Comments on the September 6, 2018 draft of the WA Department of Commerce’s proposed fuel mix legislation for 2019, and additional comments following the October 1, 2018 revised draft. Specifically, additional feedback on treatment of renewable energy certificates (RECs) that have been unbundled from the energy and used for compliance with Washington’s Renewable Portfolio Standard …
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Comments on CA EPA’s Independent Emissions Market Advisory Committee (IEMAC) Meeting Materials and Draft Subcommittee Reports
Comments focused on potential double counting and leakage due to accounting for the emissions associated with imported electricity under the Mandatory Reporting Regulation (MRR). Comments pertain to both the Subcommittee Report on Overlapping Policies and the Report on Emissions Leakage.
Impactful Corporate Renewable Energy Procurement in States With Carbon Policies
The impact of renewable energy purchases by corporations may be reduced in states with cap-and-trade and other greenhouse gas (GHG) regulations covering the power sector. Commercial buyers should ensure that their projects are reducing emissions in states with cap-and-trade and other GHG policies.
Advocacy Positions to Support Corporate Renewable Energy Procurement Under Greenhouse Gas Regulation in the Power Sector
Corporate and other voluntary green power procurement strategies can offer additional greenhouse gas (GHG) benefits on top of regulations like cap-and-trade—provided the right policy and accounting mechanisms are in place. This document highlights the advocacy positions CRS developed to support GHG regulations in the power sector.
How Markets Can Move the Needle on Climate Change (IETA Insights No. 3)
CRS contributed to the International Emissions Trading Association (IETA)’s IETA Insights: Greenhouse Gas Market Report, published in September 2018. The article, by CRS’s Todd Jones, is a look at the intersection of voluntary renewable energy purchasing by corporates with emissions markets, drawing from experience in the U.S.
Comments in Response to the July 6th Questions for Stakeholder Comment on the New Jersey Community Solar Energy Pilot Program (Docket No. QO18060646)
These comments to the State of New Jersey Board of Public Utilities provides information on industry best practices for consumer protection and the treatment of Renewable Energy Certificates (RECs) associated with community solar programs. These comments echo much of what CRS stated in its previous comments on the BPU Generic Solar Proceeding that were submitted …
Guide to Purchasing Green Power: Renewable Electricity, Renewable Energy Certificates, and On-Site Renewable Generation
The Guide provides current and potential buyers of green power with information about green power purchasing. It covers the green power procurement process, different green power supply options, benefits of green power purchasing, as well as information on how to capture the greatest benefit from your purchase.
Comments on Virginia’s January 8, 2018 Proposed Regulation 9VAC5-140, Regulation for Emissions Trading Programs
Comments on the benefits of incorporating a renewable energy set-aside mechanism into Virginia’s proposed emissions trading program that would protect voluntary and corporate renewable energy demand, purchasing, and emissions benefits in VA as the state looks to join the Regional Greenhouse Gas Initiative (RGGI).
Comments Following the September 7 Workshop on the Iowa Utilities Board (IUB) Renewable Energy Percentage Verification
Additional comments in response to the September 7 Workshop on Renewable Energy Percentage Verification. The intent of these comments is primarily to reiterate our previous written and oral comments. CRS supports the use of verified Renewable Energy Certificates (RECs) to account for the delivery and consumption of renewable energy, regardless of whether the RECs were …
Comments following the November 6, 2017 Public Workshop on the California Air Resources Board Preliminary Draft of Potential Regulatory Amendments to the Low Carbon Fuel Standard (LCFS)
Comments in response to the potential regulatory amendments to the Low Carbon Fuel Standard. The intent of these comments is to provide information on industry best practices in regard to the treatment of Renewable Energy Certificates (RECs) in the fuel pathway involving the use of renewable energy to charge electric vehicles, specifically the use of …