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Working Group Files New Disclosure Labels For Use By Retail Suppliers

January 30, 2024

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Copyright 2010-23
Reporting by Paul Ring •

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The Disclosure Label Working Group in Connecticut submitted to PURA proposed revised disclosure labels pertaining to the sale of certain supplier products, namely, Renewable Energy Certificate (REC)-only and Voluntary Renewable Offer (VRO) products, as well as updated labels for standard (RPS only) products and generation mix and emissions disclosures for actual delivered power

A prior PURA decision adopted new requirements and standards for voluntary renewable electricity supply offers (VRO) from retail electric suppliers

As previously reported, the VRO order prohibits suppliers from using the term "renewable energy" for REC-based VRO products. Under the order, a supplier may not market the product as "renewable energy" unless the offer is supported by an ownership interest in or PPA for a renewable resource used to serve the contract.

The order also established certain universal standards for REC-only and suppliers' VRO offers, including geographic limitations

See more details on the new rules here

Although the work group's filing reflects proposed labels, PURA has already established that suppliers must comply with the VRO order and its provisions by February 29, 2024, regardless

The Working Group's four proposed labels -- VRO Offers; RPS-Only Offers; REC-Only Offers; and Generation Source Information (includes emissions data) -- can be found as Attachment F of the working group's report (pages 34-38, click here)

The Working Group has also included disclosure label guidelines as Attachment G to facilitate implementation. The guidelines include information for font (size and color) and the allowed colors and sizes for the graphs, how the Disclosure Label Working Group recommends that emissions information be determined and displayed, and specific language to be used while noting where flexibility may be appropriate.

The VRO label would explain that all products must meet the RPS, which is currently 37 percent renewable

The VRO label would also state, "This offer provides an additional [listed %] of renewable certificates on top of the state-required minimum. Suppliers can purchase certificates supported by [listed %] of usage not already supporting the minimum required certificates (the gray portion of the chart above) through Voluntary Renewable Offer (VRO) products. Selection of this VRO product means that your usage supports the purchase of [listed %] of certificates in addition to the state-required minimum certificates described above."

Notably, the VRO label would also state, "The supplier’s purchase of these certificates DOES NOT mean that the specific electricity that you are buying through this offer comes from the renewable sources indicated on this Label."

In the work group, several parties took exception to how the labels would not permit suppliers to advertise products as "100%" renewable, but would rather limit suppliers to listing the percent of additional renewables over RPS (for example, a "100%" VRO would be required to be listed as 63% renewable, due to the RPS being 37%)

However, the Work Group filing notes that this issue was already settled by PURA in its VRO decision

The Work Group report said, "the Final VRO decision clearly dictates that the percentage advertised for VROs must be at or below 100 minus the RPS; see VRO Final Decision, p. 28; and the attached labels reflect what is dictated in the Final VRO Decision."

Under the labels, suppliers would be required to update RPS Percentage and REC Class annually, by November 1st

For the Generation Source Label, suppliers would be required to use the ISO-NE Regional System Mix, unless a supplier has a PPA with a specific generating resource

Suppliers would be responsible for accessing and reflecting on their labels updates to the ISO-NE data

Emissions data would be published by the state's DEEP, with suppliers responsible for accessing and reflecting on their labels any updates

"It is recommended suppliers check for updated emissions reports, and adjust emissions information to reflect any changes. Given that the reporting month is variable, the Working Group recommends that suppliers be required to reflect updated emissions data not later than two months after the report is filed," the work group report said

Docket No. 16-12-29RE01


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