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 …

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.

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.

Voluntary Renewable Energy Set-Asides For Cap-And-Trade (Fact Sheet)

A companion piece to Corporate and Voluntary Renewable Energy in State Greenhouse Gas Policy: An Air Regulator’s Guide, this fact sheet details the options available to states as they consider adoption and implementation of cap-and-trade or similar carbon regulation programs, and the impacts of these programs on renewable energy development and the voluntary renewable energy …