As we move through the final quarter of 2025, CRS continues to advance policies that strengthen the credibility and impact of renewable energy markets. Across the Western region and through ongoing work in regional and voluntary market design, CRS is helping ensure that clean energy claims remain transparent, verifiable, and aligned with evolving national and international standards. This update highlights recent regulatory filings, program developments, and initiatives that are shaping credible, market-based climate action heading into 2026.
Arizona
CRS Submits Comments Opposing Repeal of Renewable Energy Standard
The Arizona Corporation Commission (ACC) has moved forward with proceedings to repeal the state’s Renewable Energy Standard and Tariff (REST) under Title 14, Chapter 2 of the Arizona Administrative Code. CRS submitted formal comments opposing the repeal, emphasizing that eliminating renewable energy certificate (REC) retirement requirements would undermine the integrity of both compliance and voluntary renewable energy markets. The proposed rulemaking would strike the state’s longstanding clean-energy requirements, eroding the foundation for credible renewable energy claims in Arizona.
In its filing, CRS stressed the importance of REC retirement, transparent tracking, and credible verification to ensure that renewable energy claims remain accurate and verifiable. CRS cautioned that repealing REST risks widespread double counting and could drive voluntary investment out of the state—weakening Arizona’s role in regional clean energy markets.
Read CRS’s full comment letter: CRS Comments on ACC REST Repeal.
California
SB 253 Draft Reporting Template—CRS Recommends Refinements for Clarity and Market Consistency
CARB has released a draft reporting template for corporate greenhouse gas disclosures under the Climate Corporate Data Accountability Act (SB 253), outlining the format for Scope 1 and Scope 2 emissions reporting. In October, CRS submitted comments recommending several refinements to improve clarity, transparency, and consistency across reporting entities. Key recommendations include adding explicit totals for both market-based and location-based Scope 2 emissions, adding a specific line for electricity purchases, and clarifying the definition and purpose of “emission reduction” fields to ensure accurate and verifiable accounting of renewable energy procurement.
CRS also reiterated support for market-based accounting across all Scopes (1, 2, and 3), third-party verification to ensure data integrity, and alignment with the Greenhouse Gas Protocol’s dual-reporting requirements. Together, these refinements would strengthen the credibility of California’s corporate climate disclosures while ensuring alignment with national and international reporting standards.
Read CRS’s full comment letter: CRS Comments on SB 253 Draft Reporting Template (Oct 24, 2025)
CARB’s Cap-and-Invest Program Update
CRS has submitted comments to the California Air Resources Board (CARB) on the proposed updates to the state’s Cap-and-Invest Program, focusing on the need to sustain and strengthen the Voluntary Renewable Energy Program (VREP). The VREP reserve—which enables voluntary renewable energy purchases to deliver emissions reductions beyond compliance obligations—is now fully depleted, affecting a number of entities in California’s voluntary renewable market, including utilities and other electricity providers, buyers, REC sellers, and others.
CRS recommends that CARB establish a long-term, data-driven mechanism to allocate allowances more smoothly and consistently across all voluntary renewable generation. Such a framework would ensure ongoing alignment between verified renewable generation and allowance retirements, preserving the integrity and additionality of California’s voluntary renewable energy market.
Read more:
CRS Recommends Clarifications to RPS 10th Edition Guidebook
On October 20, CRS submitted comments to the California Energy Commission (CEC) on the draft Renewables Portfolio Standard (RPS) 10th Edition Eligibility Guidebook. CRS commended the CEC’s efforts to improve transparency and market integrity but noted that the draft does not fully address ambiguities around REC retirement procedures. These gaps could allow double counting between compliance and voluntary markets, creating confusion for consumers and weakening credible renewable energy claims.
CRS recommends clearer distinctions between RECs retired for RPS compliance and those used for voluntary programs, along with improved guidance for load-serving entities on WREGIS subaccount use. CRS is also urging the CEC to provide outreach and staff guidance to help Community Choice Aggregators and other utilities understand the implications for “100% renewable” and opt-up products.
Read CRS’s full comment letter: CRS Comments on RPS 10th Edition Draft Guidebook (Oct 20, 2025)
Western Region
Western Market GHG Accounting Frameworks
CRS has been actively engaged in shaping new greenhouse gas (GHG) accounting frameworks for emerging real-time and day-ahead Western wholesale power markets. These frameworks aim to serve entities in states with varying carbon reduction and reporting policies by allocating generation and emissions to load-serving entities (LSEs) and producing residual mix data across the Western region.
Both the Southwest Power Pool (SPP) and the California Independent System Operator (CAISO) have finalized their proposals—“GHG Program: Tracking and Reporting” and “Greenhouse Gas: Accounting and Reporting,” respectively. CAISO’s proposal, finalized October 15th, is available here. However, neither proposal requires null power reporting, which is needed to prevent double counting of renewable energy attributes, and neither provides for reporting market allocation data to the Western Renewable Energy Generation Information System (WREGIS). As a result, the frameworks could enable region-wide double counting of renewable attributes and emissions when used for voluntary or state GHG reporting.
CRS has previously published a blog and policy brief with more background, though these preceded the final versions of the proposals.
Voluntary Policy
Greenhouse Gas Protocol
The Greenhouse Gas Protocol (GHGP) released public consultation materials for the Scope 2 Guidance update on October 20th. The public consultation period will be open until January 31, 2026. CRS plans to submit public comments on many aspects of the public consultation draft, focusing primarily on:
- Not requiring physical deliverability for the market-based method
- Optional hourly matching for the market-based method
CRS has posted a blog post describing these key issues, and plans to share comments submitted during the public comment period thereafter.
Additionally, GHGP and the International Standards Organization (ISO) announced in September a new partnership aimed at reducing fragmentation in the GHG accounting landscape. This partnership will combine standards in the ISO 1406X series and the GHG Protocol suite of standards for corporates to help drive harmonization on standards related to corporate carbon footprinting and project level accounting. For the development of the updated product carbon footprint standard, a new Joint Working Group will be established. Members of ISO’s technical community will also join GHGP’s existing technical working groups, and ISO will become an Observing Entity of the GHGP Independent Standards Board (ISB). Under the standard ISO review process, this new harmonized standard will be reviewed for changes every five years.
SBTi Corporate Net Zero Standard (v2)
CRS staff, led by Peggy Kellen, Senior Director, Policy and Market Development, have been participating in the Scope 2 Expert Working Group that was launched following the first public comment period on the draft updated standard in June. The second public consultation period began in November and extended through December 12. Companies will be expected to use version 2 of the guidance to set new near-term and long-term targets. Near-term targets set in 2025 and 2026 will remain valid until the end of 2030.
SBTi has committed to aligning with updates to the GHG Protocol Corporate Accounting and Reporting Standard revision, but will be finalized well in advance, potentially requiring additional changes to SBTi in the 2027 / 2028 timeframe.
CRS Programs
Clean Energy Accounting Project (CEAP)
Recruiting for New Clean Fuels Series (CFS)
The Clean Energy Accounting Project (CEAP) announced the Clean Fuels Series (CFS), an 18-month effort to fill remaining gaps in emissions accounting for clean fuels, including developing the additional components needed to expand CEAP’s Market-based Accounting for Clean Fuels guidance into a comprehensive Scope 1 reporting framework.
The CFS’s final work stream will be determined by its Founding Partners in consultation with CEAP staff and the CFS Council, which operates both as a fuels-focused advisory committee and a traditional CEAP working group. For the new initiative, CEAP has streamlined the guidance development process, while maintaining CRS’s stakeholder-driven and cooperative approach to answering difficult clean energy and emissions accounting questions. Staff will lean on 1-on-1 collaborations with each Council member, convening the full Council to resolve issues where no consensus has developed.
CEAP is currently recruiting Founding Partners and Council Members for the CFS and actively seeking representation from clean fuels developers, purchasers, market instrument purveyors, and auditors / assurance providers. For more information or to join the Clean Fuels Series, contact CEAP Manager Renee O’Donnell at renee.odonnell@resource-solutions.org.
Clean Energy Tracking Collaborative (CETC)
At the 30th Renewable Energy Markets™ (REM™) Conference in Houston this September, CRS launched the Clean Energy Tracking Collaborative (CETC, pronounced “set-see”). CETC is a multi-year and multi-stakeholder program that will develop recommendations for expanded tracking system functionality.
CETC supports the evolution of energy tracking systems that are essential to the clean-energy transition. CETC provides a forum for regulators, government agencies, industry leaders, and tracking system operators to work together to identify essential tracking needs and functionalities.
CETC’s outcomes are facilitated through technical working groups (TWGs), where experts and industry leaders provide perspectives and experiences that are ultimately used to develop recommendations for functionality. CRS is actively recruiting organizations to join the Collaborative through its committees and TWG. CETC’s first TWG will be focused on hourly energy attribute certificates and data.
For more information, please reach out to: cetc@resource-solutions.org or visit resource-solutions.org/cetc.
CRS Advisory 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.
Recent Conferences & Publications
- October 22: Peggy Kellen, Senior Director of Policy, presented at the NAEM Forum 2025 on Navigating Renewable Energy and Scope 2 Accounting Changes.
- October 28–30: Peggy Kellen, Devon Johnson, and Renee O’Donnell represented CRS at the Renewable Energy Markets (REM™) Conference, sharing insights on evolving Greenhouse Gas Protocol guidance, SBTi updates, and corporate renewable energy strategies.
- At VERGE 2025, Peggy and Devon joined panels focused on corporate climate leadership and emerging accounting standards:
- Devon Johnson: Navigating New Threats and Opportunities for Corporate Renewable Buyers: SBTi 2.0, GHG Protocol, and the “One Big Beautiful Bill”
- Peggy Kellen: Shaping the Future of Scope 2: Corporate GHG Strategies Amid Evolving Standards