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Developer Marketing Requirements and Submission Details for California’s Enhanced Community Renewables Program

Developer Marketing Requirements and Submission Details for California’s Enhanced Community Renewables Program

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Center for Resource Solutions

September 16, 2016
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  1. Developer Marketing Requirements and Submission Details for California’s Enhanced Community

    Renewables Program _______________________________________________ September 16, 2016
  2. Maya Kelty, Green-e | Center for Resource Solutions Will Quinn,

    Pacific Gas & Electric Melissa Woolley, Southern California Edison Brandon Henzie, San Diego Gas & Electric
  3. • What is Green-e • Enhanced Community Renewables & split

    of responsibilities • Developer marketing material requirements • Developer marketing material submission & review process • Utility-specific requirements
  4. Creating policy and market solutions to advance sustainable energy since

    1997 • Nonprofit in San Francisco • Expert assistance and education • Certification programs • Renewable Energy Markets Conference
  5. Certifications for sellers… üUtility green power programs üCommunity solar üRECs

    üCompetitive electricity products üCarbon offsets üCommunity choice aggregation üCarbon offset natural gas programs üFederally eligible RE products Certifications for buyers… üPPAs (delivered or virtual) üOn-site power üCorporations using RE üProducts manufactured w/RE üConferences and trade shows üEV charging stations üPaper and printers
  6. Consumer protection and certification for voluntary renewable energy purchases

  7. Green-e Energy Certification Two fundamental governing documents. Stakeholder- driven standards

    and independent governance board. 1. Green-e Energy National Standard: Requirements for eligible resource types & program requirements 2. Green-e Energy Code of Conduct: Marketing & disclosure requirements for sellers
  8. • What is Green-e • Enhanced Community Renewables & split

    of responsibilities • Developer marketing material requirements • Developer marketing material submission & review process • Utility-specific requirements
  9. CA-ECR Program Developer Utility Customer Customer Bill with Energy Credit

    Power Purchase Agreement Customer Developer Agreement Customer enters into an agreement with Developer to purchase a portion of a renewable project. Utility is not a party to this agreement. Customer and developer agree on price. Developer and utility enter into a PPA. Any output from project not dedicated to specific customers is purchased by utility. Customer continues to receive a bill (with a credit) from utility. All RECs from the subscribed electricity is retired on behalf of the customers.
  10. ECR & Green-e • Green-e Energy: certifies utility’s offering, as

    required by CPUC decision • Utility: • Delivers electricity to customers • Markets overall program to customers • Delivers customer disclosures • Green-e Energy verification audit of supply and sales • Developer: • Offers specific project enrollment to customers • Markets specific projects to customers • Enrolls customers in product • Delivers customer disclosures
  11. ECR Customer Billing • Developer charges customer for generation •

    Utility charges customer certain fees, such as: • Power Charge Indifference Adjustment • CAISO Grid • Program Charge • Utility credits customer for generation only Developer Charges Utility Charges Utility Credit Total Cost to Customer
  12. • What is Green-e • Enhanced Community Renewables & split

    of responsibilities • Developer marketing material requirements • Developer marketing material submission & review process • Utility-specific requirements
  13. Developers must comply with: Developer marketing requirements Green-e Energy Code

    of Conduct Formerly the Green-e Energy Code of Conduct and Customer Disclosure Requirements Updated May 19, 2016 Version 2.1 Center for Resource Solutions 1012 Torney Ave. 2nd Floor San Francisco, CA 94129 www.resource-solutions.org Green-e Energy Code of Conduct aligns with: •FTC Green Guides •SEIA Business Code •IREC Consumer Bill of Rights and other pertinent best practices in marketing renewable energy products.
  14. Developers must comply with: Developer marketing requirements Green-e Energy Code

    of Conduct Formerly the Green-e Energy Code of Conduct and Customer Disclosure Requirements Updated May 19, 2016 Version 2.1 Center for Resource Solutions 1012 Torney Ave. 2nd Floor San Francisco, CA 94129 www.resource-solutions.org Green-e Energy requirements for renewable energy project developers participating in the California ECR program – June 2016 1 Green-e Energy requirements for renewable energy project developers participating in the California Enhanced Community Renewables program Green-e Energy provides the following guidance to renewable energy project developers (“developers”) participating in the California Enhanced Community Renewables (“ECR”) program to help them successfully communicate with consumers in a manner compliant with Green-e Energy guidelines. Green-e Energy expects that developers will take the information contained in this document and use it to create communications that accurately describe the new program, their responsibilities to consumers, and offer response mechanisms for consumers seeking additional information. I. SUMMARY OF RESPONSIBILITIES 2 II. GENERAL MARKETING COMMUNICATIONS GUIDELINES AND REQUIREMENTS 2 III. TIMELINE OF MARKETING APPROVALS 3 VISUAL TIMELINE OF MARKETING APPROVALS 5 IV. MARKETING REQUIREMENTS 6 V. ONGOING OBLIGATIONS 11 VI. ENFORCEMENT AND CENSURE 12 VII. UPFRONT DISCLOSURE TEMPLATES 14 The Green-e Energy Code of Conduct contains requirements for certified product sales and marketing. ECR Developers are required to comply with Sections IV.E (excluding E2), IV.F (excluding F.1.e and F.1.f), and IV.I. Section IV.I of the Green-e Energy Code of Conduct requires that all developers comply with the ‘Green-e Energy requirements for renewable energy project developers participating in the California Enhanced Renewables program.’ These requirements can be found at www.green-e.org/ecr.
  15. Green-e developer requirements include: • Certain required materials • Certain

    required upfront disclosures • General guidelines covering all materials • Pre-approval and annual submission
  16. • Phase one: consumer interest • Approval of phase one

    materials allows developer to gather customer interest, but not enroll customers • Phase two: consumer enrollment • Approval of phase two materials allows developer to enroll customers in the offering • Phase three: continued participation • Developer must submit any new marketing materials to utility • Developer must submit marketing materials to utility annually to remain in good standing Developer marketing requirements: Three Phases
  17. Marketing Material Phase 1 Phase 2 Phase 3 Initial marketing

    piece Required Required if in use Required if in use Upfront disclosures Required (draft) Required (final) Required (final) Call script If applicable Required Required Website If applicable Required Required Welcome Packet Not required Required Required Annual mailing Not required Not required Required Additional marketing materials If applicable If applicable If applicable Submission deadline Prior to marketing to customers Prior to enrolling customers Annually Overview of required materials
  18. Phase 1 Phase 2 Phase 3 Required Required if in

    use Required if in use • Any format, often a powerpoint or factsheet • Requirements: • Accurate description of ECR dynamic • Accurate information regarding project and benefits Initial Marketing Piece Purpose: To present information to potential customers to gather customer interest in enrolling to receive renewable energy. Section IV.1.
  19. • Sample of requirements: • Enrollment options • Resource location

    • Contact information • Link to Green-e, utility, and developer webpage • Cost • Contract length • Cancellation policy • Bill logistics Upfront Disclosures Purpose: show customers the product offered (including resource location), and clearly describe the customer’s responsibilities when purchasing the certified product. Section IV.3. Phase 1 Phase 2 Phase 3 Required (Draft) Required (Final) • Posted on website • Provided at sign up • Provided in welcome packet Required (Final) • Posted on website • Provided at sign up • Provided in welcome packet
  20. Templates available within Green-e developer requirements (www.green-e.org/ecr) • Templates are

    optional; developer can include this information in one page of the contract but must submit for approval • Price information can be provided to Green-e separately (energy@green- e.org) Upfront disclosures must be provided to all customers prior to signing a CDA Upfront Disclosures
  21. PCL Template [YEAR] PRODUCT CONTENT LABEL [Developer Product Name] is

    a renewable electricity product. This product is sold in kW. A purchase of __kW has an estimated output of ___ annually. The average home in your area requires __kW of [resource type] capacity to power it for one year. Purchase of a certain capacity (kW) does not guarantee a certain amount of output (renewable energy kWh) will be produced. Individual units’ output may vary based on weather, efficiency and other factors. [PRODUCT NAME] is sold in blocks of [###] kilowatts In [YEAR], [PRODUCT NAME] [will be] made up of the following renewable resources. Green-e Energy Certified Renewable Energy in [PRODUCT NAME] Generation Location [Resource Type] e.g. Solar 100% [City, State] TOTAL 100% To view, as a comparison, the current average mix of resources supplying [Utility], please visit [Utility] webpage [URL HERE]. The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013] (if residential customer) For specific information about this electricity product, please contact us at [Developer Company Name], [phone], [website]. For more information about [Utility]’s [Product Name], please visit [Utility ECR webpage] or contact [Utility] at [contact info]. Learn more about Green-e Energy’s requirements for California utilities under Senate Bill 43 (SB43) at [Green-e ECR webpage]. Learn more about Green-e Energy at www.green-e.org.
  22. PTC Template Price, Terms, and Conditions Company: [Developer Company Name]

    Enrollment levels: In upfront disclosures, include the enrollment level options. In Welcome Packets (at sign-up and annually thereafter), include the specific enrollment level of the customer. If a residential customer, include the statement: “The average home in the United States uses 909 kWh per month. [Source: U.S. EIA, 2013]” Whom should I contact for more information? Include contact information here including the developer’s Customer Service number, Webpage, E-mail and Billing Address. How will I be billed? Explain how customer will be billed and by whom (e.g. You will receive a monthly bill for [Product] from [Company Name]). Explain that the customer will receive a bill from you and continue to receive a bill from their utility. How will my bill be calculated? Explain how charges will be calculated. Provide all details on actual pricing structure, even if it’s complex. Taxes: You must also pay all applicable federal, state, and local taxes and charges How much will enrolling in the program cost? Provide the customer with information on how much the product will cost per/kW or kWh. Will my rates change over time? Explain how rates will change over time, if applicable. Include that the credit on the customer’s utility bill is subject to review and change based on CPUC ruling.
  23. What is the process for terminating the contract and what

    is the early termination fee? Explain how the customer can terminate the contract and if there is a fee for doing so. What length of agreement/ contract is required? e.g. 2 years What other fees might I be charged? e.g. Late charge of 3% for bills that are unpaid for more than 24 days Program Details: Include details on how the program works, including the customer’s continued relationship with the utility. [Developer] is working with [Utility Name] to have [Developer Project / Program Name] included in their [Utility Product Name]. [Utility Product Name] is Green-e Energy certified, and meets the environmental and consumer-protection standards set forth by the nonprofit Center for Resource Solutions. Under the California Enhanced Community Renewables program, renewable energy project developers take on the responsibility for marketing electricity product(s) directly to customers, who would normally receive this type of information from their utility. Green-e Energy provides third-party verification that the end customer receives accurate and sufficient disclosures. Green-e Energy also requires that product disclosures, such as the price that will be billed per unit (kWh or kW) of power and the developer’s customer service contact information, be provided to purchasers within 60 days of sign-up in the form of a Welcome Packet. Customers will also receive an annual mailing that includes product information. [Provide disclosure on whether the PPA has been signed with the utility, if the project has not been built, and when the project is scheduled to be built (if applicable).]
  24. Phase 1 Phase 2 Phase 3 If applicable Required information

    if a phone number is included within marketing materials: •ECR program dynamic and breakdown of responsibilities •Relationship between developer and Green-e •Project timeline, PPA status, and COD •Green-e and utility websites Required Required information: •ECR program dynamic and breakdown of responsibilities •Relationship between developer and Green-e •Project timeline, PPA status, and COD •Green-e and utility websites •Upfront disclosures •Additional requirements if customers can enroll via the call center Required Required information: •ECR program dynamic and breakdown of responsibilities •Relationship between developer and Green-e •Project timeline, PPA status, and COD •Green-e and utility websites •Upfront disclosures •Additional requirements if customers can enroll via the call center Call Script / Factsheet Purpose: The developer’s call center may be the only one the customer calls, and customers must be able to receive accurate and complete information about the offering. Section IV.5.
  25. Phase 1 Phase 2 Phase 3 If applicable Required information

    if a website is included in marketing materials: •Required language regarding Green-e Energy and ECR program •Required language regarding Green-e Energy certification process •Required language regarding Green-e for Businesses and Products •Description of ECR program •Developer, Green-e, and utility contact information Required Required information: •Required language regarding Green-e Energy and ECR program •Required language regarding Green-e Energy certification process •Required language regarding Green-e for Businesses and Products •Description of ECR program •Developer, Green-e, and utility contact information •Upfront disclosures if online enrollment or marketed to residential customers Required Required information: •Required language regarding Green-e Energy and ECR program •Required language regarding Green-e Energy certification process •Required language regarding Green-e for Businesses and Products •Description of ECR program •Developer, Green-e, and utility contact information •Upfront disclosures if online enrollment or marketed to residential customers Website Purpose: Although the developer is not actively involved in the certification process, their website may be the only one a consumer sees before committing to purchase, so a full description of Green-e Energy and Green- e Energy certification is required. Section IV.3.
  26. Phase 1 Phase 2 Phase 3 Not required Required Required

    Welcome Packet Purpose: Welcome packet must be delivered to all customers within 60 days of signing a CDA or other binding agreement so that they can have on record the full details of the agreement. Section IV.4. Requirements: • Upfront disclosures • Customer enrollment level • Expected COD, if applicable • If sent electronically, disclosures must be attached or hyperlinked with clear labels. Body of email must include: • Resource mix and geographic location • Enrollment level • Price of product • Contract length
  27. Phase 1 Phase 2 Phase 3 Not required Not required

    Required Annual Mailing Purpose: A mailing with certain required information must be delivered annually to customers with key information about the product they are receiving. Section IV.6. Requirements: • Portion of upfront disclosures (Section IV(3a): ‘Product Content Label’) • Customer enrollment level • kWh actually delivered in previous year • Projected COD, if applicable Can be sent in physical copy or electronically.
  28. Phase 1 Phase 2 Phase 3 If applicable If applicable

    If applicable Additional Marketing Materials Purpose: Any additional marketing materials used in relation to the project or the utility’s certified offering must be reviewed prior to use. Section II. Materials must align with Green-e’s ‘General Marketing Communications Guidelines and Requirements’ (Section II) Sample requirements: •May not use the Green-e logo, the phrase ‘Green-e Energy certifiable,’ nor ‘Green-e Energy eligible’ •Accurate portrayal of Green-e and nature of certification •Accurate and factual portrayal of the utility’s offering •Qualify all statements referring to ‘local’ or similar •Qualify all statements regarding cost savings and fixed pricing
  29. Requirements for cost comparisons and calculations • See Section II.7

    of Green-e Energy developer requirements • See the SEIA Solar Business Code •http://www.seia.org/policy/consumer-protection/seia-solar-business-code • Must be made clear the advertised price is: • An estimate • An introductory rate • Has eligibility requirements • Must be able to prove that the majority, if not all, of your customers will receive the cited cost savings Requirements for Cost Calculations
  30. Requirements for Cost Calculations Requirements for cost comparisons & price

    projections: (1) Use a clearly identified and verifiable method, see SEIA Solar Business Code of accepted methods (2) Specify the amount of electricity (in kwh) the comparison is based off of (3) Include the full cost of the product – meaning include the PCIA and other charges from the utility. It is inaccurate to compare the current cost of electricity to the cost from the developer minus the utility credit. (4) Provide citations for all sources used, and specify if and when they are subject to change (ex: utility charges and credit may fluctuate over time.) (5) Send to Green-e for approval (energy@green-e.org)
  31. Common issues Price projections and guarantees of cost savings •

    Provide list of data sources, assumptions, and under what circumstances the inputs are subject to change (See SEIA Business Code) • Specify that utility bill charges & credit are subject to change with CPUC approval • Statement must be true for the majority, if not all, of your customers Example: X You will save money over the life of your deal! ü You will save money over the life of your deal!* * Cost savings are calculated based on a 20-year projection using historical utility data from Utility Source 20XX. Please note the utility credit and utility charges are subject to change with CPUC approval.
  32. Common issues Price structure • Be careful regarding “fixed price”

    – while the CDA’s price may be fixed over time, the utility charges and credit may fluctuate over time • Savings can likely only be guaranteed if the CDA price is pegged to utility charges Example: X Sign up for a fixed price for solar for 10 years! ü You will pay a fixed price for solar generation for 10 years. The charges and credits from your utility are subject to change over time with CPUC approval.
  33. Misrepresentation of costs • Be clear on all costs, including

    ongoing billing and other fees utility will charge Common issues Example: X Sign up for solar for free! üThere are no enrollment fees – you will pay $10/month for a 1kW solar panel. 1 kW is equal to approximately XX kWh a month in California.
  34. Poor representation of bill dynamic • Be clear in all

    references to price that the customer will continue to receive a bill from the utility • Always refer to utility’s bill credit as a “bill credit” or a “credit” – never as a ‘reward’ or similar Common issues Example: X Sign up for solar energy and pay us for your electricity! ü When you sign up for solar energy you will receive two bills – one from Developer for your share of the solar farm, and one from your utility. Your utility bill will include a credit for the energy purchased from solar.
  35. Common issues Product features, such as advertising ‘local’ • See

    Section II.8 of the Green-e Energy developer requirements • Qualify by specifying the counties within which the product will be built Example: X Purchase solar in your neighborhood! ü Purchase solar in your neighborhood!* * Solar farm will be located within 5 miles of Alameda county.
  36. Ongoing obligations After initial approval, developers must: ØSubmit all new

    marketing materials, or revisions to existing marketing materials, for approval prior to use ØAnnually submit all marketing materials used for a marketing compliance review ØAnnually deliver mailing to customers
  37. Enforcement and Censure ØDevelopers determined to be out of compliance

    with requirements will be notified via letter and will have 30 days to remedy ØDevelopers inclusion in utility’s program will be terminated if developer does not come into compliance ØA developer whose inclusion in the certified offering is terminated must follow procedures outlined in Section VI.2 ØA developer whose inclusion in the certified offering is terminated for failure to remedy non-compliance cannot re- engage for 12 months Section VI of Green-e energy developer requirements
  38. • What is Green-e • Enhanced Community Renewables & split

    of responsibilities • Developer marketing material requirements • Developer marketing material submission & review process • Utility-specific requirements
  39. Submission Details 1. Submit separate materials for each proposed project

    to utility 2. Utility will respond with comments, including Green-e comments 3. Re-submit to utility 4. Submit any price information or methodology for savings to Green-e directly energy@green-e.org for approval 5. Receive formal written utility approval for a specific phase of marketing
  40. • What is Green-e • Enhanced Community Renewables & split

    of responsibilities • Developer marketing material requirements • Developer marketing material submission & review process • Utility-specific requirements
  41. 1 Regional Renewable Choice Requirements Marketing Materials Review • The

    CPUC’s final GTSR Decision (15-01-051) states that PG&E must review all developer marketing materials before they are used to market to customers. • Developer marketing materials must comply with: • Green-e Energy Developer Requirements • The California Public Utility Commission's Community Choice Aggregation Code of Conduct, which includes marketing and outreach requirements relative to Community Choice Aggregation. • Must be truthful, accurate and not false or misleading. • PG&E Disclaimer and Logo Usage Guidelines • Developer marketing materials submissions must include: • All materials the developer intends to use for marketing Phase One: Community Interest or Phase Two: Customer Enrollment as provided in the Green-e Energy Developer Requirements. • Marketing Compliance Attestation • A summary of all claims and factual statements made in marketing materials. Marketing materials should be submitted to SolarChoiceMarketing@pge.com.
  42. Marketing Materials Submission Process • To begin the review process,

    submit all materials intended for use for marketing to potential customers to: CommRenewables@sce.com • Your submission should confirm whether you’re seeking confirmation of compliance with: ‒ Marketing Phase One: Community Interest or ‒ Marketing Phase Two: Customer Enrollment • Reminder: If awarded a Power Purchase Agreement (PPA), “Community Interest” must be demonstrated within 60 days from the date of award – deadline will not be extended Southern California Edison 1
  43. What To Expect When You Submit • Confirmation of receipt

    is typically provided via email within 2 business days • Submissions are initially assessed for completeness. Content review will commence when all required materials have been submitted. • Compliance will be confirmed for submissions that include all of the required elements and align with Green-e Developer Requirements within 30 days ‒ You should expect to receive feedback regarding any required edits within 10 to 15 business days • Missing components and multiple required iterations will extend this timeline Southern California Edison 2
  44. For More Information Program Information: • on.sce.com/CRDevInfo Renewables Auction Mechanism

    RFO Instructions: • https://sceram.accionpower.com/_scecrram_1602/accionho me.asp Email: • commrenew@sce.com 3
  45. SDG&E Program Information and Marketing Review The following websites contain

    information for developers wishing to participate in SDG&E’s Share the SunSM program: 1. General Program Information – http://www.sdge.com/environment/share-sun-for-developers • Program overview • Community interest requirements • Link to open solicitations 2. Marketing Materials Review – SDG&E must review all Share the Sun marketing materials prior to use or publication – http://www.sdge.com/environment/developer-marketing-requirements-and-review- process • Marketing review timeline and instructions for submitting materials • SDG&E’s Marketing Attestation • SDG&E logo and disclaimer requirements • Green-e Energy requirements and links to important Green-e Energy documents Please submit questions to CTTS@sdge.com Ò
  46. None
  47. Questions? Green-e contact: maya.kelty@resource-solutions.org