April 22, 2022
I'd like to propose a restriction on claiming Renewable Energy Certificates originating from the state of Texas as \"GHG offsets\" in other parts of the country.
The reason for this proposed exclusion is two-fold:
1) No electricity produced in Texas is currently transmitted outside the state so it is not appropriate to claim that renewable energy produced in Texas is reducing the GHG emissions of entities outside of Texas. Recently Google Nest claimed that when you pay $10 for their Clean Energy Match product, \"...you can have confidence that every time you use electricity in your home - whether it's turning on the lights, running the dishwasher, or watching TV - it's supporting clean energy sources.\" The product they are promoting is $10/month REGARDLESS of how much electricity is used, and all offsetting RECs are being produced in TX, meaning that this statement is patently false. (see attachment)
2) Texas has electricity rate plans that encourage wasteful practices, meaning that the renewable energy produced in TX is often wasted (not effectively reducing GHGs). The de-regulation of the retail electricity space in TX has allowed retailers to create misleading rate plans that offer \"cash back credits\" for customers who hit a certain monthly usage threshold. I have personally heard TX residents explain how they run space heaters on their lawns, blast sound equipment, and utilize other power-hungry devices to \"burn off energy\" at the end of the month in order to hit their monthly bonus thresholds. (see attachment)
The combination of these two factors should preclude companies from making claims about offsetting non-Texas-based emissions with Renewable Energy Certificates originating from Texas.
Thank You
Alex