When Killian Daly was working for Air Liquide in Paris, sourcing renewable power for the industrial gas producer’s enormous energy needs, he noticed a mismatch in the way power is purchased and the way its green credentials are counted.
“When you buy power, you do hourly batching – you have to respect that electricity can’t just fly across the country,” he said. “And then you look at green power accounting and it’s detached, it’s completely different,” he said, referring to the practice of issuing renewable energy credits for grid power on an annual basis. This allows power consumers to claim they are using clean power produced any time of the year.
“You can be 100% solar powered all night long, or 100% renewable using Texas wind, even if you’re located in the Northeast,” said Daly, a native of Ireland who is now based out of Brussels as EnergyTag’s executive director. “So for me it was inevitable that someone was going to sort of raise their hand and say, ‘What’s going on here?’”
EnergyTag, a London-based non-profit, was founded in 2020 to address this issue: to make electricity carbon accounting more granular and tied to the reality of the power system. While the organization does not issue or sell renewable energy credits – or even offer its own software – its set of voluntary standards known as Granular Certificates (GCs) have become a leading framework for more systematic carbon accounting across the globe.
The GC scheme has been employed by projects and system-level REC providers internationally, amounting to 5 million MWh of tracking, which, according to Energy Tag, shows that hourly tracking is already a technical reality. In the U.S., it is the basis of the Granular Certificate Trading Alliance, which is led by LevelTen Energy and includes major partners AES, Constellation, Google, and Microsoft. And it underpins systems employed by U.S.-based REC providers like M-RETS and others.
By most accounts, the small-budget outfit has achieved outsize success in its stance on a niche issue that has had a cross-cutting, global impact. Its advisory committee consists of multi-national representation from other non-profits, governmental agencies, and corporates that are aligned on the hourly matching problem. “It’s a global topic and I suppose it gives us a global voice,” said Daly, adding that Energy Tag’s independence allows it to be more to the point than other organizations.
Its chairman, Phil Moody, helped write the rules of energy tracking in Europe, “the only standardized system in the world for certificates,” according to Daly. “That’s a pretty unique set of skills that I suppose we bring to the table that is not really coming from another organization on this specific topic.” When it comes to policy, the organization has homed in on areas like green hydrogen, “where there’s a clear need for proper electricity accounting to avoid massive consequences and massive waste of taxpayer funding,” Daly said.
Time matching for renewable energy tied to green hydrogen production has become an existential issue for many proposed projects and their developers, particularly in the U.S. Under guidance issued by the IRS, project developers would be required to match renewable generation to green hydrogen production on an hourly basis starting in 2028, a requirement that has divided the green hydrogen sector into opposing camps and has been called, by those opposed to it, the death knell of the nascent industry.
More to do
The majority of U.S. renewable energy credit (REC) tracking systems can implement hourly matching akin to the standards put forth by EnergyTag in just a few years, according to a report from the Center for Resource Solutions issued last year. WREGIS, the system covering the western U.S., estimated it would take between three and five years but could cut it closer to three with state and federal support.
“A lot of the foundational aspects of how you set up a tracking system – they’re already there,” Daly said. EnergyTag’s granular certificate standards are focused on building systems as an extension of existing programs. “We’re not reinventing the wheel,” Daly said. “We’re taking standard definition television and making it HD.”
Although many of the U.S. registries are well on their way to being ready for hourly matching by 2028, Daly said there’s some work to be done in the phase-in period “to have a standardized approach across the REC registries, just so they can talk to each other, so that they can be audited.”
Even so, the implementation of a federal standard through 45V – even if it is an energy policy administered through tax authorities – is the only comprehensive federal policy that “can help move the environmental attribute markets to where they want to go,” M-RETS CEO Ben Gerber said during a panel discussion at Clean Power in Minneapolis on May 7.
Gerber said that some concessions might need to be made to appease industry concerns. “I wouldn’t be surprised if they moved the [hourly matching implementation] date back to 2030” from 2028, he said.
In an interview, Gerber added that he would like to see the establishment of a more robust market for trade in RECs, such as a platform advanced by Incubex, allowing developers to buy credits when they are short and sell when they are long.
EnergyTag itself also notes that the ideal of reaching 100% hourly matching might not be possible, at least not in the near term. “If you’re a hydrogen producer and you are hourly matching at a high level, but then you do not match hour by hour for 2% of your hours right now, under the current proposed rules it would look like you would then be bumped out of that top tier threshold” for tax credits, Alex Piper, EnergyTag’s head of U.S. policy, said.
This functional issue has been flagged by many in the pro-hourly matching camp, Piper said, “as a risk that is pretty existential and should be reevaluated by Treasury to determine if there are different flexibility mechanisms that can be included that would allow a project to miss a number of hours without being on that brink of in and out of the money, which could absolutely undermine the entire project.”
Devraj Banerjee of Ambient Fuels, a green hydrogen developer that has been vocal about the need to modify the proposed guidance, said that, while he agrees that a more granular matching scheme makes sense once renewable portfolios and banking systems are more advanced, allowing for flexibility now would help the industry get off the ground.
“What would be a significant fix in the [45V] policy would be allowing early mover projects to have either complete annual matching for the life of the tax credit, or barring that, some kind of pro rata share of annual matching in tandem with hourly matching to not only reduce overall economics but mitigate the need to over procure and provide the ability to be a bit more flexible with renewable generation to avoid falling out of 45V compliance if there’s performance issues, etc,” he said on the Clean Power green hydrogen panel earlier this month. “So some kind of annual carve out for early movers for the life of the tax credit would be a big change, and very helpful.”
In spite of the policy progress and advancements in hourly matching certification schemes, Daly said it’s still early days for accounting standards for global green commerce. “I fundamentally do believe what we’re seeing here on hydrogen in Europe and also now in the U.S. is only the beginning of a much broader discussion and framework around creating clean trade, marketplaces that are trading clean products, because that’s rule number one: is it clean, and that’s where we need to get into these details around accounting and three pillars,” he said.
“So I think it’s just a microcosm of actually a much broader set of discussions and actions over the coming years as we look to set up Transatlantic clean trade and in other parts of the world as well.”
