RECOMMENDED ACTIONS AND PRINCIPLES FOR GREEN POWER STANDARDS Institute mandatory uniform disclosure Develop a fairly simple voluntary certification program Develop green certification principles Define green by generating resources Promote green power products Favor new resources Create a new, focused organization

There are many possible permutations of these options. My preferred package for developing green power standards includes the following seven actions and principles:

• (1) Institute mandatory uniform disclosure: State regulators and legislators should require uniform disclosure of energy resources used in generating electricity. This factual information will enable consumers to base their selection of supplier in part on their resource preferences. Speed in implementing disclosure requirements is important in states moving rapidly towards retail competition. Working out the details of disclosure, particularly substantiation of portfolio claims, also may provide technical support for the development of certification.

• (2) Develop a fairly simple, voluntary certification program:Certification is a value judgement that can be used to provide credibility in marketing and help consumers easily identify preferred power supplies. In developing a certification program, there is a fundamental trade-off between easy-to-use but potentially simplistic on the one hand, and precise and comprehensive but impractical to implement on the other. The following recommendations on implementing certification favor keeping it simple.

• (3) Develop green certification principles: Certification advocates (who mostly will be renewables and environmental advocates) should first develop a set of principles or criteria for certification. Recommended components of these principles are discussed below. Once a satisfactory draft has been articulated, they should be proposed and promoted to a wider audience, including electricity suppliers, the renewables industries, environmental organizations and consumer groups. This process will slow adoption of the principles but is critical for widespread recognition and acceptance.

• (4) Define green by generating resources: Power sources, not power suppliers, should be the focus of certification. Defining eligible resources or technologies will be challenging, but not as challenging as attempting to define a comprehensive standard of environmental performance for electricity suppliers. Also, generation resources are the focus for disclosure; maintaining this common link will reinforce the development of both disclosure and certification. If accumulated experience proves this approach to be inadequate, the definition of green may be broadened at a later time to include more comprehensive environmental attributes.

• (5) Promote green power products: Marketing environmental improvement is not the same as marketing green power. Certification should emphasize the latter. Focusing on renewable energy and sustainable technologies will appeal to a broad range of consumer motivations, not just environmental improvement. Green marketing, the characterization of a supplier's environmental orientation, could be treated as part of an overall supplier evaluation at a later stage.

• (6) Favor new resources: Preference in certification should be given to new resources and supplier commitments to develop new capacity, while recognizing that new renewable capacity is in short supply. This will support continued progress in the commercialization and competitiveness of environmentally-preferred generation technologies. Existing green resources likely will be part of a portfolio receiving certification but should not constitute the entire portfolio.

• (7) Create a new, focused organization: A new non-profit organization should be established that is dedicated to the development, implementation and advancement of green power certification. The proposed new organization, the National Renewable Energy Consumers Council, would first certify early green power products offered in emerging competitive markets. Electricity suppliers wishing to have their green brands certified would pay for the necessary evaluation and for the use of a logo and other marketing support services.

This organization, however, should not have a monopoly on certification services. Existing certification companies and other new entities will probably emerge in the electric power field. The organization's purpose therefore may quickly evolve to provide accreditation of national and regional certifiers, and to create national standards which could accommodate regional variations. It would have the following four functions: (1) accredit certifiers (reviewed and renewed biannually); (2) offer quality control in adherence to green power certification principles; (3) revise and update these certification principles as necessary; and (4) provide a forum for green power certification issues.

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