This report by Eric O’Shaughnessy, Ph.D. is the result of a series of interviews in 2023 of renewable energy market stakeholders and follow-up interviews in 2024 with four large renewable energy developers about the financial impact of renewable energy certificates (RECs) on project development. The interviews highlighted that common financial models underestimate how RECs influence …

This document reproduces Center for Resource Solutions’ (CRS’s) responses to the Greenhouse Gas Protocol’s first Scope 2 Public Consultation Survey in January 2026. The survey sought stakeholder input on proposed updates and clarifications to the Scope 2 Guidance (2015), which addresses the accounting and reporting of greenhouse gas (GHG) emissions from purchased or acquired electricity, …

This document reproduces Center for Resource Solutions’ (CRS’s) responses to the Greenhouse Gas Protocol’s Electricity-Sector Consequential Methods Public Consultation in January 2026. The survey sought feedback on consequential accounting methods for estimating avoided emissions from electricity-sector actions, which will feed into work in the Actions and Market Instruments (AMI) workstream. The responses presented here reflect …

The Advanced and Indirect Mitigation (AIM) Platform, convened by C2ES, Green Market Activation (GMA), and Gold Standard, has put out its Intervention Quality, Accounting, and Reporting (QAR) Standard for public consultation. CRS’s comments center around four key factors: Some requirements do not align with how certain market-based instruments (e.g. EACs) operate in practice. Key terms …

CRS welcomes the AIM Electricity Annex and supports its goal of providing electricity-specific guidance for Scope 3 interventions, while recommending targeted revisions to improve clarity, consistency, and guardrails. The comments ask AIM to strengthen electricity-sector direction on additionality; clearly define key regional terms such as “market boundary” and “electricity sourcing or use region” in line …

This guidance summarizes CRS’s key recommendations for organizations commenting on the GHG Protocol’s proposed scope 2 updates. It highlights areas where greater transparency and data quality are needed—such as clarifying SSS treatment and strengthening residual mix rules—while outlining concerns with proposals that would limit participation in voluntary renewable energy markets, including physical deliverability and hourly …

CRS recommends several improvements to California’s SB 253 Draft Reporting Template for greenhouse gas emissions in the submitted comments. The comments call for clearer definitions and structure, including explicit totals for both market-based and location-based Scope 2 emissions, as well as a dedicated row for electricity totals within Scope 2. Clarification is requested regarding the …

CRS comments focus on ensuring Washington’s Cap-and-Invest program accurately and fully reflects voluntary renewable electricity purchases by replacing the insufficient fixed 0.33% reserve with a demand-responsive mechanism and implementing automatic allowance retirements based on independent, auditable data sources.

CRS comments to WREGIS on its transition to a stand-alone nonprofit, emphasizing balanced governance, transparency, and key software improvements to support reliable renewable energy tracking.

CRS comments to the California ISO on its draft final proposal for the development of an Accounting and Reporting Approach—a GHG allocation framework that will produce data that will allow LSEs in the market to see and understand the emissions intensity of their portfolios, along with a residual emissions rate, and public emissions information.