CRS responded to Oregon’s Clean Energy Plan questionnaire, emphasizing the need to prevent double-counting of RECs. CRS recommends requiring utilities to retain RECs for clean energy used in Oregon, ensuring that they aren’t sold elsewhere. This protects the integrity of Oregon’s emissions reductions and ensures customers truly receive clean energy as promised under the law.

CRS commented on CAISO’s proposed Extended Day-Ahead Market (EDAM), focusing on GHG accounting and RECs. CRS recommended better coordination with WREGIS to track which renewable energy is attributed to which states, avoiding double-counting. CRS also suggests clear disclaimers to clarify that REC ownership isn’t transferred in market transactions, protecting the integrity of renewable energy claims.

CRS supports the inclusion of RECs in Oregon’s Clean Energy Plans (CEPs) to ensure transparency and prevent double-counting of renewable energy. ​CRS recommends detailed reporting on REC usage and ownership to align with Oregon’s HB 2021 law and avoid legal, market, and environmental issues. ​ Proper REC accounting is crucial for meeting clean energy goals, …

CRS submitted comments to the Oregon Public Utility Commission regarding HB 2021 implementation, emphasizing the need to clarify how RECs should be handled to avoid double-counting and ensure compliance with GHG targets. ​CRS recommended prioritizing this issue and suggested an open process allowing experts and stakeholders to contribute without formal legal representation. ​

CRS urges the Oregon Public Utility Commission to require REC retirement for compliance with HB 2021 to prevent double-counting and ensure clean energy delivery to Oregon customers. ​ Without REC retirement, renewable energy claims may be misleading, voluntary markets could be undermined, and regional renewable energy growth may suffer. ​ CRS also recommends excluding voluntary …

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 …

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 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 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.

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 …