Comments Filed by the Center for Resource Solutions on Implementation of New Portfolio Content Categories for the Renewable Portfolio Standard Program

CRS respectfully offers these comments on issues nine and ten of the Administrative Law Judge’s Ruling Requesting Comments on the Implementation of the New Portfolio Content Categories for the RPS Program. In these comments, CRS seeks to augment the record by bringing to the Commission’s attention language in the RPS statute that requires renewable energy credits (“RECs”) to include “all renewable and environmental attributes associated with the production of electricity from the eligible renewable energy resource.” In particular, CRS requests that the Commission clarify the definition of RPS-eligible energy in issues nine and ten in order to remove any apparent inconsistency with section 399.12(h).