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. …

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 …

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 …

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 …

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 …

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 from the Center for Resource Solutions on the U.S. Senate Committee on Energy and Natural Resources Clean Energy Standard (CES) White Paper.

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 …

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 …

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.