Comments on the Rulemaking Advisory Committee #3 Discussion Paper for the Oct. 22, 2020 Advisory Committee Meeting for the OR Clean Fuels Program Electricity 2021 Rulemaking

Comments on the Rulemaking Advisory Committee #3 Discussion Paper (“Third Discussion Paper”) for the October 22, 2020 Rulemaking Advisory Committee (RAC) Meeting #3 (“October 22 Meeting”) as a part of the Oregon Clean Fuels Program (CFP) Electricity 2021 Rulemaking. Comments pertain mostly to the proposed requirement for Green-e® certification of RECs used for the CFP. We provide a brief evaluation of potential eligible REC supply under DEQ’s proposal. We also make a recommendation regarding the use of RECs associated with generation that is imported to California.