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Preventing Double Claims: Best Practices in Renewable Energy Marketing (Part 1)

Preventing Double Claims: Best Practices in Renewable Energy Marketing (Part 1)

A key component of Green-e Energy certification is guaranteeing sole ownership of Renewable Energy Certificates (RECs). In RY2013 Verification, a number of RECs submitted for certification were required to be replaced. One of the primary reasons for replacement was the existence of claims on submitted RECs, rendering them ineligible for certification. With more and more players entering into the realm of renewable energy generation, clear and accurate marketing regarding renewable energy use is fundamental to maintaining market integrity. We invite you and your generator counter-parties to join us for a two-part webinar series (September 23rd and September 30th) focusing on explaining double claims and how to ensure sole ownership of the RECs you purchase.
Part 1 focuses on what kinds of marketing statements constitute claims and how you can protect yourself from claims-related issues. We explain what commitments you make under your contract with Green-e, and provide tools for you to pro-actively check existing marketing for double claims.

Center for Resource Solutions

September 23, 2015
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  1. Preventing Double Claims
    Best Practices in Renewable Energy Marketing
    September 23, 2015
    Maya Kelty
    Green-e Associate
    415-561-2133
    [email protected]
    Michael Leschke
    Green-e Energy Analyst
    415-568-2486
    [email protected]

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  2. Outline
    1. Background
    2. The Importance of Attestations
    3. Claims Review Process
    4. Timeline of Claims Review
    5. Examples
    1

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  3. Outline
    1. Background
    2. The Importance of Attestations
    3. Claims Review Process
    4. Timeline of Claims Review
    5. Examples
    2

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  4. ‘Double Claims’
    [P]ublic statements or representations that directly or through implication confer the use of
    renewable electricity or any of the environmental attributes within the REC (including
    avoided emissions) to a party who is not the REC owner. The effect of a double claim is
    that the environmental benefits of that REC are counted twice, once by the legitimate REC
    owner and once by the other claimant, which can result in environmental benefits that are
    “double-counted.” (Explanation of Green-e Energy Double Claims Policy, p.2-3).
    3

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  5. Federal Trade Commission
    FTC Green Guides: “If a marketer generates renewable electricity but sells renewable energy
    certificates for all of that electricity, it would be deceptive for the marketer to represent,
    directly or by implication, that it uses renewable energy.” (§ 260.15 (d))
    Letter to Green Mountain Power Corporation: “[A]ny statement by the company that
    might lead consumers of that electricity to infer that the energy was produced cleanly risks
    double counting. Such double counting […] not only risks deceiving consumers but also
    threatens the integrity of the entire REC market.”
    4

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  6. ‘Double Claims’ Identified in Green-e Verification
    •Affected approximately 1% of RECs submitted annually in 2013 & 2014
    •290,000 MWh replaced (2 year total)
    •90 different transactions (2 year total)
    5

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  7. Outline
    1. Background
    2. The Importance of Attestations
    3. Claims Review Process
    4. Timeline of Claims Review
    5. Examples
    6

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  8. Participant Attestation
    A commitment to perform due diligence
    7

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  9. 3) All of the renewable attributes, including any emissions avoidance, reductions or claims and all
    CO2,
    represented by the Green-e Energy certified product(s) sold in the Reporting Year indicated
    above… were transferred to customers or retired on their behalf and not sold separately to other
    customers or used to make other renewable energy claims
    Participant Attestation
    8

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  10. 5) Participant made no specific purchases and/or generation of energy that has already been
    claimed, including claims inadvertently made through generator advertising stating where
    renewable generation was delivered.
    Participant Attestation
    9

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  11. 9) For the renewable MWh sold by Participant, Participant:
    a) Did not sell, market or otherwise represent as renewable energy the electrical energy that was
    generated with the reported RECs.
    b) Did not use the electrical energy that was generated with the reported RECs to meet any […]
    renewable energy mandate.
    To the best of my knowledge, no other party participated in the actions described in a and b above with the electrical
    energy that was generated with the RECs claimed by Participant.
    Participant Attestation
    10

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  12. Chain of Custody Attestations
    G
    Untracked Facilities
    Wholesale Attestation(s)
    Generator Attestation
    W
    +
    Submitted Annually Submitted Annually
    11

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  13. Chain of Custody Attestations
    Tracking Attestation
    T
    WREGIS
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    +
    Tracked Facilities
    Submitted Annually
    Tracking Report
    Submitted every 2-3 years
    12

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  14. Outline
    1. Background
    2. The Importance of Attestations
    3. Timeline of Claims Review
    4. Claims Review Process
    5. Examples
    13

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  15. Claims Review Timing
    • Accepted all year
    • Tracking vs. Chain of Custody Attestations
    • Benefits of early submission
    Option A: Early Submission of Attestations G
    T
    W
    G
    T
    14

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  16. Claims Review Timing
    Through May
    RECs purchased
    ~June 1st
    Verification Audit
    Option B: Submission During Verification
    July through October
    Resolution of identified claims issues
    June and July
    Green-e Staff review Attestations
    W
    G T
    15

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  17. Risks for Double Claims
    Affects approx. 1% of RECs submitted annually
    •Replacement RECs
    •Interactions with counter-parties
    •Customer disclosures of varying intensity
    •Additional paperwork
    16

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  18. Outline
    1. Background
    2. The Importance of Attestations
    3. Timeline of Claims Review
    4. Claims Review Process
    5. Examples
    17

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  19. Green-e Facility Reviews
    Simple Google search.
    Review facility to ensure accuracy of attestation.
    Search via relevant companies’ webpages.
    Relevant companies’ Sustainability & Environmental webpages.
    18

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  20. Problematic Statement Determinations
    Double Claim
    • Future eligibility is contingent on removal of language and pro-active language.
    • Previously purchased RECs are ineligible
    19

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  21. Replacement RECs
    •Type: of the same resource type.
    •Timing: prompt resolution.
    •Flexibility & Disclosure: required if not same resource type or location.
    •Location: of the same geographic location.
    20

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  22. Outline
    1. Background
    2. The Importance of Attestations
    3. Claims Review Process
    4. Timeline of Claims Review
    5. Examples
    21

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  23. •Statement: “Wind Farm 22 will produce
    enough energy to power approximately 2,000
    homes. With the addition of this wind project,
    we are proud to now meet 20% of peak
    demand with renewable energy.”
    Example 1. Utility Press Release.
    Determination: Double Claim
    1 MWh Wind
    Attribute
    REC
    - - - - - - Aug 2013 - -
    - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - -
    www.utility22.com
    •Context: Press release was published in the
    past 3 years.
    •Location: Press release published on utility’s
    (generator owner) website.
    22

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  24. •Statement: Anytown, USA has installed solar panels on 5 city buildings. As a result, we
    are happy to reduce both our electricity costs and our carbon footprint
    Example 2. On-site Carbon Footprint Reduction.
    Determination: Double Claim
    - - - - - - -
    - - - - - - - -
    - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - -
    - - - - - -
    - - - - - - - -
    www.AnyTownUSA.com
    1 MWh Solar
    Attribute
    REC
    •Location: On city’s website – press release or general information on solar installations.
    Anytown, USA
    23

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  25. •Statement: After installing a solar system the school is now completely powered by clean,
    green, renewable energy.
    Determination: Double Claim
    Example 3. Third Party Articles.
    Sept 2014
    - - - - - - - -- - - - - -
    - - - - - -
    - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - -
    - - - - - -
    - - - - - - - -
    www.LocalNews.com
    1 MWh Solar
    Attribute
    REC
    •Context: Recent article on third party news site, and statement is not a direct quote from
    a school official – however, the article is linked to on school’s website ‘read about our solar
    panels in the news’
    24

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  26. • Statement: In our quest to be powered by renewable energy, we’re proud to have worked
    with Solar Installer I to install a solar system on our roof
    Determination: Double Claim
    Example 4. Onsite Generation.
    1 MWh
    Electricity
    (Null Power)
    1 MWh Solar
    Attribute
    REC
    Solar Installer
    - - - - - - -
    - - - - - -
    - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - -
    - - - - - -
    - - - - - - - -
    www.School123.com
    •Context: On host’s website.
    25

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  27. •Statement: We are proud to deliver our customers energy from the following renewable facilities.
    •Context: ‘Renewable Energy Commitments’ portion of utility website.
    Example 5. Utilities.
    Green Commitments
    - - - - - - -- - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    www.utility22.com
    1 MWh Wind
    Attribute
    REC
    26
    Determination: Double Claim

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  28. •Statement: Utility 22 has over 100 MW of wind.
    •Context: ‘Renewable Energy Commitments’ portion of
    utility website.
    Example 5. Utilities.
    Green Commitments
    - - - - - - -- - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - - - - - - - - - -
    www.utility22.com
    •Accurate power disclosure: ‘Click here to see what mix is
    delivered to our customers.’
    ‘Click here’
    Resource Type Percent
    Coal 55%
    Natural Gas 28%
    Nuclear 7%
    Other1 10%
    1 Other includes electricity not traceable to a specific resource
    type
    Determination: . .
    27

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  29. Key Takeaways
    •Be explicit – always be clear about who actually owns RECs.
    •Context matters.
    •Look to FTC Green Guides, SEIA Solar Business Code (Sept. 2015), and other publications for Best
    Practices.
    •Submit tracking attestations early, before you begin any transactions with a generator.
    •Educate counterparties.
    28

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  30. Upcoming Education Opportunities
    Webinar for Generators on Ensuring Green-e Energy Eligibility:
    Preventing Double Claims: Best Practices in Renewable Energy Marketing, Part 2 – September 30,
    2015 (11:00 AM PT) – register at: www.resource-solutions.org/events
    29

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  31. 30
    Special sessions at on Solar Claims with CRS, FTC, EPA, and solar industry

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  32. Maya Kelty
    Green-e Associate
    415-561-2133
    [email protected]
    Michael Leschke
    Green-e Energy Analyst
    415-568-2486
    [email protected]
    CONTACT

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