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.

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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 maya.kelty@resource-solutions.org Michael Leschke Green-e Energy Analyst 415-568-2486 michael.leschke@resource-solutions.org
  2. Outline 1. Background 2. The Importance of Attestations 3. Claims

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

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

    Review Process 4. Timeline of Claims Review 5. Examples 6
  8. Participant Attestation A commitment to perform due diligence 7

  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
  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
  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
  12. Chain of Custody Attestations G Untracked Facilities Wholesale Attestation(s) Generator

    Attestation W + Submitted Annually Submitted Annually 11
  13. Chain of Custody Attestations Tracking Attestation T WREGIS - -

    - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - + Tracked Facilities Submitted Annually Tracking Report Submitted every 2-3 years 12
  14. Outline 1. Background 2. The Importance of Attestations 3. Timeline

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

    of Claims Review 4. Claims Review Process 5. Examples 17
  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
  20. Problematic Statement Determinations Double Claim • Future eligibility is contingent

    on removal of language and pro-active language. • Previously purchased RECs are ineligible 19
  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
  22. Outline 1. Background 2. The Importance of Attestations 3. Claims

    Review Process 4. Timeline of Claims Review 5. Examples 21
  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
  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
  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
  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
  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
  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
  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
  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
  31. 30 Special sessions at on Solar Claims with CRS, FTC,

    EPA, and solar industry
  32. ?

  33. Maya Kelty Green-e Associate 415-561-2133 maya.kelty@resource-solutions.org Michael Leschke Green-e Energy

    Analyst 415-568-2486 michael.leschke@resource-solutions.org CONTACT