1. We felt we should update our website readers and clarify matters regarding our ROC retirement policy. Over the past seven years Good Energy has strived to be open and transparent about what we do, and seek independent verification where necessary. We have operated the same system over ROC retirement for the past seven years and not received any customer complaints.
2. When we entered the market in 1999, we were one of the first companies to receive the Energy Saving Trust accreditation “Future Energy” for our electricity product. At that time it provided suppliers with an audit procedure to check that they were matching what they sold with purchases from renewable generators. However, in 2002 the DTI decided that it no longer wanted to fund this and it was replaced by OFGEM’s Green Supplier’s Guidelines published in 2002. This indicated that the retirement of ROCs beyond compliance limits could be counted as additionality.
3. As a result of the demise of Future Energy, there was no longer any mechanism to validate the claims of suppliers under these guidelines. Good Energy decided we would use an independent verifier to check our claims in order to replace the audit procedure implemented under Future Energy.
4. At the same time OFGEM implemented a system to allow electricity suppliers to retire ROCs. However, this scheme did not give the right for ‘additional’ retired ROCs to claim rebates from the Renewable Obligation ‘buyout’ fund so that ROCs used for compliance and ROCs used for additionality were not financially equivalent.
5. The process is as follows: A supplier buys one ROC from a generator at around £50. It submits this ROC for compliance and subsequently receives approximately £12.81 rebate from the Government buyout fund. Thus, the cost of the ROC to the electricity supplier is £37.19 (for 2009).
6. For an additional retired ROC a supplier submits one ROC which it purchased from a generator at £50 per ROC. It subsequently receives nothing from the buyout fund. Therefore the cost of providing additional ROCs is £50 to the supplier. This shows that it is far more expensive to provide additionality than compliance.
7. Therefore it seemed to us that there was a conflict between the OFGEM guidelines for green suppliers, where the two types of ROCs were assumed to have the same value, and actual practice, where they clearly do not. As a result, Good Energy started its own scheme to retire additional ROCs beyond our compliance limits to the ‘equivalent economic value’ to us, the supplier - this is based on the average price we paid to generators for their ROCs.
8. We originally set ourselves a target of retiring ROCs to the equivalent economic value of 5% above our compliance levels. Doing this at £50 per ROC rather than £37.19 means we retire fewer than an actual additional 5%, but to an equivalent economic value.
9. In addition, we also pay our HomeGen customers an equivalent of three ROCs per unit produced. This we also count towards our “retired” ROCs, acting as a support mechanism to incentivise home generation. When this was originally introduced by Good Energy, there was no support for micro-generation anywhere in the country, and our initiative still goes above and beyond recent incentives introduced by government.
10. The Government buyout fund varies each year, as does the amount we pay our micro-generators. Therefore, the calculation to work out how many ROCs we should retire is complex. We also do this a year in arrears, because of the timetable set out by the ROC legislation. As a result, we decided it would be best to employ an independent firm, Smith & Williamson, to verify the figures and publish a statement confirming our approach and the figures. We publish this report every year to verify this and you can find it on our website. We’ve been doing this since 2002.
11. We believe that for any market mechanism to work effectively, the price signals need to be set at an appropriate level. By retiring beyond our compliance limits and supporting smaller generators we hope to do our bit to ensure this is the case.
12. In addition to ROC retirement we also believe that one unit of generation should only be sold once. This is why we also retire LECs (Levy Exemption Certificates) against all of our domestic customer and charity customer supplies. If sold separately from the REGO then the same unit of generation is effectively being sold twice. Good Energy believes this further distorts the market and it is a practice we feel should be prevented. However there are still many “green” tariff providers who continue to double sell their electricity.
13. Going forward, we hope that the work OFGEM is now undertaking for green tariff guidelines will provide greater clarity and transparency to the market and stop the practice of double-selling, as LECs will have to be retired for all domestic green tariffs. We are planning to update our offerings and consider an alternative to retiring ROCs. However, until this is complete we will continue to follow the original guidelines from 2002.
14. I hope this answers any queries any of our customers may have. Good Energy’s customers have always been attracted first and foremost by our 100% renewable offering. Any confusion demonstrates that what the green electricity market needs more than anything else is independent accreditation. We believe that the OFGEM green guidelines and accreditation scheme should provide some long awaited clarity to this market and we look forward to demonstrating why Good Energy and our customers are making such a difference to the UK renewable energy market.
If you have any further queries, please do not hesitate to contact me or the Good Energy team.
Kind regards,
Juliet Davenport
Chief Executive