Turning Up the Heat: CRS Q3 2025 Policy Update

As we move through the third quarter of 2025, Center for Resource Solutions (CRS) continues to play a leading role in shaping policies that safeguard the credibility and impact of renewable energy markets. From regulatory developments in Arizona, California, Minnesota, and Washington, to ongoing efforts in wholesale market design and voluntary program integrity, this update highlights how CRS is advancing clear, credible frameworks for market-based climate action.

Arizona

The Arizona Corporation Commission (ACC) is moving to repeal the state’s Renewable Energy Standard and Tariff (REST), which requires regulated utilities to source 15% of electricity from renewable energy by 2025. In early 2024, the Commission voted 4–1 to initiate formal rulemaking. This follows repeated waiver requests from Arizona Public Service (APS) to avoid retiring Renewable Energy Certificates (RECs) for compliance. In comments last year, CRS strongly opposed the waiver, warning it would result in double counting—undermining both compliance and voluntary market claims.

CRS also cautioned that repealing the REST or weakening REC requirements could drive voluntary investment out of Arizona. Corporate buyers rely on exclusive REC ownership to support emissions claims, and uncertainty around REC use risks eroding that demand. Without credible tracking and retirement, Arizona may miss out on the private capital that has helped drive renewable energy growth across the West. CRS continues to oppose both the waiver and repeal, and urges stakeholders to monitor upcoming filings and comment opportunities.

California

Voluntary Renewable Energy Program—Still Unresolved

The California Air Resources Board (CARB) has yet to act on restoring the Voluntary Renewable Energy reserve account, which remains fully depleted. This continues to threaten over 2.2 million MWh of voluntary renewable energy transactions and the credibility of avoided emissions claims backed by Green-e® certification. Without a functioning reserve, voluntary buyers cannot demonstrate that their purchases result in emissions reductions beyond what is required by law—undermining the environmental integrity and impact of their actions. This poses a serious risk to buyer confidence and market participation. CRS urges stakeholders to stay alert for potential developments and supports interim solutions to safeguard the integrity of the program.

We also urge CARB to take immediate steps to restore the reserve and ensure that the program continues to support credible voluntary market impact. A clear signal from CARB is needed to maintain trust in the system and preserve the role of voluntary renewable energy in achieving California’s climate goals.

SB 253 Rulemaking Priorities Take Shape

CARB has released a new FAQ outlining its priorities for implementing SB 253, which will require companies with over $1 billion in annual revenue doing business in California to report their Scope 1, 2, and 3 GHG emissions. CARB affirms it is committed to finalizing the regulation by end of 2025.

While details—especially on Scope 2 methodology—remain limited, the FAQ highlights CARB’s goals: a program that is effective, streamlined, and aligned with other frameworks, while providing accurate and decision-useful climate information. CRS has urged CARB to incorporate credible market-based accounting using EACs and programs like Green-e®, and to align reporting with existing California programs to reduce complexity and risk of double counting.

Washington

CRS Urges Expansion of Voluntary Reserve in Cap-and-Invest Rule

The Washington Department of Ecology is proposing updates to its Climate Commitment Act (CCA) Program rule (WAC 173-446) and GHG Reporting rule (WAC 173-441) to improve program implementation and prepare for potential linkage with the California–Québec carbon market. Included in the draft rule is a continued 0.33% set-aside of allowances for the Voluntary Renewable Electricity Reserve.

CRS will be submitting comments encouraging Ecology to strengthen this mechanism. Specifically, we recommend expanding the reserve well beyond the current 0.33% allocation to ensure sufficient allowances are available to create regulatory surplus for voluntary renewable energy purchases. The current amount will not be sufficient—Green-e® Energy certified sales in Washington alone are expected to exceed this level of demand, risking depletion of the reserve and compromising the ability of voluntary buyers to make surplus or impact claims.

Moreover, rather than relying on a limited application-based process, Ecology should consider automatically retiring allowances based on verified voluntary market activity—especially Green-e® certified transactions. This model, similar to what CRS has recommended in California, would remove administrative barriers and ensure broader participation in the program while preserving the credibility of voluntary market claims.

Minnesota

Carbon-Free Standard

The Minnesota Public Utilities Commission (PUC) held a hearing to resolve how utilities should demonstrate compliance with the state’s new Carbon-Free Standard (CFS). CRS was among a handful of commenters invited to make a public statement at the hearing. In our statement, CRS emphasized that retiring RECs and other environmental attribute certificates (EACs) are the best and only way to prevent double-counting. When double counting is permitted any emissions impact of voluntary purchases is voided and accurate accounting of progress towards the states CFS is undermined.

CRS also emphasized that proposals to apply a grid average mix to determine the portion of a utility’s net wholesale purchases that may be considered carbon-free counts twice the EACs already sold in the voluntary market and from a utility’s wholesale purchases of CFE. The Commission responded that the statute authorizing the CFS does not explicitly state that EACs should be used to account for net wholesale CFE purchases.

Additionally, the Commission noted that it is not its responsibility to safeguard the integrity of the voluntary market. Ultimately, the PUC voted to permit—but not require—utilities to demonstrate compliance using RECs and deferred on the question of how to calculate the carbon-free portion of net wholesale purchases until after it has resolved which technologies it considers carbon-free.

Western Region

Wholesale Market Developments

CRS has been 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.

Most recently, the California Independent System Operator (CAISO) has produced a draft final proposal (available on its GHG Coordination Working Group webpage) outlining the elements of its “Accounting and Reporting Approach.” CAISO is taking public comment on the proposal through August 20. Importantly, in line with our recommendations, the draft final proposal includes a requirement for null power reporting that is needed to prevent double counting of renewable energy attributes. But CAISO is considering making this optional instead. We also recommend 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 as well as our proposal to CAISO. We encourage all parties to engage with CAISO and WREGIS to support the requirement for null power reporting and coordination with WREGIS.

 

Indicators of Clean Electricity Procurement that Drives New Supply

CRS’s Clean Energy Accounting Project (CEAP) released Indicators of Clean Electricity Procurement that Drives New Supply, its most recent guidance document, which helps voluntary buyers improve the impact of their procurement strategies. These indicators offer a flexible framework to support individual procurements that send stronger signals for new clean energy, sustain existing projects at risk, and support innovation and grid integration. It’s a practical guide for anyone navigating voluntary clean electricity markets and aiming for greater climate impact. The guidance is available via the document itself, an explanatory blog post, and an expert-led webinar with developer and buyer perspectives.

“Secondary Transactions of Hourly Certificates” Initiative Sponsorship Opportunities

CEAP is launching a new initiative, “Secondary Transactions of Hourly Certificates,” to develop guidance for identifying best practices for the secondary transactions of unbundled hourly RECs to ensure integrity, transparency, and access in both voluntary and compliance markets. CEAP is currently seeking initiative sponsors to help shape the effort, offer strategic input, and gain recognition for their leadership. Sponsors collaborate closely with CRS throughout the process and are a critical part of the review process as well as a promotional partner.

The Working Group will convene in late Q3 and run through the end of the year.

To learn more or become a sponsor, contact Renee O’Donnell, CEAP Program Manager.

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, CEBA, Google, 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 O’Donnell, CEAP Program Manager.

CRS Services

CRS provides mission-driven advisory services to help organizations navigate their clean energy transitions and meet ambitious decarbonization goals. Drawing on decades of hands-on experience, we support clients in developing and implementing renewable energy strategies that are practical, scalable, and impactful—driving real emissions reductions and accelerating market transformation.

Our expertise includes renewable energy procurement, credible claims and standards development, emissions accounting, clean energy verification, and impactful procurement strategies. Whether you’re just starting or advancing your climate commitments, CRS’s Advisory Services can help you take meaningful, measurable action.

To learn more, visit resource-solutions.org/services or contact us at services@resource-solutions.org.