There are several options for certifying green power. These include developing (1) guidelines for industry self-certification; (2) principles or criteria; (3) environmental impact protocol; or (4) a customized program for product review and assessment.

(1) Develop guidelines for industry self-certification: Stakeholders would meet to develop certification guidelines. With some oversight, green power suppliers would have to certify that they meet all (or perhaps a minimum number) of these guidelines to claim approval. Advocates or competitive suppliers would have to be watchful of advertising and use the threat of public exposure to achieve compliance for questionable claims. This is the loosest approach, but it offers a way to build experience. The U.S. Environmental Protection Agency's Energy Star label for office equipment is one successful self-certifying program for energy-efficient performance. EPA will investigate any Energy Star-labeled product whose performance has been questioned.

(2) Develop principles or criteria: In this case, the application would be reviewed by an independent organization. Again, interested parties, including public sector entities, would develop and announce criteria. Instead of allowing self-certification by suppliers, an independent organization would be contracted to apply the criteria. Green power suppliers who want to be certified would have to pay the independent organization to be evaluated. This is similar to the process used to certify non-toxic household cleansers, safe electrical products, and well-managed forests.

(3) Develop environmental impact protocol: A formulaic approach could be developed for estimating environmental results. For example, a spreadsheet tool that calculates air emissions might be developed. The Natural Resources Defense Council recently ranked U.S. electric utilities based on carbon dioxide emissions, and plans to extend this information to include fine particle emissions and selected toxic pollutants.¹⁵ To be certified, a green power supply or renewable resource would be compared to the best utility performers, or it could be required to beat the top ten percent or exceed the performance of the best by some further percent. Nuclear waste, loss of natural river flows, thermal pollution, bird kills and aesthetic impacts might also be incorporated into such protocol.¹⁶

(4) Develop a customized program for product review and assessment:Instead of meeting prescriptive standards or being assessed by a formula, each green marketing or green power product desiring certification would be reviewed by an independent certifying organization to determine and document life-cycle environmental net benefits.

Consider the analogy of building energy codes, which generally offer three paths to compliance: the prescriptive path, in which a building is constructed with specified materials and thermal properties; the component approach, in which materials may vary but thermal integrity must be maintained; and demonstration of equivalence by design analysis (computer modeling). Applied to green power certification, the prescriptive-and simplest-path might relate to how the power is produced, using a narrow definition of renewable. The component approach might be a demonstration by simplified formula that environmental impacts (however narrowly or broadly defined) meet threshold standards. Finally, the demonstration of equivalence might be a more expensive customized review. This path would be used by a power supplier who blends sources but feels that significant environmental benefits are achieved.

Whichever method is chosen, the difficulty lies in finding a way to substantiate the claims made. Ascertaining "greenness" is one thing; determining whether the green power is in fact being generated and fed into the system is another. This probably will require cooperation from system operators and access to power sales/purchase contracts. Case studies are also needed to demonstrate how green power sales can be substantiated.¹⁷

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