CRS submitted comments as part of the informal rulemaking process for the Climate Commitment Act Program, Chapters 173-446 WAC, focused on implementation of the voluntary renewable reserve account and compliance obligations for certain renewable energy imports.
Archives
Comment to the US Environmental Protection Agency on the Renewable Fuel Standard (RFS) Program Standards for 2023–2025 and Other Changes
CRS submitted comments on proposed regulatory changes to the RFS program focusing on new regulations governing the generation of Renewable Identification Numbers for electricity made from renewable biomass that is used for transportation fuel (eRINs).
Comments in Response to the Proposed Rule on Federal Acquisition Regulation (FAR): Disclosure of GHG Emissions and Climate-Related Financial Risk (Far Case 2021-015)
CRS’s comments pertain to the use of a market-based Scope 2 total for GHG accounting, the use of market-based instruments in Scopes 1 and 3, the proposed exclusive use of the Greenhouse Gas Protocol (GHGP) standard, and verification of GHG inventories.
Comments on the International Sustainability Standards Board’s (ISSB) March 2022 Exposure Draft IFRS S2 Climate-related Disclosures
CRS’s comments on the ISSB’s March 2022 Exposure Draft IFRS S2 Climate-related Disclosures pertain to the transition plans and carbon offsets and cross-industry metric categories and greenhouse gas emissions. CRS’ comments emphasize the importance of not conflating carbon offsets and renewable energy certificates (RECs), disclosure specifically related to voluntary renewable energy procurement, information about voluntary …
Comments on the California Energy Commission (CEC) Clean Hydrogen Program under AB209 (Docket 22-ERDD-03)
CRS’s comments include general support for the CEC’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen production and use claims that meet the requirements of AB 209.
Comments in response to the Internal Revenue Service (IRS) request for comments on credits for clean hydrogen and clean fuel production (Notice 2022-58)
CRS’s comments in responses to questions in the Stakeholder Feedback section of the Draft Guidance include general support for DOE’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen …
Comments in NC in response to the Verified Petition for Approval of Carbon Plan filed in docket NO. E-100, SUB 179 on behalf of Duke Energy Progress, LLC and Duke Energy Carolinas, LLC
CRS’s comments pertain to the effects of the implementation of HB 951 on voluntary renewable energy (VRE) generation in North Carolina, considerations for electricity imports, reporting requirements, offset requirements, and the economic, environmental, and equity benefits of VRE markets.
Comments on the U.S. Department of Energy (DOE) Clean Hydrogen Production Standard (CHPS) Draft Guidance
CRS’s comments in responses to questions in the Stakeholder Feedback section of the Draft Guidance include general support for DOE’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen …
2022 Green-e® Verification Report (2021 Data)
The 2022 Green-e® Verification Report (2021 Data) is an annual, year-end report that aggregates reporting data from participants in the three Green-e® programs—Green-e® Climate, Green-e® Energy, and Green-e® Marketplace. The 2022 report, which was compiled from data gathered during the 2021 reporting year, highlighted significant market trends, including: 110 million retail megawatt-hours (MWh) reported from Green-e® …
Guide to Electricity Sector Greenhouse Gas Emissions Totals
This guide defines different GHG emissions totals for electricity generation that can be used by electricity suppliers and consumers to set goals, measure progress, and make claims, and by policymakers and regulators to design reporting and compliance programs.