Two complainants objected to the claim that the advertisers provided “100% green electricity” to customers as they understood that the electricity provided to customers was sourced from the national grid and was made up of both renewable and non-renewable fuel sources and that it was not possible for a company sourcing from the grid to provide only renewable energy.
The advertisers stated that they offered and communicated the supply of 100% Green Electricity and were certified to do so by the Commission for Regulation of Utilities (CRU). They said that energy companies with renewable claims were audited annually to ensure that they were complying with all requirements needed for the supply of Renewable Energy. They referred to the CRU’s latest Green Source Verification Report 2020*1 and said that the report included a summary of what constituted 100% Renewable and how the CRU go about auditing Energy Companies who supply same. They referred to the below statement from the report:
“Public/ Customer Impact Statement
Green source products are tariff plans offered by electricity suppliers guaranteeing the source of electricity to be 100% renewable for any customer on that plan. This report provides verification of electricity suppliers’ green source product offerings for 2020 to certify that a customer on such an offering was using electricity sourced entirely from renewable generation, including Guarantees of Origin certificates. Outlined in this report is each supplier’s verified fuel mix for both their green and non-green customers.
The CRU and SEMO carry out an independent verification process and publish the results of suppliers’ green source products each year. All suppliers offering green source products complete the same single verification process to make it easier for customers to understand the process and trust its accuracy. It is considered that such a verification and this subsequent CRU report on suppliers’ green source offerings should provide public confidence that appropriate oversight of suppliers’ fuel source claims are in place.”
They also said that the report outlined the classification of a Green Sourced Product as being either providing for investment in environmentally beneficial schemes (e.g. investment in a specific technology or carbon offsets); or guaranteeing that a customer’s electricity is sourced from renewable generation. They said that the Green Source Product Verification concerned the second form of green source products, that is, the guarantee that a customer’s electricity was sourced from renewable generation, including Guarantees of Origin. They said that the report included a list of energy suppliers who had applied for 100% renewable certification, including their own company, and therefore, they were entitled to make the claim by the CRU.
The advertisers also said that energy companies with 100% Renewable verification were obliged to communicate their fuel mix on their bills and screenshot of their fuel mix:
Flogas Fuel Mix Disclosure January 2020 to December 2020
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| Electricity supplied has been sourced from the following fuels | Electricity supplied by Flogas | Average for all island market (for comparison) |
|---|
| Renewable | 100% | 57.9% |
| Natural Gas | 0% | 35.8% |
| Coal | 0% | 3.0% |
| Peat | 0% | 2.1% |
| Other | 0% | 1.2% |
| Total | 100% | 100% |
The advertisers considered that they had shown that they had sought and obtained their certification as a supplier of 100% Renewable Electricity.
*1 https://www.cru.ie/wp-content/uploads/2021/11/CRU21118a-Green-Source-Product-Verification-Report-2020- V.2.1.pdf
FURTHER INFORMATION:
Commission for Regulation of Utilities (CRU):
The Executive sought a view from the CRU on the claim “100% Green Energy” when energy provided to consumers came from a pooled grid that included both renewable and non-renewable energy. The CRU provided a statement in response.
They stated that EU Renewables Directive and Irish legislation allowed the use of guarantees of origin (GOs) for fuel mix disclosure for the purposes of demonstrating to final customers the share or quantity of energy from renewable sources in an electricity supplier’s energy mix and in the electricity supplied to consumers.
They said that they recognised the importance of maintaining confidence in the Guarantees of Origin process, and rigorously oversaw the application of the CRU’s verification process and reporting of this data in line with EU legislation to ensure the validity and accuracy of what information consumers receive.
The said that they published Fuel Mix Disclosure information every year to provide consumers with the information necessary to distinguish between electricity supply companies based on their individual fuel mix and emissions associated with their supplied electricity and it was the method of independently verifying the source of electricity that suppliers claim to provide to their consumers.
They said that all suppliers with retail customers were required to submit a fuel mix declaration to SEMO (Single Electricity Market Operator*2) so that a representative fuel mix could be calculated and disclosed and that suppliers were also obliged under the terms of their licenses to present Fuel Mix Disclosure data on their bills and promotional materials.
The CRU said that the Renewables Directive was explicit in restricting the double- counting of GOs and a given GO could only be used once and any one MWh of renewable energy produced could only be issued as one GO certificate.
They said that the SEMO issued and cancelled GOs in accordance with the CRU’s “Supervisory Framework for Administration of Guarantees of Origin” and that the GO certificates were precisely defined tracking instruments of the European Commission and were only traded between European countries, and solely accounted for through a European trading hub (i.e. the Association of Issuing Bodies). They said that imported GOs must adhere to EU-wide standards as set by this hub, which tracked certificates traded between countries, ensuring that double-counting did not take place.
They said that suppliers’ fuel mix information referred not only to green electricity physically produced in Ireland, but also to the verified green electricity that could be sourced from other European countries through Guarantee of Origin (GO) Certificates. They said that Irish electricity suppliers could purchase GOs to use as proof of the share or quantity of their energy demand from renewable sources in Europe and allowed suppliers to purchase the renewable benefit of certain generators across Europe and include it in their total fuel mix. They said that this meant that the fuel mix shown by suppliers could have a higher percentage share of renewable energy sources than existed in the actual physical generation distributed to end customers via the grid in Ireland.
They said that they considered that the supervisory framework and the CRU’s verification process for green products were robust enough to provide adequate assurances of the validity of Guarantees of Origin and reliable fuel mix disclosures by suppliers for their electricity customers. Finally, they provided links to the following documents:
• CRU’s verification process for green products*3
• CRU’s “Supervisory Framework for Administration of Guarantees of Origin*4
• CRU’s annual Fuel Mix Disclosure publications*5
Following further consultation by the ASAI Executive, the CRU said that the current disclosure of the consumed product mix and supplier fuel mix is slightly confusing to the end electricity consumers in Ireland and that they recognised that the increased information would be beneficial to customers. On foot of a proposal by the ASAI Executive to explore developing advertising guidance in this area, they indicated that they would be happy to engage with the ASAI and the utility providers on the ASAI Executive’s initiative.
*2 https://www.sem-o.com/about/
*3 https://www.cru.ie/wp-content/uploads/2015/07/CER15205-Green-Source-Products-Decision-Paper.pdf
*4 https://www.cru.ie/wp-content/uploads/2011/07/cer11824.pdf
*5 https://www.cru.ie/document_group/fuel-mix-and-co2-emissions-disclosure-2/
