Statement by Chris Cooper on Behalf of CRS at MN PUC Oral Hearing on Compliance Reporting and Implementation of Minnesota’s 100% Carbon-Free Standard (CFS)

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 residual mix to exclude already claimed power, preserving the standard’s integrity and environmental impact.