Thank you for participating in this Green-e® Vietnam Market Appendix Questionnaire. Center for Resource Solutions (CRS), the NGO that administers the Green-e® programs, greatly values your feedback and knowledge of the Vietnam renewable energy market. Your feedback and input will help CRS offer Green-e® certification of qualifying renewable electricity and Energy Attribute Certificate sales made in Vietnam, by developing a Vietnam Market Appendix to the Green-e® Renewable Electricity Standard for International Certification (the International Standard).

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* 1. Please provide your name.

Below is a list of specific questions CRS has compiled that pertain to specific sections of the Vietnam Market Appendix. At the bottom of this questionnaire, there is space for you to enter any other feedback on the Market Appendix.

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* 3. In order to be used in a Green-e® certified Renewable Energy Product (including renewable energy attribute certificates) generators and generation may not be counted or attributed toward any specific national policy, scheme, or program related to emissions or the power sector.


Are there any national policies, schemes, or programs that cover emissions or the power sector in Vietnam that have binding compliance requirements or impact the end-user’s ability to claim or take ownership of environmental attributes, that you think should be considered in the Green-e® Vietnam Market Appendix? (This question relates to Section lV.B of the International Standard)


If so, please provide the name of the policy, why you think it should be considered, and a link to more information.

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* 4. Under Vietnamese law, to participate in the DPPA program, electricity generators and consumers must register DPPA arrangement. We are hoping to better understand the requirements for generators of each DPPA model.

Our current understanding is that any renewable energy facilities under Model 1 are not required to formally register with the National System Management Operator (NSMO). Parties must report the signed PPA to the local Provincial People’s Committee, the local power company, and the competent system operator. Is this understanding correct? Does the NSMO have access to any of these registrations?

It is also our understanding that for renewable energy facilities under Model 2, only facilities with a capacity of 10 MW or higher are required to register their participation with the NSMO and the Vietnam Wholesale Electricity Market (VWEM). For facilities under 10 MW, what is the procedure and mechanism for electricity generators to meet the DPPA criteria?

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* 5. CRS is hoping to understand if the following procurement method of environmental attributes separate from electricity (EACs) is common and currently being purchased in Vietnam:

A. Procurement of EACs separately from the electricity service. Providers of such EACs may also be electricity service providers or companies that provide EACs without electricity service.

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* 6. In the case where renewable generators sell renewable electricity directly to EVN through a power purchase agreement, who keeps the environmental attribute (EACS)? EVN or the generator?

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* 7. CRS would like to clarify when the voluntary EAC market in Vietnam began, and have found that the first voluntary EAC sale occurred in 2016. Green-e® program criteria limit the age of eligible generators to the year that a voluntary renewable energy market first existed. As currently written, the Vietnam Market Appendix only allows electricity and EACs from generators that first came online in 2016 or later. (This question relates to Section III.C of the International Standard)

Do you agree that 2016 is the start of the voluntary renewable energy market in Vietnam? If not, please suggest a different date and provide your rationale.

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* 8. We understand that the previous Feed-in Tariff (FiT) mechanism, set in place by Vietnam's Ministry of Industry and Trade for solar power projects, expired on 1 January 2021. Regarding renewable generators whose contracts have not expired under the FiT, is the FiT structured in a way that will impact the ability of an end-user to claim the use of the environmental attributes (impact the contract between developer and buyer)? Is this a concern for double counting of a REC?

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* 9. Only the following types of renewable resources are eligible to be used in Green-e® certified Renewable Energy Product in Vietnam: Solar including photovoltaic and solar thermal electric; Wind; and Geothermal.

If you feel that an additional renewable resource should be included as an eligible resource that is not currently listed, please comment below including the resource type, justification and reasoning behind your opinion. (This question relates to Section III.A of the International Standard)

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* 10. In which tracking systems are Vietnam renewable energy facilities commonly registered? Please add any additional tracking systems that are not mentioned below:

Evident (I-TRACK)
TIGRs

The following questions are related to the recently announced pilot Emissions Trading Scheme under Decree No. 29/2026/ND-CP (“Decree 29”).

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* 11. How do you think the pilot Emissions Trading Scheme will affect renewable electricity purchases and claims?

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* 12. Does the emissions rate for thermal plants apply only to individual entities or the entire sector? Do all generators have to show their emissions rate, or just the regulated thermal power plants?

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* 13. How were the baseline emissions rates for thermal plants calculated? And how are the declining target emissions rates calculated?

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* 14. How are credits created, issued, bought, sold, retired and counted for compliance?

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* 15. Is it possible for renewable electricity generation to either create credits, or to somehow reduce demand for credits or otherwise make more credits available?

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* 16. We understand that carbon credits issued from renewable energy generation will be registered in the national registry systems and deposited with the Securities Depository. Are there other ways that renewable energy's carbon value could be included in another tradable commodity or registered in another system? Please explain and provide links to more information.

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* 17. Please write any feedback and/or comments you may have after reviewing the Market Appendix, or anything else you would like to share with CRS.

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