E.ON UK plc
Little Oak Drive
Victoria Willis Nottingham
Energy Savings Trust Nottinghamshire
21 Dartmouth Street eon-uk.com
By email only to email@example.com
Copy to: ES&SMarkets@ofgem.gov.uk
Monday, 6th August 2007
Consultation on Accreditation of Green Tariffs
E.ON welcomes EST’s consultation on Accreditation of Green Tariffs.
However, as the development of Ofgem Guidelines on Green Supply is still
ongoing we believe it is too early to give detailed comments and would
welcome a further consultation by EST on the certification scheme once the
Guidelines have been finalised.
In principle we are supportive of a certification scheme which support’s
Ofgem proposed “Guidelines for Green Supply” but whilst this should be
“fit for purpose” it must not be overly bureaucratic or costly to administer.
Where possible the certification scheme should use existing codes e.g.
Advertising Standards Authority and “piggy back” existing processes e.g.
verification by company financial or CSR auditors.
As requested I have attached as an annex our preliminary responses to the
questions posed in the consultation document. .
E.ON UK plc
England and Wales
Regulation Manager (Consumer & FSA)
Westwood Business Park
1|1 Coventry CV4 8LG
APPENDIX 1 - Summary of Questions and Response Template
This section summarises the questions raised throughout the consultation document to which we
would like your answers. It would be helpful if you could use this template to submit your response.
Type of response:
Individual. Name: _Steve Russell_____Email: firstname.lastname@example.org _____
On behalf of (organisation): __E.ON UK plc ____________________________________
If your organisation represents a number of stakeholders (e.g. is a trade association) please
describe how the view of members was assembled: ___________________________________
If you do not consent to making your response publicly available, please click this box.
No. Question Your Response
1 Do you support the proposed No. We believe the aims of the scheme should be limited to;
aims of the scheme? • products which are able to use the scheme logo/mark should meet
the Ofgem renewable or low carbon guidelines.
• The scheme logo/mark should give customers confidence that the
renewable product does exactly what it claims to do.
2 Are there any other aims you No
think should be included for
3 Do you think that the In our view there should be two separate sets of guidelines for
accreditation scheme should renewables and low carbon products reflecting the likely different
be limited to renewable requirements. We believe that there should be two separate
energy, or should it also logo/marks for use by products which meet the either the renewable or
cover other forms of low low carbon guidelines or both. We believe that a single certification
carbon generation where scheme (rather than accreditation, see UKAS definitions UKAS FAQs)
clear additionality can be is preferable for reasons of consistency and efficiency Additionality
demonstrated? should not be a prerequisite for the scheme. The scheme should
follow the Ofgem guidelines.
4 Do you agree that the broad No. We believe that products should be separated out into renewable
definition of green tariffs products and low carbon products. A renewable product has to have
should be adopted for the at its core renewable electricity; it could as additional features of the
purpose of the accreditation product offer green funds or carbon offset. A low carbon product
scheme, covering green should have at its core low carbon generation..
supplies, green funds and
5 Do you agree that only No. The most important aspect on carbon offsets for customers is that
carbon offset tariffs approved there is transparency in the product promotion. Suppliers who develop
under Defra’s carbon carbon offset products which include offsets complying with Defra’s
offsetting accreditation carbon offsetting scheme will be able to use the carbon offsetting logo
scheme should eligible under in the promotion of their product. This will be in addition to the
the green tariff accreditation renewable logo. This will differentiate their products from other offset
scheme? If so, should products. There should be no limitation in the type of projects
qualifying offsets be limited to providing offset, to do so will stifle innovation and is an unnecessary
renewable projects? restriction.
6 Do you agree that the Yes
scheme should be voluntary?
7 Do you agree that the The scheme should only apply to those products which meet the
scheme should have UK Ofgem guidelines. Those guidelines will be drawn up to cover the
coverage? If so, are there any regulatory framework in England, Wales and Scotland only. If this was
specific issues to consider for not the case it would bring further complexity into the guidelines.
the devolved nations of the
UK in the design of the
ENERGY SAVING TRUST: Accreditation of Green Tariffs Consultation Document Page 1 of 3
8 Do you think the scheme The scheme could provide certification that products meet renewable
should be targeted at guidelines and low carbon guidelines in both domestic and business
suppliers offering products to markets. However, we would want to consider proposals from
both the domestic and the potential certifiers to determine the benefit or otherwise of a single
business markets? scheme.
9 Do you agree that No. If it is a voluntary scheme Suppliers should be able to choose to
participating suppliers should submit all, some or none of its products for certification.
be required to submit all their
green offerings for
10 Do you agree with the main No. We agree that the standards need to cover transparency and
elements proposed for the verifiable evidence.
accreditation Standards? We don’t agree that the standards should cover;
• additionality, - this should be optional and a point of differentiation
• Pre-sales activity; advertising and promotion; selling techniques,
performance information; claims and calculations; transparent
o Advertising and promotion are covered by the ASA
o Selling is regulated by selling regulations and
enforced by trading standards
o There is no evidence that establishing processes and
procedures in the other areas would lead to any
customer benefit. However, they would be
bureaucratic, time consuming and costly.
• Contracts – the unfair contract terms regulations and distance
selling regulations already provide adequate consumer protection.
• After-sales activities, guarantees, provisions for dealing with
consumer complaints –
o These standards go way beyond what is required by
the certification scheme and in some cases will be
cover by existing or new legislation (e.g. Sales of
Goods and Services Act 1982, Consumer, Estate
Agents and Redress Act 2007, Unfair Terms in
Consumer Contracts Regulations 1999).
11 How do you think additionality We don’t think additionality should be defined in the different offerings
should be defined for the or a minimum level set. This should be left to the Suppliers to
different types of offering, and describe in a way which complies with the requirements of the ASA
what would you consider to code and the commitment to transparency required by the Ofgem
be the minimum levels guidelines.
12 Do you support the broad No. The certification and compliance aspects of the scheme should
thrust of the proposed cover
accreditation and compliance o Verification that suppliers have purchased sufficient energy to
aspects of the scheme? meet that supplied under the product. Evidence for this could
be provided to the scheme certifier by the suppliers auditor or
other independent third party.
o Suppliers who fail to provide evidence should have their right
to use the appropriate logo/mark suspended until they can
provide confirmation that they have put in place robust
processes to prevent a repeat occurrence.
o The Certifier could publish a list of products/supplier which
have complied on an annual basis and those that have failed
13 Do you agree there should be No. There should be a separate logo/mark for renewable products
a single certification mark for and one for low carbon although they could have a common design
all accredited products? theme.
14 Do you think that Yes. If companies who buy the certified products are permitted to use
organisations buying the renewable and/or low carbon logos as appropriate this will spread
accredited green tariffs awareness and stimulate demand.
should also be permitted to
ENERGY SAVING TRUST: Accreditation of Green Tariffs Consultation Document Page 2 of 3
use the quality mark to
promote their green
15 Do you have views on the The panel should consist of representatives of suppliers, consumer
composition of the proposed bodies, Ofgem, DEFRA and environmental NGO’s.
independent panel to advise
on the development and/or
ongoing management of the
16 Do you agree with the We believe that it is in the national interest that the market for green
proposed financing products is vibrant, accordingly we believe that the set up of the
arrangements and indicative scheme should be funded by Government. We agree that ongoing
level of fees? costs of the certification scheme should be funded through a
subscription fee charged to each product which uses the logo/mark. In
our view the level of funding required seems appropriate for the
certification scheme we propose but looks far too low for the scheme
proposed by EST.
17 Do you have any additional We believe that there should be far less focus on the company
suggestions as to how the providing certification services, more on spreading awareness of the
scheme might be promoted? logo/mark and the benefits it offers. For reasons set out above we
believe that the Government should wholly or partly fund an initial TV
& radio advertising campaign. The learning from the Australian
experience is that such backing boosts consumer confidence.
Please email your submission to Victoria Willis at the Energy Saving Trust
(email@example.com) and also copy to Ofgem at ES&SMarkets@ofgem.gov.uk.
ENERGY SAVING TRUST: Accreditation of Green Tariffs Consultation Document Page 3 of 3