Renewable Energy Certificate Probe Launched
A coalition of 16 state attorneys general has launched an investigation into four major technology companies’ use of renewable energy certificates, according to reports. The attorneys general sent a 15-page letter to Amazon, Google, Meta, and Microsoft questioning whether their claims about achieving 100% renewable energy usage might be “deceptive or misleading,” sources indicate.
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The investigation centers on the companies’ use of unbundled renewable energy certificates (RECs), which give companies the rights to “environmental, social and other non-power attributes” of renewables. According to the Environmental Protection Agency, these certificates are obtained when one megawatt-hour of renewable-generated electricity is delivered to the grid.
Questioning Corporate Environmental Claims
The attorneys general specifically probed each company’s usage of unbundled RECs, including questions about how they analyzed if additional generation would come online, analysts suggest. The officials also requested detailed information about energy usage for each of the past five years without considering RECs and asked how such certificates are used to calculate the companies’ energy usage and scope 2 emissions.
“Major tech companies use unbundled RECs to claim that they have achieved 100% renewable energy ‘use’ or ‘consumption,’ and have reduced their emissions,” the letter stated, according to reports. “Both types of claims appear to be deceptive or misleading.” The coalition includes attorneys general from Alabama, Alaska, Arkansas, Indiana, Iowa, Florida, Kansas, Missouri, Montana, Nebraska, North Dakota, Oklahoma, Pennsylvania, South Carolina, West Virginia and Wyoming.
Understanding Renewable Energy Certificates
Unbundled RECs, while not tied to a specific project, provide renewable energy projects additional sources of income to keep projects operating and incentivize new generation, according to trade group American Council on Renewable Energy. The organization notes that unbundled RECs represent “a growing proportion of total renewable project revenue” and are “the primary way for many entities to claim the environmental attributes represented by renewable electricity,” according to their resources on renewable energy certificates.
The use of these certificates forms part of each company’s respective strategy for matching energy usage with renewable energy. Companies measure their energy consumption in kilowatt-hour units, with RECs representing one megawatt-hour of renewable electricity generation.
Company Responses and Sustainability Goals
Amazon confirmed in an email that it has received and is reviewing the letter from the state attorneys general. The company reportedly stated it expects the number of unbundled RECs it purchases will decrease over time as additional projects come online. Amazon announced last year that it matched 100% of its operational electricity usage with renewable energy in 2023, seven years ahead of its 2030 target.
In a 2024 blog post explaining how it reached its goal, Amazon noted that “no company with complex and growing operations is able today to only consume renewable energy — there simply aren’t enough sources in enough locations, and it takes a while for new projects to come online.” The company added that “like most companies with ambitious climate goals like ours, we also purchase RECs.”
Google reportedly stated it first matched 100% of its operational electricity with renewable energy in 2017 by annually purchasing the same amount of renewable energy, through physical energy purchases and RECs, as it uses. The company also has a goal to run on 24/7 carbon-free energy on every grid it operates in by 2030.
Meta said in its most recent sustainability report it has maintained net-zero across its scope 1 and scope 2 emissions since 2020, becoming one of largest corporate procurers of renewable energy. Microsoft has a goal to hit net-zero across its operations by 2025 through energy efficiency, decarbonization and reaching “100% direct renewable electricity by 2025,” according to a sustainability fact sheet.
Broader Industry Context
The investigation comes amid wider market trends and industry developments in corporate sustainability reporting. As companies face increasing pressure to demonstrate environmental responsibility, questions about the accounting methods behind these claims have gained prominence.
The probe also intersects with recent technology infrastructure challenges and related innovations in corporate energy management. These market dynamics reflect the complex balance between sustainability goals and operational realities that major corporations must navigate.
Microsoft declined to comment for this story, while Google and Meta did not respond to requests for comment, according to reports. The state attorneys have requested responses to both broad and company-specific questions mentioned in their letter by October 27. The outcome of this investigation could have significant implications for how corporations account for and report their environmental impact, potentially influencing future corporate sustainability practices across multiple sectors.
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