CRS’s comments focus on the implementation of changes to Minnesota’s Renewable Energy Standard and the newly created Carbon Free Standard under amendments to Minnesota Statute 216B.1691 adopted in 2023. CRS proposes use of a residual mix calculation as a more accurate method for determining the carbon-free characteristics of net electricity purchases by a utility, one …
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Comments on the Proposed Draft SPP Markets+ GHG Reporting Protocol
CRS suggests several edits to the draft reporting protocol, including clarifying terms and market boundaries, encouraging the use of third-party reporting protocols, standardizing null power generation accounting, and defining the use and limitations of entity average and null-power-adjusted entity average mixes.
Comments on Rhode Island Voluntary and Compliance Market (Docket 24-26-EL)
CRS comments pertain to the Rhode Island Public Utilities Commission Investigation into the current state of the voluntary and compliance renewable energy market in Rhode Island and the request for information regarding counting voluntary renewable energy certificates (RECs) towards the state’s Renewable Energy Standard (RES) compliance.
Comments on North Carolina HB 951 and Duke Customer Programs
CRS comments pertain to the effects of the implementation of HB 951 on voluntary renewable energy (VRE) generation in North Carolina and Duke’s Customer Programs.
Comments on Clean Energy Transition Act April 9 Notice and Draft Rules
CRS comments pertain to the use of “Non-Power Attribute” to comply with the greenhouse gas neutral standard, definition of “use” of electricity, and avoiding double-counting.
Comments to the California Air Resource Board on Low Carbon Fuels Standard
CRS comments pertain to updating the lookup table pathways for the Low Carbon Fuel Standard (LCFS) to using a utility-specific carbon intensity (CI) value of electricity.
Comments on Power Source Disclosure Pre-Rulemaking Draft Regulation for SB 1158
CRS comments pertain to replacing loss-adjusted load with retail sales, renewable energy certificate (REC) retirement for annual and hourly reporting, use of the term “avoided emissions,” and the emission factors assigned to unspecified power and hourly claimed renewable generation.
Comments to the California Air Resource Board on Low Carbon Fuels Standard Updates
CRS comments pertain to the definitions of environmental attributes and book-and-claim accounting, and book-and-claim accounting best practices for biomethane and hydrogen.
Making Voluntary Markets for Clean Electricity Work
In 2023 and 2024, CRS brought together a small group of market-leading corporate and federal clean electricity buyers, key non-governmental organizations, and other leading voices to discuss voluntary strategies to transform the clean electricity market. While the group had diverse perspectives on impactful clean electricity procurement and grid decarbonization pathways, several shared core principles and …
Clean Fuels in the Maritime Shipping Sector
The largest maritime shipping vessels consume a gallon of fuel every 15 feet. This prodigious consumption is one reason international shipping accounted for nearly 3% of global warming by 2018. The International Maritime Organization (IMO) is leading a global effort to reduce the carbon intensity of shipping by switching to low-carbon fuels and modernizing aging …