Building on strong momentum from the beginning of the year, CRS continues to shape key regulatory and market developments as we move into the second quarter of 2025. From California to Washington to Minnesota, agencies are advancing rules that impact the integrity of renewable energy and emissions accounting. In this update, we highlight how CRS is working to support credible, market-based climate action.
California
CARB’s Voluntary Renewable Energy Program (VREP)
The California Air Resources Board has delayed amendments to the Cap-and-Trade Regulation, stating, “We’re still working through the regulatory package and expect to move forward this year.” In the meantime, CRS urges CARB to take immediate action to address the full depletion of allowances in the Voluntary Renewable Energy (VRE) reserve account, which has jeopardized over 2.2 million MWh of voluntary renewable energy sales. The VRE reserve protects voluntary renewable energy purchases by backing them with a distinct set of emissions allowances, ensuring these purchases deliver additional emissions reductions beyond regulatory requirements. The program underpins participation in Green-e® certification and emissions reporting by businesses, universities, and municipalities pursuing meaningful climate action. Without a functioning VRE program, participants may be forced to exit, weakening California’s voluntary market and broader GHG targets. CRS has called on CARB to explore interim solutions and evaluate retroactive allowance retirements. We continue to engage with CARB and stakeholders to maintain the program’s integrity and support additional renewable deployment.
For more information, see CRS’s previous comments
For updates, see the Cap-and-Trade Program page
California’s Climate Corporate Data Accountability Act (SB 253)
CRS submitted comments on the implementation SB 253. Our recommendations focus on aligning SB 253 implementation with credible market-based emissions accounting, including adjustments to existing California programs such as Power Source Disclosure to reduce reporting burdens. CRS continues to advocate for the use of Energy Attribute Certificates (EACs) and third-party verification systems like Green-e® to substantiate renewable energy use, prevent double counting, and streamline compliance.
For more information, see CRS’s comments
Washington
Cap-and-Invest Electricity Markets and Imports
CRS is engaging in for Ecology’s Cap-and-Invest electricity forum. CRS is encouraging Ecology to adopt broader policies for verifying all renewable imports to avoid double counting and improve emissions accounting. CRS recommends aligning Ecology’s reporting with efforts at CAISO and SPP to incorporate RECs and null power into GHG frameworks. Ecology can support this by requiring import data that includes REC and null power information or using residual mix methods adjusted for null power. These improvements would enhance consistency across regional programs.
For more information, visit the Ecology Electricity Forums pageAlso see: CRS Comments to CAISO and our GHG Accounting Policy Brief for States
Markets and CETA Compliance
The Washington Utilities and Transportation Commission (UTC) has released updated draft rules under Docket UE-210183 addressing electricity market purchases under the Clean Energy Transformation Act (CETA). The revised draft reflects key concerns raised by CRS and EPA, particularly around separating renewable energy certificates (RECs) from nonpower attributes (NPAs) and preventing double counting. The draft rules clarify that NPAs are only eligible when no RECs are generated and that utilities must own or acquire RECs or NPAs for market-allocated electricity. These updates address earlier concerns about clean energy claims in centralized markets. Strong safeguards also prevent double usage across jurisdictions. CRS supports these revisions and continues to monitor implementation to protect market integrity and maintain alignment with voluntary standards.
See more information and CRS’s comments
Minnesota
Clean Energy Standard
CRS joined M-RETS, Climate Solutions Group, and others in calling on the Minnesota Public Utilities Commission (PUC) to require REC procurement and retirement to demonstrate compliance with the state’s new Carbon-Free Standard (CFS). RECs are already the primary method Minnesota utilities use for Renewable Portfolio Standard (RPS) compliance. CRS emphasized that M-RETS and other tracking systems are fully capable of supporting Energy Attribute Certificates (EACs) for carbon-free, non-renewable resources. CRS reiterated its opposition to using a region-wide grid average fuel mix for wholesale market purchases under the CFS, as this would double count attributes already sold to voluntary buyers. Instead, CRS recommended using a subregional residual mix that excludes these claimed attributes. In reply comments on CFS verification, the Minnesota Department of Commerce (DOC) proposed phasing in hourly data reporting via integrated resource plans, with benchmarks of 90% hourly matching by 2040 and 100% by 2045. CRS did not directly comment on the hourly reporting requirement, but Google, an advisory committee member of CEAP, expressed support, citing similar moves in Colorado and Arizona.
Western Region
Wholesale Market Updates
CRS continues to be actively involved in the development of accounting and reporting frameworks for greenhouse gas (GHG) emissions within new real-time and day-ahead Western regional wholesale power market offerings. As regional market operators look to serve the needs of entities in states with different carbon reduction and reporting policies, a lack of coordination with the REC system and the potential for competing allocation methods risks double counting renewable attributes and emissions that are claimed under state and voluntary programs.CRS has been participating in the California Independent System Operator’s (CAISO’s) GHG Coordination Working Group, which has begun weekly small-group discussions on the development of an “Accounting and Reporting Approach” for the Western Energy Imbalance Market (WEIM) and the Extended Day Ahead Market (EDAM). At this stage, CAISO is developing assumptions and draft positions ahead of a full straw proposal for the approach. Our priorities are proper accounting for null power and calculation of market residual mix as well as improving data transparency and coordination with the Western Renewable Energy Generation Information System (WREGIS)
We have published a new blog and policy brief with more information. We encourage all parties to engage with CAISO and WREGIS to support coordination and accurate accounting.
CEAP Publishes Guidance on Market-based Accounting for Clean Fuels
CEAP released its much-anticipated Market-based Accounting for Clean Fuels, rolling the publication out at the RNG Coalition’s Mid-year Policy Summit. CRS Policy Director Chris Cooper presented the guidance during an April 24 panel discussion and will be moderating a CRS webinar panel discussion on the report on May 21 at 9:00am PST.
Power Source and Emissions Disclosure Initiative and Sponsorship Opportunities
The Clean Energy Accounting Project (CEAP) has launched a new initiative, Best Practices for Power Source and Emissions Disclosure, to develop guidance for electricity product disclosures across diverse market structures and tracking capabilities. The initiative will evaluate products such as standard offer and green power programs, offering consistent recommendations for regulators and suppliers. A new expert-driven Working Group will begin in late May. CRS is seeking initiative sponsors to help shape the effort, offering strategic input and gaining recognition for their leadership. Sponsors collaborate closely with CRS throughout the process.
To learn more or become a sponsor, contact renee.odonnell@resource-solutions.org
CEAP Advisory Committee Membership Openings
There are current openings on the CEAP Advisory Committee. The committee includes leaders in clean energy procurement and market development, including Apple, Google, CEBA, and WSP. Members help set CEAP priorities, provide input on high-impact initiatives, and collaborate on best practices for expanding credible clean energy markets.
If you’re interested in joining, contact renee.odonnell@resource-solutions.org