CRS submitted comments to the Oregon Public Utility Commission regarding RECs and their role in meeting Oregon’s clean energy goals under HB 2021. CRS emphasized the importance of preventing “double counting,” where the same renewable energy is claimed by multiple parties or programs. RECs should be retired (not sold) when used to meet HB 2021 …
Archives
CRS Comment to the Oregon Public Utility Commission in Response to November 17, 2023 Oral Argument – OPUC Docket UM 2273
CRS responded to oral arguments in Oregon PUC Docket UM 2273 regarding HB 2021, which sets GHG reduction targets for electricity. CRS argues that Oregon must choose between a load-based or generation-based accounting method for GHG emissions. CRS strongly supports a load-based approach requiring the use of RECs to prevent double-counting of emissions reductions. Requiring …
CRS Public Testimony on Oregon Senate Bill 1102
CRS urges Oregon lawmakers to strengthen Senate Bill 1102 by requiring electric utilities to retire RECs when reporting clean electricity use under HB 2021. Without this rule, the same clean energy could be claimed by multiple states or programs (double counting).
CRS Proposal to the California Independent System Operator (CAISO) for Reporting to WREGIS and Reporting of Null Power under an Accounting & Reporting Approach
CRS proposed updates to how the California Independent System Operator (CAISO) reports renewable electricity generation and emissions data to WREGIS (the Western Renewable Energy Generation Information System). The goal is to improve accuracy and transparency in how renewable energy and related emissions are tracked and reported, especially when Renewable Energy Certificates (RECs) are involved.
Hourly Utility Product Design Background Report
Electricity providers are exploring product options to meet increasing demand for “hourly matched” carbon-free energy (CFE), in which CFE generation is matched to customer load in each hour. This background report summarizes current hourly product offerings; previous initiatives to facilitate or provide guidance, tools, or standards related to hourly CFE procurement; outcomes from previous technical …
Indicators of Clean Electricity Procurement That Drives New Supply
Voluntary clean electricity procurement plays a critical role in accelerating the energy transition—but a lack of consensus on what kind of individual purchases directly drive or have an increased indirect impact on new clean energy and maintaining existing clean energy has led to market fragmentation and uncertainty for buyers and investors. This CEAP initiative produced …
Reply to Comments on Compliance Reporting and Verification Under MN Statute 216b.1691, Renewable Energy Standard (RES) and Carbon Free Standard (CFS)
CRS supports comments submitted by other stakeholders regarding compliance reporting and verification under Minnesota Statute 216B.1691, Minnesota’s Renewable Energy Standard (RES) and the newly created Carbon Free Standard (CFS). These comments pertain to requiring the use of renewable energy certificates (RECs) and alternative energy certificates (AECs), as well as using a residual mix to represent …
Market-Based Accounting for Clean Fuels
Fuel producers and their customers concerned with managing the greenhouse gas (GHG) emissions from using fuels are pursuing ways to replace conventional fossil fuels with biologically derived and lower-emitting alternative fuels. To help spur investment in the production of these nascent fuels, these stakeholders are using markets for contractual instruments like certificates representing the environmental …
Transparency and Accurate Accounting in the Electricity Sector: The Importance of All-Generation Tracking and Residual Mixes for State Programs
All-generation electricity certificate tracking and residual mixes are two related and essential tools that can help states ensure transparency and accuracy in their electricity programs and in retail electricity markets more generally. These mechanisms help establish an accurate picture of electricity generation and consumption, prevent double counting, and support state renewable energy and climate policies.
State Clean Energy Standards: Designing Programs for Effective Emission Reductions
State Clean Energy Standards (CESs), which set carbon-free energy or greenhouse gas (GHG) emissions goals for electric utilities, represent a new approach over traditional renewable portfolio standard (RPS) programs—one that focuses on renewable energy instead of emissions. This policy brief, aimed at state public utility commissioners and their staffs, discusses the critical importance of renewable …