Green-e Energy Marketing Compliance Review

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

Transcript

1. Green‐e Energy Marketing Compliance Review August 4, 2014 Robin Quarrier, Chief Counsel Sarah Busch, Green‐e Program Associate __________________________________________________________________
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?
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
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
6. *This is just a sample.
7. 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
8. Hot Issues
9. ENROLLMENT • Online • Over the phone • In‐person/door‐to‐door • Material w/ subscription mechanism
10. 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
11. 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.
12. PROSPECTIVE PRODUCT CONTENT LABEL Required disclosure document. ‐ Contains prospective mix of resources. ‐ Follow the default template unless otherwise mandated by state.
13. 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.
14. 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
15. “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
16. 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
17. 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.
18. 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
19. 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.
20. 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.
21. 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
22. 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.”
23. 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
24. 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
25. 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
26. 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.
27. 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.
28. CONTROL OVER MARKETING MATERIALS • Who is selling me this Green‐e Energy Certified product? • Partner websites • Green‐e word mark • Green‐e Logo
29. 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
30. • 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
31. 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)
32. 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.
33. 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. .
34. 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. .
35. 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.
36. Throughout the year… Your Green‐e Energy Regional Representatives are available to review marketing materials.
37. Q&A
38. 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