Status and Trends Report
on U.S. Energy Attribute
Tracking Systems
Prepared for: m sepa
U.S. Environmental Protection Agency's W 4 GREEN
Green Power Partnership ^ \ POWER
Prepared by:
Eastern Research Group, Inc. (ERG)
and Ed Holt & Associates, Inc
EPA Publication Number: 430S25002
PARTNERSHIP
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
Status and Trends Report on U.S. Energy
Attribute Tracking Systems
This document was prepared on behalf of the U.S. Environmental Protection Agency by Eastern
Research Group, Inc., and Ed Holt & Associates, Inc. Its content does not reflect agency views or
policy and does not imply official EPA endorsement of any commercial products/services.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
Contents
Introduction 1
1. Introduction to energy attribute tracking systems 3
1.1 What are energy attribute tracking systems? 3
1.2 How are energy attribute tracking system databases designed and who uses them?...6
1.3 How are tracking systems used? 9
1.4 Tracking systems' relationship to grid operators and qualified reporting entities 12
1.5 Key principles and characteristics of tracking systems 13
1.5.1 Transparency 14
1.5.2 Integrity of claims and prevention of double counting 15
1.5.3 Verification of generation 16
1.5.4 Tracking characteristics for generators and generation attributes 17
2. Future needs of tracking system infrastructure 19
2.1 International corporate GHG accounting standards 19
2.2 Corporate reporting 21
2.2.1 Voluntary GHG emissions reporting 21
2.2.2 Mandatory corporate climate risk disclosures 21
2.3 Voluntary procurement strategies 23
2.3.1 Annual matching 23
2.3.2 Granular matching 24
2.4 Low embodied emissions products 28
2.4.1 Hydrogen production 29
2.4.2 Product category rules and EPD for heavy construction materials 33
2.4.3 International trade policy 35
2.5 Utilities and other retail electricity suppliers 38
2.6 Definitions, requirements, and procedures considerations 40
2.6.1 Definitions 40
2.6.2 Requirements 42
2.6.3 Procedures 43
3. Conclusion 45
Appendix A. Potential key features of a "North Star" energy attribute tracking system 46
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
Introduction
Tracking systems in the United States have evolved quickly over the past two decades. Utility
regulators have learned that tracking energy attributes offers a simpler way to support usage
and ownership claims to renewable energy than more difficult alternatives, such as tracking
contracts or tracking physical electricity. Systems that track energy attributes are responsible for
issuing energy attribute certificates (EACs) and managing their transfer and ownership until the
certificates are retired or claimed. Tracking systems—also called registries—do the critical work
to establish ownership rights and credibility for the many market participants that trade in EACs.
The first tracking system was launched by Texas in 2001, and there are now nine primary
systems in operation in the United States. They track compliance with renewable energy
mandates, provide power source and emissions disclosure information to consumers, and track
ownership of certificates to support voluntary procurements and energy usage claims. In all
these applications, a major objective has been to avoid double counting: no double issuance of
certificates based on the same megawatt-hours (MWh) and no double claims on the same
certificate or unit of generation. Tracking systems have succeeded in supporting this outcome.
In New England and Texas, state regulators gave their support to develop the first digital
registries to issue certificates and track them from generation sources to those who ultimately
claim them. As newer tracking systems were developed, they tended to emulate many features
of those that preceded them, with the result that each system is similar in organization,
capabilities, and sometimes even operating procedures or definitions. As each registry was
commissioned, however, they adapted to the unique requirements placed on them by the
variations in state statutes such as renewable portfolio standards (RPS) and other renewable
energy laws.
Each tracking system has focused on the needs of the states and stakeholders it serves. Each
system has its own governance, which may be a single public utility commission or state agency,
wholesale market operators, a private nonprofit company, a for-profit company, or a consortium
of states and other stakeholders.
As state policy direction and legal requirements have evolved and added new or differing
responsibilities to the tracking systems, the registries have to some extent differentiated or
grown apart to better serve their constituents.
In addition to public policy drivers, voluntary markets have been a focus and important market
driver almost from the beginning, bringing a broader set of stakeholders and interests. Market
demand for renewable electricity or emission-free electricity has grown to the point where it
appears that voluntary demand for renewable energy certificates (RECs) may be about to
overtake RPS or compliance demand. Voluntary market players also drive interest in new
capabilities, such as granular certificates.
The range of stakeholders engaging in the voluntary green power market continues to grow. The
federal government has also had an interest in the operation of tracking systems. Its goals have
been to support federal public-facing programs, such as the U.S. Environmental Protection
Agency's (EPA's) Green Power Partnership (GPP); programs focused on the internal operations of
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
federal agencies, such as the Department of Energy's (DOE's) Federal Energy Management
Program (FEMP); and successive Executive Orders (EOs) requiring agencies to procure clean
electricity. More recently, the Inflation Reduction Act and the Infrastructure Investment and
Jobs Act (also known as the Bipartisan Infrastructure Law) include provisions for tax credits and
program support for the procurement of low embodied construction materials that rely on
energy attribute tracking systems to verify that manufacturers meet eligibility criteria.
As nation-wide programs addressing clean energy become operational, there is a growing
urgency to ensure equal treatment of electricity generators and market participants among
tracking systems. Harmonization of tracking system rules, if not consistency across tracking
systems, is important to maintaining the integrity of electricity attribute markets. Functional
capabilities, rules, and procedures should be considered, including definitions, electricity and
emissions measurement protocols, independent verification, certificate issuance and
retirement, and system interoperability. Tracking systems have a broader range of stakeholders
than ever before and a wider variety of needs to be satisfied. The risk is that programs and
policymakers will develop registry alternatives if current tracking system infrastructure is
unresponsive or unable to meet new and emerging trends in the market.
This report is an attempt to articulate the status and needs of the current tracking system
infrastructure, and to initiate discussion about how best to meet the need for additional
capabilities as well as procedural harmonization across tracking systems. It is organized as
follows:
• Section 1 provides an overview of what energy attribute tracking systems are and why
they were developed. It also summarizes how tracking systems operate as well as some
key similarities and differences among them.
• Section 2 looks more closely at current trends in U.S. energy markets that are driving
tracking systems to evolve, and at the steps registries are already taking to address and
prepare for future needs.
• A Conclusion discusses the critical work of tracking systems to date in supporting
credible energy markets and why these systems might further evolve and harmonize to
serve emerging market interests and policy needs.
• Appendix A explores a hypothetical "North Star" of tracking system capabilities and
functionality driven by a set of emerging trends, policies, programs, and standards-
domestic and abroad—that present material opportunities and challenges for U.S.
businesses and multinationals.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
1. Introduction to energy attribute tracking systems
1.1 What are energy attribute tracking systems?
Energy attribute tracking systems are digital web-accessible platforms that register basic
information about each MWh of electricity generation in a specific geographic region.1 For each
MWh of electricity delivered to the grid, these database systems electronically "mint" or issue
EACs to the owner of the generation facility. Some tracking systems account for attributes from
all types of electricity generation; others only account for attributes of renewable electricity
generation. Each EAC issued by a tracking system is assigned a unique, traceable serial number
and includes specific information on the representative energy attributes. The attributes
accounted for by tracking systems include the characteristics of the electricity generator
(tracked with static data) and the generator's electricity output over time (tracked with dynamic
data). Typical types of static data include the generator's fuel or energy source (e.g., wind), its
location (e.g., state), the year it commenced operation, and its nameplate capacity in
megawatts (MW). Typical types of dynamic data include the date of generation (month and
year), volume of generation (MWh), and the generator's eligibility for voluntary and state
compliance programs.
EACs are tradeable assets representing property ownership2 of the attributes of electricity
generation. Ownership of EACs provides the legal basis for consumers' claims about the
electricity they have used. All EACs are traded independently or "unbundled" from the
underlying electricity.3 RECs,4 a type of EAC specific to electricity generation from renewable
energy sources,5 have been called a "necessary part of the machinery of U.S. electricity
markets, used to demonstrate renewable electricity purchasing, delivery, and use"6 and have
been recognized as a "tool to pursue policies that support decarbonization of the electric grid."7
Through the electronic issuance of RECs, tracking systems help bolster market credibility and
the liquidity of RECs for various compliance and voluntary market applications.
EACs are generally issued to electricity generating facilities that are registered in the tracking
system, based on MWh production volumes. Larger generating facilities may produce multiple
1 Tracking systems are also widely used in Europe as well as internationally across many countries and markets.
2 Renewable energy credits as property. (2024). Harvard Law Review, 137(3).
https://harvardlawreview.org/print/vol-137/renewable-energy-credits-as-propertv
3 A "bundled" purchase is one in which the buyer purchases both the EACs and physical power from the same
supplier. Note that, because physical electrons cannot be traced, tracked, or directed to a buyer on a shared grid,
the buyer generally cannot be assured it receives the exact physical power produced by the generator when the
EAC was issued.
4 While some states and market participants use different names for RECs (e.g., "renewable energy credits,"
"alternative energy credits"), the term generally refers to a tradeable certificate representing the attributes of one
MWh of renewable generation.
5 Renewable generation is defined as energy generated by a facility that is considered a renewable energy source as
defined by any state or province using the tracking system.
6 Center for Resource Solutions. (2023). The legal basis for renewable energy certificates. https://resource-
solutions.org/wp-content/uploads/2015/Q7/The-Legal-Basis-for-RECs.pdf
7 Renewable energy credits as property. (2024). Harvard Law Review, 137(3).
https://harvardlawreview.org/print/vol-137/renewable-energy-credits-as-propertv
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
MWh in a particular hour or day, whereas smaller facilities may take days or weeks to produce a
single MWh. Once EACs are issued, account holders can transfer them to other account holders,
in some cases export them to other tracking systems, or retire them. Tracking systems
electronically trace ownership of EACs between account holders and remove EACs from
circulation when they are retired, which prevents double counting of the same energy
attributes. Tracking systems do not generally contain any price information on EACs,8 and while
the systems account for the transfer of EACs between account holders, the financial settlement
is transacted outside the tracking system infrastructure. Power purchase contracts are also
executed outside tracking systems, though the transfer of EACs within the tracking system helps
the parties validate the contract terms and conditions.
At present, there are nine9 tracking systems in North America, which together provide full
coverage of all U.S. states:
• Electric Reliability Council of Texas (ERCOT)
• Michigan Renewable Energy Certification System (MIRECS)
• Midwest Renewable Energy Tracking System (M-RETS)
• North American Renewables Registry (NAR)
• North Carolina Renewable Energy Tracking System (NC-RETS)
• New England Power Pool Generation Information System (NEPOOL-GIS)
• New York Generation Attribute Tracking System (NYGATS)
• PJM EIS's Generation Attribute Tracking System (PJM-GATS)
• Western Renewable Energy Generation Information System (WREGIS)
The map in Figure 1 shows the tracking systems' footprints within the United States. Five the
nine systems cover multi-state areas (M-RETS, NAR, NEPOOL-GIS, PJM-GATS, and WREGIS) and
four are single-state systems (ERCOT for Texas, MIRECS for Michigan, NC-RETS for North
Carolina, and NYGATS for New York). Two systems (M-RETs and NAR) allow generators located
anywhere in North America to register with them, while the rest require generators to be within
their operational footprints.10
8 The exception is PJM-GATs, which contains information on solar renewable energy certificate (SREC) prices.
9 This report does not include Nevada Tracks Renewable Energy Credits (NVTREC), because of it is not used for
voluntary market transactions and has limited functionality. As well, Nevada is already included in WREGIS's
operational footprint.
10 Several U.S.-based tracking systems serve neighboring parts of Canada and Mexico.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
KEY
ERCOT
MIRECS
M-RETS
NAR
NC-RETS
NEPOOL-GIS
NYGATS
PJM-GATS
WREGIS
No tracking system
formally adopted.
NAR and M-RETS allow
registration of generators
located anywhere in
U.S. or P.R.
MASSACHUSETTS
RHODE ISLAND
CONNECTICUT
. mm-
Figure 1. Map of energy attribute tracking systems.
Adapted from the Center for Resource Solutions: https://resource-solutions.org/wp-content/uploads/2018/02/Tracking-Svstem-
Map.png.
As detailed in Table 1 below, six of the systems track only renewable or clean generation as
defined by the RPS or clean energy standard (CES) programs of the state(s) they cover. In some
cases, the renewable or clean generation that is issued certificates by tracking systems may
include generation from non-renewable sources or emitting sources if those are permitted in a
given RPS or CES. The three systems in the northeast United States (NEPOOL-GIS, NYGATS, and
PJM-GATS) are all-generation tracking systems, meaning they track generation from all energy
sources (including non-renewable sources). M-RETS and NAR, the two systems that allow
generators anywhere in North America to register, account for the largest volumes of certificate
issuance.
Table 1. Overview of U.S. Tracking Systems
Tracking
System
Launch
Year
Type of
Generation
Tracked
Geographic
Coverage
Number of
Generators3,15
Number of
Account
Holders
Number of
Certificates
Issued
ERCOT
2001
Renewable
Single state
420
1,236
147,337,944
MIRECS
2009
Renewable
Single state
326
163
21,808,260
M-RETS
2007
Renewable
Multi-
state/national
3,962
684
355,738,312
NAR
2009
Renewable
Multi-
state/national
947
511
264,516,285
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
Tracking
System
Launch
Year
Type of
Generation
Tracked
Geographic
Coverage
Number of
Generators3,15
Number of
Account
Holders
Number of
Certificates
Issued
NC-RETS
2010
Renewable
Single state
1,287
668
16,039,145
NEPOOL-GIS
2002
All
Multi-state
115,632
3,234
44,609,017
NYGATS
2016
All
Single state
2,924
705
129,591,042
PJM-GATS
2005
All
Multi-state
436,583
28,100
95,316,892
WREGIS
2007
Renewable
Multi-state
11,849
1,294
N/Ac
a. Generator totals were collected on July 31, 2024. ERCOT and MIRECS totals are from 2023. Where possible,
multi-fuel generators are accounted for and have only been counted once. Some tracking systems have many small
(residential) solar generators, which add to their totals.
b. Generator totals for tracking systems that track all generation include non-renewable generators.
c. WREGIS does not make its certificate totals available to the public.
In the United States, renewable energy transactions have more than tripled over the past
decade, which only increases the importance and use of tracking systems to account for the
generation, transaction, and final consumption and ownership of EACs. To illustrate the growth
and increasing reliance on tracking system infrastructure, M-RETS issuance of certificates
increased from 73 million in 2014 to 355 million in 2023, as detailed in Figure 2.
400
350
300
CD ^
« <5 250
$ "c 200
8 .2
It150 m\
¦¦¦Mill
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
Year
Figure 2. M-RETS certificate issuance (2014-2023).
1.2 How are energy attribute tracking system databases designed and who uses them?
Most tracking system databases follow similar architectural frameworks and provide similar
functionality. Any organization wishing to access and use one must register as an account holder
and create an online organizational user profile. There are typically different account holder
types (often with different associated fees and annual subscription costs), generally fitting into
the following categories: general organization; load-serving entity, or LSE (e.g., utility or
electricity supplier); project or generator owner; program administrator; reporting entity; and
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
retail purchaser (typically only used by large electricity purchasers). Depending on the account
holder type, the tracking system provides different levels of functionality and system access. For
example, a retail purchaser account holder may be able to hold EACs, accept incoming EAC
transfers, and retire EACs, but not make outgoing EAC transfers or register a generation facility.
Table 2 lists the typical types of organizational users of tracking systems and describes how they
use and benefit from the systems.
Table 2. Tracking System Organizational Users and Applications
Tracking System User
Application
Generating facility owner
Enhance value of clean generation and reduce transaction
costs
LSE
Simplify RPS reporting and compliance and product disclosure
REC marketer
Facilitate sales; demonstrate eligibility with voluntary
programs; ensure increased market liquidity
Large electricity buyer
Manage and verify EAC portfolio and retirements
Regulatory program administrator
(e.g., state RPS administrator)
Reduce program administrative costs and ensure accuracy of
reporting entities
Voluntary program administrator
Verify EACs meet program eligibility requirements; facilitate
auditing process by streamlining chain-of-custody tracking
Qualified reporting entity
Electronically report generation data to tracking system
Tracking systems also contain accounts, which can be linked to account holders within the
system. Accounts are for organizations directly involved in some part of the EAC transaction.
Figure 3 shows the structure of a sample account for an organization, specifically an LSE.
Tracking systems often support both active accounts and retirement accounts, and account
holders may have more than one of each.
An active account functions like a checking account. It is a holding place for the account holder's
active (e.g., unclaimed) EACs, which they can transfer, retire, or export/import.
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Status arid Trends Report on U.S. Energy Attribute Tracking Systems
Registered
Generator #1
Registered
Generator #2
Load Serving Entity Account Holder
Active
Account
RPS Compliance
State #2
Subaccount
Retirement
Account
Voluntary
Subaccount
(Green-e)
Other Account
Holders' Active
Accounts
Import/Export to
Other Tracking
Systems
Figure 3. Conceptual example of account structure for an LSE.
A retirement account is a repository for EACs that the account holder has designated as retired.
Retirement of an EAC essentially means it has been used, claimed, or consumed by the ultimate
owner and consequently removed from circulation so it can no longer be used, claimed, or
consumed by another party. As part of the retirement process, the account holder can often
classify the reason for the retirement from a discrete set of options determined by the tracking
system administrators—for example, "for compliance with a specific state's RPS," "retired on
behalf of customers of a utility green power program," or "retired on behalf of a single
voluntary green power consumer." Some tracking systems have special retirement subaccounts
that account holders can use to deposit retired EACs, as shown in Figure 3 above. In the case of
a retirement for a single retail consumer, the energy supplier or organization retiring the EACs
may identify the voluntary consumer, who likely does not have a tracking system account, using
the "beneficial owner" (e.g., the organization the EACs are being retired on behalf of) field
within the tracking system. Once EACs are placed in a retirement account, they are no longer
transferable to another party and generally cannot be unretired except in a rare set of
circumstances, and then only within a brief window after being retired.
Generator accounts are created for all generators registered with the system, which assigns a
unique ID number to each generator. All tracking systems publish full lists11 of currently active
registered generators, which allows other tracking systems to check that a generator is only
registered in a single tracking system at a time. Such a list typically includes names (of the
Generally, as a downloadable spreadsheet or online table.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
generator and its owner), tracking system ID number, state location, fuel or energy resource
type, date the generator commenced operation, nameplate capacity, and eligibility for state RPS
programs or voluntary programs. For example, M-RETS maintains an interactive online list of
generators that also allows for data download. Note that all tracking systems permit groups of
small generators to register as part of an aggregation, and identified as such, within the tracking
system database. These aggregate registrations come with different limitations in different
tracking systems: for example, small generators being aggregated might need to share the same
essential generation characteristics, be customer-sited, be within the same state, be associated
with the same revenue-grade meter, or be smaller than a certain size.
In all-generation tracking systems—though this may sound contradictory—generator owners
can still choose whether to register their generators. For example, the owner of a fossil-fired
generator may not see value to register because there is no demand for fossil EACs and such
EACs may have little economic value. To track all generation, the independent system operator
or balancing authority reports generation data for all generators under its control to the
tracking system, and the tracking system administrator accounts for this generation in a non-
tradable administrator's account. In this manner, the attributes can still be reported and
tracked, yielding information that can be used for compliance with regulations or to make
environmental claims about the power purchased by a consumer.
1.3 How are tracking systems used?
Electronic tracking systems, which have existed for more than 20 years, were almost exclusively
formed through direct state action, either by individual states or by coordinated groups of
states.12 ERCOT and NEPOOL-GIS were launched in 2001, PJM-GATS in 2005, WREGIS and M-
RETS in 2007, MIRECS and NAR in 2009, NC-RETS in 2010, and NYGATS in 2016. These systems
were originally designed to verify compliance of LSEs (e.g., utilities) with state RPSs or to
support power and environmental disclosure labels for consumers.13 They were designed to
independently issue EACs using data electronically submitted by transmission control areas to
ensure accuracy and avoid double counting. Most state RPS programs require compliance via
use of particular tracking systems. For example, California requires LSEs to use WREGIS to track
and report their RPS procurement as part of California's RPS compliance. See Table 3 for a
summary of which state RPS programs use which tracking systems. RECs used for compliance
with a state RPS program are retired (i.e., placed in a state RPS-specific retirement subaccount
by the LSE) to remove them from circulation and ensure they are not resold or reused, as well
as to help RPS program administrators verify compliance.
12 Hamrin, J. (2014). REC definitions and tracking mechanisms used by state RPS programs. Clean Energy States
Alliance. https://www.cesa.org/wp-content/uploads/RECs-Attribute-Definitions-Hamrin-June-2014.pdf
13 Wingate, M., & Lehman, M. (2003). The current status of renewable energy certificate tracking systems in North
America. Center for Resource Solutions, https://resource-solutions.org/document/the-current-status-of-
renewable-energy-certificate-tracking-svstems-in-north-america/
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
Table 3. State RPS Program Use of Tracking Systems
Tracking System State/Territory RPS Program
ERCOT
TX
MIRECS
Ml
M-RETS
IA, IL (partial), MN, ND, OH (partial), Wl
NAR
KS, ME (partial), MO, NC (out-of-state generators), NY (out-of-state generators), PR
NC-RETS
NC
NEPOOL-GIS
CT, MA, ME (partial), NH, Rl, VT
NYGATS
NY
PJM-GATS
DC, DE, IL (partial), MD, NJ, OH (partial), PA, VA
WREGIS
CA, CO, NM, NV, OR, UT (starting 2025), WA
Tracking systems are also used by regulators and voluntary program administrators as registries
of eligible generating facilities; to aid in the creation of electricity disclosure labels; for voluntary
green power certification programs (e.g., Green-e); and for other reasons, such as developing
residual mixes.
Energy consumers and suppliers participating in the voluntary green power market also use
tracking systems, both for wholesale and retail market transactions. Voluntary green power
markets enable consumers to procure renewable electricity at levels beyond what mandatory
policy decisions require and to reduce the environmental impact of their electricity use. EACs
that are retired within tracking systems for voluntary purposes ensure regulatory surplus and
the private claim by the ultimate consumer to the attributes of energy generation. This is true
because tracking systems can clearly delineate between voluntary and compliance EAC
retirements; it ensures that voluntary buyers who make investments in clean energy can
credibly claim their EACs are surplus to the volume of renewable generation that would have
occurred without their proactive energy procurement. EACs retired to voluntary subaccounts
within a tracking system can be privately claimed by specific purchasers, whereas EACs retired
by LSEs to comply with an RPS or for default product offerings are claimable by all ratepayers.
Furthermore, an increasing number of organizations rely on EACs to report emissions associated
with purchased electricity use under internationally recognized voluntary greenhouse gas (GHG)
accounting standards.14 These standards require that reporting organizations demonstrate a
clear claim to the attributes of delivered power, with a preference for claims based on EACs.
As depicted in Figure 4 below, retirements related to voluntary purchases of RECs accounted for
48% of the overall renewable energy market in 2023. The voluntary market is expected to grow
significantly in the years ahead and could account for more than two-thirds of total U.S.
14 Greenhouse Gas Protocol. (2015). GHG Protocol scope 2 guidance: An amendment to the GHG Protocol corporate
standard, https://ghgprotocol.org/scope-2-guidance
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
renewable generation by 2026.15 Large corporations are, and will continue to be, one of the
main drivers of the growth in the voluntary market. Not only do these types of organizations
rely on the tracking system infrastructure for certainty of ownership, but they often directly
participate in tracking systems as account holders to manage their EAC portfolios. Where
available, large purchasers often opt in to have their voluntary REC purchases disclosed publicly
by the tracking system to transparently communicate their renewable energy achievements. For
example, see NAR's Retirements Disclosed to Public report.
48%
Voluntary
52%
Compliance
2015 2017 2019 2021 2023
Figure 4. Renewable energy sales for voluntary and compliance purposes (2013-2023).
Data source: National Renewable Energy Laboratory (2024). The state of the U.S. voluntary green power market
(2023 data), https://www.nrel.gov/analvsis/assets/pdfs/status-and-trends-2023-data.pdf.
Tracking systems monitor and track transactions at the wholesale level, so the vast majority of
electricity consumers (e.g., individual retail customers such as homeowners and small
businesses) do not directly participate in the process since they generally do not hold accounts
within tracking systems. However, retail markets give these retail customers—who cannot build
or operate their own power plants—access to express their demand preferences through EACs
for electricity attributes of renewable energy projects. EACs sold in retail energy markets for
voluntary use may be transacted between multiple wholesale intermediaries or brokers until
they are sold to retail electricity suppliers, who in turn sell them to an ultimate customer. These
EACs are placed in the retirement account of the retail electricity supplier and the retirement is
categorized as on behalf of the green power product's subscribers. While the tracking systems
15 Wilson, A., & Lenoir, T. (2022, December 16). US renewable energy credit market size to double to $26 billion by
2030. S&P Global, https://www.spglobal.com/marketintelligence/en/news-insights/research/us-renewable-energy-
credit-market-size-to-double-to-26-billion-bv-2030
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
trace the ownership of EACs between tracking system account holders and ensure against
double counting, they are not substitutes for third-party certification and verification, as chain-
of-custody auditing often fails to reach the final consumer. Voluntary certification programs also
rely on tracking system data to evaluate retail marketing claims and ensure that EACs are retired
that support what is marketed and sold to retail customers.
Tracking systems have emerged as the best method for transparent and efficient tracking of
wholesale renewable energy because they can be highly automated, include specific details
about each M Wh of generation, and offer 24/7 online access to market participants. Without
electronic tracking systems, renewable electricity purchasers would have to rely solely on
contract audits and paper attestations to confirm their unique ownership to the RECs. Electronic
tracking systems significantly reduce the administrative requirements to prevent double
counting.
Finally, tracking systems have adapted and expanded their capabilities over time, often in
response to state RPS requirements and policy changes. As well as accounting for energy
attributes, they are used to track combined heat and power, renewable thermal, demand
response, and conservation and load management certificates. For example, the North Carolina
Utilities Commission issues energy efficiency certificates through NC-RETS and uses the
certificates to track the results of customer programs that focus on energy efficiency and
demand-side management.
1.4 Tracking systems' relationship to grid operators and qualified reporting entities
In the United States, balancing authorities manage the operation of the electric system within a
specific geographic area and ensure that power system demand and supply are always
balanced. There are more than 60 balancing authorities in the United States, and they are
typically either utilities, power marketing administrations, or groups of utilities that have
formed entities called regional transmission organizations (RTOs) and independent system
operators (ISOs). Figure 5 below is a map of RTOs and ISOs in the United States.
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Status arid Trends Report on U.S. Energy Attribute Tracking Systems
Figure 5, Map of RTOs and ISOs in the United States.
Image from the Federal Energy Regulatory Commission: https://www.ferc.gov/power-sales-and-markets/rtos-and-
isos.
These grid operators are responsible for balancing supply and demand, and hence they control
whether and when specific generators are dispatched and how much electricity each should
generate at a given time to meet current electricity demand on the grid. They also manage the
bulk of wholesale generation, typically based on generator capacity. In other words, large
generators are usually controlled by the grid operators, while small, distributed generation is
less likely to be similarly controlled. Grid operators report generation electronically to the
tracking system monthly for each generator. If they are RTOs, they also operate wholesale
markets in which generation is sold to different parties, so these transfers must be accurately
measured for financial settlements. Tracking systems accept these generation data as third-
party verified: that is, the grid operator is the third party. Generation from smaller generators
not dispatched by the grid operator may be verified by an independent third party, often called
a qualified reporting entity (QRE), that is approved by the tracking system to submit metered
data. In some cases, certain eligible generators are allowed to self-report if safeguards for
accuracy are followed.
1.5 Key principles and characteristics of tracking systems
Several key principles, characteristics, and procedures are foundational to the current operation
of tracking systems. Many of these characteristics and existing functional capabilities can be
standardized or enhanced as features are added to tracking systems in response to new
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programs and evolving market needs. The following collection of principles, characteristics, and
procedures helped to inform the features of the hypothetical "North Star" energy attribute
tracking system detailed in Appendix A of this report.
1.5.1 Transparency
To support transparency, all tracking systems have specific public reporting requirements and
procedures. Publicly available data and reports are typically accessible on each tracking system's
website. The types of publicly available data are not fully consistent across the tracking systems,
creating challenges when aggregating or comparing similar data across systems. All tracking
systems publish their respective operating rules, generator lists, and account holders lists on
their websites. Other data elements, such as the number of certificates issued and the number
of certificates retired, are reported by most tracking systems. Activity statistics on system-wide
data (e.g., total number of certificates issued) may be updated monthly, quarterly, or annually.
Tracking systems generally require a retirement reason (e.g., for compliance or voluntary
purposes) to be chosen during the certificate retirement process. NAR, a tracking system
generally focused on voluntary market participants, publishes reports on voluntary REC
retirements for consumers who opt in for public disclosure.
At present, tracking systems do not publish generator registration forms or the full list of data
elements collected during registration, which makes it challenging to ascertain the type of
information the tracking system has on a generator beyond what is conveyed on the certificate
or detailed on the tracking system's list of registered generators. For example, the tracking
system may collect a generator's locational latitude and longitude during registration but only
detail its state on the certificate and public list. Some data are considered sensitive and are not
made publicly available.
Table 4. Tracking System Characteristics Related to Transparency
Tracking
System
Publish
Operating
Rules
Publish
Generator
Registration
Form
Public
List of
Gene
rators
Public
List of
Account
Owners
Publish
Annual
Issuance
Total
Publish Annual
Retirement
Total
Retire
ment
Reason
Opt In
Disclosed
Voluntary
Retirements
ERCOT
Yes
No
Yes
Yes
Yes
Yes
(compliance
and voluntary)
Yes
No
MIRECS
Yes
No
Yes
Yes
Yes
Yes
(compliance
and voluntary)
Yes
No
M-RETS
Yes
No
Yes
Yes
Yes
Yes
(compliance
and voluntary)
Yes
No
NAR
Yes
No
Yes
Yes
Yes
Yes
(compliance
and voluntary)
Optional
Yes
NC-RETS
Yes
No
Yes
Yes
Yes
Yes
Yes
No
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Tracking
System
Publish
Operating
Rules
Publish
Generator
Registration
Form
Public
List of
Gene
rators
Public
List of
Account
Owners
Publish
Annual
Issuance
Total
Publish Annual
Retirement
Total
Retire
ment
Reason
Opt In
Disclosed
Voluntary
Retirements
NEPOOL-
GIS
Yes
No
Yes
Yes
Yes
Yes
Yes
No
NYGATS
Yes
No
Yes
Yes
Yes
Yes
(compliance
and voluntary)
Yes
No
PJM-GATS
Yes
No
Yes
Yes
Yes
Yes
(compliance
and voluntary)
Yes
No
WREGIS
Yes
No
Yes
Yes
No
No
Yes
No
1.5.2 Integrity of claims and prevention of double counting
Requirements preventing double issuance/counting
One of the key objectives of tracking systems is to verify that certificates are not double
counted—for example, that certificates are not issued for generation in multiple tracking
systems for the same MWh. To ensure the integrity of renewable energy claims, tracking
systems uniformly require that a generator be registered in only one tracking system for
issuance of certificates. Generators are also required to report 100% of the output from a
registered unit, tracked in a single system.
Whole EACs
Most tracking systems require that certificates be whole, or fully aggregated, meaning that none
of the energy attributes may be split off from a certificate while it is in circulation in the tracking
system. All multi-state tracking systems have similar definitions of a REC and require RECs to be
whole, meaning inclusive of all the GHG emissions avoidance benefits, including carbon dioxide
(CO2) benefits, associated with the MWh of renewable electricity when it was generated. This
requirement relates to the fact that multi-state tracking systems were designed to
accommodate multiple state RPS programs and thus need to have a broad REC definition that
includes all attributes. For example, PJM-GATS defines a whole certificate as "one where none of
the renewable Attributes have been separately sold, given, or otherwise transferred to another
party by a deliberate act of the Certificate owner. Renewable Attributes shall include the
environmental Attributes which are defined as any and all credits, benefits, emissions
reductions, offsets, and allowances, howsoever entitled, directly Attributable to the generation
from the Generating Unit(s)."16
Import and export requirements
Import and export requirements are another safeguard among tracking systems. To import or
export, each system must enter into a bilateral agreement with another, in which the exporting
16 PJM-EIS. (2024). Generation Attribute Tracking System (GATES): Operating rules, https://www.pjm-eis.com/-
/media/DotCom/pim-eis/documents/gats-operating-rules.pdf
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system agrees to retire certificates being exported and the importing system agrees to issue or
re-create certificates with the same attributes as were retired in the exporting system.
Import/export transactions between tracking systems can be certificate-only (in which only the
attributes of the EAC are transferred from one system to another) or bundled (in which both the
energy and attributes are exchanged). Tracking systems are selective about these agreements
and who they will allow imports from. One tracking system might agree to export to another
tracking system but not agree to import from that system. The decision whether to accept
imports/exports is likely driven by state RPS geographic eligibility rules.
1.5.3 Verification of generation
Verification requirements for generation largely relate to the question of independent
verification. Generators, when they register, must provide their reports to the Energy
Information Administration (EIA) and may be subject to inspection. Generating units with
capacities less than 1.0 MW usually require a third party to verify. Generation dispatched and
settled by a balancing authority is accepted as independent verification. Generation not
reported by a balancing authority may be reported by the interconnected utility or an approved
third party, i.e., a QRE. Some tracking systems also support self-reporting for small generators.
Meter requirements
Tracking systems generally require a "revenue-grade meter" for measuring generation, but
some are more specific about defining the standard that must be met than others. Operating
procedures mention an MV-90 system, pulse accumulator readings collected by the control
area's energy management system, or ANSI C-12 standard or its equivalent. The differences are
not obvious and may not be significant, but this is a potential topic for discussion and
harmonization so that all generators in similar situations are treated equally.
Data validity checks of dynamic generation data
Most tracking systems (MIRECS, M-RETS, NAR, NC-RETS, NYGATS, PJM, and WREGIS) conduct
automatic validity checks of electricity production data for all reported generation to ensure
that erroneous and technically infeasible data are not accepted. These checks compare reported
electricity production to an engineering estimate of maximum potential production using
internal algorithms.
Provision for QREs
Most tracking systems provide for QREs to help small generators not reported by balancing
authority or utilities to read meters or otherwise check production and facilitate transmittal to
the tracking system. By offering this option, tracking systems ensure that generators of all sizes,
particularly distributed generation, can receive and transfer certificates.
Self-reporting requirements
All nine tracking systems allow self-reporting for small customer-sited, behind-the-meter
generating units. Generation data may be self-reported by the customer or electronically
transmitted by a QRE. For example, in WREGIS, a generator with a nameplate capacity (AC
rating) of 360 kilowatts (kW) or less is eligible to self-report. It must submit metering records to
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substantiate its generation reporting by entering actual cumulative meter readings measured in
kilowatt-hours (kWh) or MWh, along with the dates of those readings, via a self-reporting
interface. A self-reporting generator owner must abide by the tracking system's requirements
when reporting generation data, and all self-reported data submissions are subject to the same
quality and auditing standards as generation data reported by a QRE. A self-reporting entity is
typically required to have a revenue-grade meter that meets ANSI standards (e.g., C-12) or
another industry-accepted, auditable, accurate system for metering, control, and verification.
Depending on the tracking system, actual cumulative meter readings must be entered monthly,
quarterly, or (at a minimum) annually. Self-reported data are typically validated against
expected output using an algorithm based on capacity and capacity factor.
1.5.4 Tracking characteristics for generators and generation attributes
Type of generation tracked
As discussed above, three of the nine tracking systems are "all-generation" systems that track
generation from all resource types, not just renewable generation. The other six are for
renewable generation only, but how renewable generation is defined is determined by how
state RPS programs define renewable or clean energy. Some states, for example, define the
incineration of municipal solid waste as renewable under their RPS policies, even though this
practice generates anthropogenic emissions from non-renewable feedstocks in the mixed solid
waste stream.
Multi-fuel generators
Multi-fuel generators can be registered in many tracking systems, and most systems provide
guidance for measurement or calculation of output attributable to each fuel type. These
generators are tagged within the tracking system as having a multi-fuel source. Some registries
issues independent certificates to each fuel involved in a multi-fuel generator, with those
certificates labeled as having come from a multi-fuel source.
Aggregation of small generators
Most tracking systems allow for the aggregation of small distributed renewable energy systems.
As noted above, all aggregate registrations come with limitations (e.g., be customer-sited, be
within the same state, be associated with the same revenue meter, use the same technology or
fuel type, be smaller than a certain size). For example, in NYGATS, a group of small generating
units that are not metered together and do not share the same location can be registered by
the mutual owner or by a generator agent as an aggregated project under the following
conditions: the nameplate capacity of each unit is no more than 200 kW, the aggregated
nameplate capacity is no more than 1 MW, the units are in the state of New York, and the units
use the same technology/fuel type. All aggregated projects must use a QRE to report generation
data.
Emissions data and sources
Several tracking systems have a data field for emissions or emission rates, but since most
systems track only renewables, the assumption is that they have zero emissions. The three all-
generation tracking systems (PJM-GATS, NEPOOL-GIS, and NY-GATS) include emissions data and
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calculate a residual mix, while the others do not.17 They rely on EPA- or state-agency-reported
emissions. Generators lacking continuous emissions monitoring may report emissions from a
proxy generator.
Generation unit of measurement
Tracking systems receive data in MWh and issue certificates in MWh (except for NVTRECS,
which issues certificates in kWh). Most also roll over any fractional MWh generation and issue
certificates to the generator when a full MWh is accumulated in the next issuing period. (ERCOT
is the exception: it rounds generation to the nearest whole MWh, with fractions of 0.5 MWh or
greater rounded up.) It is also common for tracking systems to allow small generators to
accumulate kWh and report when they reach a full MWh. In some cases, they may report
generation as infrequently as once a year.
Expiration of certificates
Tracking systems, especially all-generation tracking systems, are generally policy-neutral and
simply provide a framework and data requirement needs for compliance and voluntary
programs to implement requirements and policies. Consequently, most tracking systems do not
have expiration or requirements on the shelf-life of EACs.
17 Residual mixes are calculated based on the intended end use application of the residual mix. Further examination
of existing tracking system methodologies may be required based on the ultimate users intended use.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
2. Future needs of tracking system infrastructure
This section discusses emerging trends in energy procurement and energy policies and
regulations that may require changing how tracking systems verify electricity generation and
track energy attributes. These emerging trends include:
• International corporate GHG accounting standards (e.g., GHG Protocol).
• Corporate reporting.
• Emerging voluntary procurement strategies such as granular matching (i.e., hourly and
location-based).
• Low embodied emissions products (e.g., Hydrogen Production Tax Credit, cross-border
trade adjustments, environmental product declarations).
• Electricity supplier power source disclosure, including residual mix calculations.
These trends have resulted in an increased interest in a broader set of tracking applications and
increased need to validate electricity consumption.
2.1 International corporate GHG accounting standards
In the 1990s, the World Resources Institute and World Business Council for Sustainable
Development developed a set of international standards and guidance, referred to broadly as
the GHG Protocol. The GHG Protocol is the most widely used standard by organizations seeking
to measure their emissions in order to manage them.
The corporate standard guides organizations in how to account for the emissions resulting from
activities that occur within their operational boundary or footprint. The standard includes
methods for measuring the emissions associated with purchased energy, such as electricity that
an organization consumes. Suppliers and consumers of electricity rely on EACs to verify the
delivery and consumption of power, providing basic information about the attributes of energy
that a consumer uses. The GHG Protocol is used by an estimated 23,000 corporations globally,
establishing itself as the most widely used standard of its kind.
In 2024, GHG Protocol administrators began a significant update to its related standards and
guidance, including the scope 2 guidance focused on accounting for indirect emissions with
purchased electricity use.18 The GHG Protocol received input from more than 400 stakeholders
on the effectiveness and appropriateness of the current scope 2 guidance as well as feedback
on areas for updating the guidance. Feedback through this consultative process—including
feedback on implementing more granular time and location criteria associated with purchased
electricity—indicates more specific scope 2 guidance may be forthcoming. A more granular
reporting framework would require more granular data on current market instruments, such as
EACs. Furthermore, GHG accounting practices rely on residual mix calculations to avoid double
counting. Tracking systems play an important role in providing the necessary data to inform and
18 Greenhouse Gas Protocol. (2015). GHG Protocol scope 2 guidance: An amendment to the GHG Protocol corporate
standard, https://ghgprotocol.org/scope-2-guidance
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calculate a residual mix, which is used to describe unspecified power or the mix of resources
and emissions that consumers receive absent an active procurement of power from a specific
resource.
In 2023, voluntary corporate purchases of renewable electricity amounted to an estimated 319
million MWh within the United States.19 Also as of 2023, voluntary sales of renewable energy
accounted for about 48% of the total REC market, compared to 52% used for compliance with
state-mandated RPS. (See Figure 4.) S&P Global projects that voluntary demand will exceed
compliance demand in 2024 (at the time of this report, this annual data is not yet available).20
Corporate buyers of carbon-free electricity (CFE) are motivated by GHG accounting standards
and guidance around how they purchase, verify, and report their electricity choices and
consumption. Market trends in corporate GHG accounting suggest that U.S. tracking system
infrastructure may need to evolve to meet the changing needs of corporate accounting
standards and practices.
Revisions to the GHG Protocol standards are expected to be finalized by 2026. Based on topline
summaries of publicly available comments,21 the evolution of corporate GHG accounting
standards and guidance may necessitate the following enhancements to U.S. tracking system
infrastructure. The following list summarizes several capabilities that tracking systems may
consider in response to emerging trends in corporate GHG accounting practices.
Considerations for Tracking System Changes Related to Evolving International Corporate GHG
Accounting Standards
• Track energy sources and direct or stack emission rates for all generation.
• Record reasons for certificate retirement so corporate reporters can differentiate their voluntary
actions from mandated policies.
• Support full disclosure of resource mix and emissions for calculating residual mix to avoid double
counting.
• Track hourly and location based matching to consumption, as well as geographic and time
specificity for emissions matching, with more granularity.
• Adopt standardized procedures for tracking new and emerging technologies such as energy
storage, nuclear power, and carbon capture utilization and storage.
• Support standardized procedures that account for the energy inputs for product manufacturing
when evaluating a product's embodied carbon emissions.
Further needs, or revisions to these identified functionalities and capabilities, may be identified as
final revisions to the GHG Protocol are released.
19 National Renewable Energy Laboratory. (2024). The state of the U.S. voluntary green power market (2023 data)
[Conference presentation]. Renewable Energy Markets Conference.
https://www.nrel.gov/analvsis/assets/pdfs/status-and-trends-2023-data.pdf
20 Lenoir, T., & Wilson, A. (2024, February 22). Voluntary renewable energy certificates set to double state targets
past 2030. S&P Global, https://www.spglobal.com/market-intelligence/en/news-insights/research/voluntarv-
renewable-energy-certificates-set-to-double-state-targets-past-2030
21 Greenhouse Gas Protocol. (2024). Survey on need for GHG Protocol corporate standards and guidance updates.
https://ghgprotocol.org/survev-need-ghg-protocol-corporate-standards-and-guidance-updates
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2.2 Corporate reporting
Building off corporate GHG accounting standards and practices, corporations are also
increasingly reporting their emissions, either voluntarily or due to regulatory mandate. The
drive to report comes about through shareholders and investors requesting a company assesses
and reduces its climate risk.
2.2.1 Voluntary GHG emissions reporting
• Shareholder initiatives. Corporate shareholder activists are putting pressure on major
companies to report their carbon footprints and significant climate risks that could affect
their financial performance. Reuters reports that in 2024, shareholders filed 278 climate-
related proposals focusing on carbon pollution-reduction goals and strategies for
transitioning to a clean energy economy.22 Only a few proposals are ultimately approved
by shareholders, but many are withdrawn in exchange for corporate commitments to
take certain actions.
• CDP. The Carbon Disclosure Project was founded in 2000, to encourage and assist
companies in disclosing their GHG emissions. It has since broadened the scope of
environmental disclosure and expanded its outreach to support cities, states, and
regions. Over 23,000 companies, representing more than half of global market value,
currently report to CDP.23 CDP says that over 8,000 companies have committed to net
zero initiatives, and 96% of the world's top 250 companies report on sustainability.
• The Climate Registry (TCR). TCR, started in California in 2007, helps organizations in all
sectors reduce their carbon footprint. It has since broadened its focus to all of North
America. Currently, about 320 organizations report and verify GHG emissions inventories
through TCR.24
2.2.2 Mandatory corporate climate risk disclosures
• Federal requirements. On March 28, 2024, the Securities and Exchange Commission
(SEC) adopted final rules requiring certain companies to disclose climate-related risks:25
"The final rules require disclosure of Scope 1 and/or Scope 2 greenhouse gas (GHG)
emissions on a phased-in basis by certain larger registrants when those emissions
are material; the filing of an attestation report covering the required disclosure of
22 Spalding, K. S. (2024, July 15). Comment: Why climate-related shareholder resolutions are vital for markets.
Reuters, https://www.reuters.com/sustainabilitv/sustainable-finance-reporting/comment-whv-esg-shareholder-
resolutions-are-vital-strong-financial-markets-2024-07-15/
23 CDP. (2024, June 19). 1.5°C still the goal: Businesses disclosing climate transition plans jumps nearly 50% [Press
release], https://www.cdp.net/en/articles/media/15c-still-the-goal-businesses-disclosing-climate-transition-plans-
iumps-nearlv-50
24 The Climate Registry, (n.d.). About, https://theclimateregistrv.org/about/
25 The Enhancement and Standardization of Climate-Related Disclosures for Investors, 89 F.R. 21668 (proposed
March 28, 2024) (to be codified in 17 C.F.R. §§ 210, 229, 230, 232, 239, and 249).
https://www.federalregister.gov/documents/2024/03/28/2024-Q5137/the-enhancement-and-standardization-of-
climate-related-disclosures-for-investors
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such registrants' Scope 1 and/or Scope 2 emissions, also on a phased-in basis; and
disclosure of the financial statement effects of severe weather events and other
natural conditions including, for example, costs and losses."26
Affected companies must calculate both scope 1 and scope 2 emissions, provide
calculation methods, and disclose their use of carbon offsets and RECs. Although the
final rules do not specify the GHG Protocol as the accounting standard, it seems likely
that the revised GHG Protocol will influence how companies choose to report.
The final rules have been challenged in court and the SEC delayed the final rules of April
12, 2024, pending the completion of judicial review in the Eighth Circuit.27
• State requirements. Regardless of the court ruling on the SEC rules, state laws are likely
to result in similar outcomes. California has adopted two climate disclosure laws
requiring businesses to report their GHG emissions and climate-related financial risks:
o Senate Bill 253, the Climate Corporate Data Accountability Act, requires companies
with annual revenues over $1 billion to disclose their GHG emissions (scopes 1, 2,
and 3) to the state in accordance with the GHG Protocol Corporate Standard. The
first disclosures are required in 2026 for 2025 data. Companies must also pay an
annual fee and get third-party assurance of their reports.28
o Senate Bill 261, the Climate-Related Financial Risk Act, requires companies with
annual revenues over $500 million to disclose climate-related financial risks and their
mitigation strategies to the public every two years.29
Unlike the SEC rules, these state laws extend to private companies based on revenue
thresholds, not just to publicly traded companies. The California Air Resources Board is
responsible for issuing implementing rules for these laws.
• European Union (EU) requirements. The EU's Corporate Sustainability Reporting
Directive entered into force in early 2023 and will affect multinational companies doing
business in the EU.30 Beginning with the 2024 financial year (for reports published in
2025), large companies operating within the EU are required to disclose information
26 U.S. Securities and Exchange Commission. (2024). Fact sheet: The enhancement and standardization of climate-
related disclosures: Final Rules, https://www.sec.gov/files/33-11275-fact-sheet.pdf
27 The Enhancement and Standardization of Climate-Related Disclosures for Investors, 89 F.R. 21668 (proposed
March 28, 2024) (to be codified in 17 C.F.R. §§ 210, 229, 230, 232, 239, and 249).
https://www.federalregister.gov/documents/2024/03/28/2024-Q5137/the-enhancement-and-standardization-of-
climate-related-disclosures-for-investors
28 Persefoni. (2024, September 11). California SB 253 and SB 261: What businesses need to know. Insights.
https://www.persefoni.com/blog/california-sb253-sb261.
https://www.quarles.com/newsroom/publications/californias-new-climate-disclosure-and-ghg-related-claims-laws
29Persefoni. (2024, September 11). California SB 253 and SB 261: What businesses need to know. Insights.
https://www.persefoni.com/blog/california-sb253-sb261.
30 European Commission. (2024). Corporate sustainability reporting, https://finance.ec.europa.eu/capital-markets-
union-and-financial-markets/companv-reporting-and-auditing/companv-reporting/corporate-sustainabilitv-
reporting en
See also EU law: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464.
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regarding their scope 1, 2, and 3 GHG emissions as part of their mandatory sustainability
reports. The law applies to both listed and large private companies, with some non-EU
companies also required to report if they generate significant revenue within the EU
market.
Many companies are facing increasing requirements with respect to reporting emissions and
climate risks. Ensuring registries and tracking system infrastructure can support credible claims
about electricity consumption and related emissions—direct and indirect—will be critical for
accurate emissions accounting. Reporting companies need to get information specific to the
LSEs that serve them, including full disclosure about emissions associated with any LSE fossil
ownership or purchases. For unspecified purchases made by LSEs (i.e., from the spot market),
tracking systems need to report generation and emissions from generators even if the generator
is not registered with the tracking system for certificate issuance. This reporting enables a
complete disclosure of power resources and an accurate calculation of residual mix. The
following list summarizes several capabilities that tracking systems may consider in response to
evolving trends in corporate reporting.
Considerations for Tracking System Changes Related to Evolving Corporate Reporting
• Track energy sources and direct or stack emission rates for all generation.
• Record reasons for certificate retirement so that corporate reporters can differentiate their
voluntary actions from mandated policies.
• Support full disclosure of resource mix and emissions for each LSE and LSE electricity product.
• Support standardized procedures that account for the energy inputs for product manufacturing
when evaluating a product's embodied carbon emissions.
• Streamline the process for verifying that a generator is only registered in a single registry to
prevent double issuance.
Additional considerations may be identified as revisions to the GHG Protocol are released.
2.3 Voluntary procurement strategies
2.3.1 Annual matching
In the early years of green power markets, renewable electricity use was measured by the
quantity of renewable energy purchased relative to a company's annual electricity use within
the same market.31 Some utilities offered green power products that were a set percentage of
electricity from renewable sources. As renewable energy supply increased, corporations
stepped up and established targets of using renewable energy purchases to match 100% of their
annual electricity use, over and above state RPS requirements. As more companies achieved
this goal, some began to differentiate their success by emphasizing their impacts on renewable
energy development by sourcing their generation from new projects.
31 The United States has been defined as a single market for the purposes of GHG accounting. Nevertheless, some
buyers may prefer to purchase renewable energy that can be physically delivered to the U.S. subregions where
their facilities are located.
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It also became apparent, however, that not all companies have access or the ability to purchase
from an electricity supplier other than their local utilities. Choice of supplier or a preferred
product (e.g., source from a new project) is not an actionable choice in some regions of the
market; according to a study by EPA's Green Power Partnership, the only choice is unbundled
RECs for an estimated 22% of U.S. nonresidential consumers.32 Even if choices are available, not
all companies have the creditworthiness or purchasing power to enter into long-term contracts,
or balance sheets to help finance new projects. Smaller companies can find aggregating with
other buyers to be time consuming, requiring significant staff resources and technical expertise
that many buyers do not have in-house. Clearly, one size does not fit all. Creating more demand
is not enough for some buyers, but it's all that some can do. Purchasing EACs to match annual
load is still a necessary and appropriate target for many consumers. For GHG reporting,
consumers still need to know the emissions associated with their purchases.
2.3.2 Granular matching
More recently, numerous large energy consumers began pursuing more precise ways to match
electricity generation to their own electricity use, both on a temporal and a geographic basis.
• Temporal granularity. Because many renewable resources generate power
intermittently, their generation may not coincide with the timing of the consumer's
actual demand, undermining the consumer's goal of renewable electricity use or net
zero emissions claims on a granular level. In some cases, dispatchable sources of
generation may fill gaps when CFE cannot be delivered and matched to a consumer's
electricity demand. If consumers match their purchase of clean electricity to their own
electricity use profile, they can help ensure more credible usage claims and address
investment risk as more intermittent resources are added to the grid.33
In terms of hourly generation data, most tracking systems in the United States do not
currently issue certificates with hourly information. This information exists with the
balancing authorities or RTOs that control and dispatch regional generation but may not
be shared with all tracking systems. Most tracking systems do not request it because
they have not felt the need for that level of detail. Increasing granularity will require
specification and build-out of tracking system capability for systems that do not already
offer hourly data.
Some tracking systems have begun to act on hourly matching. M-RETS began tracking
hourly certificates in 2019 and demonstrated the ability to issue and track hourly
certificates in January 2021, supporting a Google transaction.34 PJM Environmental
Information Services, the manager of the Generation Attribute Tracking System,
announced in February 2023 that it will provide hourly, timestamped certificates for PJM
32 U.S. Environmental Protection Agency. (2022). National assessment of consumer access to green power supply:
Leadership and impact considerations (EPA 400-R-22-001). https://www.epa.gov/green-power-markets/leadership-
and-access
33 U.S. Environmental Protection Agency. (2024). 24/7 hourly matching of electricity, https://www.epa.gov/green-
power-markets/247-hourlv-matching-electricitv
34 M-RETS. (n.d.). Solutions: 24/7 hourly tracking, https://www.mrets.org/hourlvdata
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generation to those who want them.35 NEPOOL recently approved work on its NEPOOL-
GIS to support issuing and tracking hourly certificates on an opt-in basis.36 Other tracking
systems have also made progress towards offering granular data on certificates.
Some utilities, such as Entergy Arkansas and Nevada Power, have already entered
contracts with individual large customers to provide hourly matching services, and
Georgia Power and Duke Energy have proposed similar services.37
To help develop this hourly matching capability, EnergyTag, a nonprofit promoting net
zero electricity carbon accounting, has developed a Granular Certificate Scheme38 and a
Granular Certificate Matching Standard,39 where "granular certificate" represents both
temporal and geographic granularity. This standard provides a methodology that can be
used as a guide, or as a starting point for discussion, for tracking systems interested in
implementing hourly data tracking. Those who advocate for granular certificates may
want to consider the early experience of U.S. tracking systems creating hourly
certificates. For example, some tracking systems are adding hourly timestamps to annual
certificates rather than issuing individual certificates for every hour.
It is not only the private sector pushing hourly matching. At the federal level, EO 14057
requires federal agencies to "seek to match" electricity use with 50% CFE on an hourly
basis by 2030.40
It is important to note that providing hourly data is not a practical goal for all tracking
applications. There are still important applications, such as state RPS requirements and
environmental disclosure of electricity products to consumers, as well as voluntary
market participants and users, that will continue to depend on annual certificate data for
annual-based accounting.
• Geographic granularity. Also referred to as location matching, this means that
consumers try to purchase electricity from the same grid region where their facilities are
located. Tracking systems could record the location of each generator by latitude and
longitude, which are already recorded by generators reporting to EIA. Generators of less
than 1.0 MW not reporting to EIA would have to provide this information to the tracking
system upon registering. As part of retiring EACs, tracking systems could also support the
35 PJM-EIS. (2023, February 13). PJM EIS to produce energy certificates hourly [Press release], https://www.pjm-
eis.com/-/media/about-pim/newsroom/2023-releases/20230213-pim-eis-to-produce-energy-certificates-
hourlv.ashx
36 Lamson, J. (2024, September 8). NEPOOL Participants Committee votes to support hourly GIS tracking. RTO
Insider, https://www.rtoinsider.com/86808-nepool-participants-committee-support-hourlv-gis-tracking/
37 Hausman, N., & Bird, L. (2023). The state of 24/7 carbon-free energy: Recent progress and what to watch. World
Resources Institute, https://www.wri.org/insights/247-carbon-free-energy-progress
38 EnergyTag. (2024). Granular Certificate Scheme Standard: Version 2. https://energytag.org/wp-
content/uploads/2024/12/EnergyTag Granular-Certificate-Scheme-Standard-V2.pdf
39 EnergyTag. (2024). Granular Certificate Matching Standard: Version 1. https://energytag.org/wp-
content/uploads/2024/03/Granular-Certificate-Matching-Standard Vl.pdf
40 Exec. Order No. 14057. 86 F.R. 70935. https://www.federalregister.gov/documents/2021/12/13/2Q21-
27114/catalvzing-clean-energy-industries-and-iobs-through-federal-sustainabilitv
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ability to record the location where the beneficiary or owner of the retired EACs will be
claimed to enable consumers to match generation location to their own facility location.
• Electricity storage. Because of the intermittent nature of many renewable generation
resources, energy storage will play a much bigger role in temporal matching. Balancing
authorities are also finding storage increasingly important for grid management and
reliability. Absent storage, increasing the concentration of renewables in some regions
can result in curtailed energy dispatch, which does not result in any energy,
environmental, or economic benefits to the buyers or the grid.
Recognizing this fact, project developers are investing heavily in battery storage.41
Lithium-ion battery storage is dominant right now and may remain that way for the
foreseeable future, but its current application is in managing short-term variations in
electricity supply and demand. Questions remain about long-term seasonal storage,
where several technologies are still seeking commercialization.
In addition to smoothing imbalances between supply and demand—which is critical to
adding significantly more intermittent renewables, and hence to decarbonization—
storage is also important to enable consumers to match generation to their consumption
(e.g., 24/7) and can help achieve high matching rates at lower costs.
Tracking systems have not totally ignored storage, but it has historically been an
afterthought because it does not create any new energy. Tracking systems have been
careful not to double count the original generation and the energy released from
storage, but with the rapid and significant growth of storage installations, some co-
located with generation, some located for general grid support, measurement and
tracking of storage deserves more attention.
EnergyTag has proposed a new approach to tracking storage.42 Basic to the EnergyTag
approach is the idea of time-shifting. Storage devices enable time-shifting because they
are charged at one time and discharged at a later time. By tracking the attributes of the
electricity used to charge the device, and assigning the attributes to electricity
discharged at a different time, tracking systems can better support time-shifting.
Because storage enables time-shifting, storage tracking requirements are included as
part of a broader granular certificates (time and location) standard. While EnergyTag has
proposed a solution for tracking storage, it has not been widely implemented. Further
review and amendment may be required to suit the U.S. market.
• Emissions matching. Emissions matching is a purchasing strategy in which consumers
purchase zero-emissions EACs to match their electricity use, but from regions with the
41 Colthorpe, A. (2024, April 25). Energy storage market grew faster than ever in 2023, BESS [battery energy storage
system] was most invested-in energy tech, according to BNEF, IEA. Energy Storage News, h tt p s: //w w w. e n e rg v-
storage.news/energv-storage-market-grew-faster-than-ever-in-2023-bess-was-most-invested-in-energy-tech-
according-to-bnef-iea/
42 EnergyTag. (2024). 1.6.5: Time-shifting of storage input attributes to output. In: Granular Certificate Scheme
Standard: Version 2. https://energytag.org/wp-content/uploads/2024/12/EnergvTag Granular-Certificate-Scheme-
Standard-V2.pdf
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highest carbon emissions to maximize their emissions impacts. Advocates of emissions
matching say that choosing generation in locations with high average emissions will
minimize carbon emissions faster. A number of corporations, as well as the Clean Energy
Buyers Association, support emissions matching as well as hourly/location matching as
procurement strategies.
Emissions matching is also championed by the Emissions First Partnership. The Emissions
First principles encourage companies to invest in decarbonizing global electricity grids
and deploy capital to areas that have not historically benefited from corporate
investment in clean energy. They argue that an emissions-based approach ensures all
technologies are measured in the same manner: in tons of CO2 reductions.
Some companies emphasize purchasing from regions with the highest locational
marginal emissions (LMEs). One definition of LME follows:
"LME is a metric that measures tons of carbon emissions displaced by 1 MWh of clean
energy injected to the grid at a specific location and a specific point in time. LMEs are
calculated at each power system node in a manner similar to the Locational Marginal
Prices (LMPs) used to set wholesale electricity market prices. LMEs measure
emissions by identifying the marginal generators—the generators that would have
been producing energy but for the renewable injection to the grid at that location at
that moment."43
Tracking marginal emissions would require discussion and consensus among tracking
system representatives as to how "marginal" should be defined, particularly in terms of
location and time duration, so they can provide a consistent specification to grid
operators for emissions data. A consistent specification across tracking systems would
also be key for energy buyers as they seek to evaluate the emissions impact of various
purchase options.
There should be clear education and safeguards around applying marginal emissions
information to energy certificates, as EACs should not be treated as emissions
instruments, such as a project offset. While marginal emissions data are suitable for
targeting project and investment opportunities, EACs are fundamentally designed to
describe the power and source that generated it.
Given the multiple strategies pursued in the market surrounding clean energy investments,
registries and tracking system infrastructure need to track and capture data in ways that inform
sound business decisions resulting in consumer impact and allow purchasers to assess how well
they are meeting the objectives of their energy procurement strategies. The following list
summarizes several capabilities that tracking systems may consider in response to emerging
trends in voluntary procurement strategies.
43 Oates, D. L., & Spees, K. (n.d.). Locational marginal emissions: A force multiplier for the carbon impact of clean
energy programs. https://resuretv.com/wp-content/uploads/2022/Q3/REsuretv-Locational-Marginal-Emissions-A-
Force-Multiplier-for-the-Carbon-lmpact-of-Clean-Energy-Programs.pdf
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Considerations for Tracking System Changes Related to Emerging Voluntary Procurement Strategies
• Track energy sources and direct or stack emission rates for all generation.
• Standardize the method of determining marginal emission rates and track marginal emission rates
for hourly emissions matching.
• Make it easier to check across all tracking systems for duplicate generator registrations.
• Standardize a generator location data element (e.g., latitude and longitude) so it can be used to
associate generators with different geographic eligibility definitions for location matching.
• Issue hourly generation timestamps to annual certificates for temporal matching.
• Track retirements for compliance (by state) and for voluntary purposes to support residual mix
calculations, and track voluntary retirements by location of claim/beneficiaries to support location
matching.
• Adopt a more precise unit of measurement (watt hour [W hr] or MWh decimals) for shorter
intervals.
• Register storage devices and track inputs and outputs for hourly time shifting.
• Standardize how carbon capture, utilization, and storage will be tracked.
2.4 Low embodied emissions products
Looking beyond electricity generation, there is a growing need to track or verify carbon
emissions in intermediate and final products. Hydrogen is one such intermediate product and
can be used in producing final products. The United States has adopted new laws to encourage
hydrogen production, in part based on the embodied carbon emissions associated with
hydrogen production.
Environmental product declarations (EPDs) are useful tools to help identify low embodied
carbon products, and other federal initiatives are also driving policies in this direction. One
example is EPA's Construction Material Opportunities to Reduce Emissions (C-MORE) labeling
program focused on heavy construction materials.44 In a related fashion, international trade
policy based on embodied carbon emissions is also becoming a factor in manufacturing
competitiveness. The competitiveness of U.S.-made products abroad could be impacted by the
companies' ability to assess the emissions associated with the electricity used to manufacture
products.
These drivers require accurate and verifiable documentation to inform assessments of the
embodied emissions, which account for emissions released in all stages of creating a product.
Embodied emissions, as defined in EO 14057, are "the quantity of emissions, accounting for all
stages of production including upstream processing and extraction of fuels and feedstocks,
emitted to the atmosphere due to the production of a product per unit of such product."45
44 U.S. Environmental Protection Agency. (2024). C-MORE labeling materials & products.
https://www.epa.gov/greenerproducts/labeling-materials-products
45 Section 603. In: Exec. Order No. 14057. 86 F.R. 70935.
https://www.federalregister.gov/documents/2021/12/13/2021-27114/catalvzing-clean-energy-industries-and-iobs-
through-federal-sustainabilitv
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2.4.1 Hydrogen production
Hydrogen is an energy carrier. It can be used directly as a versatile fuel, but today it is most used
in petroleum refining and fertilizer production.46 Hydrogen is also being explored for use in
steelmaking, where hydrogen may replace coal; in making cement, another carbon-intensive
process; and other heavy construction materials.47
• The Inflation Reduction Act, passed by Congress and signed into law by President Biden
in 2022, creates a new tax credit through Section 13204 of the law that subsidizes the
production of clean hydrogen.48 This tax credit is usually referred to as simply "45V"
from its section in the Internal Revenue Code. The size of the 45V credit available to
hydrogen producers is based on emissions associated with hydrogen production and is
expected to stimulate the construction of electrolyzers that produce hydrogen using
electricity by separating water (i.e., H2O) into its molecular components, hydrogen and
oxygen. Electrolysis requires generating large amounts of electricity, which constitutes
the principal emissions involved with hydrogen production, hence the interest in
determining emissions.49
The Internal Revenue Service issued final rules to implement 45V on January 10, 2025.50
The final rules describe how to determine life cycle GHG emissions rates resulting from
hydrogen production processes, as well as other related issues. The rules are critical to
tax credit eligibility, and to understanding the kinds of support required from tracking
systems.
First, the final 45V rules define EACs and state that EACs, including those from
renewable sources issued through a registry or accounting system, must be used to
validate the emissions of electricity used in hydrogen production and the energy inputs
46 U.S. Department of Energy. (2017, February 21). Hydrogen: A clean, flexible energy carrier.
https://www.energv.gov/eere/articles/hvdrogen-clean-flexible-energy-carrier
47 Fuel Cell & Hydrogen Energy Association, (n.d.). Hydrogen in industrial applications.
https://www.fchea.org/hvdrogen-in-industrial-applications
48 Bergman, A., & Krupnick, A. (2022, August 29). How the Inflation Reduction Act can help hydrogen hubs succeed.
Resources, https://www.resources.org/common-resources/how-the-inflation-reduction-act-can-help-hvdrogen-
hubs-succeed/
49 There is also a 45Q tax credit based on carbon capture, utilization, and storage. This credit will likely be tapped by
hydrogen producers relying on a totally different technology, fossil fuel reformation. Both technologies
(reformation and electrolysis) are eligible for either 45V or 45Q credits, but not both credits. Resources for the
Future offers articles, issue briefs, and blog posts on the topic of hydrogen policy. See for example: Krupnik, A., &
Bergman, A. (2022, November 9). Incentives for clean hydrogen production in the Inflation Reduction Act. Resources
for the Future, https://www.rff.org/publications/reports/incentives-for-clean-hvdrogen-production-in-the-inflation-
reduction-act/
50 Credit for Production of Clean Hydrogen and Energy Credit (to be codified in 26 C.F.R. § 1).
https://federalregister.gOv/d/2024-31513
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used by taxpayers (i.e., hydrogen producers) under the 45VH2-GREET model.51 An
eligible EAC must provide the following information, as excerpted from the rules:
"(A) A description of the facility, including the technology and feedstock used to
generate the electricity;
(B) The amount and units of electricity;
(C) The COD [commercial operations date] of the facility that generated the
electricity;
(D) For electricity that is generated before January 1, 2030, the calendar year in
which such electricity was generated;
(E) For electricity that is generated after December 31, 2029, the date and hour
(including time zone, or in UTC) in which such electricity was generated;
(F) Other attributes required by 45VH2-GREET or in the determination of a PER
[provisional emissions rate] to accurately determine the emissions associated with
such electricity;
(G) For electricity generating sources that use carbon capture equipment, the
placed in service date of such equipment; and
(H)The project identification number or assigned identifier."52
A qualified EAC registry or accounting system, as excerpted from the 45V rules, is a
tracking system that:
"(A) Assigns a unique identification number to each EAC tracked by such system;
(B) Enables verification that only one EAC is associated with each unit of electricity;
(C) Verifies that each EAC is claimed and retired only once;
(D) Identifies the owner of each EAC; and
(E) Provides a publicly accessible view (for example, through an application
programming interface) of all currently registered generators in the tracking system
to prevent the duplicative registration of generators."53
Note that the above lists do not represent a comprehensive list of requirements.
For purposes of geographic eligibility, "region" is defined as any one of 13 regions in the
continental United States that corresponds to 72 Balancing Authorities listed in Table 1
to Section 1.45V-4(d)(2)(ix) of the final rule. This table is the definitive source for
51 Greenhouse gases, Regulated Emissions, and Energy use in Technologies (GREET®) is a tool used to assess a range
of life cycle energy, emissions, and environmental impacts. See U.S. Department of Energy, (n.d.) GREET.
https://www.energy.gov/eere/greet
52 Internal Revenue Code Section 1.45V-4(d)(2)(iii), Eligible EAC. https://public-inspection.federalregister.gov/2024-
31513.pdf
53 Internal Revenue Code Section 1.45V-4(d)(2)(viii), Qualified EAC registry or accounting system.
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identifying regions, but the regions are illustrated in Figure 6 below. Alaska, Hawaii, and
each U.S. territory will be treated as separate regions.
Northwest
Midwest
Mountain
Mid-Atlantic
Plains
lifornia
Southeast
Southwest
Alaska
Delta
Texas
Hawaii
Figure 6. Map of U.S. regions from DOE's National Transmission Needs Study (2023).
The 45V rule specifies that eligible EACs must meet the following requirements,
sometimes referred to as the "three pillars." These requirements are paraphrased from
the rule to save space. The final rule should be consulted for more details.
o Incrementality. The generating facility must have a COD no more than 36 months
before the hydrogen production facility was placed in service. If the generating
facility uses carbon capture and sequestration (CCS), the CCS technology must have a
COD no more than 36 months before the hydrogen production facility was placed in
service. An increase in nameplate capacity to an older facility may also be eligible if
the uprate occurred no more than 36 months before the hydrogen production
facility was placed in service and the incremental electricity is part of the generating
facility's uprated production. The rule also provides an opportunity for restarted or
decommissioned generating facilities, and existing nuclear facilities (with limits), to
qualify under certain conditions.54
o Temporal matching. EACs used to claim a hydrogen tax credit must be from
electricity generated in the same hour that the taxpayer's hydrogen production
facility uses electricity to produce hydrogen. Until January 1, 2031, a transition
period allows EACs generated in the same calendar year to be considered generated
in the same hour that the hydrogen production facility uses electricity to produce
hydrogen. Temporal matching may be assisted by electricity storage under certain
conditions:55
54 Internal Revenue Code Section 1.45V-4(d)(3)(i), Incrementality.
55 Internal Revenue Code Section 1.45V-4(d)(3)(ii), Temporal matching.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
The electricity represented by the EAC must be discharged from a storage system
in the same hour that the hydrogen production facility uses electricity to produce
hydrogen.
The storage system must be located in the same region as both the hydrogen
production facility and the facility generating the stored electricity.
The volume of electricity use substantiated by each EAC representing stored
electricity must account for storage-related efficiency losses.
EACs from stored electricity must reflect the energy attributes of the electricity
generating facility that provided electricity to the storage facility, and reflect the
temporal attributes regarding when the electricity is discharged from energy
storage.
The requirement that EACs be claimed and retired only once applies equally to
storage EACs.
o Deliverability. The 45V rule aims to connect sources of electricity generation to the
hydrogen production facility by ensuring that the electricity is actually deliverable to
the hydrogen production facility. Both the electricity generator and the hydrogen
production facility must be in the same region, and they must be physically
connected to a balancing authority (not necessarily the same one) in that region. An
interregional delivery of electricity is allowed if it meets certain conditions:56
The electricity generation represented by the EAC must have transmission rights
from the generator location to the region in which the hydrogen production
facility is located. That generation must be delivered to (i.e., scheduled and
dispatched or settled in) the hydrogen production facility's region.
The interregional delivery must be demonstrated on at least an hour-to-hour
basis, with no direct counterbalancing reverse transactions, and must be verified
with NERC E-tags or the equivalent.
The qualified EAC registry or accounting system for each eligible EAC
representing delivered electricity must track such delivery.
For electricity imported from Canada or Mexico, the electricity generator must
provide an attestation to the hydrogen production facility that the use or
attributes of the electricity represented by each EAC are not being claimed for
any other purpose.
The Hydrogen Production Tax Credit will face similar tracking challenges as hourly
matching, given that 45V also requires hourly and location matching. 45V incorporates
the requirement of "incrementality" by requiring that the generator powering the
electrolyzer be placed in service no more than 36 months before the hydrogen
production facility began operation. Tracking systems typically already record the
56 Internal Revenue Code Section 1.45V-4(d)(3)(iii), Deliverability.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
commercial operations date (COD), and have rules for uprating or adding capacity to
generators.
• The Infrastructure Investment and Jobs Act of 2021, also called the Bipartisan
Infrastructure Law, authorized DOE to spend $8 billion to create at least four "regional
clean hydrogen hubs."57 Clean hydrogen refers to hydrogen produced through
electrolysis using renewable or low-carbon emissions energy sources. Clean hydrogen
can also refer to hydrogen produced using thermal conversion processes with carbon
capture and permanent storage (CCS) technologies that reduce GHG emissions.
The hubs will be localized centers for the production, transportation, storage, and end
use of hydrogen that will help accelerate the large-scale production and use of clean
hydrogen. DOE has selected seven regional hubs with the intention of further developing
them into a national clean hydrogen network to facilitate the production and use of low-
emission hydrogen in sectors of the economy that will be difficult or impossible to
electrify.
The identified hubs in Figure 7 indicate the regions of the country where hydrogen
production is likely to occur first, and may require tracking system support to receive
available tax credits.
SELECTED REGIONAL CLEAN HYDROGEN HUBS
Pacific Northwest
Hydrogen Hub
Heartland
Hydrogen Hub
Heartland Hub(HH2H)
California
Hydrogen Hub
Alliance for Renewable Clean
Hydrogen Energy Systems
(ARCHES)
Midwest
Hydrogen Hub
Appalachian
Hydrogen Hub
Mid-Atlantic
Hydrogen Hub
OCED
Figure 7. Map of DOE-selected regional clean hydrogen hubs.
2.4.2 Product category rules and EPD for heavy construction materials
Product category rules (PCRs) and EPDs are tools used to assess the environmental impact of
construction materials. PCRs define the rules and requirements for creating life cycle
assessment (LCA) studies for specific product categories. EPDs summarize the results of LCA
studies for specific products or product categories. There are two types of EPDs: (1)
industrywide EPDs that provide a general understanding of the typical impact of a product but
57 See https://www.resources.org/common-resources/a-first-look-at-the-hvdrogen-hubs-decisions/ and
https://www.energy.gov/oced/regional-clean-hvdrogen-hubs-selections-award-negotiations.
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cannot be used to compare products, and (2) product-specific EPDs that represent the impacts
of a specific product and manufacturer across multiple facilities. It is expected that developing
EPDs, through funding from the Inflation Reduction Act, will accelerate embodied carbon
emissions data sharing and support federal, state, and local "Buy Clean" initiatives. It will also
add momentum to state, regional, and local low embodied carbon building code policies.
PCRs and EPDs are important because they:
• Promote transparency and completeness of LCA studies.
• Lead to consistent practices across industries.
• Make it easier for consumers to compare products by their embodied emissions.
LCA is the thread that connects PCRs and EDPs with two programs that are meant to help the
federal government procure construction materials with low embodied carbon. However, note
that the role of EAC tracking systems is to track emissions from electricity used in the various
stages of production, not to track the entire LCA. The two programs are:
• Federal Buy Clean Initiative. An often-overlooked source of GHG emissions is embodied
carbon in building and infrastructure construction. The Federal Buy Clean Initiative
promotes the use of construction materials with lower embodied emissions in federal
procurement and federally funded projects. The Buy Clean recommendations will
advance green building materials procurement for federal building and transportation
projects and are expected to stimulate private-sector demand for low-carbon versions of
concrete, steel, asphalt, and flat glass.
Inflation Reduction Act funding will enable the General Services Administration to
acquire and install low embodied carbon materials and products to use in constructing
or altering buildings under its control. Funding can also be used to support capital
investments at industrial facilities to decarbonize production of steel, cement, and other
hard-to-abate building materials.58
Beyond buildings, the Federal Highway Administration will provide incentives to eligible
recipients for using low embodied carbon materials and products in transportation
construction projects. This initiative is an important demand-side investment in
transportation infrastructure decarbonization, specifically for concrete, asphalt, and
steel materials. When leveraged as part of the transportation projects developed
through the Infrastructure Investment and Jobs Act, this investment could achieve
significant climate impact reductions and further catalyze regional supplies of low-
carbon cement and other materials.59
58 Olgyay, V., Tilak, A., & Usry, C. (2022, September 15). New White House "Buy Clean" guidance targets huge
emissions hidden in building materials. RMI. https://rmi.org/white-house-buv-clean-guidance-targets-emissions-in-
building-materials/
59 Olgyay, V., Tilak, A., & Usry, C. (2022, September 15). New White House "Buy Clean" guidance targets huge
emissions hidden in building materials. RMI. https://rmi.org/white-house-buv-clean-guidance-targets-emissions-in-
building-materials/
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• EPA's Federal Labeling Program. In support of the Inflation Reduction Act of 2022, which
among other things addresses embodied carbon in construction materials, EPA is
implementing the C-MORE labeling program. Through C-MORE, EPA and partner
agencies are developing strategies to support enhanced standardization, measurement,
reporting, and verification of EPDs to drive the market for lower embodied carbon
construction materials, with a particular focus on four key materials: concrete, glass,
asphalt and steel.60 C-MORE targets these construction materials because of the high
GHG emissions associated with their production and the large quantities purchased by
the federal government for federal buildings, highways, and infrastructure projects. The
C-MORE initiative will provide more impetus to address the challenge of tracking
embodied emissions and adds to the focus being brought by cross-border adjustment
mechanisms or carbon disclosure policies.
EAC or REC registries increasingly need to support the ability of manufacturers to describe the
energy inputs into their manufacturing processes so U.S. manufacturers can maintain their
competitiveness, as products will be assessed based on their embodied carbon.
Manufacturers seeking to assess emissions embodied in their products will be required to
validate the purchase and ownership of EACs from specified lower emissions electricity sources.
The EACs will enable manufacturers to calculate the life cycle emissions associated with the
electricity used in producing a product. Manufacturers, however, will be required not just to
demonstrate ownership of EACs, but also to show through EAC retirement which facility,
manufacturing process, and even product caused the underlying energy attributes to be retired.
Essentially, corporations that have purchased EACs at a corporate account level will be required
to allocate and document through the retirement process where in the manufacturer's footprint
an EAC was applied. Verifiers have expressed that having this disclosure on the EAC retirement
report will greatly facilitate audits and verification processes.
Tracking embodied emissions is important not only domestically for U.S. industry,
manufacturing, and consumers, but also for U.S. jobs and global competitiveness if faced with
tariffs based on a product's embodied emissions, as discussed next.
2.4.3 International trade policy
Tariffs may be imposed on critical products imported from countries that subsidize specific
manufacturing industries, and consequently whose products may be cheaper than similar
products made in the United States. Cross-border adjustment mechanisms are a form of tariff
intended to protect the competitiveness of domestic industries under carbon regulation, such
as cap and trade, where a competing country may have a cost advantage because its industry is
not required to meet an equivalent standard. The EU has already adopted such a law, as
described below.
• Carbon Border Adjustment Mechanism (CBAM). This law will affect some U.S. exports
to the EU; it intends that certain goods imported into the EU must meet the same
60 See https://www.epa.gov/greenerproducts/cmore.
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emissions standards as required by the EU Emission Trading Scheme (ETS), a cap-and-
trade program. The products initially affected by the law are in the industrial sectors of
aluminum, cement, fertilizers, iron and steel, chemicals (only hydrogen at this time), and
electricity. CBAM took partial effect October 1, 2023, and enters into full force January 1,
2026.61
Companies exporting these types of products to the EU, called CBAM declarants, must
register in the CBAM registry. Their emissions responsibility is based on the average
emissions intensity of the exporting country. To the extent their average emissions
exceed the EU baseline, they must pay for CBAM certificates at the weekly average price
of EU ETS emission allowances.
CBAM declarants may get credit for a carbon price paid in the country of origin, in the
form of a carbon tax or emission allowances under a GHG emissions trading system.
Further, to the extent that companies can prove they have reduced their emissions in
the country of origin, they may reduce their obligation to purchase CBAM certificates by
proving lower direct and indirect emissions.62 The emission factor for electricity must be
backed by a power purchase agreement (PPA). Discussion is ongoing regarding whether
financial or virtual PPAs (or EAC contracts) will be included in the definition of a PPA.
CBAM and other carbon border adjustments are complex, requiring detailed accounting
of emissions (for CBAM, the metric is tonnes of CO2 equivalent per tonne of goods), and
the tracking implications are broad, pertaining to all sources of electricity generation, as
well as other inputs.63
For companies in the United States, the motivation will be to demonstrate lower
emissions from electricity generation used in manufacturing the specified industrial
materials and to document the embedded emissions at every stage of production
leading up to export to the EU. Tracking systems may play a key role in documenting and
verifying the emissions of electricity inputs into the manufacturing process for the
specified products.
• U.S. manufacturer competitiveness. The EU CBAM policy may stimulate trade policies in
the United States to protect domestic manufacturing competitiveness. Several pieces of
legislation were proposed in the U.S. Senate in the 118th Congress:
61 Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon
border adjustment mechanism. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0956. This
summary is a much simplified version.
62 The EU law calls these "embedded" emissions, whereas U.S. policy calls them "embodied" emissions.
63 Kopp, R. J., Rennert, K., & Pizer, W. (2023, October 4). Sailing uncharted waters: International trade becomes an
element of climate policy. Resources, https://www.resources.org/archives/sailing-uncharted-waters-international-
trade-becomes-an-element-of-climate-policv/
Elkerbout, M., Kopp, R. J., & Rennert, K. (2023, December 6). Comparing the European Union Carbon Border
Adjustment Mechanism, the Clean Competition Act, and the Foreign Pollution Fee Act. Resources for the Future.
https://www.rff.org/publications/reports/comparing-the-european-union-carbon-border-adiustment-mechanism-
the-clean-competition-act-and-the-foreign-pollution-fee-act/
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o The Fair. Affordable. Innovative, and Resilient Transition and Competition Act, or FAIR
Act, sponsored by Senator Chris Coons (D-DE).
o The Clean Competition Act (CCA), introduced by Senator Sheldon Whitehouse (D-RI).
o The Foreign Pollution Fee Act, introduced by Senators Bill Cassidy (R-LA), Lindsey
Graham (R-SC), and Roger Wicker (R-MS).64
These bills were not adopted, but different proposals may be forthcoming in a new
Congress. It is worth noting that members of both parties in the Senate recognize the
risk to U.S. export industries, and are aware that international tariffs currently have the
lead in defining what will be required of imports to the EU. The following list summarizes
several capabilities that tracking systems may consider in response to increasing interest
in low embodied emissions products.
Considerations for Tracking System Changes Related to Interest in Low Embodied Emissions
Products
• Track energy sources and direct or stack emission rates for all generation for carbon disclosure
requirements and embodied emissions calculations.
• Streamline the process to determine duplicate generator registrations, which could be done if
each system adopted and used a standardized application programming interface (API) framework
to provide access to its currently registered generators.
• Enhance retirement purpose data fields to allow consumers to identify the application of the
retired EACs, such as for hydrogen production, or for specific facilities or locations.
• Standardize CODs (or placed in service dates) to determine incrementality eligibility, and track
generator uprate output separately to qualify that output for hydrogen production tax credits.
• Standardize a generator location data element (e.g., latitude and longitude) so it can be used to
associate generators with different geographic eligibility definitions for determining tax credit
eligibility and for location based voluntary procurement strategies.
• Issue hourly generation timestamps for temporal matching to help determine eligibility for
hydrogen production tax credits.
• Adopt a more precise unit of measurement (W hr or MWh decimals) for shorter intervals.
• Register storage devices and track inputs and outputs for hourly time shifting.
• Track embodied carbon emissions from electricity generation for electricity used in raw material
production as well as consumer product manufacturing.
• Standardize how carbon capture, utilization, and storage will be tracked for tax credit eligibility.
64 For reviews of these bills, see:
• Kopp, R. J., Pizer, W., & Rennert, K. (2023, October 10). Carbon border adjustments: Design elements, options,
and policy decisions. Resources for the Future, https://www.rff.org/publications/reports/carbon-border-
adiustments-design-elements-options-and-policv-decisions/
• Elkerbout, M., Kopp, R. J., & Rennert, K. (2023). Foreign Pollution Fee Act: Design elements, options, and policy
decisions. Resources for the Future, https://www.rff.org/publications/issue-briefs/foreign-pollution-fee-act-
design-elements-options-and-policv-decisions/
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2.5 Utilities and other retail electricity suppliers
In some states, LSEs (i.e., retail electricity suppliers) are required to disclose to their customers
the generation sources, and related emissions, supplied for consumer use. Even when not
required, many corporate consumers across the country report their emissions from electricity
use voluntarily, and they need this information from their LSEs. In addition, a few utilities are
trying to provide hourly matching supply options, and the federal government has entered into
agreements with LSEs to obtain CFE for federal facilities. These efforts are described below.
• Power source and emissions disclosure. Nineteen states require utilities and other LSEs
to disclose their power sources; some of these states also require associated emissions
to be disclosed in consumer labels.65 Generally, these labels have prescribed information
and formats, like nutrition labels for food products, but the method of calculating
sources and emissions is not always specified.
Power source and emissions disclosure is about electricity delivered to consumers.
Reporting generation owned by the utility, or generation purchased by the LSE, is not
sufficient if that power is resold in the wholesale market. The retail power products
should be verified by EACs owned and retired by the LSE on behalf of its consumers, and
they should be specific to differentiated products so all customers of the LSE are not
reported to be using the attributes of the green power sold only to customers paying for
that product. These needs are best supported by all-generation tracking.
A complete accounting of power sources and emissions requires calculating residual
mixes, which consist of "the attributes of unallocated or unclaimed energy delivered to
customers on the electricity grid and are a critical tool that prevents the double counting
of clean energy and supports accurate calculations of greenhouse gas emissions
resulting from electricity use."66 Essentially, each retail product marketed as renewable
energy must be matched with EACs.67 If there are fewer EACs than M Wh sold of that
product, the shortfall of MWh not covered (often referred to as "null power") should be
assigned the residual mix attributes. A tracking system is uniquely positioned to inform a
calculation of the residual mix and assign it, as needed, to each LSE and LSE product.
Whether or not a state requires power source and emissions disclosure, many corporate
consumers need this information to complete their carbon emissions inventories and
report to CDP, The Climate Registry, or other target-based programs. The GHG Protocol
65 Sedano, R. P. (2002). Electric product disclosure: A status report. National Council on Competition and the Electric
Industry. https://www.raponline.org/wp-content/uploads/2023/09/rap-sedano-electricproductdisclosure-20Q2-
07.pdf
66 Center for Resource Solutions. (2024). Guidance for calculating residual mix. https://resource-
solutions.org/document/030624/
67 According to the Federal Trade Commission's Guides for the Use of Environmental Marketing Claims, "A marketer
should not make unqualified renewable energy claims...if fossil fuel, or electricity derived from fossil fuel, is used to
manufacture any part of the advertised item or is used to power any part of the advertised service, unless the
marketer has matched such non-renewable energy use with renewable energy certificates"
(https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revised-green-
guides/greenguides.pdf).
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Scope 2 Guidance recommends the following order of preferred sources for the market-
based accounting method using emission rates from data sources with the greatest
precision:
o Emission rates from EACs purchased and retired on behalf of the consumer.
o Emission rates from generation purchased or contracts (e.g., PPAs) from specified
sources.
o Supplier or utility emission rates for products sold to consumers and disclosed
publicly.
o Residual mix emission rates.
o Grid average emission rates.68
• Community Choice Aggregations (CCAs). CCAs allow local governments to procure
power on behalf of their residents, businesses, and municipal accounts from an
alternative supplier while still receiving transmission and distribution service from their
existing utility provider. CCAs are currently authorized in California, Illinois, Maryland,
Massachusetts, New Hampshire, New Jersey, New York, Ohio, Rhode Island, and Virginia.
As an example, Peninsula Clean Energy is a CCA serving California's San Mateo County,
providing electricity from clean energy sources at lower rates than the incumbent utility.
Its current goal is 100% clean energy, and 100% renewable energy by 2030, while
maximizing 24/7 energy matching on a time-coincident, hourly basis. See "Granular
Matching" above.
• Utility plans to serve federal government facilities. At the time of writing, large utility
groups are responding to the federal government's interest in transitioning to 100% CFE.
In response to EO 14057, the federal government is working with numerous large
utilities to fulfill the order's goal of achieving 100% CFE on an annual basis and to match
use on an hourly basis to achieve 50% 24/7 carbon pollution-free electricity by fiscal
year 2030.69 Some examples include:
o Entergy Arkansas and the General Services Administration entered a memorandum
of understanding in which Entergy agreed to design and file a CFE tariff by the end of
2022 to help achieve the federal government's sustainability goals in the state of
Arkansas.
o Xcel Energy has entered a similar memorandum of understanding to serve federal
facilities in Minnesota, Michigan, North Dakota, South Dakota, and Wisconsin with
100% CFE by 2030.
68 See p. 48 in Greenhouse Gas Protocol. (2015). GHG Protocol scope 2 guidance: An amendment to the GHG
Protocol corporate standard, https://ghgprotocol.org/scope-2-guidance
69 Section 203. In: Exec. Order No. 14057. 86 F.R. 70935.
https://www.federalregister.gov/documents/2021/12/13/2021-27114/catalvzing-clean-energy-industries-and-iobs-
through-federal-sustainabilitv
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o The Southern Company has agreed to develop CFE options for federal facilities in its
service territories in Georgia, Alabama, and Mississippi.
o El Paso Electric has agreed to develop CFE tariffs or other offerings for federal
facilities in the company's service territory in southern New Mexico and western
Texas.
o The federal government issued a request for information in 2024 to serve Mid-
Atlantic and Midwestern states, and the General Services Administration and U.S.
Department of Defense are seeking utility partners to similarly serve defense
facilities.
The following list summarizes several capabilities that tracking systems may consider in
response to emerging trends through utilities and retail electricity service suppliers. These
capabilities would provide load-serving entities with the ability to track delivery and control of
EACs, calculate residual mix for the load they serve, verify hourly matching, and generally keep
track of goals achievement.
Considerations for Tracking System Changes Related to Emerging Trends Through Utilities and Other
Retail Electricity Suppliers
• Track energy sources and direct or stack emission rates for all generation for accurate carbon
emissions disclosure.
• Track certificate retirements for compliance by state, and retirements for voluntary purposes to
support residual mix calculations and avoid double counting.
• Support full disclosure of resource mix and emissions for each LSE and LSE electricity product.
• Support calculation of residual mix by each LSE and for each LSE product.
• Make it easier to check across all tracking systems for duplicate generator registrations, which
could be done if each system adopted and used a standardized API framework to provide access
to its currently registered generators.
• Track greater granularity, such as hourly and location based matching to consumption, and
geographic and time specificity for average and marginal emissions matching.
2.6 Definitions, requirements, and procedures considerations
The following list of definitions, requirements, and procedures indicates areas where tracking
systems may not show clear consistency in application. The discussion for each item in the list
relates to the challenges in equal treatment of generators and generation to be eligible for
federal programs. They are identified here as potential issues for discussion by registry
operators to determine if differences in language potentially create inconsistent treatment, and
whether the language could or should be standardized.
2.6.1 Definitions
• Generator. The hydrogen tax credit Section 45V rule requires information about the
"generator" because it needs to track emissions associated with electricity used to
produce the hydrogen. But it also refers to "generator" as a "generating facility."
Registries sometimes use slightly different terminology such as "generating facility,"
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"generating project" and "generating unit." The differences in terminology may or may
not be significant, but consistent definitions and treatment by tracking systems is
important. A potentially useful guide is provided by EIA Form 860 for generator
reporting.
• Commercial operation date. The COD is the date when a generator first began operation
affects eligibility for some state RPS policies; voluntary markets have a recommended
15-year eligibility for generators serving voluntary consumers. To be eligible for
hydrogen tax credits, a generator must have commenced operation no more than 36
months before the hydrogen production facility was placed in service. Most registries
require a COD, which is usually determined as a date entered by the generator registrant
with no apparent verification and no definition. For example, it might be determined by:
o Start-up
o Pre-test
o Operational certification
o Date of approval to interconnect
A COD needs a more precise definition to ensure generators in different tracking regions
are treated equally.
• Generator location. The deliverability requirement for the hydrogen tax credit requires
qualifying EACs to represent electricity produced by an electricity generating facility in
the same region as the relevant hydrogen production facility. The location of an
electricity generation source and the of a hydrogen production facility will be based on
the balancing authority to which it is electrically interconnected (not its geographic
location), with each balancing authority linked to a single region.70 A region, according to
the 45V definition, "means a Region that corresponds to a Balancing Authority, as
identified in the following table."71i°BJ]The balancing authority for each generator is
reported on Form EIA-860.
For other programs, such as location matching, the location information currently
collected by registries may be:
o ZIP Codes
o Latitude or longitude
o Mailing addresses
o Physical addresses
o States
70 The MISO balancing authority is an exception because it is split into two U.S. regions, as shown in the map
located at GREET User Manual as of December 26, 2023. Alaska, Hawaii, and each U.S. territory will be treated as
separate regions.
71 The table referred to is shown in Section 1.45V-4(d)(2)(ix).
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
o Balancing authorities
To support this program or procurement strategy, it will be important that potential
buyers of EACs can consistently identify generator location by their balancing authority
and regions, by consulting a tracking system's public list of generators, or via an API.
Tracking systems and program managers should discuss whether each certificate should
carry this location data point.
• Repowering or uprates. Adding capacity to a generation project is often called
repowering and sometimes called an uprate. Definitions of both terms offered by EIA
refer to any increase in rated nameplate capacity.72 The incremental capacity may only
be eligible for some programs based on the increment's COD. Therefore, the incremental
capacity and the COD for that increment are important data points, and the incremental
output may have to be metered separately. As part of reviewing this issue, tracking
systems should consult Instructions for Form EIA-860, or with EIA staff, to determine a
threshold for repowering. A consistent approach may be seen as fair.
2.6.2 Requirements
• Meter quality. Tracking systems generally require a "revenue-grade meter" for
measuring generation. Operating procedures mention an MV-90 system, pulse
accumulator readings collected by the control area's Energy Management System, or
ANSI C-12 standard or its equivalent. The differences are not obvious, and perhaps not
significant, but it would be a topic for discussion and harmonization so all generators in
similar situations are treated equally.
• Verification. Most tracking systems support using independent reporting entities that
are registered and qualified to report generation data to the tracking system on behalf of
generators that are not settled in the control area markets. For quality control reasons, it
may be helpful to create a comprehensive or consolidated list across tracking systems of
such approved reporting entities, for two reasons:
o It may make it easier for small generators in need of such independent parties to find
one.
72 The EIA glossary (https://www.eia.gov/tools/glossarv/index.php) defines these two terms as follows:
• "Uprate: An increase in available electric generating unit power capacity due to a system or equipment
modification. An uprate is typically a permanent increase in the capacity of a unit."
• "Repowering: For power plants that use combustible fuel, repowering refers to refurbishing a plant by
replacing the power-generating technology with a new prime mover and energy source (for example,
switching from coal to natural gas). As a result of this replacement, the plant's efficiency usually improves, its
emissions decline, or its generation capacity increases. The repowering process usually uses existing facility
infrastructure (for example, roads, buildings, interconnection equipment, and fuel and ash storage and
handling). For wind farms, repowering refers to replacing existing wind turbines with new, generally larger and
higher capacity turbines or with more efficient components. These replacements result in increased
nameplate capacity or convert kinetic wind energy into electricity more efficiently. When a wind farm
undergoes a full repowering, the existing turbines are replaced with newer turbines and new towers and
foundations are often installed. When a wind farm undergoes a partial repowering, the existing towers and
foundations are usually retained, while the turbines and other components are replaced."
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
o A list could be used to record problems that arise with the reporting from such
registered entities, identify the types of problems that arise, and identify whether
problems tend to occur with some independent reporters more than others.
This information would make it easier to spot patterns and recurring problems that
could then be corrected more easily, particularly across tracking systems via an API.
2.6.3 Procedures
• Generator registration. The rule for hydrogen production tax credits defines a "qualified
EAC registry or accounting system" as one that, among other things, "Provides a publicly
accessible view (for example, through an application programming interface) of all
currently registered generators in the tracking system to prevent the duplicative
registration of such generators."73 Most of the tracking systems do make public a list of
registered generators, but there is no easy way to check for duplicative registrations
across tracking systems. A comprehensive list of registered generators, searchable by
name and location, could help prevent duplicate registrations. Alternatively, the
suggested API could facilitate such checking by the registries themselves and by national
program operators doing their due diligence.
• Generation data communication. Tracking systems accept different methods of
reporting dynamic data, including downloads from balancing authorities, telemetering
from individual generators, third-party manual reporting, and in some cases self-
reporting. It might be helpful if these approaches could be harmonized so all generators
(in their own size class or situation) are treated similarly. Tracking systems generally have
safeguards related to third-party reporting and the relationship of the third party to the
generator. Generators that self-report generation, typically of small capacity, should be
noted as such (either on the generator profile, list of generators, or the EACs issued to
the generator owner) since there is a potential conflict of interest.
• Generation data validity checks. Most tracking systems use engineering algorithms to
check whether reported generation is realistic or likely misreported as greater than what
is technically possible. These validity checks usually apply to specific types of generators,
typically small or distributed generators. It may be helpful for tracking systems to
standardize the types of generators to which this method of error detection applies, as
well as to adopt a consistent margin of error that would be accepted or trigger review.
The goal of validity checks is to ensure generators are treated equally and generation
quantities are equally reliable.
• Multi-fuel generators. Some tracking systems enable generators that use multiple fuels
to register for certificate issuance subject to an approved methodology for allocating
production by fuel type. It is difficult to tell if this allocation formula is unique to each
situation, or if it is amenable to a consistent logic, if not formula. It may be helpful if
registries jointly review how they enable generators to use multiple fuels and how they
might harmonize their approach so emission attributes could be appropriately assigned.
73 Internal Revenue Code Section 1.45V-4(d)(2)(viii), Qualified EAC registry or accounting system.
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In addition, some tracking systems accept de minimis amounts of fuel feedstocks when
fuel inputs are reported for multi-fuel generators. The threshold that defines de minimis
may be important to determining eligibility for production tax credits or embodied
emissions for CBAM, possibly triggering ineligibility.
• Interconnection verification. Some, but not all, tracking systems register and issue
certificates to off-grid generators. Because some market participants or program
operators prefer to recognize EACs that affect grid operation and emissions, it is
important to distinguish between generators that are connected to the grid and those
that are not. Furthermore, the hydrogen production tax credit rule requires that the
generator and electrolyzer be located in the same region. This requirement means
regulators must be able to verify that the generator to which the EACs were issued is
interconnected to the same physical grid in which the hydrogen producer consumes
electricity. Hence, it must be possible to distinguish EACs from different grid regions.
Tracking systems might collaborate to determine if the interconnection location should
appear on the certificate, as part of the public list of generators, or should be accessible
via an API.
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3. Conclusion
Tracking systems play an important role in supporting well-functioning and credible clean
energy markets. The nine tracking systems operating in the United States are responsible for
issuing and retiring EACs to support credible claims and to track reporting for both compliance
and voluntary purposes. As such, they do critical work to account for energy attributes and
avoid double counting and double claiming of energy on a shared grid. They establish ownership
rights and ensure credibility for the many market participants that trade in EACs.
U.S. tracking systems have been responsive to their stakeholders and are especially strong in
supporting the electricity policies and accounting needs of the states that they serve. They also
perform an important function in enabling demand for clean electricity within the voluntary
market to thrive and grow.
Several new policies and emerging market trends may require that U.S. tracking systems expand
their functional capabilities to meet the market's need. New federal tax credits and emerging
voluntary procurement practices necessitate the credible tracking of energy attributes to
capture a broader set of generating resources and granular generation data on a temporal,
locational, and potentially emissions basis. These new demands are driven by market
participants, standards-setting organizations, the federal government, and even international
legislation. While U.S. tracking systems originated from state regulatory requirements, such as
renewable or clean energy portfolio standards and electricity source and environmental
disclosure policies, the emergence of a growing voluntary market may require further attention
from tracking system operators, who may need engage with stakeholders that have been less of
a focus in the past.
The federal government seeks to support consistency, uniformity, and credibility within markets
that support U.S. electricity consumers and those that rely on tracking systems. Although the
nine tracking systems are similar in many ways, there may be opportunities for collaboration
(with each other and with affected stakeholders) to harmonize the details of their evolution and
implementation to meet emerging market needs. A collaborative response from tracking
systems would serve federal, state, business, and market interests and needs.
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Appendix A. Potential key features of a "North Star" energy attribute tracking
system
The table below describes a set of characteristics and capabilities that, together, make up a
hypothetical tracking system called "North Star." These characteristics and capabilities could
serve as a guide as features are added to U.S. tracking systems. They fit into three broad
categories:
• Standardizing and enhancing already existing functional capabilities
• Responding to new programs and market needs
• Developing consistency in definitions, requirements, and procedures among tracking
systems to support national programs.
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
All-generation tracking
Expand tracking of energy sources and direct/stack emission rates for all
generation. Some tracking systems already do this, and tracking all
generation has become increasingly important for corporate emissions
accounting; calculating residual mix; and tracking embodied emissions for
EPDs, energy-intensive construction materials, and international trade.
Tracking all generation would not require all generators to register with the
tracking system, but all generation would need to be reported to the
tracking systems by balancing authorities. The GHG Protocol calls for
assigning residual mix attributes to load not covered by specified
certificates. Three all-generation tracking systems already do this, and the
LSEs that use these tracking systems can use the residual mix to provide a
complete accounting for each of their electricity products. This practice
could be standardized and followed by the other tracking systems. Tracking
all emissions is essential to tracking energy storage, which is also key to
achieving accurate 24/7 emissions accounting and in emissions matching.
Looking ahead, tracking all generation may be increasingly important as
CCS enters the commercial market. Emerging applications (corporate
accounting, 24/7, 45V, border adjustment mechanisms, EO 14057) are all
about emissions, and the whole picture will not be clear unless emitting
generation is tracked along with non-emitting generation.
API for generator
registration
Streamline the process for verifying that a generator is registered in a
single registry to prevent double issuance of EACs. Each tracking system
provides a public list of registered generators, but there is also a benefit to
checking all registries for national programs. An API would make it easier to
check across all tracking systems for duplicate generator registrations. It
would be beneficial if tracking systems routinely facilitate APIs for
generator registration or for account holders. Some users, particularly
those pursuing hourly and location matching, are looking for APIs to
support data aggregation by location and by hour across tracking systems,
and to provide streamlined and third-party access in support of hourly and
location matching.
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"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Carbon capture and
sequestration (CCS)
Standardize how CCS will be tracked. CCS is eligible for hydrogen tax
credits and will figure increasingly in broader carbon reduction efforts.
Tracking systems should work on a consensus proposal about the best
way(s) to measure and verify CCS. CCS relates to sections 45Q and 45V of
the tax code and tax credits for hydrogen producers using CCS. Eligible
hydrogen projects must capture a "qualified carbon oxide/' which the
statute defines broadly as any C02 that is captured by eligible industrial
(e.g., ethanol, steel, cement, and chemicals), power (coal, natural gas, and
biomass-fired power plants), and direct air capture facilities.
eGRID residual mix
Support the calculation of a residual mix. EPA's eGRID produces average
emission rates for several levels of geography, and these emission factors
are used widely by companies reporting their carbon emissions footprint.
As renewable energy claimed by the voluntary market and retired for RPS
compliance has grown, however, the overlap between average grid
emissions and privately claimed zero emission resources results in
increasing double counting. To incorporate a residual mix emission factor
into eGRID, EPA needs to know the number of certificates that are retired
each year. Most of the information used for eGRID comes from generator
reports to EIA, but retired and claimed certificates, in aggregate, are known
only to the tracking systems. To calculate residual mix for regions,
subregions, states, EPA seeks to work with each tracking system to publish
an annual public report showing (1) the number of zero emission
certificates issued, by location of generation (state, eGRID subregion,
balancing authority); (2) the number of certificates retired for compliance,
by state for which the compliance is claimed, by vintage, and by location of
generation (state, eGRID subregion, balancing authority); and (3) the
number of certificates retired for voluntary claims, by location of
generation (state, eGRID subregion, balancing authority), and by location
of purchaser/beneficiary (state, eGRID subregion, balancing authority). In
addition to an annual public report, it would be desirable to share this
aggregated information electronically with EPA directly. For hydrogen 45V,
it would improve accuracy and reduce double counting if the regional
residual mix were calculated.
Embodied emissions
Support standardized procedures to document embodied carbon
emissions, from initial electricity generation to electricity used in raw
material production to electricity used in consumer product manufacture.
EO 14057 establishes a "Buy Clean" Task Force to expand consideration of
embodied emissions and pollutants of construction materials in federal
procurement and federally funded projects. Embodied emissions also play
an important role in U.S. exports to Europe because of the EU CBAM and
would undoubtedly play an important role in similar carbon assessments
that might be adopted for imports to the United States. Tracking the
multiple stages of processing from electricity generation to raw material
production to refined consumer product will require some reimagining
how certificates are used and tracked.
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"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Energy storage
Adopt standardized procedures for tracking energy storage. Most tracking
systems currently do not issue certificates for storage because the energy
used for charging is not known. Tracking systems will need to register
storage devices and track inputs and outputs for hourly time-shifting. With
the expected tremendous growth of battery storage, a more systematic
approach should be adopted. One proposal includes EnergyTag's Granular
Certificate Scheme Standard (Section 1.6), which provides the most
detailed approach.
Generator
Consider normalization of terminology across tracking systems. The
hydrogen tax credit (45V) rule requires information about a "generator"
because it needs to track emissions associated with electricity used to
produce the hydrogen. But it also calls it a "generating facility." Registries
sometimes use slightly different terminology, such as "generating facility,"
"generating project," and "generating unit." The differences may or may
not be meaningful, but a useful guide is provided by EIA Form 860 for
generator reporting.
Generation data
communication
Harmonize energy generation reporting methods and practices. Tracking
systems accept different methods of reporting dynamic data, including
download from balancing authorities, telemetering from individual
generators, third-party manual reporting, and in some cases self-reporting.
It would be helpful if these approaches could be harmonized so that all
generators (in their own size classes or situations) are treated similarly.
Tracking systems generally have safeguards related to third-party reporting
and the relationship of the third party to the generator. Generators that
are self-reported, although typically of small capacity, should be noted as
such (either on the generator profile/list of generators or on the EACs
issued to the generator owner) since there is a potential conflict of
interest.
Generation data validity
checks
Develop and apply consistent methodologies for validating the technical
potential of generators to be issued EACs. Most tracking systems use
engineering algorithms to check whether reported generation is realistic or
likely misreported as greater than what is technically possible. These
validity checks usually apply to specific types of generators, typically small
or distributed generators. It would be helpful if tracking systems would
standardize the types of generators to which this method of error
detection applies and adopt a consistent margin of error that would be
accepted or trigger review. The goal is to ensure that generators are
treated equally and that the generation quantity is equally reliable.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Generator registration
Provide an API of registered generators to prevent double registration.
The 45V rule for hydrogen production tax credits defines a "qualified EAC
registry or accounting system" as one that, among other things, "Provides
a publicly accessible view (for example, through an application
programming interface) of all currently registered generators in the
tracking system to prevent the duplicative registration of such
generators."74 Most of the tracking systems do in fact make available a
public list of registered generators, but there is no easy way to check for
duplicative registrations across tracking systems. A comprehensive list of
registered generators, searchable by name and location, could be
important to prevent duplicate registrations. Alternatively, the suggested
API could facilitate such checking by the registries themselves and by
national program operators doing their due diligence. Feedback is
encouraged on a preferred approach and rationale for that approach.
Generator COD
Standardize the COD (or placed-in-service date). Tracking systems already
record the COD for generators when they register, but definitions of COD
may vary and need to be harmonized for federal/national programs. The
same data point must be used for uprates or additions to capacity, because
the incremental output may meet eligibility criteria for the hydrogen
production tax credit based on COD. The date when a generator first began
operation affects eligibility for some state RPS policies, and for voluntary
markets there is a recommended 15-year eligibility. For eligibility for
hydrogen tax credits, a generator must have commenced operation no
more than 36 months before the hydrogen production facility was placed
in service. Most registries require a COD; for most it is a date entered by
the generator registrant, with no apparent verification and no definition. It
could include, for example, start-up, pre-test, operational certification, and
date of approval to interconnect.
Generator emissions rate
Apply emissions rate data to certificates. Several tracking systems have a
data field for emission rates, but most track only renewables, and the
assumption is that they have no emissions. All-generation tracking systems
rely on EPA- or state-agency-reported emissions. Generators lacking
continuous emissions monitoring may report emissions from a proxy
generator. Recording emission rates will also be important for emitting
plants that adopt CCS, and for hydrogen life cycle emissions as required by
the 45V rule for tax credit eligibility.
74 Internal Revenue Code Section 1.45V-4(d)(2)(viii), Qualified EAC registry or accounting system.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Generator location
Standardize a generator location data element so that it can be used to
associate generators with different geographic eligibility definitions.
Every tracking system has one or more location data elements. This
capability is important to check for double registrations; to associate
generators with different definitions of "region" e.g., for tax credit
eligibility; and for location matching. Location is essential for
understanding what market the generator is in, and a required data
element by GHG-P scope 2, location matching, 24/7, 45V, storage and
emissions matching. What may be challenging for third parties is that
tracking systems collect different levels of location data, from state to
balancing authority to North American Electric Reliability Corporation
(NERC) region and eGRID subregion. EIA collects physical address and
latitude/longitude as well as NERC region and balancing authority for each
generator (reported on Form EIA-860). Tracking systems may have these
data, but what is available publicly may vary. Location information
currently collected by registries may include ZIP code, latitude/longitude,
mailing address, physical address, state, and balancing authority. It is
desirable that location data be provided with consistency. Potential buyers
of EACs need to be able to consistently identify the generator location by
its region, by consulting a tracking system's public list of generators, or via
an API. Whether this location data point should be carried on each
certificate should be discussed by tracking systems and program managers.
Generator resource type
(energy source)
Standardize naming resource type naming conventions. Identification of
resource or fuel type is important because regulatory and voluntary
programs have requirements on which types of resource/fuel are eligible
for the program. In addition, voluntary green power buyers may have
preference for certain resource types. The naming conventions are not
standardized, however, and definitions may vary across tracking systems,
making it difficult to aggregate fuel types. Further, there is growing interest
in expanding fuel types from just renewable to resources based on carbon
emissions, and to all generation. It is not clear how easy it would be to map
fuel types from one tracking system to another. EIA defines fuel types
carefully; if it were necessary to standardize, that would be a good model
to consider.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Generator size (capacity)
Standardize method for tracking details related to generator incremental
capacity. This data point is collected because generator capacity may be
important for RPS eligibility. Capacity is also used by tracking systems
currently as part of a computation to check validity of reported output,
particularly for distributed generation. Generator capacity can affect
eligibility. For example, the Section 45V rule for hydrogen tax credits
requires that generation comes from new incremental capacity relative to
when the electrolyzer was built. Whether that generating capacity is
entirely new and independently metered, or whether it is incremental
relative to existing capacity there are some variations that tracking
systems might need to track. Incremental capacity on an existing generator
is problematic because we assume that that incremental output would be
evenly distributed across all EACs issued, i.e., the incremental capacity's
contribution would be proportionally assigned to all EACs. However, the
45V rule also includes a flat percentage of existing generation to count but
could be moderated based on a generator's ability to demonstrate that
new eligible incremental capacity was added. It would be helpful to have a
tag that allows a program to say generation from this source is eligible
because it has had new incremental capacity added within three years of
the electrolyzer's COD.
Generator/generation
verification
Support the creation of a comprehensive list across tracking systems of
approved third-party reporting entities. Generators, when they are
registered, must provide EIA report documents and may be subject to
inspection. Generating units with capacities less than 1.0 MW usually
require a third party to verify. Generation dispatched and settled by a
balance authority is accepted as independent verification. Generation not
reported by balance authority may be reported by the interconnected
utility or an approved third party, often called a QRE. Some tracking
systems also support self-reporting for very small generators; if so, this is
checked against expected output using an algorithm based on capacity and
capacity factor. For quality control reasons, it would be helpful to create a
comprehensive or consolidated list across tracking systems of such
approved reporting entities, for two reasons: (1) it would make it easier for
small generators in need of such independent parties to find one and (2) it
could be used to record problems that arise with reporting from such
registered entities. This information would make it easier to spot patterns
and recurring problems that can then be more easily corrected, particularly
across tracking systems via an API. The 45V rule for hydrogen requires
accreditation of a qualified verifier and CBAM rules require a much more
extensive verifier report by accredited verifiers.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Hourly generation data
Track greater temporal and locational granularity. Matching hourly
generation to hourly consumption profiles and matching generator
location to location of consumer facilities has become a significant market
driver for voluntary markets and has also been incorporated into some
federal programs. Two tracking systems offer this option and a third has
announced plans to do so, and some large utilities are already working on
contracts with the federal government for hourly matching. More granular
generation information (at least hourly) is needed for 24/7, 45V, and
storage tracking. EnergyTag has a detailed description of a proposed
procedure. It should be possible to aggregate or roll up hourly or sub-
hourly data to monthly or other time periods. Approaches to providing
hourly data vary.
Interconnection
disclosure
Standardize disclosure at registration about the electrical system to which
a project is interconnected, or a statement that it is not interconnected.
Some tracking systems issue certificates to "off-grid" generators or to a
project that serves a "micro-grid," while others register only projects that
are grid-connected. This distinction becomes important when a program or
policy considers only grid-connected projects to be eligible (or the
opposite, only off-grid projects). To determine eligibility, there is a need for
a tag that distinguishes a generator that is grid-interconnected from "off-
grid," or a project that serves a "micro-grid." This would require verifiable
information upon registration about the electrical system to which a
project is interconnected, or a statement that it is not interconnected. In
the case of the hydrogen tax credit (45V), the generator must be in the
same region as the electrolyzer, and that determination depends on the
balancing authority to which the generator is interconnected, so in that
case the balancing authority must also be named.
Interconnection
verification
Treat grid interconnection status consistently. Some, but not all, tracking
systems register and issue certificates to off-grid generators. Because some
market participants or program operators prefer to recognize EACs that
affect grid operation and emissions, it is important to distinguish between
generators that are grid-connected, directly connected (off-grid or
"islanded generation") and co-located (e.g., with storage or with hydrogen
production facilities). Tracking systems should collaborate to determine if
the type of interconnection should appear on the certificate, appear as
part of the public list of generators, or be accessible via an API.
Location of beneficiary
Enable location of claim or beneficiary. Data on the location of use by the
consumer/beneficiary would help market observers and federal agencies
better understand market demand dynamics. For example, each year NREL
publishes a Status and Trends in the U.S. Voluntary Green Power Market
report, which is hindered by the lack of data on the location of renewable
energy consumption. Some residual mix calculations also require as a data
point the location of use of claimed certificates. Knowing the location of
the consumer/beneficiary is also recommended by the advocates of 24/7
to help match generator location to consumer location.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Marginal emissions rate
Standardize a method for determining and tracking marginal emission
rates. Most emissions data represent direct emissions from power plants
and are averaged for the month or year. They end up being used largely for
calculating residual mix. But, separately some consumers seek to maximize
their impact by purchasing clean energy from regions with high marginal
emissions. This will require agreement about how marginal plants are
defined, as well as unit of time and specificity of place for marginal
emissions. Operationally marginal emissions rate (MER) is the emissions
from the last generator or generation that is dispatched by a balancing
authority to serve load at any point in time. A MER might be for the entire
region if it is a single market, or it might be for subregional nodes if the
balancing authority operates markets or bidding for different zones. The
time interval would have to be noted. In any case, the data would have to
be provided by the grid operators to the tracking systems. These data are
needed to calculate emission reductions and to match customer hourly use
(and emissions responsibility) against hourly MER.
Meter quality
Harmonize meter quality requirements. Tracking systems generally require
a "revenue-grade meter" for measuring generation, but some are more
specific about defining the standard that must be met than others.
Operating procedures mention an MV-90 system, pulse accumulator
readings collected by the control area's energy management system, or
ANSI C-12 standard or its equivalent. The differences are not obvious and
may not be significant, but this should be a topic for discussion and
harmonization so that all generators in similar situations are treated
equally. The 45V hydrogen rule requires revenue-quality meters in some
instances and also requires an "industry-appropriate quality assurance and
quality control." Hydrogen producers would also need a pipeline
interconnection and measurement using a revenue-grade meter. Requiring
a revenue-grade meter is not new or unique to these new programmatic or
regulatory applications but may be worth considering among tracking
systems.
Multi-fuel generators
Treat multi-fuel generators consistently. Some tracking systems enable
generators that use multiple fuels to register for certificate issuance,
subject to an approved methodology for allocating production by fuel type.
It is difficult to tell if this allocation formula is unique to each situation or if
it is amenable to a consistent logic, if not formula. It would be helpful if
registries would be willing to jointly review how they do this and how they
might harmonize their approach so that emission attributes are
appropriately assigned. In addition, some tracking systems accept de
minimis amounts of fuel feedstocks when fuel inputs are reported for
multi-fuel generators. The threshold that defines de minimis may be
important to eligibility for production tax credits or embodied emissions
for CBAM, possibly triggering ineligibility. We encourage tracking systems
to standardize their de minimis definitions so that multi-fuel generators are
not unintentionally penalized.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Production unit of
measurement
Adopt a more precise unit of measurement (W-hr or MWh decimals) for
shorter-duration issuance. Tracking systems receive data in MWh and issue
certificates in MWh. Most also carry forward any decimals and issue a
certificate when a full MWh is accumulated in the next issuing period. They
also allow small generators to accumulate kWh and report it when they
have a full MWh or at least once a year. Advocates of 24/7 recommend
recording generation in W-hr because they believe it will be necessary if
the production interval is reduced to one hour or less.
Program administrator
account access
Provide administrator accounts to administrators of independent
programs. This feature grants access to the tracking system by program
administrators of independent programs that seek to layer additional
features to certificates, such as environmental certification programs (e.g.
Green-e®), or eligibility for other programs. Granting access does not mean
they can move certificates. Most tracking systems allow this, but there may
be more meanings to this capability than is evident. For example, NAR
notes that "program administrators can use a Program Administrator
Account. This type of Account is provided to administrators of compliance
and voluntary programs that utilize NAR and/or have eligibilities noted for
certain Certificates. It will allow Program Administrators to review eligibility
and compliance reports. Asset details will only be displayed in a Program
Administrator Account if the Account Holder registering that Asset has
listed it as eligible according to the specific program/certification." Tracking
systems should be prepared to create program administrator accounts for
new types of program administrators, such as federal administrators of the
hydrogen federal tax credit 45V.
Program/policy
application
Allow for tracking of additional eligibilities as new programs and policies
emerge. Most tracking systems collect the eligibility of generators for
voluntary programs and state RPS compliance, and these are often detailed
as data elements on the certificate. For example, NC-RETS has certificate
fields related to voluntary programs for "Green-e® Energy Eligible" and
"LIHI Certified," which are confirmed by the respective program
administrators. In the future, additional eligibilities could be included, such
as Green-e® Energy Federal Option, 45V, EPA Green Power Partnership, EO
14057, and others. Tracking systems also provide fields indicating the
eligibility of a generator for state RPS programs. In many cases, states
retain control over certification of RPS eligibility, and they require
compliance to be achieved by generators registering in a specific tracking
system. For example, California requires the use of WREGIS. Tracking
systems should provide a separate data field related to eligibility for each
state RPS program.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Public reports: aggregated
EAC issuance and
retirements
Standardize public reporting frameworks. All tracking systems provide
some public reports, but they are all different and some more difficult to
use than others. All-generation tracking systems track non-renewable
generation as well as renewable generation, but fossil generator owners
generally do not register their generators because there is no value for
such EACs and hence are not issued EACs (though their output is reported
by the balancing authority to the tracking system and tracked in an
administrator's account). They should be able to track anything issued into
an account holder's account, and they should be able to track all EACs
issued that are defined as renewable or emission-free, and how many are
retired (claimed). Such reports should not be difficult to produce but would
be more helpful if standardized. Aggregating EAC issuance and retirements
by hour rather than quarterly or annually as well as by state and grid
region (balancing authority or eGRID subregion) should be considered for
future reporting.
Qualified reporting entities
(QREs)
Enhance QRE quality control. Most tracking systems provide for QREs,
independent services registered to report generation data to the system on
behalf of generators that are not settled in the control area markets or
reported by balancing authorities or utilities. QREs are independent
verifiers that read meters or otherwise check production and facilitate data
transmittal to the tracking system. Supporting this option ensures that
generators of all sizes, particularly distributed generation, can receive and
transfer certificates. For quality control, it would be helpful to create a
comprehensive or consolidated list across tracking systems of such
approved reporting entities. This would make it easier for owners of small
generators to find an independent QRE. It could also be used to record
problems that arise with the reporting from such registered entities, to
identify the types of problems that arise, and to identify whether problems
tend to occur with some independent reporters more than others. This
information would make it easier to spot patterns and recurring problems
that could then be more easily corrected, particularly across tracking
systems via an API.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
REC retirement
reason/beneficiary data
field
Enable and require reasons for certificate retirement. Most tracking
systems support adding retirement information, but it may be optional. It
should be done consistently, including to (1) differentiate between
voluntary and compliance retirements (compliance by state); (2) provide
greater insight into market development; (3) support residual mix
calculations for regions, states, and LSEs; (4) enable the assignment of
retired EACs to their specific beneficiaries or consumer facilities, to support
location matching; and (5) provide aggregate information by state and
tracking region. Some tracking systems also support indicating the
beneficiary (the entity the RECs are being retired for). Naming the
beneficiary may be important if it is necessary to match a specific
consumer to generation within a specific area. The hydrogen 45V rule
defines "qualified EAC registry or accounting system" to mean a tracking
system that "...identifies the owner of each EAC."75 Naming the beneficiary
in public reports, however, is not necessary for residual mix calculations.
Repowering or uprates
Standardize approach to repowering and uprates. Adding capacity to a
generation project is often called repowering and sometimes called an
uprate. Definitions of both terms offered by EIA refer to an increase in
rated nameplate capacity. The incremental capacity may be eligible for
some programs based on the increment's COD. Therefore, the increment
and the date are critical data points. As part of reviewing this issue,
tracking systems should consult with instructions for Form EIA-860, or with
EIA staff, to determine a threshold for repowering. A consistent approach
would be fair.
Residual mix
Support calculation of residual mix for full disclosure of resource mix and
emissions by LSEs. Calculating residual mix is an important way to avoid
double counting environmental attributes and to assign attributes to
electricity whose attributes are unknown ("null power"). Further—because
the GHG Protocol prioritizes LSE-level data for corporate accounting of
emissions—tracking systems should calculate residual mix for each
balancing authority or standardized region to support full disclosure by
each LSE and for each of an LSE's differentiated products. Many consumers
look to their retail electricity supplier (or LSE) for data about their
generation sources and air emissions, but the method LSEs use to create
this information is not very transparent. For example, some might just
report their owned generation, whether or not it is all used to serve their
retail load. Some might have multiple products, but not differentiate
among products. Some might exclude null power from their calculations.
Tracking systems can support consistency by: (1) calculating residual mix,
(2) creating software that makes it easier for LSEs to allocate EACs to each
retail electricity product, and (3) assigning the most current residual mix
attributes to any MWh in a product that is not matched by an equal
number of EACs.
75 Internal Revenue Code Section 1.45V-4(d)(2)(viii), Qualified EAC registry or accounting system.
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Status and Trends Report on U.S. Energy Attribute Tracking Systems
"North Star" Tracking
System: Characteristic or
Capability
"North Star" Features Rationale and Considerations
Telemetered vs. manual
reporting
Identify manually reported generation data consistently. Tracking systems
have adequate safeguards related to third-party reporting and the
relationship of the third party to the generator. It may be of interest to
note when generation is manually reported by the generator owner, since
there is a potential conflict of interest. It would also be useful to ensure
that tracking systems use consistent methods for capping the total
generation potential of a particular project/generator such that
misreported generation greater than what is technically possible is
avoided.
Universal generator ID
Adopt a method of assigning a unique ID number to registered generators
that is consistent across tracking systems. Currently each tracking system
has its own way of assigning ID numbers and collecting information about
the generator's name, location, owner, and designated account holder. To
avoid double issuing certificates to a generator that is requesting
registration, tracking systems currently must search the list of generators
already registered. This works well when they check their own lists of
generators, but it is not clear if they also search to see if the generator
applicant is already registered in other tracking systems. EIA already
assigns unique IDs for generators over 1.0 MW, but the tracking systems
nevertheless assign their own IDs rather than use the EIA ID. If they used
the EIA ID, that ID could be used to compare data from tracking systems
with data collected by Form EIA-860 (latitude/longitude, balancing
authority, use of storage, capacity upgrade/downgrade, etc.). This would
reduce duplicate effort for generator owners already reporting to EIA.
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