CRS Comments on CARB’s Proposed Regulation for the 33% Renewable Energy Standard

This letter, addressed to Gary Collard at the California Air Resources Board in reference to the draft 33% RPS, details CRS’s position that a REC is a property right, that CARB’s recognition of these property rights inherent in RECs would not increase CARB’s risk of a regulatory taking under the Fifth Amendment, and that declaring …

2009 Green-e Verification Report

The report highlights Green-e Certified renewable energy and carbon offset sales in 2009, as well as organizations that participated in Green-e Marketplace to demonstrate their commitment to renewable energy. The report shows a 43% increase in total Green-e Energy sales volume over the previous year, with over 18 Million MWh purchased by over 545,000 residential …

Best Practices in Public Claims for Green Power Purchases and Sales

Growth in the largely unregulated voluntary renewable energy market has highlighted the need for clear guidelines on what constitutes legitimate environmental claims. In order to evaluate green electricity claims, one must first determine what constitutes a claim. Some claims are explicit and easy to identify. Others, however, can be simply implied or even unintentional. This …

Letter to CARB Chairman Nichols and Board after passage of AB32, offering Support for the Voluntary Renewable Energy Set-Aside but concerns about the WCI recommendation that RECs have no role in cap-and-trade accounting

CRS wrote a letter to California Air Resources Board (CARB) Chairwoman Nichols and the Board expressing support for the inclusion of a voluntary renewable energy set aside in AB 32, and our remaining concerns about the Western Climate Initiative recommendation that renewable energy certificates (RECs) have no role in mandatory GHG reporting and compliance protocols. …

Comments of Center for Resource Solutions (CRS) to the Commodity Futures Trading Commission (CFTC) Request for Information (RFI) for Public Input for the Study Regarding the Oversight of Existing and Prospective Carbon Markets pursuant to Section 750 of the Dodd‐Frank Wall Street Reform and Consumer Protection Act (Dodd‐Frank Act)

The intent of these comments is to introduce CRS as an interested party; to describe the services that we provide for the voluntary over‐the‐counter (OTC) carbon offset market through our Green‐e Climate certification and consumer‐protection program; to briefly explain our position that the current structure and existing oversight mechanisms in the voluntary carbon offset market …

CRS Comments on Proposed Revisions to the FTC Green Guides

Comments submitted on the Federal Trade Commission (FTC)’s proposed update to its Guides for the Use of Environmental Marketing Claims (“Green Guides”). Overall, we are very supportive of the proposed update and find that it reinforces many of the consumer-protection practices required by Green-e certification, but there are a few areas where we suggest further …