Green-e Energy Participant Training Webinar: Autumn 2017 Marketing Compliance Review

Join Green-e Energy staff for a review of the Autumn 2017 Marketing Compliance Review (MCR) process. We will discuss the requirements of the Green-e Energy Code of Conduct that apply to the marketing of Green-e Energy certified renewable energy and renewable energy certificate (REC) products. Aired Monday, August 14, 2017 at 11:00am-12:00pm Pacific .

Transcript

1. Green-e Energy Marketing Compliance Review Training Webinar Autumn 2017 August 14, 2017, 11am Pacific ________________________________________________ Sarah Busch Manager, Partnerships & Certification Programs Kirsten Ho Analyst, Certification Programs
2. 1. MCR Submission Process • Purpose • Timeline 2. Key Requirements • Prospective & Historical Product Content Labels • Price, Terms & Conditions • Enrollment and Sales Channels • REC product requirements • Green-e Energy certified logo use • General marketing requirements • ‘Green-e Eligible’ vs. ‘Green-e Certified’ • PPA Best Practices 3. Q&A The MCR Process
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 on the annual August cycle and semi-annual cycle What to submit...All materials relating to the certified product • Products on semi-annual cycle: Submit materials used from 01/01/2017 to 06/30/2017 • Products on annual cycle: Submit materials used from 07/01/2016 to 06/30/2017 When to submit…….…………by COB Thursday, August 31, 2017 • 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: https://www.green-e.org/energy-portal Access code: True4878
8. Materials to Submit – Single mix
9. Materials to Submit – Multiple mix
10. • Prospective & Historical Product Content Labels • Price, Terms & Conditions • Enrollment and Sales Channels • REC product requirements • Green-e Energy certified logo use • General marketing requirements • ‘Green-e Eligible’ vs. ‘Green-e Certified’ • PPA Best Practices Key Requirements
11. Prospective Product Content Label Purpose: Shows customers the product offered (including resource type) Timeline: Prospective PCL must be sent to customer within 60 days of enrollment and must be updated annually by April 1, including posted on website and sent to customers under automatic enrollment. Requirements: • Prospective PCL template provided. • Specific title required: “[Year] Prospective Product Content Label” • 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
12. 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. Timeline: Historical PCL must be delivered to customers by August 1 of the following year, at minimum. Requirements: • Historical PCL template provided. • Resource type and proportion of the actual supply procured • Generation location (by state or states) of the actual supply procured • Delivered to all customers that purchased the Green-e certified product in the previous year. • Upfront Historical PCL (one-time sales only).
13. • Templates available at www.green-e.org/pcl • More templates added over time • Keep overall PCL format and phrasing • Minor changes, such as font, color, and borders permitted Common PCL Issues: • REC products: Omitting REC disclosure/ using old language. • Inconsistent product name. • Electricity products: Listing states outside of the product’s region. Or, listing a region instead of specific states. • Use of “and” instead of “or.”
14. 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. 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 by Green-e staff and changes greater than 10% 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
15. Verification & PCLs Example: 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 NOTE: Substantial Differences in supply require additional review by Green-e staff, and may require a vote by the Green-e Governance Board.
16. Price, Terms & Conditions Purpose: Clearly describes the customer’s responsibilities when purchasing the certified product. Sample requirements: • Cost of product, other fees • REC product must clarify when price includes REC and electricity costs as one charge. • Rate structure (variable or fixed) • Contract length • How the customer will be billed • Termination fees, and cancellation policy • Company contact information
17. PTC template not required, but requirements must be disclosed clearly. Template available within Green-e Energy Participant Handbook.
18. 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.
19. Website Direct Mailer Door-to-Door Over-the-phone At enrollment Fully visible subscription mechanism requirements & hyperlinked PPCL, HPCL and PTC Subscription mechanism requirements Subscription mechanism requirements 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: For customers on automatic renewal, deliver the current year’s Prospective PCL to customers by April 1. Enrollment & Timing of Disclosure
20. Welcome Packet 2017 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. Physically-mailed welcome packets for REC products must contain Long REC Disclosure.
21. 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 v2.1: Emailed welcome packets must contain clarification of enrollment level, and either hyperlinks to the PPCL and PTC or a fully-displayed PPCL and PTC.
22. 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 Required 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.
23. 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. 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.
24. Prior to customer enrollment… Option 1 Fully-display the 2017 Prospective PCL, 2016 Historical PCL, and current Price Terms & Conditions. Option 2 Fully-display Material with Subscription Mechanism information, hyperlinks to 2017 Prospective PCL, 2016 Historical PCL*, and current Price Terms & Conditions. *Applies to products certified prior to 2017. 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
25. Call Center Enrollment • 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 offer AwesomeRenewableEnergyProduct. It is made up of electricity generated from 100% renewable energy generated in California and costs $10 per 1 MWh. Your purchase is month-to-month and there are no termination fees.”
26. 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.
27. 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 www.green-e.org/REC.” • 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 • Links to online Long REC Disclosure Language at www.green-e.org/rec REC Product Disclosure
28. 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.” Long REC language must be 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: www.green-e.org/rec. REC Product Disclosure
29. • 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 Marketing Restrictions for REC Products
30. • Statements about customers using renewable energy through the purchase of RECs are permitted. Examples “Use renewable energy by purchasing WindREC and electricity from UtilityCompany.” “By purchasing WindREC and electricity, you are using renewable energy for your home or business.” • Statements about RECs being sourced from renewable energy are allowed. Examples “WindREC 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
31. 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 *If the certified product is advertised on Participant website, display logo and updated language must be present.
32. 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. Facility specific claims will need to verified during annual verification
33. Carbon Equivalency Claims 1. All carbon equivalency claims must be substantiated. 2. Participants should use and cite the EPA’s carbon equivalency calculator. 1. https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator 3. Claim must be associated with the generation or supply. 1. Ex. “The renewable energy used in [product name] avoided [xx] pounds of CO2.” 2. Ex. “The 100% renewable electricity that you choose avoids [X] metric tons of carbon dioxide-equivalent per MWh on the Western grid.” 3. NOT ALLOWED: “By purchasing 1 MWh of [product name], you are avoiding [xx] pounds of CO2.” 4. If you are unsure about your claim, contact your Green-e representative.
34. Green-e Eligible vs. Green-e Certified 1. Confusion in the market about “Green-e eligible” vs. “Green-e certified.” 2. If the facility’s attestation is processed, it will be placed on the Tracking Attestations Received list. Green-e participants have exclusive access. 3. This does not mean the RECs are or are guaranteed to be Green-e Energy certified. 4. Only current participants can represent RECs as certified. 5. No longer allowing use of terms “Eligible” or “Certifiable” in marketing materials for the Green-e Energy certified product.
35. Commercial and Wholesales: Best Practices 1. The Green-e Wholesale Attestation is a document for Green-e’s internal use during the annual verification audit, and is not a REC contract that should be given to an end-use customer. 2. PCL template is not required, but the contents of the PCL are required information for customer buying Green-e Energy certified products. 3. Historical PCL information is required if the prospective information is broad (such as “Green-e National).” 4. If selling to non-residential customers, PCL format may differ from the templates provided if and only if: (1) it includes the required Product Content Label information, and (2) the template has been pre-approved by Green-e staff. 5. For wholesale transactions, all required information must be presented within one document, such as a contract. For a template of how participants selling a wholesale REC or renewable electricity product can present the PCL requirements within a contract, visit www.green-e.org/pcl.
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. Takeaways 1. MCR submissions due August 31, 2017 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). 3. Submit materials for your multiple-mix products. 4. Green-e staff will provide feedback based on version 2.1 of the Code of Conduct. 5. Throughout the year, your Green-e Energy Regional Representatives are available to review marketing materials.
39. October 22-24, New York, NY www.renewableenergymarkets.com Early bird registration deadline ends August 14th (today)
40. For More Information MCR Instructions and Checklist: http://www.green- e.org/getcert_re_veri.shtml#mcr Map of Green-e Energy Regional Representatives: https://resource- solutions.org/wp-content/uploads/2017/04/Green-e-Reps-Map.png Questions? Contact: Energy@green-e.org