Victoria Willis Energy Savings Trust 21 Dartmouth Street London

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Victoria Willis Energy Savings Trust 21 Dartmouth Street London Powered By Docstoc
					                                                                                E.ON UK plc
                                                                                Little Oak Drive
Victoria Willis                                                                 Nottingham
Energy Savings Trust                                                            Nottinghamshire
                                                                                NG15 0DR
21 Dartmouth Street                                                   
                                                                                Steve Russell
                                                                                02476 181356
By email only to
Copy to: ES&

Monday, 6th August 2007

Dear Victoria

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. .

Yours sincerely
                                                                                E.ON UK plc
                                                                                Registered in
                                                                                England and Wales
                                                                                No 2366970

Steve Russell
Regulation Manager (Consumer & FSA)

                                                                                Registered Office:
                                                                                Westwood Way
                                                                                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: _____

           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
      the scheme?
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
      carbon offsets?
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
                                           between products.
                                        • Pre-sales activity; advertising and promotion; selling techniques,
                                           performance information; claims and calculations; transparent
                                           pricing -
                                                     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
                                                to comply.
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
       ( and also copy to Ofgem at ES&

        ENERGY SAVING TRUST: Accreditation of Green Tariffs Consultation Document          Page 3 of 3