Comments in response to the recently published questions for stakeholders to address regarding the New Jersey Generic Solar Proceeding. The intent of these comments is to provide information on industry best practices in regard to the treatment of Renewable Energy Certificates (RECs) and consumer protection standards for solar energy marketing and consumption claims. CRS strongly …
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Comments on the July 28, 2017 Order Setting Reply Comments on Rule Making for Renewable Energy Percentage Verification (Iowa)
CRS comments in response to the July 28, 2017 Order Setting Reply Comments on Renewable Energy Percentage Verification. The intent of these comments is to inform the Iowa Utilities Board (IUB) of industry best practices for renewable energy accounting, especially in regard to the treatment of Renewable Energy Certificates (RECs). While CRS supports the intent …
Comments on the Illinois Power Agency (IPA) Long-Term Renewable Resources Procurement Plan
The intent of these comments is to provide information on industry best practices in regard to Section 7.6.3: Marketing Claims Related to the Ownership of RECs and Community Renewable Generation Subscriptions. Specifically, the decision to allow utilities to retire the associated Renewable Energy Certificates (RECs) for Renewable Portfolio Standard (RPS) compliance raises significant issues for …
Comments to the U.S. Environmental Protection Agency on Advanced Notice of Proposed Rulemaking on State Guidelines for Greenhouse Gas Emissions from Existing Sources
Comments on the benefits of incorporating a mechanism to protect voluntary and corporate renewable energy demand, purchasing, and emissions benefits under potential regulation of greenhouse gas emissions from electric utility generating units.
Comments to the California Energy Commission on the Revised Proposal for Implementation of AB 1110 and Power Source Disclosure
CRS issues a second set of comments regarding fundamental misunderstandings and conflations of important concepts that continue to persist and are again reflected in the Revised Proposal for implementation of AB 1110. Our first set of comments were submitted on July 28, 2017 for the June 27, 2017 Initial Proposal, which do not appear to …
Supplemental comments to the California Energy Commission on GHG Emissions Intensity Calculation Proposal for Implementation of AB 1110 and Power Source Disclosure
Supplemental comments in response to PG&E’s Supplemental Comments Regarding Greenhouse Gas (GHG) Methodology and Supplemental GHG Metric Presentation (Docketed August 23, 2017). CRS expresses a concern that if RECs are not required as a part of demonstrating an LSE’s share of GHG-free from renewables delivered in a given hour, there is a potential for double …
Comments to the California Energy Commission on the Initial Proposal for Implementation of AB 1110 and Power Source Disclosure
CRS is providing comments to the CEC to help illuminate fundamental misunderstandings of important concepts among Commission Staff, Air Resources Board (ARB) Staff, and other stakeholders. These comments include a section on Accuracy to try to address misunderstandings and conflations. Following that, we provide our comments on the Proposal, which are divided into Primary and …
Overview of Renewable Portfolio Standard Design Options from the U.S. Experience
This report highlights the main principles and options that inform Renewable Portfolio Standard (RPS) program design based on experiences in the United States. Applicable examples are highlighted throughout the report, and an overview of implications for China is included at the end of the report. This report is also available in Mandarin.
REC Questions and Answers
An overview of common questions about renewable energy certificates (RECs).
Tracking Environmental Attributes: A Discussion Paper
The differences in renewable energy certificate (REC) definitions, information, and tracking capability are problematic for a liquid market, can create confusion, or possibly create opportunities for fraud. This paper focuses on the question of how RECs are defined by different tracking systems, and examines options for harmonizing RECs among tracking systems.
