This letter urges the Commission to reject Staff’s proposal of “Track and Monitor” because of the impact on Arizona renewable energy generators and customers, and because it violates the requirements of the REST while raising issues with double counting.

CRS submitted comments to the Association of Climate Change Officers (ACCO) in response to their call for input on their Core Competencies for Climate Change Officers and Professionals.

CRS commented on the proposed revisions to the Energy Information Administration’s (EIA) data collection practices, reiterating the need for continued data collection and the continued relevance of the data, as the EIA data collected on utility green electricity programs and renewable electricity is one of the few sources of hard information that can be used …

CRS submitted comments to the California Air Resources Board (CARB) regarding proposed changes to the California cap-and-trade program, as contained in a July 2013 Discussion Draft and presented at the July 18, 2012 Public Workshop.

On April 9, 2012 the Green-e Governance Board approved changes to the Green-e Energy National Standard that modified the then-existing language defining the eligibility of biomass as a renewable fuel source under the Standard. The new language clarified the circumstances under which organic matter can be used for electricity generation and considered eligible for inclusion …

CRS submitted comments on the Draft Standards for the Technology & Communication Sector that recommended that renewable energy certificates be retained for all claims to the use of renewable energy. CRS also supports the inclusion of emissions from purchased electricity use (scope 2 emissions) to the proposed disclosure language and guidance in all applicable SASB …

In 2010, reports of boiler rooms operating in carbon markets and selling emissions reduction credits (carbon offsets) as investments began to emerge out of the U.K. In 2013, CRS began work examining what investor protections are needed in carbon markets, particularly in voluntary OTC markets, and what practices market participants could adopt to regulate carbon …

This document is intended to articulate Green-e Energy’s standard approach to resolving questions and disputes regarding the eligibility of RECs for use in Green-e Energy certified transactions or products, when multiple parties have made statements related to the environmental attributes of the REC or underlying electricity.

Existing renewable energy certificate (REC) tracking systems hold promise as an enabler of 111(d) compliance with renewable resources such as solar and wind generation. REC tracking systems, together with state policies designed to increase the production and use of renewable electricity, will provide one key to helping states reduce the carbon intensity of their power …

CRS suggests changes to the proposed revision that will reduce the potential for double counting, including rejecting Track and Monitor and Track and Record, purchasing least cost RECs or kWh, creation of a maximum conventional energy requirement, the option of mandatory upfront incentives, and others