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.

CRS provided input on the implementation of SB 253 and SB 261. CRS emphasized the importance of ensuring that market-based emissions accounting, particularly for Scope 2 emissions, is properly integrated into the regulations, and that reporting aligns with widely used GHG accounting standards while addressing California’s specific needs.

CRS strongly opposes the EPA’s plan to repeal greenhouse gas (GHG) standards for power plants, arguing it harms public health, worsens climate change, and undermines clean energy progress. CRS highlights EPA data showing the rules prevent thousands of health issues and save $120 billion in health costs. Repealing them would increase emissions, hurt renewable energy …

This letter registers whether CRS supports, opposes, or takes no position on 36 different decision options commissioners of the MN PUC will take up during its July 17 Agenda Meeting. CRS strongly supports procuring and retiring RECs and other Energy Attribute Certificates to demonstrate compliance with the CFS, and strongly opposes applying a grid average …