Comments on Implementation of Changes to Minnesota’s Renewable Energy Standard and Carbon Free Standard

CRS’s comments focus on the implementation of changes to Minnesota’s Renewable Energy Standard and the newly created Carbon Free Standard under amendments to Minnesota Statute 216B.1691 adopted in 2023. CRS proposes use of a residual mix calculation as a more accurate method for determining the carbon-free characteristics of net electricity purchases by a utility, one which better achieves the intent of the legislature in adopting the new CFE standard. CRS is also concerned about applying a systemwide annual average fuel mix to ascertain the portion of a utility’s net purchases from the RTO, which it may characterize as carbon-free for purposes of complying with the CFE standard.