Comments on Supplemental Notice of Proposed Rulemaking (SNOPR), Fossil Fuel‐Generated Energy Consumption Reduction for New Federal Buildings and Major Renovations of Federal Buildings, Docket No. EERE-2010-BT-STD-0031

  • Author: Todd Jones
  • Date: December 15th, 2014| Comment | 7 Pages
  • CRS expresses support for several requirements proposed in the SNOPR, responds to DOE concerns, and responds to certain specific requests for comment. Specifically: RECs are required for any renewable electricity usage claim, Off‐site renewable electricity usage and low‐cost options should be available to federal agencies, concerns with federal agencies’ lack of control over off‐site renewable energy and generation at facilities generating unbundled RECs, concerns with the additionality of off‐site renewable energy and generation of unbundled RECs, concerns on the impact of purchasing off‐site renewable energy and unbundled RECs with respect to reductions in fossil fuel generation, and concerns with tracking and accounting of RECs.

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