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CCEF Requests that Conn. Competitive Suppliers Be Subject to Additional Labeling for Renewable Products

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October 14, 2010

Connecticut competitive electric suppliers offering products with renewable content beyond the RPS should be required to conform their products to the labeling and disclosure requirements of the Connecticut Clean Energy Options (CCEO) program, the Connecticut Clean Energy Fund (CCEF) said in comments to the DPUC (10-05-07).

The DPUC is currently reviewing the CCEO, which allows customers to purchase RECs while on default service supply.

"[T]o the extent other competitive suppliers are offering voluntary clean energy products, they should be required to have the same labeling and disclosure as the CCEO products (i.e., resource, geographic location, percentage above the Renewable Portfolio Standard (RPS))," CCEF said.

"The CCEF believes that many consumers do not understand the differences between CCEO and non-CCEO clean energy products.  Accordingly, they may choose to support a less-expensive product without understanding that it contains less-expensive Renewable Energy Credits or a smaller percentage above the RPS," CCEF added.

Sterling Planet added that, "any company selling RECs to Connecticut residents should be required to disclose the specific technology supplied to avoid confusion and to promote transparency."

CCEF further said that, "[t]he combination of CCEO products with lower priced generation services represents an opportunity to reach potential new customers."

"Although the current CCEO suppliers have sought to forge partnerships with certain competitive suppliers, the Department could enhance the CCEO program by (a) promoting consumer opportunities to support CCEO products at lower rates, and (b) requiring any non-CCEO clean energy suppliers to clearly identify product content by renewable technology, geographic source, and percentage above the RPS," CCEF said.

Additionally, CCEF urged the DPUC to encourage the electric distribution companies to expand their promotion of the CCEO program including messaging on printed envelopes, newsletters, and communications to electronically billed customers.  CCEF said that the distribution companies should be compensated for such marketing as appropriate.

CCEF also asked that the electric distribution companies, "be required to facilitate completion of enrollments by looking up account information."

"Many signups are obtained at public events at which customers do not possess the requisite bill information.  By providing account information on a timely basis, the EDCs would help the program by ensuring that CCEO supplier outreach personnel working on commission [sic]," CCEF said.

CCEF favors maintaining the current limit of two CCEO REC suppliers.

Sterling Planet, one of the current suppliers, did not oppose a minimal expansion in the number of CCEO suppliers, but said such new suppliers should be, "experienced and qualified Green marketers.

In supporting the continuation of the CCEO program despite the emergence of competitive renewable supply offers in the mass market, Sterling Planet offered that, "many competitive electric suppliers appear to use voluntary clean energy electric service in order to solely gain market share as a brown electric supplier.  The current CCEO Program structure allows competitive electric suppliers to offer licensed CCEO supply as a bundled product.  As a result, the marketing campaigns across towns have been able to grow as a bundled product in many towns."

United Illuminating also supported continuation of the CCEO program.  "A limited - though involved and passionate - customer base participates in the program and the Company would not want to diminish customer expectations or options," UI said.

UI said that it, "see[s] a potential difference between Renewable Energy Certificates ('RECs') provided by suppliers in the CCEO program and RECs provided by competitive energy suppliers ('CES') above and beyond the Renewable Portfolio Standard requirements."

"The CCEO suppliers must provide RECs of a specific vintage and type as per the program RFP requirements.  CES suppliers do not have such a requirement and therefore such offered RECs may not be in direct comparison (type, price, region, etc.)," UI said.

UI further said that it, "sees a need to have a verification process in place to review the RECs offered to CES customers that are over and above the RPS.  It is the Company's understanding that such a review will be included in Docket No. 10-09-06"

    
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