How to end the "100% renewable" fraud
An FTC rule called the "Green Guides" lets Apple, Google, Meta and hundreds of other companies claim be “100% renewable” while using mostly fossil fuel electricity.
Apple, Google, Meta and hundreds of other companies claim to be “100% renewable” while using mostly fossil fuel electricity.
How is this possible?
Because an FTC rule called the “Green Guides” lets them buy so-called “credits” to count others’ solar and wind use as their own.1
No significant US company is close to being “100% renewable,” since all such companies rely on the mostly fossil fuel electricity grid.
But in 2012, the Obama FTC rewrote a guidance document called the “Green Guides” to let companies falsely claim to be “100% renewable” anyway.2The FTC has published the “Green Guides” since 1992 to specify what constitutes deceptive environmental marketing claims under The FTC Act.
In particular the Green Guides specify when it is misleading—and therefore illegal—to claim to use a given amount of “renewable” energy.Under the Obama FTC’s update of the Green Guides, companies are allowed to claim they are powered by any percentage “renewable” energy they wish, if they purchase enough “renewable energy certificates” (RECs) to “match” their non-renewable electricity use.3
RECs are claims to credit for “renewable” electricity that someone else is using.
For example, if Apple actually consumes 15% of its electricity from “renewable” sources and 50% from fossil fuel sources, it can spend a lot of money on RECs and then claim to be 65% “renewable.”Buying RECs not only gives a company false credit for others’ “renewable” use, it also gives others false blame for a company’s fossil fuel use.
When Apple buys RECs, it foists the blame for Apple’s fossil fuel use onto ratepayers and less wealthy (or less dishonest) companies.In practice, the Obama Green Guides have enabled hundreds of companies to falsely and absurdly claim to be “100% renewable” while running mostly on fossil fuels—and foist the blame for their fossil fuel usage onto citizens and other companies.4
The EPA estimates that between 2014 and 2023, “voluntary” REC sales—i.e., those not mandated by policies like state renewable standards—generated $3-5 billion for the US “renewable” energy industry.5
In 2023, “voluntary” REC sales reached 319 million MWh annually—which is 44% of all US “renewable” generation. In other words, almost half of solar and wind generation in the US is being taken credit for by people who aren't actually using it!6
REC-backed renewable energy claims are incredibly misleading.
Everyone rightly interprets a claim of X% renewable—e.g., “powered by 100% renewable energy”—as referring to the energy a company uses, not a label they pay for.When a company says they are “100% renewable,” it suggests that the company has figured out a way of just powering itself via solar and wind.
People would not be impressed if they knew that the company was simply using its money to blame-shift its massive non-renewable energy use.The effects of the Obama Green Guides have been disastrous.
By sanctioning the use of RECs to falsely claim high, often 100%, renewable usage, the Guides have created the illusion that neither fossil fuels nor nuclear are necessary for low-cost, reliable electricity in the US.Based on the illusion that solar and wind alone can power our country, voters have been insufficiently concerned about disastrous policy efforts to shut down reliable power plants.
These efforts have created a reliability crisis that will only get worse with new demand from AI.7What can be done about the Green Guides’ “100% renewable” fraud?
It’s simple: The FTC should update the Green Guides to prohibit companies from using renewable energy certificates to falsely overstate their renewable energy consumption.The FTC should issue updated Green Guides (16 CFR Part 2608) that
1. Strike the Obama admin’s 2012 language that allows REC-backed “renewable” claims.
2. Add new language that explicitly explains that you can only claim to use as much renewable energy as you actually use.1. The FTC should update the Green Guides to strike the Obama administration’s 2012 language that allows REC-backed “renewable” claims.
See this cut to section 15(a) of the Green Guides.
2. The FTC should add new language to the Green Guides that explicitly explains that you can only claim to use as much renewable energy as you actually use.
Here's some model language to add to the Green Guides, covering the terms “renewable,” “zero emissions,” and “net-zero.”
The FTC can actually move rapidly on a Green Guides revision thanks (inadvertently) to the Biden administration.
In 2022, the Biden FTC opened a file on whether to update the Guides (Matter No. P952501) but never moved forward. The current FTC can proceed immediately based on that file.9It’s time to stop hundreds of companies including Apple, Google, and Meta from lying about being “100% renewable” and deceiving American voters into thinking that solar and wind can power a modern economy.
Tell the FTC to end the “100% renewable” fraud!
Michelle Hung, Steffen Henne, and Daniil Gorbatenko contributed to this piece.
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“A marketer should not make unqualified renewable energy claims, directly or by implication, if fossil fuel, or electricity derived from fossil fuel, is used to manufacture any part of the advertised item or is used to power any part of the advertised service, unless the marketer has matched such non-renewable energy use with renewable energy certificates.”
FTC - Green Guides
Apparently, the Obama and subsequent administrations learned a lesson from Pope Leo X of the early 16th Century. Leo sold indulgences - absolving people of their sins - for cold, hard cash. So, like the fools of Leo's time, who thought they could buy their way into Heaven, Apple, Google, and Meta think they can get to a Carbon-free Heaven by writing a check. Moreover, then as now, the purported "Heaven" doesn't even exist! Which is worse, the grift or the ignorance? Both seem to transcend time.