Solar Power Use Claims

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The scenarios below are designed to provide guidance to organizations that have—or are considering installing—on-site solar systems. The scenarios can provide these organizations with examples and rationale for the types of claims they can legitimately make pertaining to their “use” of solar power and any associated carbon footprint reduction claims.

Renewable Energy Certificates (RECs) are the legal instruments used in renewable electricity markets to account for renewable electricity and its attributes and are issued in megawatt-hour (MWh) increments. The owner of a REC has exclusive rights to the attributes that MWh of renewable electricity. And as owner, can make unique claims associated with renewable electricity that generated the REC (e.g., using or being supplied with a MWh of renewable electricity, or reducing the carbon footprint associated with electricity use). Claims based on a REC can only be made by one party. Once made, no other entity can legitimately make claims on the electricity associated with that REC.

Scenario 1: On-site Solar System & Own Associated RECs

In this scenario, your organization has a solar photovoltaic (PV) system on site and keeps the RECs associated with the system’s electricity generation.

Examples of acceptable claims:

Claim Rationale for why it is acceptable
"We installed a solar project on site, and our facility is powered with renewable energy."

This claim statement is acceptable because by owning and retaining the associated RECs from the solar system, you can legally substantiate claims of using the renewable electricity produced by that onsite project.

This claim statement could be improved by recognizing the organization's ownership of the RECs associated with the on-site project, since installing a project does not explicitly convey that the organization own the RECs from the project. Furthermore, be sure to always make claims that match the scope of the organization's green power use. If you are using green power for a subset of your organization (e.g., facility-level), then that should be communicate the scope of green power use (e.g., "at our facility") when making the claims.
"We are using solar energy from a project whose development we facilitated."

This claim statement is acceptable because by owning and retaining the associated RECs from the solar system, you can legally substantiate claims of using the renewable electricity produced by that on-site project.

Direct ownership and self-financing of a renewable project offer the most intuitive and direct connection to claims of project facilitation.
"We are using on-site solar to match X percent of our annual electricity use."

This claim statement is acceptable because by owning and retaining the associated RECs from the solar system, you can legally substantiate claims of using the renewable electricity produced by that on-site project.

The statement related to the percent of renewable electricity use should also be based on the MWh equivalent represented by the RECs produced by the on-site system and any other sources of RECs owned and retained by the organization.
"Our PV system is powering our facility with solar electricity and reducing our carbon footprint."

This claim statement is acceptable because by owning and retaining the associated RECs from the on-site solar system, you can legally substantiate claims of using the renewable electricity produced by that on-site project.

Owning and retaining the solar RECs from the project also substantiates the organizations use of zero-emissions electricity, which supports the claim of reducing their carbon footprint or Scope 2 emissions (Scope 2 are the indirect greenhouse gas [GHG] emissions associated with the consumption of purchased electricity under a greenhouse gas inventory).
"By using X MWh of zero-emissions on-site solar energy, we have reduced our Scope 2 emissions and our organization's carbon footprint."

This claim statement is acceptable because by owning and retaining the associated RECs from the solar system, you can legally substantiate claims of using the renewable electricity produced by that on-site project.

Owning and retaining the solar RECs from the project also substantiates their use of zero-emissions electricity, which supports the claim of reducing their carbon footprint or Scope 2 emissions (Scope 2 are the indirect GHG emissions associated with the consumption of purchased electricity under a greenhouse gas inventory).

The project/REC owner, however, should take care to not make claims about reducing either direct or global emissions, as a REC instrument does not convey ownership of a ton of direct emissions reductions to its owner as a project offset instrument would.
If the solar project owner either does not own or chooses to sell the associated RECs/attributes from the system, the new owner/buyer is the only one who can claim the solar attributes.

If the solar project owner and the new REC buyer both claim the same environmental benefits or to both be using energy produced by the same solar project, then that is considered a double claim on the same MWh of solar.

Example of an Unacceptable Claim:

Claim Rationale for why it should be avoided
"Our PV system is powering our facility with solar electricity and reducing more than X tons of emissions annually."

Unlike carbon offset instruments, RECs do not convey to their owner a claim of tons of emissions reduced. And because RECs do not convey this  emissions reduction to their owners, these types of claims should be avoided.

RECs are measured in MWh increments/units and only convey to their owner a renewable electricity use claim regarding that MWh. There is no contractual mechanism that exists under a bilateral renewable energy contract that would have the electric utility (a third party to the bilateral contract and the actual owner of the direct emissions reduction associated with electricity generation) give up their ownership of the direct emission claim to a renewable electricity user.

Scenario 2: On-Site Solar System and Does Not Own Associated RECs

In this scenario, your organization has a solar PV system on site but does not own the RECs associated with the system’s electricity generation.

Examples of acceptable claims:

Claim Rationale for why it is acceptable
"We installed on-site solar, but our utility receives the RECs from the system."

This claim statement is acceptable because it conveys that while a solar project may be hosted by the system owner, the electricity generation and associated RECs are owned by another party.

Without exclusive ownership of any RECs, you cannot publicly claim the use of renewable electricity or having reduced your carbon footprint. An owner of a renewable energy project can always claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy, they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs).
"We increase the amount of renewable energy on the grid by supplying our utility with the solar energy generated at our facility."

This claim statement is acceptable because it conveys that while a solar project may be hosted by the system owner, the electricity generation and associated RECs are sold to the utility and no replacement RECs are procured.

Without exclusive ownership of any RECs, you cannot publicly claim the use of renewable electricity or having reduced your carbon footprint. An owner of a renewable energy project can always make the claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs).
"Our project supplies solar electricity to our utility in order for the utility to meet its renewable energy goals."

This claim statement is acceptable because it conveys that while a solar project may be hosted by the system owner, the electricity generation and associated RECs are transferred to the utility and no replacement RECs are procured.

Without exclusive ownership of any RECs, you cannot publicly claim the use of renewable electricity or having reduced your carbon footprint. An owner of a renewable energy project can always make the claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs).

Examples of unacceptable claims:

Claim Rationale for why it should be avoided
"We have an installed on-site solar project and are powered by that renewable energy."

This claim statement is unacceptable because you are not the exclusive owner of the RECs associated with the solar project and therefore cannot legally substantiate your claims about using the solar electricity produced by your project.
"We are using solar energy from a project whose development we facilitated."

This claim statement is unacceptable because you are not the exclusive owner of the RECs associated with the solar project and therefore cannot legally substantiate your claims about using the solar electricity produced by that system.
"We are using on-site solar to match X percent of our annual electricity use."

This claim statement is unacceptable because you are not the exclusive owner of the RECs associated with the solar project and therefore cannot legally substantiate your claims about using the solar electricity produced by that system.
"Our PV system is powering our facility with solar electricity and reducing our carbon footprint."

This claim statement is unacceptable because you are not the exclusive owner of the RECs associated with the solar project and therefore cannot legally substantiate your claims about using the solar electricity produced by that system.

Owning and retaining the solar RECs from the project substantiates your use of zero-emissions electricity, which supports the claim of reducing your carbon footprint or Scope 2 emissions (Scope 2 are the indirect GHG emissions associated with the consumption of purchased electricity under a greenhouse gas inventory).
"By using X MWh of on-site solar, we have reduced our Scope 2 emissions by X tons of CO2."

This claim statement is unacceptable because you are not the exclusive owner of the RECs associated with the solar project and therefore cannot legally substantiate your claims about using the solar electricity produced by that system.

Owning and retaining the solar RECs from the project substantiates the consumers use of zero-emissions electricity, which supports the claim of reducing their carbon footprint or Scope 2 emissions (Scope 2 are the indirect GHG emissions associated with the consumption of purchased electricity under a greenhouse gas inventory).

Scenario 3: On-Site Solar System and Does Not Own Associated RECs, but Purchases Replacement RECs

In this scenario, your organization has a solar PV system on site, but does not own the RECs associated with the system’s electricity generation; however, your organization purchases other RECs to replace the RECs that the on-site system generated.

Examples of acceptable claims:

Claim Rationale for why it is acceptable
"We installed a solar PV project, and the developer retained the RECs to help finance the project. We purchased replacement RECs from a different project so that our electricity is renewable."

This claim statement is acceptable because it conveys that you (ie, the owner of the solar PV system) does not own the RECs associated with your solar project and that replacement RECs were procured from a different project in their place.

The consumer's renewable electricity use claims should now be based on the attributes (e.g., resource type, location, vintage) conveyed by the replacement RECs—not from the original solar RECs sold from the customer's own solar project.
"We generate renewable electricity from our self-financed on-site solar project but sell the RECs to our local utility. In their place, we purchase a REC-based bundled wind power product to power our own operations with renewable electricity through a separate transaction." This claim statement is acceptable because it conveys that the renewable electricity (both RECs and energy) associated with the your self-financed solar project was sold to the utility.

An owner of a renewable energy project can always claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs). The claim statement also conveys that through a separate transaction, the customer is also purchasing a REC-based wind power product, so the organization can claim to be using renewable electricity for its operations.
"Our PV system generates and supplies renewable electricity to the grid. We use wind power by purchasing RECs equal to X percent of our annual power use." This claim statement is acceptable because it conveys that the renewable electricity (both RECs and energy) associated with the customer-sited solar project was sold and supplied to the electric grid.

An owner of a solar energy project can always make the claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs). The claim statement also conveys that replacement wind RECs were procured from a wind resource in order to substantiate the consumer's claim of using renewable electricity in an amount equal to the percent specified in the claim.
"We sell the solar electricity generated from our on-site system and have replaced it with renewable electricity from another zero-emissions renewable resource."

This claim statement is acceptable because it conveys that the RECs associated with the electricity generated from the customer-sited solar are sold.

An owner of a renewable energy project can always make the claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs). The claim also conveys that in replacement of the sold RECs, alternative RECs from a different zero-emissions renewable resource are procured. Claims must be specific to the type of renewable energy resource embodied in the REC. If the RECs that substantiate the claim are from a different project, avoid any suggestion that the renewable energy being used originated from the  on-site solar system.

Examples of unacceptable claims:

Claim Rationale for why it should be avoided
"We use solar electricity."

This claim statement is unacceptable because it is unqualified and not specific enough to inform readers about the source of your renewable energy use situation.

Readers may presume that organizations are using solar power from their on-site solar project and not the solar energy that was purchased from a different project.

An owner of a renewable energy project can always claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs). This claim statement does not convey where the solar use is coming from and could be misleading.
"We host a PV solar system on our roof. We are solar powered."

This claim statement is unacceptable because it is unqualified and not specific enough to inform readers about the source of your renewable energy use.

Readers may presume that organizations are using solar power from their on-site solar project and not the solar energy that they purchased from a different project. An owner of a renewable energy project can always claim to be generating renewable energy, but in order for the project owner to also claim to be using renewable energy (e.g., as a consumer), they must be able to substantiate their use by owning the associated renewable energy attributes (i.e., RECs). The claim does not convey where the solar energy is coming from and could be misleading.

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Last updated on January 15, 2024