Comments following the November 6, 2017 Public Workshop on the California Air Resources Board Preliminary Draft of Potential Regulatory Amendments to the Low Carbon Fuel Standard (LCFS)

Comments in response to the potential regulatory amendments to the Low Carbon Fuel Standard. The intent of these comments is to provide information on industry best practices in regard to the treatment of Renewable Energy Certificates (RECs) in the fuel pathway involving the use of renewable energy to charge electric vehicles, specifically the use of …

Comments in Response to the November 27th Questions for Stakeholder Comment on the New Jersey Board of Public Utilities (BPU) Generic Solar Proceeding

Comments in response to the recently published questions for stakeholders to address regarding the New Jersey Generic Solar Proceeding. The intent of these comments is to provide information on industry best practices in regard to the treatment of Renewable Energy Certificates (RECs) and consumer protection standards for solar energy marketing and consumption claims. CRS strongly …

Comments on the Illinois Power Agency (IPA) Long-Term Renewable Resources Procurement Plan

The intent of these comments is to provide information on industry best practices in regard to Section 7.6.3: Marketing Claims Related to the Ownership of RECs and Community Renewable Generation Subscriptions. Specifically, the decision to allow utilities to retire the associated Renewable Energy Certificates (RECs) for Renewable Portfolio Standard (RPS) compliance raises significant issues for …

Supplemental comments to the California Energy Commission on GHG Emissions Intensity Calculation Proposal for Implementation of AB 1110 and Power Source Disclosure

Supplemental comments in response to PG&E’s Supplemental Comments Regarding Greenhouse Gas (GHG) Methodology and Supplemental GHG Metric Presentation (Docketed August 23, 2017). CRS expresses a concern that if RECs are not required as a part of demonstrating an LSE’s share of GHG-free from renewables delivered in a given hour, there is a potential for double …

Comments to the California Energy Commission on the Initial Proposal for Implementation of AB 1110 and Power Source Disclosure

CRS is providing comments to the CEC to help illuminate fundamental misunderstandings of important concepts among Commission Staff, Air Resources Board (ARB) Staff, and other stakeholders. These comments include a section on Accuracy to try to address misunderstandings and conflations. Following that, we provide our comments on the Proposal, which are divided into Primary and …