CRS’s comments on the ISSB’s March 2022 Exposure Draft IFRS S2 Climate-related Disclosures pertain to the transition plans and carbon offsets and cross-industry metric categories and greenhouse gas emissions. CRS’ comments emphasize the importance of not conflating carbon offsets and renewable energy certificates (RECs), disclosure specifically related to voluntary renewable energy procurement, information about voluntary …
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Comments on the California Energy Commission (CEC) Clean Hydrogen Program under AB209 (Docket 22-ERDD-03)
CRS’s comments include general support for the CEC’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen production and use claims that meet the requirements of AB 209.
Comments in response to the Internal Revenue Service (IRS) request for comments on credits for clean hydrogen and clean fuel production (Notice 2022-58)
CRS’s comments in responses to questions in the Stakeholder Feedback section of the Draft Guidance include general support for DOE’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen …
Comments in NC in response to the Verified Petition for Approval of Carbon Plan filed in docket NO. E-100, SUB 179 on behalf of Duke Energy Progress, LLC and Duke Energy Carolinas, LLC
CRS’s comments pertain to the effects of the implementation of HB 951 on voluntary renewable energy (VRE) generation in North Carolina, considerations for electricity imports, reporting requirements, offset requirements, and the economic, environmental, and equity benefits of VRE markets.
Comments on the U.S. Department of Energy (DOE) Clean Hydrogen Production Standard (CHPS) Draft Guidance
CRS’s comments in responses to questions in the Stakeholder Feedback section of the Draft Guidance include general support for DOE’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen …
2022 Green-e® Verification Report (2021 Data)
The 2022 Green-e® Verification Report (2021 Data) is an annual, year-end report that aggregates reporting data from participants in the three Green-e® programs—Green-e® Climate, Green-e® Energy, and Green-e® Marketplace. The 2022 report, which was compiled from data gathered during the 2021 reporting year, highlighted significant market trends, including: 110 million retail megawatt-hours (MWh) reported from Green-e® …
Guide to Electricity Sector Greenhouse Gas Emissions Totals
This guide defines different GHG emissions totals for electricity generation that can be used by electricity suppliers and consumers to set goals, measure progress, and make claims, and by policymakers and regulators to design reporting and compliance programs.
Comments to the U.S. Securities and Exchange Commission (SEC) on Proposed Climate-Related Disclosures for Investors
CRS’s comments include general support for required climate-related disclosures and detailed recommendations and background related to renewable energy certificates (RECs) and Scope 2 emissions accounting.
Comments on the WA Clean Fuels Program Electricity 2021 Notice of Proposed Rulemaking and Draft Rules
CRS provided feedback to the Washington State Department of Ecology on the March 15, 2022 draft of the Washington Clean Fuel Standard (WAC Chapter 173-424). Our comments primarily focused on proposed reporting and documentation requirements for renewable energy certificates (RECs) and proposed rules for calculating incremental credits, proposed requirements for RECs and use of offsite …
Supplemental Comments to the Washington Utilities and Transportation Commission on Draft Rules for Implementation of the Clean Energy Transformation Act (CETA)
CRS submitted comments under Docket UE-210183 in response to a December 6, 2021 Joint Rulemaking Workshop on “use” and clarifying written comments submitted on November 12, 2021 and December 6, 2021.