CRS Comments on CARB’s Proposed Regulation for the 33% Renewable Energy Standard

  • Author: Matt McDonnell, Robin Quarrier
  • Date: July 16th, 2010| Comment | 8 Pages
  • This letter, addressed to Gary Collard at the California Air Resources Board in reference to the draft 33% RPS, details CRS’s position that a REC is a property right, that CARB’s recognition of these property rights inherent in RECs would not increase CARB’s risk of a regulatory taking under the Fifth Amendment, and that declaring that RECs do not constitute property rights could irreparably harm existing REC markets.

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