Comments on the WA Clean Fuels Program Electricity 2021 Notice of Proposed Rulemaking and Draft Rules

CRS provided feedback to the Washington State Department of Ecology on the March 15, 2022 draft of the Washington Clean Fuel Standard (WAC Chapter 173-424). Our comments primarily focused on proposed reporting and documentation requirements for renewable energy certificates (RECs) and proposed rules for calculating incremental credits, proposed requirements for RECs and use of offsite renewable electricity and carbon intensity, and proposed requirements for utility renewable electricity products.