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.

Comments on LEED 2012 Rating System Drafts

General Comments in support of the LEED 2012 Rating System Drafts, including the inclusion of criteria and points for green power and carbon offset purchasing in the LEED Standards, and LEED’s citation and reference to the Green-e Standards for renewable energy (Green-e Energy) and carbon offsets (Green-e Climate). Also suggested changes to help bolster and …

Opening Comments Filed by the Center for Resource Solutions on Decision Implementing Portfolio Content Catagories for the Renewables Portfolio Standard Program

In these comments, CRS recommends removal or clarification of the tenets proposed on page 14 of the Administrative Law Judge’s Proposed Decision Implementing Portfolio Content Categories (“Proposed Decision”) for the Renewables Portfolio Standard Program (“RPS”) pursuant to Pub. Util. Code §399.16 (2011), “What you buy is what you have.” and “What you have is what …