CRS expresses support for several requirements proposed in the SNOPR, responds to DOE concerns, and responds to certain specific requests for comment. Specifically: RECs are required for any renewable electricity usage claim, Off‐site renewable electricity usage and low‐cost options should be available to federal agencies, concerns with federal agencies’ lack of control over off‐site renewable …
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Comments on the U.S. EPA’s Clean Power Plan, Section 111(d)
CRS comments on the June 2014 Proposed Rule Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (the Clean Power Plan “Proposed Rule”). The comments focus on integrating renewable energy (RE) and existing RE markets, instruments, and tracking systems into 111(d) compliance and state plans; accounting and potential double counting of emissions …
Guidelines for Quantifying the Carbon Emissions Benefits of Green-e Energy Certified Products
This document is intended as a guide to resources that can help participants advise their customers on defensible carbon claims and comply with Green-e marketing compliance rules.
Comments on Rulemaking to Consider Modifications to the Electricity Generation Source Disclosure Regulations and Pre-Rulemaking Draft Regulations to the Power Source Disclosure Program
CRS comments on the Power Source Disclosure (PSD) Program Pre-Rulemaking Draft Regulations, released by the California Energy Commission for public comment on May 14, 2015.
Comments on Version 2.0 of the Association for the Advancement of Sustainability in Higher Education’s (AASHE’s) Sustainability Tracking, Assessment & Rating System (STARS) Technical Manual
CRS comments strongly support the Sustainability Tracking, Assessment & Rating System (STARS), and particularly the inclusion of criteria and points for measuring and reducing GHG emissions; generating, using, and/or purchasing clean and renewable energy; sustainable purchasing, and referencing Green-e.
CRS Comments on 2015 update to National Green Building Standard, Home Innovation Research Labs
Comments on definitions, concepts in the National Green Building Standard.
Comments of CRS on SASB Public Exposure Draft Standards‐ Consumption I
CRS comments on the January 2015 Sustainability Accounting Standards Board (SASB) Exposure Draft Standards for Public Comment for Consumption I sectors, including Agricultural Products, Processed Foods, Non‐Alcoholic Beverages, Alcoholic Beverages, Household & Personal Care Products, and Meat, Poultry, and Dairy.
Navigating EPA’s Clean Power Plan for Compliance With Renewable Energy
In this paper, CRS and the Regulatory Assistance Project have collaborated to help readers to understand some of the ways in which states are using renewable energy today, and appreciate how existing renewable energy compliance practices provide well-established and suitable approaches for regulators to use as part of their efforts to demonstrate compliance under the …
Supporting State Compliance With the EPA Clean Power Plan
In this paper, CRS and the Regulatory Assistance Project have collaborated to describe how the existing functionality of the regional renewable energy tracking systems can be used by states to track renewable energy and support compliance with the EPA Clean Power Plan, as well as to identify enhancements that may be needed to support state …
Guidelines for Renewable Energy Claims: Guidance for Consumers and Electricity Providers
A description of how ownership of renewable energy attributes remains with the renewable energy certificate, and examples of claims issues between hosts, utilities, and owners.