In 2023, CRS highlighted a year of progress in advancing clean, sustainable energy through policy advocacy, education, and market certification. CRS strengthened renewable energy markets by ensuring the integrity of renewable energy certificates (RECs) and greenhouse gas (GHG) accounting. The Clean Energy Accounting Project (CEAP) developed guidance on renewable procurement for complex supply chains and …
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Background Report: GHG Allocation and RECs in Western Markets
This background report explores how new market frameworks for greenhouse gas (GHG) accounting and allocation impact renewable energy credits (RECs) in the Western U.S. These frameworks aim to meet state-specific emissions requirements but face challenges around double counting and REC tracking. Recommendations are provided to increase transparency and alignment between market frameworks and WREGIS for …
Response to the Proposed Decision Modifying Green Access Program Tariffs and Adopting a Community Renewable Energy Program
CRS believes the proposed decision modifying California’s Green Access Program Tariffs orders substantial negative changes to the existing Disadvantaged Communities Green Tariff program (DAC-GT). Specifically the proposals to eliminate the requirement to retire Renewable Energy Credits, abolish VREP reporting, and eliminate Green-e® certification, which will create a program that offers a lesser clean power product …
Comments on Implementation of Changes to Minnesota’s Renewable Energy Standard and Carbon Free Standard
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 …
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.