The current legislative semester is crucial in Vermont’s effort to address the climate crisis. Lawmakers are working hard to turn the recommendations of Vermont’s first Climate Action Plan into effective policy that puts us on the right path towards limiting our Greenhouse gas emissions, transitioning to renewable energy, and preparing our infrastructure for climate-related challenges.

A key element of this project is the establishment of fair and effective environmental standards: ones that hold us accountable to our stated goals, help us reach them, and ensure that the costs and benefits of doing so are shared equitably between all Vermonters.

The legislature is now evaluating our Renewable Energy Standard (which sets guidelines for Vermont’s electric distribution utilities) and a proposed Clean Heat Standard (which would affect suppliers of heating fuel). There are serious problems with both: they leave open loopholes that let us think we’re making far more progress than we are. Without a course correction, we could end up in a situation where Vermont’s energy sector meets state environmental standards, and yet we do very little to curb emissions and reduce our reliance on fossil fuels and other environmentally-destructive energy sources.

Developing effective and sensible energy standards is especially crucial as we move towards electrifying our transportation and heating: driving an electric car or installing a heat pump are fine, but what if the electricity that powers them is still generated from emissions-heavy sources? To ensure that these standards do what they should, we need to examine them carefully.

Vermont’s renewable energy standard is higher than those found in many of our neighboring states. However, this is misleading: our definition of “renewable” is broader than the one found in these comparable standards. Our utilities are able to meet their mandated quota of renewably generated electricity because we treat large-scale hydropower as a renewable source of energy; it has a dubious claim to the title, to say the least.

Hydropower produced by the massive Canadian utility, Hydro-Québec (our state’s largest energy provider, from whom we now get about 30% of our electricity) generates substantial amounts of both methane and carbon dioxide. These emissions are completely disregarded under the Renewable Energy Standard, which treats hydropower as an emissions-free energy source. (Methane is especially worrisome because it drives short-term global warming even more than CO2 does.)

The network of dams operated by Hydro-Québec also floods a yearly average of about 6,000 square miles of land, some of which is unceded First Nations territory, causing massive ecosystem disruption. There’s an “out-of-sight, out-of-mind” quality to our disregard of the environmental impact of Hydro-Québec: imagine nearly 2⁄3 of Vermont being underwater for all or part of the year.

Large-scale hydropower may be renewable in the sense that water isn’t used up in the process, but it certainly fails in the task of “protecting and promoting air and water quality in the State and region” and may ultimately fail in “contributing to reductions in global climate change”—two goals of the Renewable Energy Standard set forth in Vermont statute.

The same holds true for two other energy sources currently being treated as “clean” for the proposed Clean Heat Standard: biofuel and “renewable natural gas.” Both present significant problems in terms of emissions, ecosystem damage, and social impact.

Biofuels (liquid or gas fuels made from plant material or agricultural waste) almost always end up emitting more carbon than fossil fuels do, when we take into account both their production and combustion. Biofuel is a land-intensive source of energy: not only does it displace food crop production (resulting in instances of food shortages and increases in food prices), it results in large-scale deforestation that prevents a given ecosystem from naturally absorbing carbon dioxide—exacerbating its Greenhouse gas emissions problem.

“Renewable natural gas” is methane captured from organic waste and wastewater treatment, livestock operations, and factory farms. Like biofuel, it is predominantly produced out of state, making potential pipeline leakage and other transportation concerns an issue. To take it seriously as a “clean heat” energy, we would need to overlook the significant environmental impact of (for example) the large-scale industrial dairy operations that make renewable natural gas production profitable. Renewable natural gas is an effective public relations tool for the natural gas industry, but, ironically, it’s unscalable as an energy source; it just isn’t possible to generate enough of it to significantly meet Vermont’s energy demands in the first place.

We should also note that the environmental impacts of large scale hydropower, renewable natural gas, and biofuel are disproportionately severe for members of the vulnerable communities near which production sites are often located. This suggests that, when we treat them as “clean” sources of energy, perhaps what we really mean is: they’re clean for us.

If meeting the demands of the climate crisis were just a matter of making numbers work out on a spreadsheet, Vermont would be in great shape. But unfortunately, it’s a matter of actually reducing our Greenhouse gas emissions and preserving our ecosystems. To understand how Vermont’s environmental standards work, and how we can improve them, we need to take a closer look at the way they quantify the environmental effects of different energy sources.

Utilities and regulators keep track of the production and consumption of renewable energy through a system of Renewable Energy Credits, or RECs. The proposed Clean Heat Standard would require a comparable system of “Clean Heat Credits” in order to function. These systems are necessary for our energy accounting, but they also allow for misleading claims about how clean our energy actually is. RECs are certificates that correspond to amounts of renewable energy: one REC is “created” when 1 megawatt hour of energy is produced from a renewable source. When that energy is consumed, the REC is “retired,” or taken out of circulation. A utility complies with the Renewable Energy Standard by “retiring” a sufficient number of RECs per year, demonstrating that the energy it provided to consumers was generated from renewable sources.

Energy credits can also be bought and sold as separate commodities. (When this happens with RECs, the REC is said to be “unbundled” from its corresponding unit of renewable energy; what is being bought and sold are the “environmental attributes” of the energy, rather than the energy itself.) This allows utilities to offset their distribution of fossil fuel energy through the supplemental purchase and retirement of RECs.

In theory, credit systems ensure that standards are met, incentivize the use of renewable energy, and keep consumer costs as low as possible. But they can also act as a disincentive for utilities and suppliers to provide energy from genuinely clean and emissions-free sources. Here are two examples:

1. Most of Vermont Gas Systems’supply of “renewable natural gas” comes from biomethane recovered from a wastewater treatment plant in Iowa. But the reality is more complicated. Vermont Gas Systems purchases the “environmental attributes” of this biomethane, sells the actual gas in Iowa, and replaces it with fracked gas from a hub in Ontario. This gas, rather than the biomethane, is supplied to Vermont consumers.

2. Because Hydro-Québec is considered a renewable energy source by the state, Green Mountain Power can meet most requirements of the Renewable Energy Standard by buying and retiring the RECs generated from Hydro-Québec alone. This allows it to sell (at a profit) the renewable energy credits it purchases from in-state solar and wind producers to other, out-of-state utilities (who use them to meet their own state requirements). In this example, the sale of unbundled RECs means that the electricity GMP ends up providing to its customers isn’t generated from solar or wind at all: the utility has forfeited the right to make that claim when it sold those credits.

If it’s permitted, and cost-effective, to meet environmental standards by purchasing renewable energy credits but delivering non-renewable energy, then utilities have no reason to invest in genuine renewable energy at all. We’re stuck with a textbook case of “greenwashing,” where the language of environmental responsibility is used to obscure environmentally damaging practices.

If we’re serious about climate change mitigation, we need to begin by honestly accounting for the environmental impact of large-scale hydropower from Hydro-Québec. Treating this energy as renewable is an abuse of the term that borders on fraud. Luckily, the Renewable Energy Standard already includes a structure for differentiating between different categories of renewables. We need to adjust the rules of compliance such that utilities move away from a reliance on out-of-state hydropower, and towards achieving resiliency through in-state energy production (using provably cleaner and emissions-free renewables like solar and wind energy.)

Likewise, if we want to make genuine progress on cleaning up our heating fuel supply, we can’t play word games with the definition of “clean.” More progress can be made towards reducing the environmental impact (and costs) of heating by investing in weatherization than by investing in biofuel and renewable natural gas.

As with other financial products, Renewable Energy Credits (and proposed Clean Heat Credits) need proper regulation. It’s of doubtful wisdom to let environmental credits from large-scale hydropower, biofuel, or renewable natural gas allow Vermont utilities and fuel providers to comply with state standards. Ultimately, we should rule out the sale of unbundled RECs and Clean Heat Credits altogether on the grounds that they make greenwashing far too easy.

Environmental Standards are hard, complicated things to get right: they require us to balance short and long term objectives, weigh aspirations against realities, and consider the needs of everyone they affect. But we do ourselves and our descendants no favors when we misrepresent what they’re actually achieving.

Roger White is an artist, teacher, and volunteer with 350VT from Middlebury