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 Other Comments to highlight the three most important changes that we feel must be made to the Proposal in order to prevent market disruption, avoid divergence from best practice and federal guidance, and ensure California businesses and other customers receive accurate disclosure and are not denied benefits or put at a disadvantage in terms of taking action to reduce emissions.

Finally, we provide our preferred general approach to power source and emissions disclosure, including key requirements and an example power content label (PCL).