WASHINGTON ― President Biden wants all federal agencies to use 100% carbon-free electricity (CFE) ― 50% of which will be matched hour for hour 24/7 ― by 2030. Rhode Island’s Renewable Energy Standard will require the state’s retail electricity suppliers to ensure that 100% of the power they provide is from renewable sources by 2033. And Google (NASDAQ:GOOGL) is targeting 100% clean energy, matched hour for hour 24/7, by 2030.

Despite their very different goals, these clean energy buyers all face a common challenge: figuring out how to keep track of both the clean energy they use and the carbon emissions they cut, according to a Feb. 13 panel discussion at the National Association of Regulatory Utility Commissioners’ Winter Policy Summit.

“The way we account [for] CFE — in fact, the way the industry generally counts CFE — is not actually aligned with the way greenhouse gas emissions are counted for Scope 2 emissions,” said Tanuj Deora, director of clean energy at the White House Council on Environmental Quality.

Scope 2 emissions are the greenhouse gas emissions generated by the electric power purchased by an organization. Scope 1 are the emissions an organization directly owns or controls, while Scope 3 are the emissions produced from sources an organization neither owns or controls, such as from companies in its supply chain.

“One could take actions that result in a 100% CFE score but [with] some emissions being … assigned to the user,” Deora said. “On the other hand, we could actually zero out our Scope 2 greenhouse gas emissions but not actually be consuming only carbon-free electricity.”

Moderating the session, Rhode Island Public Utilities Commissioner Abigail Anthony framed the panel as the beginning of a discussion on the need for “harmonized certificate tracking and emissions accounting systems” for clean energy and emissions reductions. States with and even without renewable or clean energy mandates are affected, Anthony said, as whether or not they have a legal obligation, businesses in a state may have their own clean energy targets.

“I want all my regulator colleagues to understand their role as a market regulator of … generation certificates,” she said. “This is not a conversation we sit on the sidelines of. … Some states are going to need to be able to defend their own claims of emission reductions, and then you need to have systems that allow us to defend those claims legally,” as will corporations doing business in those states.

While not calling on NARUC for an official working group on the issue, Anthony would like to see the organization provide “another space for us to work together to develop standards that would allow the determination of who has what and will allow new products to be developed more easily to enable more complex emission accounting.”

She pointed to PJM’s recent announcement of its new clean energy tracking service that will provide certificates broken down by the hour as an example of the level of detail and innovation that will be needed. (See related story, PJM EIS Announces New Hourly Clean Energy Certificates.)

“It’s really important for us to figure out how to reconcile” these issues, Deora agreed. With more than 300,000 federal buildings across the U.S., the federal government is the country’s largest energy consumer, with a load of about 54 TWh of electricity a year, he said. Producing that much clean energy, at least half of it 24/7, will require accounting standards that are “going to be inclusive of both the statutory requirements across all the states who have their own rules, as well as each individual buyer’s specific targets and goals,” he said.

Betsy Beck, who leads global energy markets and policy for Google, said the company has been procuring enough clean power and retiring the associated renewable energy credits to cover its global operations. But, Beck said, developing accounting standards for its 24/7 goals means “you need to think about the grid at a more granular level.”

“It’s not enough to just balance at a high level,” Beck said. “Now we really need to be thinking about what are the right sources we need to fully decarbonize the grid. It can’t just be building the cheapest renewable energy sources, which have been wind and solar, but what do we need for the carbon-free energy supply in all hours of all days so that we do not need other fossil resources kind of backing renewables up?”

Who Has the Carbon Emissions?

As a member of NEPOOL, Rhode Island uses a relatively straightforward method for emissions accounting based on energy certificates, and not only for renewables, said Todd Bianco, chief economic and policy analyst for the state’s PUC.

“Coal has certificates too, and we follow those certificates to sort of understand what our emissions are,” Bianco said in a Monday phone interview with RTO Insider. “And we use renewable ones to help us calculate how much we’ve reduced emissions from the baseline.”

But, echoing Deora, Bianco said the clean energy and emissions certificates are not aligned.

“Folks have … focused on … the renewable aspect, which is great, but when you try to do the actual carbon emissions, you also have to have the highest fidelity to be able to show, well, who does have those carbon emissions? You’re in a power pool; there’s gas and coal and oil, let’s say, so if you didn’t use them, who did?”

During the NARUC panel, Bianco ran through a few scenarios in which the allocation of certificates could get blurred or just confusing. For example, if two businesses are on the same power system, and one is procuring wind energy and one gets electricity from a fossil fuel plant, who gets the certificates for the clean energy?

If a state agency is just looking at compliance for a renewable portfolio standard, Bianco said, it might use the clean energy credits from the wind-powered business to zero out the greenhouse gas emissions from the firm getting its electricity from the fossil fuel plant.

The agency could make “a legally defensible claim that the state is not evading emissions consistent with our statutory mandate,” he said. “But what would those two businesses tell their investors?

“And that’s where the certificates could go to the next level. Everybody has to agree,” Bianco said. “It’s no longer that I can make my claim in a bubble. Everyone has to agree to how they’re going to measure.”

Common Tool Set Needed

The General Services Administration announced its first 24/7 CFE agreement in November, working with Entergy to provide clean power to federal buildings in Arkansas. Moving ahead, Deora said, the federal government could be modeling its clean energy procurements on corporate practices.

“We’re going to [be] technology neutral, so we’re inclusive of all carbon-free electricity technologies beyond what is traditionally considered renewable,” he said. Nuclear, hydropower and fossil generation with carbon capture will be included.

Federal guidelines released in August also stress “temporal matching” on an annual and hour-for-hour basis, and “locational matching,” so that CFE is generated in the same region or service territory in which it is consumed, Deora said.

Like the federal government, Google is looking beyond wind and solar, Beck said, and the diversity of energy resources is going to make data accessibility and transparency critical for clean energy and emissions accounting.

“Whether your state has an RPS or not, you’ve probably got the federal government in your state; you probably have Google and other large energy customers,” she said. “Sorting out these inconsistences [in emissions accounting] and having systems in place to enable this data and this transparency is going to be critically important.

“We cannot continue figuring out these systems in silos,” Beck said. “Our sustainability goal is not going to be same as the government’s; it’s not going to be the same as the next company’s. But if we have a common tool set, we can use that to achieve our goals, hopefully in a meaningful and transparent way.”