Instructions for using Renewable Energy Certificates in the Clean

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Oregon Department of Environmental Quality

Instructions for using Renewable Energy

Certificates in the Clean Fuels Program

Contact: [email protected]

Initially posted: May 2021

Revised: December 2023

This document provides instructions on how to use Renewable Energy Certificates in the Clean Fuels

Program. The instructions cover how to generate incremental credits in quarterly reports and how the credits

are considered in renewable electricity generators’ fuel pathway applications.

Types of renewable electricity

The program rules identify electricity generated from solar, wind, some hydropower and ocean energy as

having a carbon intensity value of zero. For the 2023 reporting period, use the fuel pathway code

“ORREC2023” to report offsite renewable electricity use from those sources. The last four digits of the code

represent the year this fuel pathway can be used. A new fuel pathway code is generated annually for the next

reporting year, (e.g., ORREC2024 for the 2024 reporting year).

Electricity generated from other renewable sources requires a generator-specific fuel pathway obtained

through the fuel pathway application process. The generator-specific fuel pathways may also be updated

through the Annual Fuel Pathway Reporting process. Table 1 outlines the types of renewable electricity that

have a zero carbon intensity and those that are required to go through an application process.

Table 1: Renewable electricity generator eligibility by fuel type

Type of renewable electricity

Carbon intensity (CI)

Solar

Deemed CI of Zero

Wind

Deemed CI of Zero

Hydropower (subject to certain conditions)

Deemed CI of Zero

Biomass

Generator-specific Fuel Pathway application

Biodiesel

Generator-specific Fuel Pathway application

Biogas

Generator-specific Fuel Pathway application

Fuel Cell

Generator-specific Fuel Pathway application

Ocean Energy

Deemed CI of Zero

*Geothermal is excluded from carbon intensities indicated in this table; it is not a zero CI

renewable electricity source but is mistakenly indicated under OAR 340-253-0470(6)(a).

Eligibility requirements for RECs

1. Certification through Green-e. All RECs used in the program must have Green-e certification. This

requirement ensures compliance with Green-e standards and prevents the double-counting of carbon

attributes from renewable electricity. Annual Green-e certification guarantees that credits issued

represent genuine carbon reduction, which helps meet the requirement under the program’s statute that

all credits must represent real reductions of carbon emissions. It is essential for renewable electricity

generators and/or reporting entities to understand and stay updated on Green-e standards. Access the

latest information at https://www.green-e.org/programs/energy/documents

2. Vintage. RECs must meet the Green-e standard’s vintage requirement for use in a reporting year,

which means it must been generated in that calendar year, or in the last six months of the prior year or

the first three months of the following year, for a total of a 21-month eligibility window. For example, to

use RECs for 2023 electricity reporting, the RECs must be generated between July 2022 – March

2024.

3. Start date. RECs must come from renewable electricity generators that started operating in or after

January 2016. For biogas to electricity projects, they must have started within the last 14 years in line

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with the start date requirements of the Green-e standard. For example, in 2023, the project must have

started operating in 2009 or after.

4. Location. RECs used in the program must come from electric generators located in the Western

Electric Coordinating Council Region

5. Tracking System. RECs used in the program must be recorded and retired in WREGIS

What can Renewable Energy Certificates be used for?

In the program’s 2021 rulemaking, DEQ added “incremental credits” to the program’s existing “base credits” for

electricity. Base credits are generated by comparing the CI of gasoline or diesel with the CI of grid electricity.

Incremental credits are earned by further reducing the CI of electricity through the retirement of RECs. RECs

can be retired by electricity credit generators when reporting renewable electricity used for non-residential and

residential electric vehicle charging.

• Non-residential charging covers charging of electric vehicles including cars, trucks, transit vehicles,

cargo handling equipment, forklifts, transport refrigeration units, ground service equipment, and vessel

shorepower. Charging can take place in the public, at workplaces, at private fleet locations, or at multi-

unit (more than four) dwellings. These credit generators can purchase and retire RECs to lower the

carbon intensity of the electricity they provide to electric vehicles and generate incremental credits

under the program’s rules.

• Residential charging covers charging of electric vehicles at residences (four or less dwelling units).

The electric utility generates the credits for that charging. The backstop aggregator and incremental

aggregator are eligible to claim base and incremental credits, respectively, that an electric utility could

have generated if it fails to register in the program or designate an aggregator. Utilities may: 1) retire

RECs on behalf of their customers’ EV charging, 2) they can demonstrate to DEQ that their customers

have purchased a qualifying utility renewable electricity product, or 3) purchase bundled renewable

electricity with its RECs to generate incremental credits.

Hydrogen fuel producers who employ electrolysis as a production technology are also allowed to retire RECs

from offsite generation to lower the CI of their production process and resulting hydrogen fuel. There is a

lookup table value for hydrogen produced via electrolysis in Oregon using solar and wind that the producer can

apply to use. For all other types of production of hydrogen, including any other source of renewable electricity

being used or out-of-state hydrogen production, the fuel producer must submit a Tier 2 fuel pathway

application.

Instructions for electricity credit generators

When reporting non-residential charging in a quarterly report, the reporting party selects the appropriate

renewable electricity fuel pathway code to report their charging use for the respective year (Table 1). For

example, if you are using solar electricity in 2023, use the ORREC2023 fuel pathway code. If you are using

renewable electricity from biogas, select the generator-specific fuel pathway code for that biogas-to-electricity

generator.

As required by OAR 340-253-0640(2)(d), quarterly reports that include off-site renewable electricity must

include the REC retirement records from WREGIS in both PDF and Excel formats uploaded in the

supplemental documentation section of that report. The retired RECs must match the renewable electricity fuel

pathway codes used in that report.

For more information on WECC, please see: https://www.wecc.org/epubs/StateOfTheInterconnection/Pages/Western-

Interconnection.aspx

For more information on WREGIS, please see: https://www.wecc.org/WREGIS/Pages/Default.aspx

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On an annual basis, the reporting entity that retired RECs for its reporting must submit proof of completion of 
final verification or validation from Green-e for all the RECs it reported in the prior year to the program. Those 
verification or validation statements must be submitted to DEQ via an email to 
OregonCleanFuel[email protected]. Failure to submit such proof is grounds for DEQ to invalidate any 
incremental credits issued to the entity under the procedures of OAR 340-253-0670.  
For utilities generating incremental credits from residential charging, RECs should be retired in the same way 
they are required for quarterly reports, detailed above. Because residential credit generation is done outside of 
the quarterly reports, DEQ will inform the utility of the amount of charging that occurred in their service territory 
on a biannual basis and REC retirement reports be submitted via email to 
OregonCleanFuel[email protected]. These RECs must also be certified through Green-e and proof of 
completion must be emailed to DEQ.   
Retiring RECs through the Western Renewable Energy Generation Information System 
Registered parties should follow the instructions in this guidance to document their REC retirements. The only 
REC tracking system currently recognized by DEQ is the WREGIS. DEQ is not considering approving another 
REC tracking system at this time.  
In WREGIS, RECs must be placed into a retirement subaccount named for the fuel pathway code you use to 
claim in the program. So, if the retiring of RECs to claim zero-carbon electricity is used under ORREC2023,  
use the title of the subaccount with that fuel pathway code. If the retiring of RECs in WREGIS before the CFP 
is added as a retirement reason under “Other Regulatory Program,” select the “Other Retirement Reason” and 
record the field provided by WREGIS, the name of the program, the fuel pathway code, and the quarter for 
which the REC is being retired for. For example: “Oregon CFP ORREC2021 Q1 2023.” 
If there is a separate entity purchase and retire RECs on your behalf, they must provide you with REC 
retirement reports from WREGIS where they have: 
•  Created a retirement subaccount with the organization’s name as it appears in the Oregon Fuels 
Reporting System and the fuel pathway codes the RECs are being retired to claim.  
•  For example, ABCCorp_ORREC2023 followed the retirement instructions above. 
After the RECs are retired and reflected in a quarterly report, use the upload supplemental documentation 
feature for that quarterly report to upload both the PDF and Excel copies of the WREGIS retirement report into 
the OFRS.  
Failure to submit REC retirement records with the quarterly reports where incremental credits are claimed, is 
grounds for DEQ finding those credits invalid, and removing those incremental credits from the respective 
account under OAR 340-253-0670.  
Instructions for renewable electricity generators 
For electricity fuel pathways subject to a fuel pathway application for the electric generator, the fuel producer is 
responsible for the following: 
•  The fuel producer or pathway holder is responsible for informing any fuel reporting entities using RECs 
from this generator of the amount that can be claimed under each fuel pathway code assigned to a 
generator from each given month if the generator has multiple fuel pathway codes.  
•  The efficiency of the electric generating station must be determined based on operating records that 
demonstrate the net amount of electricity produced during the previous 24 months of operating data 
compared to the net quantity of fuel consumed by the electricity generating assets owned and operated 
by the producer during the same period unless a provisional pathway.  
•  For the fuel pathway application: The amount of electricity must be calculated using the electric 
generator’s energy efficiency as reported in the fuel pathway application or annual report, whichever is 
the most current. 

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• The fuel producer or pathway holder must calculate a user-defined Emissions Factor (EF) for electricity

generation (gCO

e/kWh), which must be based upon the efficiency of electric generating assets, the

quantities of fuel consumed, and the emissions factors for CH

, N

O, CO, and VOC emissions

(g/MMBtu of fuel input) using the appropriate Global Warming Potential values (for converting to CO

equivalent values) from the DEQ OR-GREET 3.0 model. The applicant must use this EF to determine

the GHG impacts of electricity acquired and consumed by the producer.

• The source, type, and quantity of fuel consumed annually, and the type of electricity-producing

equipment used by the producer to generate electricity, are subject to annual verification by a

Verification Body if a third party must verify the pathway under OAR 340-272.

• The quantity of electricity produced annually, and the quantity exported by the producer are also

subject to annual verification by the Verification Body.

• The information requested above must be included in the Annual Fuel Pathway Report and separate

tabs of the Tier 1 Simplified CI Calculator worksheet presented to the Verification Body. A fuel producer

is subject to verification if its fuel pathway codes generate more than 6,000 credits and deficits

annually.

• If the renewable electricity, biomethane, or other qualifying sources of low-CI inputs is owned by

another party, the unredacted contract and unredacted invoices by which the fuel pathway holder

obtained those environmental attributes must be provided.

Instructions for hydrogen fuel producers employing renewable electricity for hydrolysis

• For any renewable electricity, including an on-site or directly connected generator, that is used to

reduce the CI of electricity used as a fuel or hydrogen production via electrolysis where that hydrogen

was used as a fuel, the fuel pathway holder must upload records demonstrating that the electricity used

was renewable. If the renewable electricity generation is on the same site and directly connected to the

hydrogen production facility, and no RECs were generated, the producer may provide an affidavit and

proof that the electricity generation is not registered in a REC tracking system. If any RECs were

generated, they must be retired in WREGIS or another comparable, recognized REC tracking system to

lower the certified CI.

• (If applicable) If renewable electricity supplied through RECs is used for process energy for hydrogen

production where the hydrogen is being used as a fuel, the retirement report demonstrating REC

retirement must be downloaded from WREGIS and uploaded to the AFP as part of each Annual Fuel

Pathway Report to demonstrate the quantity of renewable electricity consumed within the fuel pathway

and claimed to lower the CI of the produced fuel.

o Note that this retirement account for process energy is distinct from, and in addition to, the

requirement for any fuel reporting entity claiming electricity directly as a transportation fuel in the

OFRS under this pathway to demonstrate quarterly REC retirement as part of each quarterly

report.

o This REC retirement is not applicable if the pathway holder can demonstrate the low CI

electricity used as process energy generated no RECs during the entire reporting period. In

those cases, the responsible party must provide an attestation letter in the annual fuel pathway

report stating that the energy consumed behind the meter or interconnection to the outside grid

does not and will never generate RECs in any renewable electricity tracking system. The RECs

and/or the associated environmental attributes for energy reported as process energy in a fuel

pathway can no longer be sold, transferred, or claimed by any entity or for any other purpose.

Special eligibility issues for California and Washington-sited projects

Because of the Cap-and-Trade programs in effect in California and Washington and of the way the Oregon

calculates emissions obligations for the electric sector, there are additional steps that RECs from renewable

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electricity generators in both jurisdictions need to take for their RECs to be certified by Green-e and to be

eligible for use in the in the program.

Under the Green-e standard

, all California-sited renewable electricity generators and Washington-sited

generators that started operation after Jan. 1, 2020, have to retire allowances against any renewable electricity

claims made outside of those states. This requirement also covers renewable electricity generators whose

electricity is directly delivered into California or Washington. This requirement, set by Green-e, maintains the

environmental integrity of RECs and the validity of carbon reductions claimed in the program.

While the California Cap-and-Trade Program has a Voluntary Renewable Electricity Program that retires

allowances on behalf of voluntary renewable electricity claims, it is restricted to only voluntary uses of

renewable electricity and the CFP is considered by California and Oregon to be a mandatory program. For

California, the number of allowances that must be retired is calculated by multiplying the number of MWh of

renewable electricity being claimed by 0.428mt/MWh, as provided in the Green-e Standard, and then rounding

up to the nearest whole metric ton. The retirement records for the allowances must be provided to Green-e

during the annual certification of the RECs that were claimed in the program.

The same process must be followed for Washington except the number of allowances is calculated by

multiplying the number of MWh of renewable electricity being claimed by 0.427mt/MWh, as provided in the

Green-e Standard.

For additional information contact OregonClea[email protected].

Non-discrimination statement

DEQ does not discriminate on the basis of race, color, national origin, disability, age, or sex in the

administration of its programs or activities. Visit DEQ’s Civil Rights and Environmental Justice page.

See pages 34-39 for California and pages 42-43 for Washington in the standard here: https://www.green-

e.org/docs/energy/Green-e%20Standard%20US.pdf