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Preventing Double Claims: Best Practices in Renewable Energy Marketing, Part 2 (for Generators and Project Developers)

Preventing Double Claims: Best Practices in Renewable Energy Marketing, Part 2 (for Generators and Project Developers)

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 2 is geared towards renewable energy generators and project developers. We walk through the meaning and weight of Green-e Attestations; describe how reviews are completed; and explain how double claims can impact business relationships.

Center for Resource Solutions

September 30, 2015
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  1. Preventing Double Claims
    Best Practices in Renewable Energy Marketing
    September 30, 2015
    Maya Kelty
    Green-e Associate
    415-561-2133
    [email protected]
    Michael Leschke
    Green-e Energy Analyst
    415-568-2486
    [email protected]
    Ensuring Green-e Energy Eligibility

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  2. Outline
    1. Green-e Energy
    2. Background
    3. The Importance of Attestations
    4. Claims Review Process
    5. Examples
    1

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  3. Outline
    2
    1. Green-e Energy
    2. Background
    3. The Importance of Attestations
    4. Claims Review Process
    5. Examples

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  4. About Green-e Energy
    The nation's leading voluntary certification program for renewable energy.
    3

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  5. Renewable Energy Basics: Two Markets. Comparison of compliance and voluntary markets for renewable energy, 2005–2012. Courtesy
    National Renewable Energy Laboratory
    Renewable Energy Basics: Two Markets
    4

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  6. Outline
    1. Green-e Energy
    2. Background
    3. The Importance of Attestations
    4. Claims Review Process
    5. Examples
    5

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  7. One claim per MWh
    6

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  8. ‘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).
    7

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  9. Federal Trade Commission
    FTC Green Guides - guidelines for marketers on environmental claims,
    including what constitutes a deceptive claim.
    8
    §260.15 Renewable Energy Claims: Marketers should not make broad, unqualified renewable energy claims,
    directly or by implication.
    “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.”
    (d)
    “Research suggests that reasonable consumers may interpret renewable energy claims differently than
    marketers may intend. Unless marketers have substantiation for all their express and reasonably implied
    claims, they should clearly and prominently qualify their renewable energy claims.” (b)

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  10. Federal Trade Commission
    February 2015 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.”
    9
    Letter further specifies:
    •All claims should be qualified and accurate
    •Burden to inform customers of REC ownership changes
    •Clarification should be prominent and accurate

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  11. ‘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)
    10

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  12. Risks for Double Claims
    Affects approx. 1% of RECs submitted annually
    •Interactions with counter-parties
    •Business relationships
    •Website changes
    •Supplementary paperwork
    11

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  13. Outline
    1. Green-e Energy
    2. Background
    3. The Importance of Attestations
    4. Claims Review Process
    5. Examples
    12

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  14. Chain of Custody Attestations
    13
    A commitment to accurate
    renewable energy claims

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  15. Chain of Custody Attestations
    Tracking Attestation
    T
    WREGIS
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    - - - - - - - - - - - - -
    +
    Tracked Facilities
    Submitted Annually
    Tracking Report
    Submitted every 2-3 years
    15

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  16. Chain of Custody Attestations
    G
    Untracked Facilities
    Wholesale Attestation(s)
    Generator Attestation
    W
    +
    Submitted Annually Submitted Annually
    16

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  17. Chain of Custody Attestations
    “All the renewable attributes (including CO2 benefits), including any emissions offsets,
    reductions or claims, represented by the renewable electricity generation [sold to Purchaser]
    were transferred to Purchaser.”
    17

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  18. Chain of Custody Attestations
    “To the best of my knowledge, the renewable attributes were not sold, marketed or otherwise claimed by
    a third party other than Purchaser.”
    18

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  19. Chain of Custody Attestations
    “The renewable attributes or the electricity that was generated with the attributes was not used to meet
    any federal, state or local renewable energy requirement, renewable energy procurement, renewable
    portfolio standard, or other renewable energy mandate by Seller, or to the best of my knowledge, any
    other entity other than Purchaser.”
    19

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  20. Chain of Custody Attestations
    “The electricity that was generated with the attributes was not separately sold, separately marketed or
    otherwise separately represented as renewable energy by Seller, or, to the best of my knowledge, any
    other entity other than Purchaser.”
    20

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  21. Chain of Custody Attestations
    “Only fully aggregated Renewable Attributes are traded in tracking system.”
    (Tracking Attestation)
    21

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  22. Outline
    1. Green-e Energy
    2. Background
    3. The Importance of Attestations
    4. Claims Review Process
    5. Examples
    22

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  23. Green-e Facility Review Timeline
    23
    Green-e evaluates claims:
    • When tracking attestations are submitted
    (accepted throughout the year)
    • During annual verification (Summer)
    • Upon request
    Submitted every 2-3
    years
    T
    RECs sold to Green-
    e participant
    G
    W
    T
    G
    W
    Review
    during
    July
    and
    August

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  24. Green-e Facility Reviews
    Simple Google search.
    Review facility to ensure accuracy of attestation.
    Search via relevant companies’ webpages.
    Relevant companies’ Sustainability & Environmental webpages.
    24

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  25. Problematic Statement Determinations
    Double Claim
    • Future eligibility is contingent on removal of language and pro-active language.
    • Previously sold RECs are ineligible
    25

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  26. Future REC Eligibility
    •Addition of clarifying / proactive language.
    •Removal of language.
    •Eligibility begins at time of changes.
    26

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  27. Outline
    1. Green-e Energy
    2. Background
    3. The Importance of Attestations
    4. Claims Review Process
    5. Timeline of Claims Review
    6. Examples
    27

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  28. •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.
    28

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  29. •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
    29

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  30. •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’
    30

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  31. • 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.
    31

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  32. FTC Green Guides: Marketers who generate renewable energy – say, by using solar panels
    – but sell RECs for all the renewable energy they generate shouldn’t claim they “use”
    renewable energy. Using the term “hosting” would be deceptive in this circumstance.
    Determination: Double Claim
    Example 4. Onsite Generation.
    1 MWh
    Electricity
    (Null Power)
    1 MWh Solar
    Attribute
    REC
    Solar Installer
    - - - - - - -
    - - - - - -
    - - - - - -
    - - - - - - - - - - - - - - - - -
    - - - - - - - - -
    - - - - - -
    - - - - - - - -
    www.School123.com
    32

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  33. •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
    Determination: Double Claim
    33

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  34. •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: . .
    34

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  35. 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, if possible.
    35

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  36. Special sessions at on Solar Claims with CRS, FTC, EPA, and solar industry
    36

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  37. 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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