certified renewable energy and carbon offset sales in 2011, as well as organizations that participated in Green-e Marketplace to demonstrate their commitment to renewable energy.

Comments of Environmental Defense Fund, The Nature Conservancy, and the Center for Resource Solutions on the proposal to link California's cap-and-trade program with Quebec's program

CRS submitted comments on the proposed changes to the GRP 2.0.

CRS submitted a comment letter to the Arizona Corporation Commission regarding the proposed Track and Record option for utilities to use kilowatt-hours (kWh) from interconnected distributed generation (DG) for compliance with Arizona's Renewable Energy Standard and Tariff (REST), instead of using Renewable Energy Certificates (RECs).

A brief description of the requirements and benefits of Green-e Energy.

A review of the highlights of the Green-e program in 2011. The brief shows 21% growth from the previous year, including 39 Million MWh in total certified transactions; 50 organizations and over 500 products participating in Green-e Marketplace; and certified sales growth by nearly 9% in Green-e Climate

CRS, along with 62 other partner organizations, submitted this joint comment letter to the Federal Housing and Finance Agency (FHFA) in support of local government Property Assessed Clean Energy (PACE) programs.

A review of CRS activities and programs through 2011.

CRS submitted comments to ICLEI-Local Governments for Sustainability on revisions to its Community Protocol, the national standard for community-scale reporting of greenhouse gas emissions.

CRS, along with its partners Environmental Defense Fund, Natural Resources Defense Council, and The Nature Conservancy, submitted comments to the California Air Resources Board (CARB) regarding proposed amendments to California's Cap-and-Trade Regulation to allow for the use of compliance instruments issued by linked jurisdictions.

CRS submitted comments to the California Air Resources Board (CARB) regarding potential regulatory changes to the Regulation for the Mandatory Reporting of Greenhouse Gas Emissions, or Mandatory Reporting Regulation (MRR) (title 17, California Code of Regulations, sections 95100-95157).

CRS submitted comments to the Council on Environmental Quality regarding the DRAFT Federal Greenhouse Gas Accounting and Reporting Guidance. All CRS comments pertain to Section 4.0 of the DRAFT Federal Greenhouse Gas Accounting and Reporting Guidance, "Renewable Energy and Carbon Offsets" (pg. 24-31).

CRS submitted comments to the USGBC on the proposed LEED 2012 Rating System Drafts regarding carbon offsets and RECs.

CRS submitted comments on the proposed changes to the GRP 2.0.

The report highlights Green-e Certified renewable energy and carbon offset sales in 2010, as well as organizations that participated in Green-e Marketplace to demonstrate their commitment to renewable energy. The report shows a 23% increase in total Green-e Energy retail sales volume over the previous year, equivalent to over 23 million MWh of renewable energy generation purchased by over 583,000 residential and 66,000 commercial customers in 2010. This represented over 65% of all retail renewable energy sales in the voluntary market in 2010.

2010 Annual Report

The Oregon Department of Energy arranged for WREGIS to create RECs retroactively for stranded electricity. Under this arrangement, all RECs created through this process must be exclusively used for Oregon RPS compliance. The Center for Resource Solutions was contracted to complete a review of the stranded generation RECs against voluntary market transactions. This report summarizes the results of this review.

The Verified Carbon Standard (VCS) Program is a standard and framework for GHG emission reductions and removals. It is also a Green-e Climate Endorsed Program. On 1 September 2011, VCS released for public consultation draft requirements for standardized approaches for baselines and additionality. CRS submitted comments in general support of the VCSA's decision to move forward with standardized approaches, requesting clarification on several aspects of the new proposed requirements, and making several suggestions for improvement and clarification.

In these comments, CRS recommends removal or clarification of the tenets proposed on page 14 of the Administrative Law Judge's Proposed Decision Implementing Portfolio Content Categories ("Proposed Decision") for the Renewables Portfolio Standard Program ("RPS") pursuant to Pub. Util. Code §399.16 (2011), "What you buy is what you have." and "What you have is what you retire for RPS compliance," for the process of determining compliance with the portfolio content categories. To refer to these simplified rules of thumb as "tenets" may cause confusion in the event that the proposed tenets conflict with California Energy Commission ("CEC") findings during RPS compliance verification. CRS requests that the California Public Utilities Commission either remove the tenets completely, or at a minimum, rename the tenets "rough guidelines," "considerations" or "rules of thumb" to clarify that the CEC verification and Commission compliance determination supersede the tenets, and that the tenets create no guarantee of RPS eligibility.

CRS submitted comments to the Washington Utilities and Transportation Commmission with regard to Puget Sound Energy's (PSE) petition to bifurcate the apprentice labor multiplier from the Renewable Energy Credit (REC). CRS believes this bifurcation would directly result in the double counting of renewable energy attributes if the REC were sold into the voluntary market, or to meet another state's RPS, and the multiplier was claimed by a utility in Washington using it for RPS compliance.

Comments on the second 15-day amendments to the California Cap on Greenhouse Gas (GHG) Emissions and Market-Based Compliance Mechanisms proposed regulations.

A coalition letter supporting the California Air Resource Board's (CARB) inclusion of a set aside for the voluntary renewable electricity (VRE) market. Comments regarding the following issues: eligibility of renewable energy generators by online date, clarification regarding the use of tracking systems, and how to "true up" allowances to account for oversubscription.

General Comments in support of the LEED 2012 Rating System Drafts, including the inclusion of criteria and points for green power and carbon offset purchasing in the LEED Standards, and LEED's citation and reference to the Green-e Standards for renewable energy (Green-e Energy) and carbon offsets (Green-e Climate). Also suggested changes to help bolster and clarify the credits for Green Power and Carbon Offsets, Renewable Energy Production, and Green Energy Production and Utilization.

Suggestions for changes to be made to language under GIB Credit: On-site Renewable Energy Sources and the subheading "ND Plan, ND"

CRS applauds Quebec for proposing such a comprehensive system for reducing greenhouse gas emissions, and urges you to adopt a Voluntary Renewable Energy (VRE) set aside as enabled under Western Climate Initiative rules.

Comments to the draft standard as part of the WindMade public consultation process. We support the inclusion of a definition of "green credentials" and requiring a unique ID number; and we suggest adding additional information regarding the allowable claims and condoned uses of the label, keeping a clear distinction between renewable energy and carbon offsets derived from renewable energy projects,

CRS respectfully offers these comments on issues nine and ten of the Administrative Law Judge's Ruling Requesting Comments on the Implementation of the New Portfolio Content Categories for the RPS Program. In these comments, CRS seeks to augment the record by bringing to the Commission's attention language in the RPS statute that requires renewable energy credits ("RECs") to include "all renewable and environmental attributes associated with the production of electricity from the eligible renewable energy resource." In particular, CRS requests that the Commission clarify the definition of RPS-eligible energy in issues nine and ten in order to remove any apparent inconsistency with section 399.12(h).

Center for Resource Solutions (CRS) submitted comments to the California Air Resources Board (ARB) on the proposed 15-day modifications to the California Cap on Greenhouse Gas (GHG) Emissions and Market-Based Compliance Mechanisms. The comments focused on the following topics: Accounting for Null Power Imports and Voluntary Renewable Electricity.

The intent of these comments is to introduce CRS as an interested party, to describe the services that we provide for the voluntary over-the-counter ("OTC") market for environmental commodities through our Green-e Energy and Green-e Climate certification and consumer-protection programs, and to provide comments on the Joint Notice of Proposed Rulemaking Request ("JNOPR") for comments on further definition of "SWAP" pursuant to Section 721 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Specifically, in response to question 32 on page 29832 of Federal Register/Volume 76 No. 99, we believe that environmental commodities such as renewable energy certificates ("RECs") and carbon offsets ("offsets") are nonfinancial commodities that qualify under the forward contract exclusion from the swap definition.

Comments from the Center for Resource Solutions on the U.S. Senate Committee on Energy and Natural Resources Clean Energy Standard (CES) White Paper.

CRS believes Washington State's HB 1712 could negatively impact the clean energy industry because as currently written the inclusion of null power in the definition of renewable resource and the ambiguous nature of the definition of null power constitutes a potential double claim of renewable energy attributes. Generation owners in Washington whose null power was defined elsewhere as renewable would become ineligible to sell their RECs into a Green-e Energy certified product.

CRS believes Washington State's S.1506.1 could negatively impact the clean energy industry because if RECs are no longer used as a declared resource for electric utility fuel mix disclosures, generation owners in Washington whose null power is represented as renewable for utility fuel mix disclosures would become ineligible to sell their RECs into a Green-e Energy certified product.

The intent of these comments is to introduce CRS as an interested party; to describe the services that we provide for the voluntary over‐the‐counter (OTC) carbon offset market through our Green‐e Climate certification and consumer‐protection program; to briefly explain our position that the current structure and existing oversight mechanisms in the voluntary carbon offset market are, at this stage, appropriate and adequate to ensure protection of market participants and the public; and finally to offer ourselves and our organization as a valuable resource for the interagency working group and its member agencies in matters regarding carbon and other environmental commodity markets.

CRS wrote a letter to California Air Resources Board (CARB) Chairwoman Nichols and the Board expressing support for the inclusion of a voluntary renewable energy set aside in AB 32, and our remaining concerns about the Western Climate Initiative recommendation that renewable energy certificates (RECs) have no role in mandatory GHG reporting and compliance protocols. We reiterated why we think this is a misguided approach.

A joint letter from CRS, clean energy businesses, organizations, and environmental groups write to you in support of including a provision in the Cap and Trade Regulation to establish a Voluntary Renewable Energy Set-Aside.

Comments submitted on the Federal Trade Commission (FTC)'s proposed update to its Guides for the Use of Environmental Marketing Claims ("Green Guides"). Overall, we are very supportive of the proposed update and find that it reinforces many of the consumer-protection practices required by Green-e certification, but there are a few areas where we suggest further consideration and clarification.

Summary of comments on the Federal Trade Commission (FTC)'s recently released proposed update to its Guides for the Use of Environmental Marketing Claims ("Green Guides"). CRS will be submitting comments, and we have developed a summary of the key points we will be making to the Commission. Overall, we are very supportive of the proposed update and find that it reinforces many of the consumer-protection practices required by Green-e certification, but there are a few areas where we suggest further consideration and clarification.

The report highlights Green-e Certified renewable energy and carbon offset sales in 2009, as well as organizations that participated in Green-e Marketplace to demonstrate their commitment to renewable energy. The report shows a 43% increase in total Green-e Energy sales volume over the previous year, with over 18 Million MWh purchased by over 545,000 residential and 37,000 commercial customers in 2009. This represented over 60% of all retail renewable energy sales in the voluntary market in 2009.

Growth in the largely unregulated voluntary renewable energy market has highlighted the need for clear guidelines on what constitutes legitimate environmental claims. In order to evaluate green electricity claims, one must first determine what constitutes a claim. Some claims are explicit and easy to identify. Others, however, can be simply implied or even unintentional. This paper identifies some typical types of claims and provides guidance to renewable energy sellers on truthful advertising practices.

CRS submitted a comment letter to New Mexico's Environmental Improvement Board urging the adoption of a set aside to ensure that voluntary renewable energy purchases continue to reduce carbon dioxide emissions after their cap-and-trade program goes into effect.

The price of gasoline is a telling economic weathervane. When gas is cheap, it is not given much attention. When gas prices hit record highs, however, as in 2008, the downside of America's dependence on imported energy is made painfully obvious. This report analyzes how Assembly Bill (AB) 32, California's Global Warming Solutions Act, will help protect California's economy from energy price spikes by reducing California's dependence on imported oil and natural gas.

This report contains the activities and financial reporting documents for 2009.

This letter, addressed to Gary Collard at the California Air Resources Board in reference to the draft 33% RPS, details CRS's position that a REC is a property right, that CARB's recognition of these property rights inherent in RECs would not increase CARB's risk of a regulatory taking under the Fifth Amendment, and that declaring that RECs do not constitute property rights could irreparably harm existing REC markets.

This letter expresses CRS's view on off-the top as well as other allocation issues. We express our view that CARB's proposed approach to allowance distribution would be an unfortunate overreaction to emission leakage concerns, and resulting overcompensation of carbon emitters would represent a lost opportunity to bolster the emerging clean energy economy that can contribute badly needed new jobs.

CRS authored a letter to the California Air Resources Board on the issue of off-the-top treatment of voluntary renewable energy purchases and marshaled another coalition of nonprofit organizations and clean energy industry stakeholders to support the concept.

The Center for Resource Solutions urges the WCI Partners, the Electricity Committee and Markets Committee to reconsider and rescind the recently released recommendation that renewable energy certificates (RECs) have no role in mandatory GHG reporting and compliance protocols. If implemented, this recommendation would strip the zero-emission attribute from renewable energy certificates (RECs) and destabilize the system of trading renewable energy in the Western Electricity Coordinating Council region that has been in place for more than a decade.

This Green-e Marketplace Case Study on Codero, a webhost in Overland Park, KS, examines the company's environmental initiatives, including purchasing certified renewable energy for 100 percent of its electricity use.

Comments and recommendations submitted on the WCI's Market Design Committee's whitepaper by the WeCAN Markets and Cap Setting and Allowance Distribution Committees, pertaining to the disposition of unsold allowances and general auction design.

A policy brief that offers some discussion and comparison of three updated forecasts of the economic impact of California's global warming law, AB 32. The three studies are from the California Air Resources Board, Charles River Associates, and the University of California's Professor David Roland-Holst.

Comments focusing on several broad market issues in the development of an RES as described by the March 11, 2010, Preliminary Draft Regulation, and the presentations made during the March 18, 2010 workshop.

This Green-e Marketplace Case Study on Tom Arma Studios examines the studio's environmental actions, including how its purchase of renewable energy fits with its overall sustainability goals.

Revised Feb 1, 2011. This Guide to Purchasing Green Power is intended for organizations that are considering the merits of buying green power as well as those that have decided to buy it and want help doing so. The guide was written for a broad audience, including businesses, government agencies, universities, and all organizations wanting to diversify their energy supply and reduce the environmental impact of their electricity use.

Comments on WCI paper "Voluntary Renewable Energy Market: Issues and Draft Recommendations," express agreement with and support of the comments of the Western Climate Advocates Network and the Renewable Energy Markets Association, which are supportive of a VRE Set Aside. Three main comments: 1) We urge the Partners to adopt a uniform VRE Set Aside rule, 2) The final recommendations should recognize that the driver of the impressive VRE market growth has been large purchasers who have been motivated by the desire to show that they are making a difference in the effort to curb global warming, and 3) We suggest that you revise your discussion of the economic implications of a VRE set aside to more clearly recognize the benefits, especially the lowered demand for allowances due to fossil fuel‐based generation avoided due to VRE purchases resources.

CRS comments on VCS's proposed Maine State Housing Authority Methodology for Weatherization of Single and Multi-Family Buildings. CRS recognizes the value of energy efficiency measures as a vital means to reduce GHGs and mitigate the effects of climate change, and applauds the Maine State Housing Authority for taking the initiative to introduce such an important program. However, this methodology in its current form allows for double counting, and certain energy efficiency measures under the proposal will not result in any real reductions in GHG emissions due to the presence of a cap and trade on CO2 emissions in Maine. CRS recommends that the methodology be limited to only include emission reductions from efficiency measures outside of electricity consumption, such as measures that will result in reduced natural gas consumption for central heating.

Both carbon offsets and renewable energy certificates (RECs) are used as ways to reduce greenhouse gas (GHG) emissions. As these marketplaces grow, it is important to examine how they overlap and avoid any double counting of carbon benefits or claims. The paper, which CRS assisted in drafting, examines REC tracking systems, GHG project registries, and GHG inventory systems.

This is a one-page description of Green-e Energy.

WeCAN comment letter submitted to the WCI's Electricity Committee on its paper "Voluntary Renewable Energy Market: Issues and Draft Recommendations."

As markets for renewable energy grow, there is increasing interest in securing and selling Renewable Energy Certificates and renewable electricity. Some renewable electricity generation technologies, like solar photovoltaics, are slow to be widely adapted to market transactions because of the administrative costs of aggregating output into products that can be readily sold into compliance and voluntary electricity markets. This document presents a series of questions and answers regarding PV and the issues specific to selling and claiming RECs from such systems. Though the paper focuses mainly on PV, many of the issues discussed below pertain to other types of distributed generation as well.

A report of the California Economic and Technology Advancement Advisory Committee (ETAAC) Advanced Technology Sub-Group focusing on clean transportation, energy efficiency and renewable energy and updating selected sections of the February 2008 ETAAC report.

As California policymakers move to implement the state's Global Warming Solutions Act, Assembly Bill 32 (AB 32), there has been considerable controversy over the economic impacts of this landmark law to reduce global warming emissions. Multiple macroeconomic analyses have been conducted by a variety of economic modeling teams. But, to date, there has been no comparative analysis conducted of the assumptions or models used to produce these macroeconomic results. By providing an examination of the most prominent of these analyses, this report aims to provide context and transparency with respect to these modeling programs to better inform public discourse on the economic impacts of AB 32.

This is a one-page description of Green-e Marketplace.

This report contains the activities and financial reporting documents for 2008.

This CRS-led joint letter to the EAAC on economic analysis of the impacts of AB 32 recommended that EAAC issue a statement on economic modeling that communicates that: CARB results are consistent with other studies; CARB's analysis to date has met reasonable expectations given time constraints, limited resources, and the state of modeling science; peer review criticism of CARB's economic modeling has been misrepresented; consideration of co-benefits, required by law, is left out of the economic modeling; impacts should be modeled by income level, and modeling does not reflect the near certainty that innovation will lower costs.

The report highlights Green-e Certified renewable energy and carbon offset sales in 2008, as well as organizations that participated in Green-e Marketplace to demonstrate their commitment to renewable energy. The report shows a 45 percent increase in total Green-e Energy sales volume over the previous year, equivalent to over 13 million MWh of renewable energy generation. This represented over half of all retail renewable energy sales in the voluntary market in 2008.

Commercial entities and organizations are increasingly looking to reduce the environmental impacts they are responsible for. The potential of renewable energy as a practical and effective market solution to a number of societal issues has garnered support from social, political, and business communities. Commercial demand significantly influences the overall renewable energy market, as commercial purchasers have become the largest and fastest growing sector of the voluntary renewable energy market. Together with demand from state renewable portfolio standards, the increasing demand of the voluntary market is a clear driver for renewable energy in the United States. This report documents increasing renewable energy purchases by commercial customers and offers analysis of procurement trends, market drivers, and impacts.

WeCAN's Cap Setting and Allowance Distribution Committee is recommending the addition of a fourth set of principles to WCI's "Draft Statement of Principles," one that recommends against overcompensating parties that have perceived concerns with maintaining competitiveness by granting unjustified or free allocations. This practice could lead to windfall profits, opportunity costs in the form of lost investments to advance clean energy development, transitioning workers, and consumer protection.

ETNNA was asked by the WREGIS working group on inter-registry transfers to draft a white paper summarizing the status of the working group activities and identifying potential next steps (including the pros and cons of each), as well as preliminary recommendations. At the same time it has become apparent that Congress may pass a federal Renewable Energy Standard (RES) this year or next, in which case all the tracking systems/registries may need to develop compatible import/export protocols and a mechanism for implementing such protocols. As a result this white paper lays out a potential pilot project to test the feasibility of the structures and protocols required for a robust inter-registry transfer system. This pilot project could, in addition to meeting current inter-registry transfer needs, lay the groundwork for implementation of protocols necessary to implement a national RES program if such legislation is passed by Congress.

In 2009, Green‑e Marketplace conducted its second annual survey of program participants, to gain understanding of how certification and renewable energy fit into their overall corporate sustainability efforts.

The historic House passage of H.R. 2454, the American Clean Energy and Security Act (ACESA), was an important step toward a long-term clean energy policy, but unless certain modifications are made to the renewable electricity standard (RES) and cap-and-trade provisions of these bills, it could inadvertently undercut the thriving voluntary renewable energy market which serves to complement RES policies.

The historic House passage of H.R. 2454, the American Clean Energy and Security Act (ACESA), was an important step toward a long-term clean energy policy, but we have concerns that the design of a cap-and-trade program proposed under the ACESA bill could undercut the thriving voluntary renewable energy market. As the Senate Environment and Public Works Committee continues its work of developing federal climate legislation, we write to advocate for a different approach, one that doesn't discourage but instead encourages those not directly covered by cap-and-trade that wish to contribute to clean energy development in order to fight global warming.

A brief study of consumer attitudes prepared by Natural Marketing Institute and Center for Resource Solutions.

Western Climate Advocates Network response to WCI stakeholder discussion questions pertaining to addressing competitiveness concerns.

Comments of the Western Climate Advocates Network on the WCI's white paper on rewarding early action, the White Paper on Early Reduction Allowances (ERAs)

CRS is in agreement with and supports the comments calling for the set aside and retirement of allowances for voluntary renewable energy purchases (also known as an off-the-top approach to voluntary renewable energy purchases) submitted separately by the coalition of public interest nonprofit groups and renewable energy industry stakeholders.

We applaud the Air Resources Board (ARB) for changing its Scoping Plan to specifically recognize that voluntary renewable energy set-asides could contribute to California's climate goals by providing an incentive for voluntary purchases of renewable energy and additional reductions in the pollution responsible for global warming. This letter focuses on the topic of the use of set-asides to promote renewable energy.

Comments relating to the establishment of the cap in California's cap-and-trade program. We are troubled by CARB's proposal to set the cap in 2012 at the level of expected actual emissions, i.e. a level that achieves no reductions. The implication of setting the cap at expected actual emissions is that the price of allowances will be close to zero.

Climate policy in California has been at the forefront in the North American effort to fight global warming. California has been a leader in energy policy for decades. The paper explores the state's energy policy over the past few decades, as well as the economic, psychological, and institutional factors that support the emerging best practice. It describes climate change exernalities that are the basis for carbon pricing policies, such as carbon taxes or cap-and-trade, and explores some of the institutional challenges created by climate change policy. Also emission trading schemes such as cap-and-trade programs.

Without careful design, cap and trade could hinder the voluntary market for renewable energy. The voluntary market has played an important role in advancing clean energy development in large part because socially responsible organizations and individuals want to help fight global warming. Cap and trade should include an off-the-top rule to account for voluntary renewable energy purchases.

Letter commenting on issues relating to emissions leakage in a California cap-and-trade program. Minimizing the shifting of emissions out of California in a way that reduces the net decrease in global greenhouse gas emissions due to California's programs is a statutory requirement of AB 32 and an important design objective in any cap-and-trade program. And California should aim to avoid shifting emissions to other states and countries that lack, or have less stringent, climate programs, but it is possible to overstate the ease with which economic activity and associated emissions can be relocated, and we believe that CARB should be suspect of exaggerated claims that industries will relocate or expand in other jurisdictions as a result of AB32.

This is a one-page description of Green-e Climate

Comments, Questions, and Recommendations for the WCI CSAD committee on Data review and collection, Competitiveness Analysis, Offsets compliance limit, and Early Reduction Allowances.

California Energy Commission Staff Workshop on 2006 RPS Procurement Verification Data Review, Comments of CRS Regarding RPS Procurement; Attachment B: Questions Regarding Outstanding RPS Procurement Claims

Commenting on issues relating to voluntary early emissions reductions in a California cap-and-trade program and CARB's efforts in designing an effective cap-and-trade program as part of AB32. Recommending auction allowances to incentivize early action, carving out early action allowances from within the cap, maintaining distinction between capped sources and uncapped sources, ensuring reductions occur before 2012, incentivizing air quality and public health co-benefits, and "keeping it simple."

Poster presentation for AWEA Windpower 2009 Conference by Andreas Karelas on community choice aggregation programs in Berkeley and Marin County

Urging the House Energy and Commerce Committee to include specific language that recognizes the ability of voluntary renewable energy purchases to produce reductions in addition to those directly required by a cap-and-trade program, such as an off-the-top provision.

Urging the House Energy and Commerce Committee to include specific language that recognizes the ability of voluntary renewable energy purchases to produce reductions in addition to those directly required by a cap-and-trade program, such as an off-the-top provision.

Urging the Senate Environment and Public Works Committee to include specific language that recognizes the ability of voluntary renewable energy purchases to produce reductions in addition to those directly required by a cap-and-trade program (an off-the-top provision).

Comments on the Climate Registry's Electric Power Sector Protocol

These are the submitted comments from the Center for Energy Efficiency and Renewable Technologies (CEERT) and the Center for Resource Solutions (CRS)on the treatment of RECs and null power (power generated at a renewable source that is no longer bundled with its RECs) within the Western Climate Initiative. The comments detail our organizations' several key objectives with regard to the treatment of RECs and null power. These objectives include: accurate accounting of emissions and emissions reductions; retention of incentives for the development of renewable electricity; avoidance of perverse incentives toward higher-emitting generation; and Consistent treatment of in-region and out-of-region generators.

SEPA's new report addresses utilities' acquisition of large-scale solar, which currently occurs primarily through requests for proposals (RFPs) and subsequent power purchase agreement (PPA) contracts. This report draws best practices from both the utility and solar industries, and provides education and insights for both parties that can lower costs, improve expectations, and streamline efficiency. Additionally, it looks beyond traditional RFP/PPA processes, and investigates other innovative ways utilities can procure large amounts of solar in new and potentially better ways.

This paper is intended to provide guidance for tracking systems that would like to create uniformity in the treatment of environmental attributes associated with RECs in a manner that meets the needs of all state RPS programs and other compliance markets as well as the needs of the voluntary REC market. There are several opportunities presented for tracking system operators to help increase liquidity in the larger marketplace, improve flexibility of the tracking systems and provide more accurate information for their clients.

This paper is intended to provide guidance for tracking systems that would like to create uniformity in the treatment of environmental attributes associated with RECs in a manner that meets the needs of all state RPS programs and other compliance markets as well as the needs of the voluntary REC market. There are several opportunities presented for tracking system operators to help increase liquidity in the larger marketplace, improve flexibility of the tracking systems and provide more accurate information for their clients.

Order Instituting Rulemaking to Implement the Commission's Procurement Incentive Framework and to Examine the Integration of Greenhouse Gas Emissions Standards into Procurement Policies

These comments detail and explain several issues concerning the unintended impacts an emissions cap could have on the voluntary renewable energy market, as well as disincentives it could impose on energy efficiency efforts voluntarily undertaken by citizens and business. The comments additionally presents ideas on how some of these issues can be effectively addressed in policy, relying in part on how states participating in the Regional Greenhouse Gas Initiative in the Northeast have attempted to resolve these issues.

In December of 2007, the Green-e Marketplace team conducted a survey of all current program participants to gather information to help us enhance the understanding of what drew clients to Green-e and what their current and future plans for logo use are.

This paper reviews wind power industry policies in China, investigates how similar regulations in other industries have been treated under the policies of the WTO, and assesses the likely international trade implications of the aforementioned policies in the wind sector. It concludes with a brief discussion of whether ongoing and proposed Chinese government policies to promote local wind turbine manufacturing are likely to be challenged by other WTO member countries.

Reviews the respective policy environments for wind energy in India, China, and Spain and how these policies have influenced the rise of a major domestic wind turbine manufacturer in each national context. Examines and compares the manner in which Suzlon, Goldwind and Gamesa became domestic leaders in their respective countries' wind industries, with a focus on the acquisition of technology, technological know-how, and the associated intellectual property rights that allowed each company to become a leading wind turbine manufacturer in its own domestic market.

This paper demonstrates the benefits of renewable energy as a hedge against electricity market fuel price fluctuation. It considers how regulators and electricity customers may address this opportunity either as a socialized cost/benefit scenario (by including renewable energy in the rate base), on an individual customer basis (through green pricing options that convey price stability benefits, via on-site installation of renewable energy generation technology under different business models, and through fuel switching), or through several approaches simultaneously.

2007 report to the IEA, aiming to (1) explain why certain global energy scenarios contain larger shares of renewable energy than others; (2) identify key assumptions; and (3) recommend appropriate settings for assumptions critical to the role of renewable energy that might be used in future global energy scenarios.

High-level overview of the implementation costs for four renewable energy policy tools: feed-in law, public benefits fund, renewable portfolio standard, and competitive tendering process. Provides an idea of the range of administrative costs that can be expected to implement each of these policies.

James Hansen, Director of the Goddard Institute on Space Studies and one of the foremost experts on climate change, has said that man has just 10 years to reduce greenhouse gas (GHG) emissions before global warming reaches what he calls a tipping point and becomes unstoppable.3 Energy efficiency is a critical means to meeting a variety of policy goals - from increasing energy security to improving the standard of living of the poor to decreasing the human impact on the environment.

In existing cap-and-trade schemes, there is a need for effective energy efficiency measurement and verification programs, along with a credible tracking system that guards against double counting and identifies measures that meet "additionality" criteria. Energy savings certificates (ESCs), it is argued, may be the necessary tool to make this link. ESCs may be particularly useful to attract investment in hard-to-reach sectors (such as rental buildings, and weatherization in low-income communities) as well as to attract investment in energy efficiency measures with long paybacks that have been slow to enter into the market.

The paper provides an overview of the key market demand and supply-side drivers for renewable electricity in each of the three North American countries. It then identifies regulatory mandates, voluntary purchases, self-supply and financial incentives as the most important drivers of a renewable electricity market in North America today. The paper also explores the opportunities for growing the renewable electricity market in each of the three countries. It then concludes with a series of brief recommendations for the market overall and for the Parties of the North American Agreement on Environmental Cooperation (NAAEC) to help foster a North American renewable electricity future.

Historical overview of the German 250 MW Wind Program, perhaps the most significant effort of any country to support the piloting and demonstration of new wind turbines and wind turbine designs. The paper also details the criteria used in the grant application process and in the quota system meant to benefit domestic manufacturers. Emphasis is on the German government's proactive response to new technologies that are not yet scaled to break into the existing industrial energy market; by using public funds to supplement research and development, and by freely disseminating the resulting technical advances, the Germans have both accelerated their domestic wind power deployment and cultivated a mature export manufacturing industry.

This document contains recommendations to enable, when and where desired, seamless certificate transfers between certificate tracking systems in North America. These recommendations were developed by the Center for Resource Solutions (CRS), in consultation with North American Association of Issuing Bodies (NAAIB) Working Group.

This final consensus document was developed by the NAAIB Working Group of certificate-based tracking system operators and regulators under the auspices of NAAIB.

This document contains recommendations for best practices for avoiding double counting of RECs. The final consensus document was developed by the North American Association of Issuing Bodies (NAAIB) Working Group.

The Regulator's Handbook on Renewable Energy Programs & Tariffs is a reference guide for regulators involved in the design of renewable energy programs. Written with a specific focus on tariff setting, it suggests best practices for designing renewable energy programs and highlights success stories in a series of case studies. This Handbook is divided into sections that can be read sequentially or referred to individually when particular issues arise. Key issues discussed in this Handbook include: Green Pricing; Check-off Programs; Community Aggregation; Renewable Portfolio Standards; Public Benefits Funds; and Net Metering.

The purpose of the report is to assess how to accelerate and expand the current CPUC Renewable Portfolio Standard (RPS) and related programs to achieve the Governor's goal of meeting 33 percent of statewide electric power supply with renewable energy by 2020. This report identifies what the CPUC can do within the scope of its current jurisdiction and what changes in law are needed to expand renewables to meet the Governor's goal.

Reviews the Regional Greenhouse Gas Initiative (RGGI) process and outlines lessons learned for incorporating renewable energy and specifically the voluntary renewable energy market into greenhouse cap-and-trade regimes. Draws conclusions about greenhouse gas reduction efforts in general and key elements in their success or failure.

This report contains the activities and financial reporting documents for 2004.

Discusses a variety of tax incentives introduced as policy tools in 29 countries and 35 US states, offering lessons based on international experience with these tax incentive programs. Prepared for the Energy Foundation China Sustainable Energy Program.

Explores the motivations behind establishing a local wind power industry, and the paths that different countries have taken to develop indigenous large wind turbine manufacturing industries within their borders. Includes a series of detailed country case studies showing how 12 different countries have sought successfully or unsuccessfully to encourage local wind turbine manufacturing. Identifies lessons learned from other countries that might be applied to China; prepared for the Energy Foundation China Sustainable Energy Program.

Text of a 2005 Chinese act proposing "to promote the development and utilization of renewable energy, increase energy supply, improve the energy structure, safeguard energy security, protect the environment, and realize the sustainable development of the economy and society."

Brief on the issue of "disaggregated" Trade Renewable Certificates (TRCs) [also known as Renewable Energy Credits (RECs)]. Because there is both a TRC market and an emissions credit market, there emerges the possibility for confusion in the accounting of ultimate environmental benefit. TRCs that have had their discrete emisssions values separated and sold individually, the paper argues, should cease to be marketable as complete commodities.

The question has been raised about the need for Green-e certification and verification in regions where tracking systems are in place. Is Green-e still relevant in an era when each unit of renewable energy is identified and tracked from generation to retirement? This document provides a discussion of the comparative functions of tracking systems and the Green-e Program.

Discusses and compares the existing or proposed Renewable Energy Credits (REC) tracking systems in North America and introduces the North American Association of Issuing Bodies (NAAIB), an institution that will help network renewable certificate tracking bodies in North America.

A resource guide targeted to municipal utilities, to improve marketing decisionmaking, to educate staff as well as consumers on effective methods of communicating renewable energy messages visually and verbally, and to leverage municipal efforts to increase participation in green power programs.

Summarizes international experience with Public Benefit Fund (PBF) policies that target renewable energy (RE) and energy efficiency (EE) investments, and identifies lessons learned from these experiences that are applicable to the Chinese context.

Proposes the formation of an organization for the central tracking of renewables certificates in North America, and makes recommendations for the structure and responsibilities of such a body. The overarching goal of such an organization will be to facilitate the creation of the minimum standards and protocols that ensure compatibility between systems issuing and tracking renewable certificates.

Report to the North American Fund for Environmental Cooperation, examining the technical, legal and economic issues involved in developing a North American market for tradable renewable energy certificates (TRCs) from Mexico. Assesses both the feasibility of using TRCs to encourage the development of renewable energy in Mexico, and the challenges and opportunities associated with building a North American certificate-trading scheme.

As markets for green power develop, regulators must ensure that these markets function in an effective manner. Consumers must have confidence in the integrity of the product claims. Developers and purchasers of renewable resources must have a platform for transparent and fluid transactions. This Handbook will facilitate the development of these markets. This Handbook provides information to regulators, state energy offices, Attorneys General and consumer advocates regarding the development of the rapidly growing TRC market in the US and worldwide and identifies regulatory issues that would benefit from further discussion and recommendations from the regulatory community

Based on based on a survey of green pricing program managers at public utilities combined with advice from leading renewable energy experts on green pricing best practices, this Public Renewables Partnership (PRP) report offers a public utilities background on lessons learned from public utilities that have implemented green pricing programs and offers recommendations to consider when implementing a green pricing program.

Reviews US and EU experiences with feed-in policies, tendering, and renewable portfolio standards, and compares the relative merits and disadvantages of each approach both generically and for application in China.

Identifies the most common elements of renewable energy (RE) project development and how they have been applied with various types of policy approaches, and points out the critical factors affecting their use. Discussion limited to larger (1 MW), grid-connected facilities.

Investigates the potential for coordination between existing voluntary and mandatory tracking and verification regimes for tradable renewable certificates (TRCs) in the US. Provide recommendations for the development of a national network to track and verify certificates, with the underlying assumption that the development of a coordinated US network for tracking and verifying TRCs will build consumer confidence, eliminate the potential for double counting of TRCs, and accelerate the market for renewable energy more generally. Prepared for the National Renewable Energy Laboratory.

This paper recommends establishing a similar association in the US that will facilitate coordination between existing issuing and tracking systems. It also includes recommendations for establishing issuing and tracking systems for generators that fall outside of existing tracking regime boundaries.

The rate of dissemination of off-grid renewable energy technologies is greatly dependent on the satisfaction of end-users and therefore the quality of past installations. Many systems currently installed are not functioning at the promised levels. One of the main causes of sub-optimal system performance is the use of poorly made components and a lack of consumer education regarding the limitations of potential system output. Certification and accreditation of off-grid renewable energy system components is an important step in improving the quality of installations

Governmental support is one of the main drivers of renewable energy dissemination throughout the world. Subsidies, import tariffs, quality enforcement programs, and governmental provision of financial intermediaries can all play a role in expanding the market for off-grid renewable energy services. This memorandum outlines actions a government can take to stimulate the growth of renewable energy markets and reviews case studies from three countries.

There are many barriers to the widespread diffusion of renewable energy technologies in the rural environment. One of the main barriers is financial, as many rural families have little expendable capital and lack access to credit. This memorandum outlines schemes that have been utilized to finance solar photovoltaic projects.

Discusses the linkages and relationships between Renewables Portfolio Standard (RPS) and Systems Benefit Charge (SBC) policies in place in particular US states, to explore possible combinations of these two policies in China.

Reviews the relative merits and disadvantages of various ways to apply an RPS to affected electricity suppliers, with particular emphasis on the complexities of applying a capacity-based renewable energy purchase obligation. Includes a review of the Texas experience with this approach.

Detailed study of the motivation, design, implementation and progress of the 1999 Texas electricity restructuring legislation, a bill containing some of the most aggressive Renewables Portfolio Standard (RPS) policies yet implemented in the US.

Details Renewables Portfolio Standard (RPS) design principles that ensure an effective and low-cost RPS, recounts lessons learned from specific case studies, and summarizes the advantages and disadvantages of taking certain paths, with recommendations for a proposed RPS approach in the Chinese context.