Solar Energy on Campus: Opportunities and common pitfalls in communicating renewable energy use in higher education

As universities and colleges nationwide green their electricity with solar through onsite generation, power purchase agreements (PPAs), and renewable energy certificate (REC) purchases, these institutions must be clear and accurate in their claims to avoid reputational and legal risk. Understanding the implications of various purchasing options is central to ensuring that desired solar energy claims will be supported by your purchase. Join representatives from Center for Resource Solutions (CRS) and the National Renewable Energy Laboratory (NREL) in a free webinar to discuss:

• The role of RECs in renewable energy claims
• Acceptable language for making accurate claims
• The advantages and risks of solar purchasing options including onsite generation, PPAs, and REC purchases
• Specific approved claims for each solar purchasing option
• Decoding environmental attribute ownership within solar PPAs
REC arbitrage done right
• Additional considerations, including state incentives, operating within cap-and-trade programs, and state laws

This webinar is aimed at sustainability professionals in higher education, including energy and sustainability managers.

SPEAKERS
Maya Kelty, Green-e Associate, CRS
Jenny Heeter, Senior Energy Analyst, NREL

Transcript

1. Solar Energy on Campus Opportunities and common pitfalls in communicating renewable energy use in higher education Friday July 15, 2016 Jenny Heeter, Senior Energy Analyst, NREL Maya Kelty, Green-e Associate, Center for Resource Solutions
2. Housekeeping •Enter questions within control panel •Questions will be answered at the end
3. 1 SunShot Program Structure SunShot 2020 Goal
4. 2 With funding from the Department of Energy’s SunShot Initiative, NREL is providing technical support to Higher Education Institutions NREL is Assisting Universities to Deploy PV
5. 3 1. Educational Materials o Using Power Purchase Agreements for Solar Deployment at Universities, http://www.nrel.gov/docs/gen/fy16/65567.pdf o Writing Solar Requests for Proposals (RFPs): Lessons from NREL’s University PV Implementation Assistance Program, http://www.nrel.gov/docs/gen/fy16/66369.pdf 2. Technical Assistance http://www.nrel.gov/tech_deployment/tools_universities.html o PV Screenings using NREL’s REopt model, application period opening next month o Implementation Assistance; application period just closed, will be open again in Winter 2016 3. Forthcoming Publications o PV market potential in the higher education sector – Technical assessment paired with assessment of barriers and solutions o Fact Sheet: Financing Options When PPAs are not Feasible o Case Study: PV at Colorado State University NREL Resources
6. 4 Campus PV Installations: Key Numbers Source: Data from AASHE >160 MW installed to date >110 Campuses with Solar Installations
7. 5 Polling Question Results Does your university own the Renewable Energy Certificates (RECs) from the system? 25 Answers YES 6 32% NO 18 68% FOR SOME YEARS 1 4% YES NO FOR SOME YEARS
8. Solar Energy on Campus - achieving your institutional goals: • Using renewable electricity to power your institution. • Reducing your institution’s carbon footprint by switching to solar power. • Meeting commitments under external initiatives and partnerships like the White House’s American Campus Act on Climate Pledge, the Climate Leadership Commitment, or the Environmental Protection Agency’s (EPA) Green Power Partnership. • Protecting against fluctuations in electricity prices. • Investing in renewable energy generation.
9. •Renewable Energy Certificates 101 •Making credible renewable energy usage claims •Solar deals, RECs, and renewable energy claims
10. Renewable Energy Certificates
11. What is a Renewable Energy Certificate (REC)? • the full suite of attributes of 1 megawatt-hour of renewable energy generation on the electricity grid • the sole means to claim usage of grid-connected renewable electricity in the United States
12. Renewable energy is consumed and delivered via renewable energy certificates (REC).
13. Renewable Energy Certificate Markets Source: NREL, Status and Trends in the U.S. Voluntary Green Power Market (2014 Data)
14. Renewable Energy Usage Claims
15. What are Renewable Energy Usage Claims? • This institution is powered by clean energy. • We are powered by solar energy. • By installing solar panels we have reduced our carbon footprint. • We purchase our electricity from a solar facility.
16. Scope 2 Greenhouse Gas Accounting Market-based method •Accounts for specified purchases, including RECs •RECs are the market-based instruments for renewable energy in USA •More information at: http://www.ghgprotocol.org/scope_2_guidance Location-based method – average emissions of region assigned to each MWh
18. 260.15(d) […] 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. Federal Trade Commission Green Guides
19. Renewable Energy Purchasing Options & Claims
20. Solar Purchasing Options • Self-generation (Onsite or Offsite) • Direct purchase: PPA (Onsite or Offsite), Virtual PPA • Community renewables • Retail purchase: Unbundled RECs • Retail Purchase: Green Pricing Programs (Utility or Competitive Electricity Products)
21. Claims & Self Generation Any situation where you own a PV system (on-site or off-site) and receive the generation from it. University PV System On-site or Off-site Owned by University kWh
22. Claims & Self Generation Claim: “We are powered by solar energy.” Claim: “Our solar panels allow us to reduce our carbon footprint.” 1. You own the RECs produced by your system, and 2. You have not sold the RECs produced by your system.
23. Claims & Self Generation Claim: “We generate solar energy but sell the RECs.” 1. The solar developer retained the RECs via contract; or 2. You have sold your RECs to another entity. A system owner that contractually sells their RECs can no longer claim to be using renewable electricity.
24. Claims & Self Generation Claim: “We help the state meet its renewable energy goals.” 1. You sell the RECs from your system to the utility, or 2. You receive an incentive that results in the utility owning the RECs from your system. For example: Xcel & Solar*Rewards
25. Claims & Onsite PPA or Lease Another entity owns a PV system that is located on your property. University PV System On-site Owned by 3rd Party kWh Solar Developer 3rd Party
26. Claims & Onsite PPA or Lease Claim: “We are powered by solar energy.” Claim: “Our solar panels allow us to reduce our carbon footprint.” 1. PPA states that you, the customer, receive the RECs from your system.
27. Claims & Onsite PPA or Lease Claim: “We generate solar energy but sell the RECs.” 1. PPA states that the developer retains all RECs. Look for RECs within your PPA
28. Understanding RECs within your PPA Look for ‘Renewable Energy Certificates,’ ‘Environmental Attributes,’ or similar Available at: https://financere.nrel.gov/finance/content/terms-service-commercial
29. Understanding RECs within your PPA Look for ‘Renewable Energy Certificates,’ ‘Environmental Attributes,’ or similar
30. Understanding RECs within your PPA Look for ‘Renewable Energy Certificates,’ ‘Environmental Attributes,’ or similar …and for an inclusive and comprehensive definition
31. Understanding RECs within your PPA … and additional articles mentioning RECs
32. “Even if the manufacturer uses the electricity generated by the solar panels, it has, by selling renewable energy certificates, transferred the right to characterize that electricity as renewable […] It also would be deceptive […] to advertise that it ‘‘hosts’’ a renewable power facility because reasonable consumers likely interpret this claim to mean that the manufacturer uses renewable energy.” - Federal Trade Commission, Green Guides Claims & Onsite (Owned, PPA, or Lease)
33. What can you say about your onsite solar panels if you do not own the RECs? “We generate renewable energy and sell the RECs to our utility.” “We generate renewable energy, but sell all of it to others.” “We installed solar panels, but sell the renewable energy to others.” Claims & Onsite (Owned, PPA, or Lease)
34. Claims & … • Direct Purchase PPA (Offsite) • Direct Purchase Virtual PPA • Community Solar Another entity owns the system and you enter into a contract or sign a PPA with this entity. University PV System Off-site Owned by 3rd Party kWh/RECs/Hedge Solar Developer 3rd Party
35. Claims & … • Direct Purchase PPA (Offsite) • Direct Purchase Virtual PPA • Community Solar Claim: “We are powered by solar energy” Claim: “We buy solar energy to reduce our carbon footprint.” 1. PPA or contract states that you, the customer, receives the RECs from the system.
36. Claims & Unbundled SRECs (Retail Option) Claim: “We are powered by solar energy.” Claim: “We reduce our carbon footprint with solar energy.” “RECs combined with plain grid electricity are functionally equivalent to green power purchases from a local utility, no matter where the REC may be sourced.” - EPA, Guide to Purchasing Green Power Purchasing unbundled RECs from a REC seller.
37. Qualified Claims “It is deceptive to make an unqualified “made with renewable energy” claim unless all, or virtually all, of the significant manufacturing processes… are powered with renewable energy or non-renewable energy matched by renewable energy certificates.” - FTC, Green Guides
38. Additional Deal Features & Considerations
39. REC Arbitrage • Arbitrage involves purchasing RECs from a different renewable energy generating facility • Consider REC arbitrage to maintain RE usage and carbon reduction claims • Claim must be associated with the REC that is owned
40. REC Arbitrage - Solar RECs “We have installed solar panels and are now powered by solar energy.” Purchasing RECs from a different solar facility and pairing with null power. “We are powered by solar energy.” ”We’ve installed solar panels to sell electricity back to the grid, and purchase solar energy from Offsite Solar Farm X to meet our electricity needs.”
41. REC Arbitrage – Non-Solar RECs “We are powered by solar energy.” Purchasing RECs from a different non-solar facility and pairing with null power. “We have installed solar panels and are now powered by renewable energy.” ”We’ve installed solar panels and receive renewable energy from Offsite Wind Farm X.” “We are powered by renewable energy.”
42. Additional Considerations: Incentives Incentives: Some state incentives require that the RECs be conveyed to the utility or state to help RPS requirements. Example: Xcel’s Solar*Rewards program • Transfers RECs to Xcel under contract Claim 1: “By installing solar panels, we help the utility meet it’s renewable energy goals.” Claim 2: “We use renewable energy.”
43. Additional Considerations: State Laws Example: Arizona Corporation Commission Decision no.74882 • DG within an affected utilities’ service territory is an “indicator of market sufficiency activity” and can be used towards RPS compliance • Risk of double claims on solar PV RECs generated from DG within affected utilities’ footprints, even those retained on-site Claim 1: “By installing solar panels, we help the utility meet it’s renewable energy goals.” Claim 2: “We use renewable energy.”
44. Additional Considerations: State Laws Example: Carbon Cap-and-Trade covering the electricity sector (California, RGGI, Québec) • Without a set-aside, renewable energy generation does not avoid greenhouse gas emissions on the grid • Based on state of generation • Restricts carbon claims, not renewable energy claims Claim 1: “We use solar energy.” Claim 2: “The solar energy we use avoids greenhouse gas emissions.”
45. What institutional goals are you trying to meet with solar energy? • Using renewable electricity to power your institution. • Reducing your institution’s carbon footprint by switching to solar power. • Meeting commitments under external initiatives and partnerships like the White House’s American Campus Act on Climate Pledge, the Climate Leadership Commitment, or the Environmental Protection Agency’s (EPA) Green Power Partnership. You must retain the renewable energy certificates in the deal.
46. What institutional goals are you trying to meet with solar energy? • Protecting against fluctuations in electricity prices. • Investing in renewable energy generation. You may not need the RECs, but you must be clear and transparent in marketing.
47. 1. You must be the exclusive owner of, or have exclusive right to, the REC for the renewable generation you’re claiming. 2. If you are purchasing RECs only, the RECs must be based on metered generation data and transferred in a legally enforceable contract or through an electronic tracking system. 3. The REC has to be fully aggregated, so individual environmental attributes of renewable energy, like carbon attributes, cannot have been sold off, used to create other instruments like carbon offsets, or used by another party or policy/regulation. 4. RECs should be applied to consumption that occurs within close temporal proximity to the time of REC generation. 5. Specify: resource type, quantity (e.g. kWh), time period of consumption, and consumption covered. Making Renewable Energy Usage Claims
48. See Center for Resource Solutions’ webpage for a full list of additional resources pertaining to RECs and renewable energy usage claims: http://resource-solutions.org/learn/rec-claims-and-ownership/ Additional Resources
49. Maya Kelty, Green-e Associate Center for Resource Solutions 415-561-2133 maya.kelty@resource-solutions.org Questions?