CRS Comment to the Oregon Public Utility Commission in Response to November 17, 2023 Oral Argument – OPUC Docket UM 2273

CRS responded to oral arguments in Oregon PUC Docket UM 2273 regarding HB 2021, which sets GHG reduction targets for electricity. CRS argues that Oregon must choose between a load-based or generation-based accounting method for GHG emissions. CRS strongly supports a load-based approach requiring the use of RECs to prevent double-counting of emissions reductions. Requiring RECs wouldn’t conflict with other state programs (like California’s and Washington’s) and would enhance consistency across the region. Not requiring RECs would risk undermining renewable energy markets.