Revisions to Partnership Requirements
The EPA Green Power Partnership (GPP) updated its partnership requirements on May 14, 2019. The first update increases the minimum amount of green power Partners use annually and simplify the benchmarks for Green Power Communities. The second update requires organizations to use a certain amount of electricity every year to participate as Partners. Both updates will allow the program to better serve the marketplace, use resources more effectively, and increase environmental benefits over time.
Since the Green Power Partnership was established in 2001, the GPP has regularly reviewed and updated the Partnership's requirements to help protect human health and the environment and advance the U.S. green power market. These updates are also intended to:
- Utilize and deploy program resources to best serve voluntary market stakeholders;
- Enhance program credibility by reflecting changes in the green power market;
- Support best practices and leadership in green power use;
- Strengthen program integrity by making changes that are easy to communicate, understand, and implement; and
- Increase program cost-effectiveness by simplifying program administration.
In response to this evolving marketplace, in late 2017, the GPP solicited feedback from Partners and stakeholders on several proposed Partnership requirement updates. Those recommended program changes were driven by (1) a periodic review of the effectiveness of our green power use benchmarks relative to the market and (2) a longer-term evaluation of the best way to support and serve smaller organizations. Learn more about the original proposal and final requirement updates here.
While overall feedback was supportive and positive regarding the proposed changes, EPA did receive limited feedback in two key areas that has resulted in the moderated approach that the program is implementing.
- Several smaller Partners expressed concern for the extent to which the proposed program requirement updates would have on organizations using less than 1,000,000 kWh of electricity annually. In response, EPA lowered the minimum electricity use requirement downward to only 100,000 kWh.
- Several stakeholders, including Partners and Green Power Communities (GPCs), noted that an increase to the GPP benchmarks would increase benchmarks for GPCs too, which would be more difficult for communities to meet or respond to. In response, EPA has chosen to create a separate, single GPC benchmark.
On May 14, 2019, EPA will implement the following updates to the GPP's Partnership requirements:
- Increase the benchmarks for Partners' green power use (percentage of annual electricity use) and institute a single benchmark for Green Power Communities' green power use (5 percent of communities' annual electricity use) and
- Add an annual electricity use eligibility requirement for Partners (i.e., minimum annual electricity use of 100,000 kWh or greater).
Updating the Green Power Benchmarks
|Partner's Annual Electricity Use||Old Minimum Green Power Usage Requirements (Benchmarks)||New Minimum Green Power Usage Requirements (Benchmarks)|
|If the organization's annual electricity use is...||A Partner previously used this much or more green power annually||A Partner uses this much or more green power annually|
|100,000,001 kWh or greater||3% of an organization's use||7%* of an organization's use|
|10,000,001 - 100,000,000 kWh||5% of use||10%* of use|
|1,000,001 - 10,000,000 kWh||10% of use||25%* of use|
|100,000* - 1,000,000 kWh||20% of use||50%* of use|
*Indicates new requirement changes relative to past levels
Rationale for Increasing the Minimum Green Power Use Benchmarks:
- Partners' Trend: Average and median green power use among existing Partners has increased substantively since the program's last increase to the benchmarks.
- Market Trend: Macro trends in green power consumption in the market, including cost reductions in renewable technologies, have resulted in green power generally becoming more affordable and available.
- Theory of Change: A credible benchmark increase raises the level of ambition while continuing to encourage broad market engagement with the Partnership and green power. The GPP's history of success is built on setting credible benchmarks for Partners' first steps and then encouraging them to use more green power through education and recognition.
- Broader Applicability: In response to comments on the proposal, GPP proposed a single benchmark for EPA's Green Power Communities.
Rationale for Establishing an Annual Electricity Use Eligibility Requirement:
- New Program Offerings: The eligibility requirements for small Partners reflects a new strategic approach to supporting organizations that focuses on technical information and resources, rather than managing partnerships.
- Alternative Pathways: Some small Partners will be able to be eligible for the Partnership by scaling to a larger part of their organization. Other small partners may be able to partner with EPA through Green Power Communities, which aggregate the green power use of non-residential and residential electricity consumers in local communities.
- Cost-effective strategies: The GPP's cost of partnering with smaller Partners to encourage green power use is not a cost-effective strategy, according to our analysis. For these reasons, the GPP already does not offer partnerships with residential consumers.
- Limited Return on Investment: Most smaller Partners initially purchase green power for 100% of their electricity needs, unlike larger Partners. Thus, the expense of maintaining and managing the partnerships with smaller Partners offers limited returns to the program, whereas the long-term value of partnering with larger Partners has contributed to more than 60% of the Partnership's growth, measured in terms of program kWh.
- All current Partners will have one year to meet the updated program requirements. After May 2020, Partners who are no longer eligible will not be listed as a Partner on EPA's website.
- New Partners that submit Partnership Agreements after today will be required to meet the updated program requirements.
- Green Power Communities will have two years to meet the single, new green power benchmark of five percent.
These program requirement updates represent difficult decisions that affect some organizations that have been long-standing Partners with EPA. We greatly value Partners’ engagement in the program and applaud their commitment to green power use. The GPP will focus on providing information and resources to help support organizations in achieving their future green power objectives. Organizations will continue to have access to existing and new guidance, tools, peer exchange, and program communications via GPP’s mailing list and website. EPA will also recognize organizations for their commitment to and use of green power during their time as a Partner.