Toward Transparent Power: Best Practices for Power Source and Emissions Disclosure

Posted on by Jeff Swenerton

Every customer has the right to know—with confidence and clarity—the sources of the electricity they have purchased and the associated emissions

 

by Rachel Palmer

The Clean Energy Accounting Project’s (CEAP’s) Best Practices for Power Source and Emissions Disclosure Guidance provides a comprehensive guide for regulators, utilities, and electricity suppliers to deliver accurate, standardized power source disclosure (PSD) to customers in the United States.

FRAGMENTATION AND INCONSISTENCY

Today, roughly 3,000 electric utilities serve customers nationwide, each operating under different state policies and disclosure rules. As of 2025, only 25 states mandate generation disclosure, most of which describe generation at a regional level and do not tell customers what they are receiving. This patchwork makes it difficult for customers to understand their electricity purchases, for corporate buyers to verify their climate commitments, and for regulators to track clean energy progress.

A FRAMEWORK FOR CREDIBLE DISCLOSURE

Accurate PSD allows customers to understand their electricity use, compare offerings across suppliers, and evaluate their role in supporting decarbonization. It also provides regulators with a consistent basis for oversight and tracking progress toward clean energy goals.

This guidance establishes best practices that will foster national consistency, enable valid voluntary clean energy claims, and strengthen policy insight through comparable, auditable disclosure.

SIX KEY RECOMMENDATIONS

  1. Delivered Attributes, Not System Mix: Disclosures must reflect the generation attributes contractually delivered to retail customers—what they purchased and can claim—rather than overall utility averages that obscure individual product characteristics.
  2. Comprehensive Tracking Systems: All-generation tracking systems provide the most accurate form of disclosure by ensuring consistent tracking across all generation types, enabling robust residual mix calculations, and reducing double-counting risks.
  3. Retrospective Reporting with Optional Forward View: PSD should be backward-looking, based on certificate retirements corresponding to delivered generation. Forward-looking disclosures may supplement but should never replace historical disclosure.
  4. Alignment with Emissions Accounting: Reported greenhouse gas emissions must align directly with the disclosed resource mix, ensuring clarity and consistency between generation sources and emissions reporting.
  5. Integration of State Load-Based Policies: Disclosures must account for state RPS, CES, and load-based GHG regulations to ensure that what appears on the disclosure aligns with what customers are legally entitled to claim under these programs.
  6. Appropriate Granularity: At minimum, generation and attributes should be matched to load on an annual basis. More granular matching (monthly or hourly) can provide additional insights as supplemental information. Matching should be considered separately from reporting frequency.

IMPLEMENTATION SUPPORT

CEAP’s PSD guidance doesn’t stop at principles. It also provides detailed best practices covering product-specific disclosure, comprehensive energy attribute certificate (EAC) accounting, all-generation tracking systems, alignment with load-based policies, and consistent resource categories. The guidance illustrates applications across different market scenarios and offers step-by-step calculation methodologies with worked examples.

As electricity markets evolve, credible disclosure becomes increasingly critical. These best practices provide a clear roadmap for regulators, utilities, and suppliers while ensuring every customer receives the transparency they deserve.

—Rachel Palmer is a Senior Program Analyst at CRS