CRS comments to the California ISO on its draft final proposal for the development of an Accounting and Reporting Approach—a GHG allocation framework that will produce data that will allow LSEs in the market to see and understand the emissions intensity of their portfolios, along with a residual emissions rate, and public emissions information.

CRS provided input on the implementation of SB 253 and SB 261. CRS emphasized the importance of ensuring that market-based emissions accounting, particularly for Scope 2 emissions, is properly integrated into the regulations, and that reporting aligns with widely used GHG accounting standards while addressing California’s specific needs.

CRS strongly opposes the EPA’s plan to repeal greenhouse gas (GHG) standards for power plants, arguing it harms public health, worsens climate change, and undermines clean energy progress. CRS highlights EPA data showing the rules prevent thousands of health issues and save $120 billion in health costs. Repealing them would increase emissions, hurt renewable energy …

This letter registers whether CRS supports, opposes, or takes no position on 36 different decision options commissioners of the MN PUC will take up during its July 17 Agenda Meeting. CRS strongly supports procuring and retiring RECs and other Energy Attribute Certificates to demonstrate compliance with the CFS, and strongly opposes applying a grid average …

CRS urges the Minnesota PUC to prevent double-counting in the Carbon-free Standard by requiring RECs and EACs to verify claims. Using a grid-average mix lets utilities claim clean energy attributes already owned by voluntary buyers, undermining climate goals. The Commission should close this loophole, ensuring only retired RECs or EACs justify claims and using a …

CRS responded to Oregon’s Clean Energy Plan questionnaire, emphasizing the need to prevent double-counting of RECs. CRS recommends requiring utilities to retain RECs for clean energy used in Oregon, ensuring that they aren’t sold elsewhere. This protects the integrity of Oregon’s emissions reductions and ensures customers truly receive clean energy as promised under the law.

CRS commented on CAISO’s proposed Extended Day-Ahead Market (EDAM), focusing on GHG accounting and RECs. CRS recommended better coordination with WREGIS to track which renewable energy is attributed to which states, avoiding double-counting. CRS also suggests clear disclaimers to clarify that REC ownership isn’t transferred in market transactions, protecting the integrity of renewable energy claims.

CRS supports the inclusion of RECs in Oregon’s Clean Energy Plans (CEPs) to ensure transparency and prevent double-counting of renewable energy. ​CRS recommends detailed reporting on REC usage and ownership to align with Oregon’s HB 2021 law and avoid legal, market, and environmental issues. ​ Proper REC accounting is crucial for meeting clean energy goals, …

CRS submitted comments to the Oregon Public Utility Commission regarding HB 2021 implementation, emphasizing the need to clarify how RECs should be handled to avoid double-counting and ensure compliance with GHG targets. ​CRS recommended prioritizing this issue and suggested an open process allowing experts and stakeholders to contribute without formal legal representation. ​

CRS urges the Oregon Public Utility Commission to require REC retirement for compliance with HB 2021 to prevent double-counting and ensure clean energy delivery to Oregon customers. ​ Without REC retirement, renewable energy claims may be misleading, voluntary markets could be undermined, and regional renewable energy growth may suffer. ​ CRS also recommends excluding voluntary …