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Solar Power Use Claims Guidance

Solar Power Use Claims GuidanceSolar “use” claims and associated claims about greenhouse gas footprint reductions are contingent on the ownership of, or exclusive rights to, the renewable energy certificates (RECs) associated with the solar generator’s output. A REC is a tradeable, market-based instrument that represents the legal property rights to the “renewable-ness”—or all non-power attributes—of renewable electricity generation. The REC owner has exclusive rights to make claims about “using” or “being powered with” the renewable electricity associated with that REC. A REC is issued for every megawatt-hour (MWh) of electricity generated and delivered to the electric grid from a renewable energy resource. For more information on example claims related to solar power, see the Solar Power Use Claims page.

Below are resources providing guidance to help electricity consumers understand the exclusive legal right that RECs offer their owners when making solar power use claims, as well as best practices in making renewable energy use claims.

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Guide to Making Claims About Your Solar Power Use
This guide describes best practices for appropriately explaining and characterizing solar power activities and the fundamental importance of renewable energy certificates (RECs) for solar power use claims. This guidance is primarily focused on claims associated with on-site projects but is equally relevant for off-site owned projects as well.
The Legal Basis for Renewable Energy Certificates (PDF) (25 pp, 351K)
There is a strong legal basis for the use of RECs as instruments that represent the attributes of renewable electricity generation. RECs are not controlled by any one organization or group of organizations, and neither are they instruments of recognition or donation. Rather, RECs are a part of the machinery of U.S. electricity markets, used to demonstrate renewable electricity purchasing, delivery, and use within the broader context of functioning voluntary and compliance renewable electricity markets. This document provides a summary of how different authorities have recognized the role of RECs in the United States.
Guidelines for Renewable Energy Claims: Guidance for Consumers and Electricity Providers (PDF) (2 pp, 570K)
Homes and businesses that generate on-site renewable energy—from a rooftop solar photovoltaic system, for example—can claim the renewable energy their system generates only if they are retaining the RECs created by the system. REC ownership is usually determined by the contract between the system owner and the owner of the facility the system is mounted on, which means that the owner of the house or building might not own the renewable energy. This two-page issue brief provides an overview of the role of RECs and examples of claims issues between hosts, utilities, and owners.
Solar Energy on Campus: Renewable Energy Usage Claims (PDF) (3 pp, 752K)
As centers of innovation and social progress, more colleges and universities are pursuing clean energy solutions—in particular, solar energy. It is important to understand how various solar purchasing options align with the institutional goals you hope to meet. Importantly, your institutional goals might manifest in certain benefits and claims that you and your colleagues plan to make, which could be rendered inaccurate based on the structure of your chosen purchasing option. Failing to understand or consider the relevant purchasing mechanisms involved in transactions of renewable energy could negatively affect the non-financial or environmental value of your investment in solar. This report describes RECs, why they are important, and what kinds of statements can be made depending on who owns them.
Making Credible Renewable Electricity Usage Claims (PDF) (16 pp, 846K)
Companies can make a variety of statements about renewable electricity (RE) relating to its development, generation, use, and environmental and social benefits and impacts. But the ability to demonstrate and claim use or delivery of RE on a shared electricity distribution network, or “grid,” requires the support of markets and contractual instruments that meet specific criteria to be credible. This briefing note provides a set of criteria that RE sources and purchasing mechanisms must meet in order to support credible RE usage and delivery claims. These criteria can be applied across a range of local electricity market conditions and RE market development levels. This briefing, from the RE100 Technical Advisory Group, provides guidance for verification, reporting, and communication of RE use.
Renewable Electricity: How do you know you are using it? (PDF) (2 pp, 543K)
This National Renewable Energy Laboratory publication explains the nature of RECs, on what basis a consumer of electricity can claim to be using renewables, and how RECs are tracked throughout the United States to ensure they are not double-counted.
Federal Trade Commission: Guides for the Use of Environmental Marketing Claims (PDF) (3 pp, 356K)
This Federal Trade Commission document summarizes the revisions to the Guides for the Use of Environmental Marketing Claims, effective as of October 11, 2012. The Commission modified sections for the following claims: General Environmental Benefit, Compostable, Degradable, Ozone, Recyclable, and Recycled Content. Additionally, the Commission created the following new sections: Carbon Offsets, Certifications and Seals of Approval, Free-of, Non-toxic, Made with Renewable Energy, and Made with Renewable Materials.
National Association of Attorneys General’s Environmental Marketing Guidelines for Electricity
It is the purpose of these guidelines to: 1) diminish the potential for deceptive environmental marketing by providing guidance to the electric power industry as it undertakes to craft its advertising and information campaigns, 2) facilitate compliance with the law by providing industry with an interpretation by the Attorneys General of what state prohibitions on deceptive and misleading advertising mean in the context of environmental advertising for electricity, and 3) offer a model for state legislation and/or rulemaking.

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