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Green-e Energy Marketing Compliance Review

Green-e Energy Marketing Compliance Review

Originally Presented by Sarah Busch and Robin Quarrier, Center for Resource Solutions, on August 4, 2014.

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  1. Green‐e Energy Marketing Compliance
    Review
    August 4, 2014
    Robin Quarrier, Chief Counsel
    Sarah Busch, Green‐e Program Associate
    __________________________________________________________________

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  2. Code of Conduct Updates
    • Why are we making the update?
    • When will it be completed?
    • Is this a formal stakeholder process?
    • How will the update occur?

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  3. WEBINAR OUTLINE
    MCR Process
    ‐ Checklist/Follow Up Form
    ‐ Timeline
    Hot Issues
    ‐ Enrollment
    ‐ Disclosure Documents
    ‐ Green‐e Energy Certified Logo
    ‐ Carbon Equivalency Claims
    ‐ Products with Special Features
    ‐ Call Centers
    Questions and Answers

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  4. HOUSEKEEPING
    Who submits…..........Participants selling to residential customers
    How to submit..............................................energy@green‐e.org
    What to submit.......all materials relating to the certified product
    When to submit……………………………………….by Friday, August 29th

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  5. *This is just a sample.

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  6. THE MCR PROCESS
    By the 1st of
    August
    August 29th Early Fall Mid Fall 1 Month Later
    Request for
    Materials
    MCR Materials
    Due
    1st Staff Review
    Follow Up
    Forms Sent to
    Participants
    Completed
    Changes Due
    2nd Staff Review

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  7. ENROLLMENT
    • Online
    • Over the phone
    • In‐person/door‐to‐door
    • Material w/ subscription mechanism

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  8. ENROLLMENT
    Prospective
    Product
    Content Label
    Price, Terms
    & Conditions
    Welcome
    Packet
    (PPCL + PTC)
    Historic
    Product
    Content Label
    Online X including
    subscription
    mechanism
    requirements.
    X including
    subscription
    mechanism
    requirement.
    X X
    Over the phone Subscription
    mechanism
    requirements
    Subscription
    mechanism
    requirements
    X X
    Material with a
    Subscription
    Mechanism
    Subscription
    mechanism
    requirements
    Subscription
    mechanism
    requirements
    X X
    Automatic renewals Annually, or
    when resource
    mix changes.
    Whenever
    significantly
    changed.
    X X

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  9. MATERIALS WITH SUBSCRIPTION MECHANISMS
    Common Mistakes: Forgetting resource mix, or states. (Electricity products must list region.)
    Super Awesome REC Product
    50% Wind Texas
    This product is sold at a rate of…
    $X.00/#kWh
    Required contract length and fee for early termination (if
    applicable).
    50% Hydro New York
    ‰ Yes, I subscribe!
    Your purchase of renewable energy certificates (RECs) is supporting electricity production in [states or
    region here]. You will continue to receive a separate electricity bill from your utility (if applicable). For
    every unit of renewable electricity generated, and equivalent amount of RECs is produced. The purchase of
    RECs helps offset conventional electricity generation in the region where the renewable electricity
    generator is located. The purchase also helps build a market for renewable electricity and may have other
    local and global environmental benefits such as reducing global climate change and regional air pollution.
    For more information about RECs, please visit www.green‐e.org.

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  10. PROSPECTIVE PRODUCT CONTENT LABEL
    Required disclosure document.

    Contains prospective mix of resources.

    Follow the default template unless otherwise mandated by state.

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  11. Product Content Label for Electricity (Green Pricing and Competitive) Products sold as Percentage of Use
    PRODUCT CONTENT LABEL1
    This product matches [ ]% of your estimated electricity usage. The product will be made up of the following
    new renewable resources averaged annually.
    Green‐e Energy Certified New2 Renewables in
    [PRODUCT NAME]
    Generation Location
    ‐Biomass 0%
    ‐Geothermal 0%
    ‐Small or low impacthydroelectric3 0%
    ‐Solar 0%
    ‐Wind 0 %
    Total Green‐e Energy Certified New
    Renewables
    0%
    ‐Other Renewables 0%
    ‐Large Hydroelectric 0%
    ‐Coal 0%
    ‐Natural Gas 0%
    ‐Oil 0%
    ‐Other 0%
    Total 0%
    1. These figures reflect the power that we have contracted to provide. Actual figures may vary according to resource availability. We
    will annually report to you the actual resource mix of the electricity you purchased during the preceding year.
    2. New Renewables come from generation facilities that first began commercial operation [on or after 1/1/2000 OR within the last 15
    years or less].
    3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (http://www.green-e.org/getcert_re_stan.shtml)
    and include facilities certified by the Low Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org).
    For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil (
    x %), Natural Gas ( x %), Hydroelectric ( x %), and Other ( x %).
    For specific information about this electricity product, please contact [Company Name], [phone], [Web site].
    Green-e Energy certifies that [Product Name] meets the minimum environmental and consumer protection standards established by
    the non-profit Center for Resource Solutions. For more information on Green-e Energy certification requirements, visit www.green-
    e.org.

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  12. PRODUCT CONTENT LABEL1
    The product sold in blocks of [###] kilowatt‐hours (kWh). The product will be made up of the following
    renewable resources.
    Green‐e Energy Certified New2 Renewables in
    [PRODUCT NAME]
    Generation Location
    ‐Biomass 0%
    ‐Geothermal 0%
    ‐Small or low impacthydroelectric3 0%
    ‐Solar 0%
    ‐Wind 0 %
    TOTAL 0%
    1. These figures reflect the power that we have contracted to provide. Actual figures may vary according to resource availability. We
    will annually report to you the actual resource mix of the electricity you purchased during the preceding year.
    2. New Renewables come from generation facilities that first began commercial operation [on or after 1/1/2000 OR within the last 15
    years or less].
    3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (http://www.green-e.org/getcert_re_stan.shtml)
    and include facilities certified by the Low Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org).
    For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil (
    x %), Natural Gas ( x %), Hydroelectric ( x %), and Other ( x %).
    For specific information about this electricity product, please contact [Company Name], [phone], [Web site].
    Green-e Energy certifies that [Product Name] meets the minimum environmental and consumer protection standards established by
    the non-profit Center for Resource Solutions. For more information on Green-e Energy certification requirements, visit www.green-
    e.org.
    Product Content Label for Electricity (Green Pricing and Competitive) Products sold in
    blocks

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  13. “For comparison, the current average mix of resources supplying
    [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil
    (x%), Natural Gas (x%), Hydroelectric (x%), and Other (x%).”
    - Utility Green Pricing Programs must disclose the resource mix that
    the customer would have otherwise received.
    - Use the most recently available data, and cite the year.
    - RECs reported in alternative mix must be retired.
    COMPARATIVE ELECTRICITY MIX

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  14. PRODUCT CONTENT LABEL1
    This is a renewable energy certificate (REC) product. For every unit of renewable electricity generated, an
    equivalent amount of RECs is produced. The purchase of RECs supports renewable electricity generation, which
    helps reduce conventional electricity generation in the region where the renewable generator is located. You
    will continue to receive a separate electricity bill from your utility (if applicable).
    The product is sold in blocks of [###] kilowatt‐hours (kWh). The product will be made up of the following
    renewable resources.
    Green-e Energy Certified New2 Renewables in
    [PRODUCT NAME]
    Generation Location
    -Biomass 0%
    -Geothermal 0%
    -Small or low impact
    hydroelectric3
    0%
    -Solar 0%
    -Wind 0 %
    Total Green-e Energy Certified
    New Renewables
    0%
    TOTAL 0%
    1. These figures reflect the power that we have contracted to provide. Actual figures may vary according to resource availability. We
    will annually report to you the actual resource mix of the electricity you purchased during the preceding year.
    2. New Renewables come from generation facilities that first began commercial operation [on or after 1/1/2000 OR within the last 15
    years or less].
    3. Eligible hydroelectric facilities are defined in the Green-e Energy National Standard (http://www.green-e.org/getcert_re_stan.shtml)
    and include facilities certified by the Low Impact Hydropower Institute (LIHI) (www.lowimpacthydro.org).
    For comparison, the current average mix of resources supplying [region or your electric utility] includes: Coal (x%), Nuclear (x%), Oil (
    x %), Natural Gas ( x %), Hydroelectric ( x %), and Other ( x %).
    For specific information about this electricity product, please contact [Company Name], [phone], [Web site].
    Green-e Energy certifies that [Product Name] meets the minimum environmental and consumer protection standards established by
    the non-profit Center for Resource Solutions. For more information on Green-e Energy certification requirements, visit www.green-
    e.org.
    Product Content Label for REC products

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  15. HPCL DELIVERY
    WHAT: Actual proportion and location of resources that were
    delivered to (retired for) the customer.
    WHO: All customers that purchased the certified product in the
    previous year.
    • Currently, Utility Green Pricing Programs must send the HPCL to all
    customers.
    WHEN: Annually, by June 30th.
    HOW: Electronically or via mail.
    • May be contained in a newsletter.

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  16. HISTORIC PRODUCT CONTENT LABEL
    Prospective/REC Product
    Hydro 50% National
    Wind 50% National
    Historic/REC Product
    Hydro 50% New York
    Wind 50% Texas
    Prospective/PJM Electricity Product
    Hydro 50% Pennsylvania
    Virginia
    New Jersey
    Wind 50% Pennsylvania
    Ohio
    Historic/PJM Electricity Product
    Hydro 50% Virginia,
    New Jersey
    Wind 50% Pennsylvania

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  17. HISTORIC PRODUCT CONTENT LABEL
    Prospective/REC Product
    Hydro 50% National
    Wind 50% National
    Historic/REC Product
    Hydro 50% New York
    Wind 50% Texas
    Prospective/PJM Electricity Product
    Hydro 50% Pennsylvania
    Virginia
    New Jersey
    Wind 50% Pennsylvania
    Ohio
    Historic/PJM Electricity Product
    Hydro 52% Virginia,
    New Jersey
    Wind 48% Pennsylvania
    Important to include Footnote 1 in your Prospective PCL if you expect a up to 4% variance.

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  18. Common Issues: PRODUCT CONTENT LABELS
    Prospective
    • Electricity products listing states outside of their region.
    • Listing NERC region, instead of listing states is confusing for customers.
    • Incorrect New Date (also issue for HPCL).
    • Confusing formatting (also issue for HPCL).
    Historic
    • Delivery.
    • What if the Prospective matches Historic?
    • Specifying states for REC products.

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  19. PRICE, TERMS & CONDITIONS
    Clearly describes the customer’s responsibilities when
    purchasing the certified product.
    • Price/rate
    • Contract length
    • How the customer will be billed
    • Fee for early termination
    • How to contact the company

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  20. Price, Terms & Conditions
    [Product] is certified by Green-e Energy, which requires companies to provide
    their customers with this notice of Price, Terms and Conditions of service. From
    the time you receive this, you have three business days to change your mind
    about purchasing [Product] from [Company Name]. You may cancel
    your agreement to purchase [Product] from [Company Name] by calling the
    customer service number or writing to the billing address listed below. For more
    information about Green-e Energy, write Green-e Energy, 1012 Torney Ave,
    2nd Floor, San Francisco, CA 94129 or log onto www.green-e.org,.
    Company: [Company Name] (a subsidiary of [Name] Corporation)
    Whom should I contact for more information? Include contact information here including Customer Service number, Web Page,
    E-mail and Billing Address.
    How will I be billed? Explain how customer will be billed. e.g. You will receive a monthly bill for
    [Product] from [Company Name].
    How will my bill be calculated? Explain how charges will be calculated. Provide all details on actual pricing
    structure, even if it’s complex; may be different depending on product type.
    Taxes: You must also pay all applicable federal, state, and local taxes and
    charges**
    Participants selling RECs should also include the following language:
    “This purchase is in addition to charges by your electric utility. You will continue to
    receive a separate electricity bill from your utility.”

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  21. Price, Terms & Conditions continued...
    How much will my total electricity
    service cost, including utility
    charges?
    Provide the customer with an estimate of how much their electricity will cost. At the
    option of the utility, the table could include these estimates on a utility service
    territory basis, as a monthly average, as a percentage of their current electricity bill
    and/or at different electricity usage levels.
    e.g. Based on a monthly average usage of 500 kWh, the following table provides
    you an estimate of your 2008 monthly electricity bill if you receive service from
    your local utility supplier, and the extra monthly cost for the [Company Name]
    service. Your actual bill will vary based on your use of electricity.*
    2008 Monthly Electricity Cost $53.50
    Green Pricing Premium $5.20
    Total: $58.70
    Will my rates change over time? Explain how rates will change over time. Include chart of historic price variability
    after first year, if applicable. (e.g. The existing rate structure for your [Company
    Name] service is guaranteed for the length of the contract (2 years).
    What sources will be used in my
    certified product?
    Include power content label here or reference it on another part of this one page
    sheet.
    If I want to terminate this
    agreement/ contract, what is the
    early termination fee?*
    e.g. $XX
    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

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  22. WELCOME PACKET
    Welcome packet must be delivered to customers within
    60 days of enrollment.
    Prospective Product
    Content Label
    Price, Terms & Conditions
    _____________________________
    ___________________________________
    ____________
    ________________________________
    _____________
    _____________
    _____________
    ____________
    __
    _______________
    __ ___________
    _______________
    ___________ ______________________
    ___________ ______________________
    ___________ ______________________
    ___________ ______________________
    ___________ ______________________
    ___________ ______________________
    ___________ ______________________
    D
    D
    d
    Nice.
    Green-e Energy Certified New2
    Renewables in [PRODUCT NAME]
    Generation
    Location
    Wind 50% TX
    Hydro 50% NY

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  23. LOGO USE
    • Meet the color guidelines and other requirements of the
    Green‐e Logo Use Guidelines.
    • On websites, should be a direct link to www.green‐e.org.
    • Placement on a white background.
    • Use the “Green‐e Energy certified” logo on PCL, PTC and, and only in
    association with the certified product. Other uses of the Logo: green‐e.org

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  24. LOGO LANGUAGE OPTIONS
    Green‐e Energy certifies that [product name] meets the minimum environmental and consumer
    protection standards established by the non‐profit Center for Resource Solutions. For more
    information on Green‐e Energy certification requirements, call 1‐888‐63‐GREEN or log on to
    www.green‐e.org.
    The Green‐e Energy logo helps consumers easily identify environmentally superior renewable
    energy options. For more information on Green‐e Energy certification requirements, call 1‐888‐
    63‐GREEN or log on to www.green‐e.org.
    Green‐e Energy was established by the non‐profit Center for Resource Solutions to provide
    information and an objective standard for consumers to compare renewable energy options, and
    to verify that consumers get what they pay for. For more information on Green‐e Energy
    certification requirements, call 1‐888‐63‐GREEN or log on to www.green‐e.org.

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  25. LOGO LANGUAGE OPTONS
    [Company] voluntarily accepts and supports the Green‐e Energy Code of Conduct and Customer
    Disclosure Requirements and independent verification methods. Green‐e Energy assures
    customers that Participants portray their Green‐e Energy Certified renewable energy option
    accurately. The Green‐e Energy logo shown here can only be used with renewable energy options
    like this one that promise to meet Green‐e Energy’s high standards of environmental and
    marketing integrity. For more information on Green‐e Energy certification requirements, call 1‐
    888‐63‐GREEN or log on to www.green‐e.org.
    When you see the Green‐e Energy logo, it means:
    • The renewable energy option contains only new renewable resources;
    • The sources of energy supplying the renewable energy option are independently verified by
    Green‐e Energy, operated by the non‐profit Center for Resource Solutions;
    • The purchaser of a Green‐e Energy Certified renewable energy option is the sole "owner" of
    the environmental attributes of a specific megawatt hour (MWh) of energy added to the grid.
    Independent verification ensures that no MWh are double‐counted, and
    • The company offering the certified renewable energy option agrees to abide by the Green‐e
    Energy Code of Conduct and Customer Disclosure Requirements governing its ethical
    treatment of customers.
    • For more information on Green‐e Energy certification requirements, call 1‐888‐63‐GREEN or
    log on to www.green‐e.org.

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  26. CONTROL OVER MARKETING MATERIALS
    • Who is selling me this Green‐e Energy Certified product?
    • Partner websites
    • Green‐e word mark
    • Green‐e Logo

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  27. MATERIALS WITHOUT SUBSCRIPTION MECHANISMS
    • FTC Green Guides
    • Back up Local Claims
    • Ethical Guidelines/General Guidelines
    • Wind farm pictured when it is only 2% of a biomass product
    and the biomass facility is not featured

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  28. • Provide methodology
    • Provide relevant data such that Green‐e Staff can check your
    calculations
    • Over the last 10 years our company has helped customers
    purchase RECs equivalent to planting 5 million trees.
    CARBON EQUIVALENCY CLAIMS

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  29. PRODUCTS WITH SPECIAL FEATURES
    Green‐e Energy only certifies the particular product.

    Green‐e Energy does not certify special features.

    (such as a donation as a result of the purchase, or a fund to
    develop renewable energy projects)

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  30. CALL CENTERS
    Required: Disclose the information contained in a material with
    a subscription mechanism.
    ‐ Product’s resource mix
    ‐ Geographic location of resources
    ‐ Product’s rate structure
    ‐ Contract length and fee for early termination
    ‐ Short REC Disclosure language
    Recommended: Provide customer service representatives with
    a cheat sheet or FAQ containing this, and other information
    about the certified product.

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  31. Common Issues: CALL CENTERS
    What is this program?...You are supporting renewable energy.
    What is the product made of?...Renewable energy.
    Where is the renewable energy generated?...Nearby.
    What is a REC?…A donation to a clear energy project, a way to finance green
    energy, supporting renewable energy.
    Is my purchase tax deductible?...Yes.
    .

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  32. Common Issues: CALL CENTERS
    What is this program?...Your utility is offering a program to purchase [renewable
    energy or Renewable Energy Certificates].
    What is the product made of?...This product is composed of 50% wind power and
    50% hydropower.
    Where is the renewable energy generated?...The wind is generated in [according
    to Prospective PCL] and the hydropower is generated in [according to Prospective
    PCL] .
    What is a REC?…A Renewable Energy Certificate embodies the environmental
    benefits of renewable energy. You can purchase RECs, match them with your
    electricity consumption, and effectively be using renewable energy.
    Is my purchase tax deductible?...No. You are purchasing [renewable energy or
    RECs] through this program.
    .

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  33. Best Practices: CALL CENTERS
    • The customer will receive a welcome packet within 60 days of
    enrollment.
    • For REC products, clarify that changes on the bill will be in addition
    to charges for electricity service.
    • Green‐e Energy is a third‐party certification program for the
    [product name] [product type] product.
    • Point customers to resources such as Green‐e.org if they seek more
    information about renewable energy, or the certification program.
    • The facilities that generate the product (renewable energy or
    product) became commercially operational in the last 15 years.

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  34. Throughout the year…
    Your Green‐e Energy Regional Representatives are available to
    review marketing materials.

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  35. FMI
    MCR Instructions and Checklist: http://www.green‐
    e.org/getcert_re_veri.shtml#mcr
    Map of Green‐e Energy Regional Representatives: http://www.green‐
    e.org/images/Green‐e‐Reps‐Map.png
    Robin Quarrier
    Chief Counsel
    rquarrier@resource‐solutions.org
    Sarah Busch
    Green‐e Program Associate
    sbusch@resource‐solutions.org

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