CRS Comment to the Oregon Public Utility Commission on OPUC Staff’s Straw Proposals on Analytical Improvements – OPUC Docket UM 2225

CRS supports the inclusion of RECs in Oregon’s Clean Energy Plans (CEPs) to ensure transparency and prevent double-counting of renewable energy. ​CRS recommends detailed reporting on REC usage and ownership to align with Oregon’s HB 2021 law and avoid legal, market, and environmental issues. ​ Proper REC accounting is crucial for meeting clean energy goals, maintaining program integrity, and ensuring consistency with similar policies in other states. ​