Supplemental comments to the California Energy Commission on GHG Emissions Intensity Calculation Proposal for Implementation of AB 1110 and Power Source Disclosure

Supplemental comments in response to PG&E’s Supplemental Comments Regarding Greenhouse Gas (GHG) Methodology and Supplemental GHG Metric Presentation (Docketed August 23, 2017). CRS expresses a concern that if RECs are not required as a part of demonstrating an LSE’s share of GHG-free from renewables delivered in a given hour, there is a potential for double counting as both the physical power and REC can be used to report delivery/consumption of zero-emissions power in different programs.