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Summary of CRS Comments on Proposed Revisions to the FTC Green Guides

Summary of comments on the Federal Trade Commission (FTC)’s recently released proposed update to its Guides for the Use of Environmental Marketing Claims (“Green Guides”). CRS will be submitting comments, and we have developed a summary of the key points we will be making to the Commission. Overall, we are very supportive of the proposed …

Letter to Washington State Senate Environment, Water and Energy Committee on S.1506.1

CRS believes Washington State’s S.1506.1 could negatively impact the clean energy industry because if RECs are no longer used as a declared resource for electric utility fuel mix disclosures, generation owners in Washington whose null power is represented as renewable for utility fuel mix disclosures would become ineligible to sell their RECs into a Green-e …

Letter to Washington State Senate Environment, Water and Energy Committee on HB 1712

CRS believes Washington State’s HB 1712 could negatively impact the clean energy industry because as currently written the inclusion of null power in the definition of renewable resource and the ambiguous nature of the definition of null power constitutes a potential double claim of renewable energy attributes. Generation owners in Washington whose null power was …

Comments of the Center for Resource Solutions (“CRS”) to the Commodity Futures Trading Commission (“CFTC”) and Securities and Exchange Commission (“SEC”) on Notice of Proposed Rulemaking; Request for Comments on Further Definition of “Swap,” “Security-Based Swap,” e.t.c., (17 CFR Part 23, RIN 3038 AC96 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”) market for environmental commodities through our Green-e Energy and Green-e Climate certification and consumer-protection programs, and to provide comments on the Joint Notice of Proposed Rulemaking Request (“JNOPR”) for comments …

CRS Comments to Draft WindMade Standard

Comments to the draft standard as part of the WindMade public consultation process. We support the inclusion of a definition of “green credentials” and requiring a unique ID number; and we suggest adding additional information regarding the allowable claims and condoned uses of the label, keeping a clear distinction between renewable energy and carbon offsets …

Comments on Proposed 15-Day Modifications to the CA Cap-and-Trade Mechanisms

Center for Resource Solutions (CRS) submitted comments to the California Air Resources Board (ARB) on the proposed 15-day modifications to the California Cap on Greenhouse Gas (GHG) Emissions and Market-Based Compliance Mechanisms. The comments focused on the following topics: Accounting for Null Power Imports and Voluntary Renewable Electricity.

Comments Filed by the Center for Resource Solutions on Implementation of New Portfolio Content Categories for the Renewable Portfolio Standard Program

CRS respectfully offers these comments on issues nine and ten of the Administrative Law Judge’s Ruling Requesting Comments on the Implementation of the New Portfolio Content Categories for the RPS Program. In these comments, CRS seeks to augment the record by bringing to the Commission’s attention language in the RPS statute that requires renewable energy …

Comments on Second 15-Day Amendments – Voluntary Renewable Electricity Set Aside

A coalition letter supporting the California Air Resource Board’s (CARB) inclusion of a set aside for the voluntary renewable electricity (VRE) market. Comments regarding the following issues: eligibility of renewable energy generators by online date, clarification regarding the use of tracking systems, and how to “true up” allowances to account for oversubscription.