Guarantees of Origin Documents
Guarantees of Origin are green electricity certificates regulated by the EU. They lead to widespread problems of double counting green electricity.
- How Iceland sold the same Green Electricity twice (May 11 2023)
- Double Counting and other problems with Green Electricity Certificates (Jun 05 2023)
Guarantees of Origin in Norway
The German law firm "Becker Büttner Held" analyzed double counting of guarantees of origin in Norway for the Austrian electricity company "Verbund" in 2021.
These documents were made public due to a request by Lennart Mühlenmeier based on German freedom of information laws and first published on the freedom of information portal "Frag den Staat".
Automated translations for German documents are provided as well. Due to the limited quality of the original documents, the translation is incomplete and sometimes hard to read.
- Gutachten Herkunftsnachweise Norwegen, Becker Büttner Held (German)
- Legal Opinion Guarantees of Origin Norway, automated translation
- Attachment 1: Memorandum on certain aspects of the use of guarantees of origin in Norway, law firm Hjort
- Attachment 2: Regulations on guarantees of origin for the production of electrical energy - English translation of Norwegian regulation
- Attachment 3: Vorschrift zu den Herkunftsnachweisen der Produktion von elektrischer Energie - German translation of Norwegian regulation
- Attachment 4: Regulations on metering, billing, invoicing of grid Services and electrical energy, the grid company's neutrality, etc. - English translation of Norwegian regulation
- Attachment 5: Act on generation, conversion, transmission, trading, distribution and use of energy etc. (Energy Act) - English translation of Norwegian law
- Externes Rechtsgutachten zur Anerkennbarkeit norwegischer Herkunftsnachweise (HKN) - Anmerkungen Umweltbundesamt
- External legal opinion on the recognizability of Norwegian guarantees of origin - remarks by German Environment Agency / Umweltbundesamt, automated translation
The BBH analysis mentions a report created by Oslo Economics for the Norwegian Ministry of Petroleum and Energy in 2018, which is publicly available. It already mentions issues with guarantees of origin, but it was only available in Norwegian. Therefore, an automated English translation is provided here. (It appears that a similar report created by Oslo Economics around the same time is available in English, but that is a different document.)
- Report on guarantees of origin and product declarations for electricity, by Oslo Economics for the Norwegian Ministry of Petroleum and Energy - automated English translation
Lowest Energy Prices
In the 1990s, the Icelandic Ministry of Energy and Industry and the company Landsvirkjun operated a marketing unit (Markaðsskrifstofa iðnaðarráðuneytis og Landsvirkjunar, Icelandic Energy Marketing Unit) to advertise the potential for cheap and environmentally friendly electricity in Iceland to companies worldwide. A brochure titled "Lowest Energy Prices" was published in 1995.
This is noteworthy, as it was only much later that Icelandic electricity companies started selling the same "green properties" that they used to attract energy-intensive companies a second time in the form of guarantees of origin.