Comments of the Center for Energy Efficiency and Renewable Technologies and the Center for Resource Solutions Regarding the Treatment of Renewable Energy within the Western Climate Initiative

These are the submitted comments from the Center for Energy Efficiency and Renewable Technologies (CEERT) and the Center for Resource Solutions (CRS)on the treatment of RECs and null power (power generated at a renewable source that is no longer bundled with its RECs) within the Western Climate Initiative. The comments detail our organizations’ several key objectives with regard to the treatment of RECs and null power. These objectives include: accurate accounting of emissions and emissions reductions; retention of incentives for the development of renewable electricity; avoidance of perverse incentives toward higher-emitting generation; and Consistent treatment of in-region and out-of-region generators.