Comments on the July 28, 2017 Order Setting Reply Comments on Rule Making for Renewable Energy Percentage Verification (Iowa)

CRS comments in response to the July 28, 2017 Order Setting Reply Comments on Renewable Energy Percentage Verification. The intent of these comments is to inform the Iowa Utilities Board (IUB) of industry best practices for renewable energy accounting, especially in regard to the treatment of Renewable Energy Certificates (RECs). While CRS supports the intent of this Rule Making and agrees that providing customers with the ability to make verified renewable energy claims will support demand for green products in Iowa, we are concerned that the treatment of RECs may undermine the legitimacy and accuracy of this verification process.