Green-e Energy Marketing Compliance Review Training Webinar Autumn 2016

Join Green-e Energy for an overview of the submission process for Autumn 2016 Marketing Compliance Review. Staff discussed recent updates to the Green-e Energy Code of Conduct and the timeline for implementing the requirements of Version 2.0 of the Code of Conduct, which went into effect July 24, 2016, and Version 2.1 of the Code of Conduct, which goes into effect January 1, 2017.

Transcript

1. Sarah Busch Green-e Analyst & Partnerships Specialist Green-e Energy Marketing Compliance Review Training Webinar Autumn 2016 And updates to the Green-e Energy Code of Conduct ________________________________________________ August 11, 2016
2. Webinar Outline 1. MCR Process 2. Updates to the Code of Conduct - Version 2.0 - Version 2.1 3. Hot Topics 4. Q&A
3. Purpose of MCR A twice-annual evaluation of marketing, disclosure, and enrollment materials used for Green-e Energy certified products against the requirements of the Code of Conduct. The Green-e Energy Code of Conduct contains requirements for certified product sales and marketing.
4. The MCR Process Who submits….... Participants selling to residential customers • MCR for products sold to commercial buyers starts February 2017 What to submit...all materials relating to the certified product • Products on semi-annual cycle: Submit materials used from 02/01/2016 to 06/30/2016 • Products on annual cycle: Submit materials used from 08/01/2015 to 06/30/2016 When to submit……………………………by Wednesday, August 31 • Send submission to energy@green-e.org
5. The MCR Process By August 1st August 31st Early Autumn Mid Autumn 1 Month Later Request for Materials MCR Materials Due 1st Staff Review Follow Up Forms Sent to Participants Completed Changes Due* 2nd Staff Review *Ask questions and complete all requested changes before the deadline.
6. The MCR Process MCR Instructions: http://www.green-e.org/getcert_re_veri.shtml#mcr
9. Updates to the Code of Conduct Version 2.0, Released July 24, 2015 (effective July 24, 2016) Version 2.1, Released May 19, 2016 (effective January 1, 2017) www.green-e.org/coc Autumn 2016 MCR Submissions reviewed against Version 2.0, and any feedback applicable to Version 2.1 will be included.
10. Code of Conduct 2.0 Highlights • New document organization • Timeline of Green-e deadlines • Use of Product Content Label template is required • Price Terms & Conditions template removed/not required • Utilities are no longer required to send Historical PCL to customers that did not purchase the certified product (now only purchasers must receive HPCL) • HPCL deadline moved to August 1 • Updated Green-e Energy Logo Language • Updated REC language (short and long) and new disclosure requirements
11. Code of Conduct 2.1 Highlights • Reorganized sections and streamlined language for enhanced usability • Adjusted REC seller language requirements to prevent customer confusion • Updated greenhouse gas emissions guidance • Clarified requirements applicable to products sold to commercial buyers • Streamlined disclosure requirements • Links to downloadable Product Content Label templates at www.green-e.org/pcl • Long REC language hosted at www.green-e.org/rec • Creation of a new Participant Handbook containing marketing language examples, call center guidelines, and Price Terms & Conditions template
12. Code of Conduct 2.1
13. • Prospective & Historical Product Content Label • Price, Terms & Conditions • Enrollment & Welcome Packet • Subscription Mechanism Requirements • REC product requirements • Call center requirements • Green-e Energy certified logo use • General marketing requirements Hot Topics
14. Prospective Product Content Label Purpose: Shows customers the product offered (including resource type) Sample requirements: • Prospective Product Mix (resource type, proportion, and location) • Enrollment level options or selection (selection must be disclosed in PPCL or welcome packet) • For REC products: Short REC disclosure language with hyperlink to online Long REC disclosure language • Comparative mix • New Date Footnote Required v2 and 2.1: Prospective PCL template required. Specific title required: “[Year] Prospective Product Content Label” New v2.1: Starting 2017, Prospective PCL must be updated annually by March April 1, including posted on website and sent to customers under automatic enrollment.
15. • Templates available at www.green-e.org/pcl • More templates added over time • Minor changes made from v 2 to 2.1 • Keep overall PCL format and phrasing • Minor changes, such as font, color, and boarders permitted
16. Historical Product Content Label Purpose: Communicates the actual resource type, proportion and location of resources that were delivered to (retired for) the customer in a specific year. Sample requirements: • Resource type and proportion of the actual supply procured • Generation location (by state or states) of the actual supply procured Required v2 and 2.1: • Historical PCL template required. • Delivered to all customers that purchased the product in the previous year. • Starting 2016, Historical PCL must be delivered to customers by August 1, at minimum. • Upfront Historical PCL (one-time sales only).
17. Verification & PCLs Green-e Energy program requirement: Supply must match marketing disclosures (sales) to ensure that the customer receives the product promised at time of purchase. 2016 Prospective Product Content Label Hydro 50% Pennsylvania, Virginia, New Jersey Wind 50% Pennsylvania, Ohio 2016 Historical Product Content Label Hydro 60% New York Wind 40% Pennsylvania Required in v2 and 2.1: New process for addressing Substantial Difference in Supply
18. Verification & PCLs Tips 1. Changes in product mix may impact your product’s annual Verification Audit and certification. 2. The best time to change your product mix for the upcoming year is Jan 1 of that year. 3. Mid-year changes, such as additions or removals of resource types or states, and variance greater than 4%, require approval from the Green-e Governance Board. 4. Marketing teams and supply teams should coordinate on product mix and changes. 5. Talk to your Green-e staff representative as you plan a product mix change. • See requirements in Section V of Code of Conduct v2.1 • Examples within Green-e Energy Participant Handbook
19. Price, Terms & Conditions Purpose: Clearly describes the customer’s responsibilities when purchasing the certified product. Sample requirements: • Cost of product, other fees • Rate structure (variable or fixed) • Contract length • How the customer will be billed • Termination fees, and cancellation policy • Company contact information • New v2.1: REC product must clarify whether cost includes electricity + REC, and who (the REC seller, or customer’s utility or energy service provider) will charge the customer for electricity
20. New v2 and 2.1: PTC template not required. Although, requirements must be disclosed clearly. Template available within Green-e Energy Participant Handbook.
21. Purpose: In order for customers to make an informed decision about their purchase, Green-e Energy requires specific disclosure prior to the time of purchase. Sales Channels include: • Online, and other electronic media • Over-the-phone • In-person/door-to-door • Physical materials with subscription mechanism Customer Enrollment Reminder: Only the company in contract with Green-e Energy to sell a certified product may enroll customers. At all times, the company name must be clearly represented to the customer.
22. Website Direct Mailer Door-to-Door Over-the-phone At enrollment Required v2 and 2.1: Fully visible subscription mechanism requirements & hyperlinked PPCL, HPCL and PTC Subscription mechanism requirements Subscription mechanism requirements Required v2 and 2.1: Call center language Within 60 days of enrollment Welcome Packet (PPCL + PTC) Welcome Packet (PPCL + PTC) Welcome Packet (PPCL + PTC) Welcome Packet (PPCL + PTC) Annually by August 1 (previously June 30) Historical PCL HPCL HPCL HPCL Required v2.1: For customers on automatic renewal, deliver the current year’s Prospective PCL to customers by April 1. Enrollment & Timing of Disclosure
23. Welcome Packet 2016 Prospective Product Content Label Price, Terms & Conditions _____________________________ ___________________________________ ____________ ________________________________ _____________ _____________ _____________ ____________ __ _______________ __ ___________ _______________ ___________ ______________________ ___________ ______________________ ___________ ______________________ ___________ ______________________ ___________ ______________________ ___________ ______________________ ___________ ______________________ D D d Nice. Green-e Energy Certified New2 Renewables in [PRODUCT NAME] Generation Location Wind 50% NY Hydro 50% NY All customers must receive an emailed or mailed welcome packet within 60 days of enrollment NEW v2.1: Physically-mailed welcome packets for REC products must contain Long REC Disclosure
24. Welcome to AwesomeUtilityCompany’s Green Power Program! Dear Jane Doe, Thank you for purchasing renewable energy! You are enrolled to use 50% renewable energy… Please view the 2016 Prospective Product Content Label and Price Terms & Conditions for information about the renewable energy you are purchasing. Sincerely, AwesomeUtilityCompany Required v2 and 2.1: Emailed welcome packets must contain clarification of enrollment level, and either hyperlinks to the PPCL and PTC or a fully-displayed PPCL and PTC.
25. Welcome to AwesomeUtilityCompany’s REC Program! Dear Jane Doe, Thank you for purchasing Renewable Energy Certificates! You are enrolled to buy 500 kWh per month… Please view the 2016 Prospective Product Content Label and Price Terms & Conditions. For more information about the RECs you are purchasing, visit: www.green-e.org/rec. Sincerely, AwesomeUtilityCompany NEW v2.1: Emailed welcome packets for REC products must contain a link to the Long REC Disclosure Language. The language may be hosted on participant’s website, or linked to www.green-e.org/rec.
26. Subscription Mechanism Requirements Requirements: 1. Resource mix 2. Geographic location 3. Price of certified product, fixed or variable rate, other fees 4. Contact length 5. Fee for early termination (if applicable) 6. “Green-e Energy certified” Logo, with www.green-e.org or Green-e Energy logo language Additional Requirements for REC Products 7. Short REC Disclosure Language 8. NEW v2.1: REC products sold by electricity providers must disclosure whether price contains cost of certified REC product and cost of electricity Tip: These requirements are met by displaying the full Prospective PCL and Price Terms & Conditions within the subscription mechanism.
27. Required v2 and 2.1 Option 1 Prior to customer enrollment, fully display the current year’s Prospective PCL, previous year’s Historical PCL, and current Price Terms & Conditions. OR Option 2 Prior to customer enrollment, fully display Material with Subscription Mechanism information, hyperlinks to the current year’s Prospective PCL, previous year’s Historical PCL (if product certified prior to 2016), and current Price Terms & Conditions. Examples: • For a complete list of the resources included in AwesomeProductName view the Prospective Product Content Label. • To see what customers received last year, view the Historical Product Content Label. • To view highlights of the condition of your subscription, see the Price, Terms & Conditions. Enrollment Through Website
28. Call Center Enrollment Required v2 and 2.1: • Communicate the information contained in the Material with Subscription Mechanism requirements to customers prior to over-the- phone enrollment • For REC products, the Short REC Disclosure must be read Tip: See examples for electricity and REC products within the Green-e Energy Participant Handbook Example for Electricity Products: “We [or, Company Name] offer [Product Name]. It is made up of electricity generated from [list all resource types found on Prospective Product Content Label] [power / energy] located in [insert names of states, provinces, or territories listed on Prospective Product Content Label]. Would you like to know more about [Product Name]?
29. Best Practices: Call Centers 1. Provide customer service representatives with a cheat sheet about the certified product. 2. For REC products, clarify that changes on the bill will be in addition to charges for electricity service. 3. Clarify the resource type and generation location of the RECs or renewable energy. Must match the Prospective PCL. 4. “Green-e Energy is a third-party certification program for the [product name] [product type] product.” 5. Submit call center scripts, cheat sheets, and other materials during MCR.
30. Short REC Disclosure Language “[Product Name] is a Renewable Energy Certificate (REC) product and does not contain electricity. A REC represents the environmental benefits of 1 megawatt hour (MWh) of renewable energy that can be paired with electricity. For more information, see [hyperlink to the Participant’s or Green-e’s webpage containing long REC disclosure language].” • Fully visible on Prospective Product Content Label • Fully visible on Historic Product Content Label • Fully visible on Price Terms & Conditions • Fully visible on all marketing materials with a subscription mechanism • Fully visible prior to online purchase • NEW: Links to online Long REC Disclosure Language at www.green-e.org/rec REC Product Disclosure
31. Long REC Disclosure Language “Your purchase of Renewable Energy Certificates (RECs) supports renewable electricity production in the region of generation. A REC represents the environmental benefits of 1 megawatt hour (MWh) of renewable energy. For every unit of renewable electricity generated, an equivalent amount of RECs is produced, and by purchasing and pairing RECs with your electricity service you are using and receiving the benefits of that renewable electricity. Your REC purchase also helps build a market for renewable electricity. Increased demand for, and generation of, renewable electricity helps reduce conventional electricity generation in the region where the renewable electricity generator is located. It also has other local and global environmental benefits which may include emitting little or no regional air pollution or carbon dioxide. The RECs in [Product Name] are verified and certified by Green-e Energy, and [Company Name] is required to disclose the quantity, type and geographic source of each certificate. Please see the Product Content Label for this information. Green-e Energy also verifies that the renewable certificates are not sold more than once or claimed by more than one party. For information on Green-e Energy please visit its website, www.green-e.org.” Required v2 and 2.1: Long REC language fully displayed on Participant website, or a link on website with a sentence such as the following: “For more information about Renewable Energy Certificates (RECs), see: [hyperlink to Participant’s or Green-e’s webpage containing Long REC Disclosure language].” REC Product Disclosure
32. • Green-e Energy does not allow REC sellers to refer to or represent their product as “renewable energy.” RECs do not contain electricity. • Accurately represent that only the REC product is certified. • Clarification is required for REC product names that contain “energy,” “power,” or similar terminology implying that the product contains electricity. Example “Buy AwesomeWindPower and lower your carbon footprint! AweasomeWindPower is a REC product, and does not contain electricity.” See requirements in Section IV.E2.c, Code of Conduct v2.1 Restricted Language for REC Products
33. • Statements about customers using renewable energy through the purchase of RECs are permitted. Examples “Use renewable energy by purchasing AwesomeWindREC and electricity from AwesomeUtilityCompany.” “By purchasing AwesomeWindREC and electricity, you are using renewable energy for your home or business.” • Statements about RECs being sourced from renewable energy are allowed. Examples “AwesomeWindREC is sourced from wind farms across the country.” “By purchasing this renewable energy certificate product, you are supporting 100% wind generated power.” See examples in the Green-e Energy Participant Handbook Permitted Language for REC Products
34. Green-e Energy Certified Logo [Product Name] is Green-e Energy certified, and meets environmental and consumer-protection standards set forth by the nonprofit Center for Resource Solutions. Learn more at www.green-e.org. Green-e Energy certified logo and program language must be present on the 1. Historical PCL 2. Prospective PCL 3. Price, Terms and Conditions, and 4. Participant website Required v2 and 2.1: Display logo and updated language on Participant website, if certified product advertised.
35. General Marketing Requirements 1. Use environmental marketing claims that are clear and factually-based. 2. Broad statements about being the “first” renewable energy company/REC seller in X or to provide X must be accurate and substantiated. 3. Use of “local” or “regional” requires disclosure of state in the Prospective PCL in immediate proximity to the marketing statement. 4. Each certified product must have a clear and unique product name, and marketing must distinguish certified products from non-certified products. 5. Make specific statements. 6. Do not overstate the environmental benefits of purchasing the certified product. 7. Do not refer to, or represent, RECs as offsets. 8. Reference the source for carbon-equivalency claims.
36. Green-e Energy Participant Handbook • Guidance and explanation about Green-e Energy procedures • Sections to be added over time • www.green-e.org/coc Version 1 includes: • Detailed description of Green-e Energy processes • Templates for Price Terms & Conditions • Long Green-e Energy Description Language • REC Seller Example Language • Call Center Guidance • Marketing language guidance for GHG emissions value of renewable energy products
37. Q&A
38. 5 Takeaways 1. MCR submissions due August 31, 2016 for all products sold to residential customers 2. Submit all materials related to the certified product (even if they do not mention Green-e or certification), including 2016 Historical PCLs 3. Green-e staff will provide feedback based on version 2 of the Code of Conduct, and highlight any changes that could be made to meet version 2.1 4. Starting February 2017, Green-e will require products sold only to commercial customers (multiple-mix and single-mix) to complete MCR 5. Throughout the year, your Green-e Energy Regional Representatives are available to review marketing materials
40. October 16-18, San Francisco, CA www.renewablenergymarket.com Early bird registration deadline ends August 16th
41. For More Information 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 Questions? Contact: Energy@green-e.org