CRS comments pertain specifically to reinstating the allocation of allowances to the Voluntary Renewable Electricity Program (VREP) and the Renewable Energy Certificate (REC) Reporting Requirement for Specified Source Imports.
Archives
Residual Mix Applications and Existing Data
This document, released by CRS’s Clean Energy Accounting Project (CEAP), is intended to provide background on how residual mixes (electricity delivered as part of system mix and untracked or unclaimed energy) and associated emissions should be defined and calculated in the U.S. for different uses. Residual mix calculations are often used for greenhouse gas emissions …
Comments to DOE’s Office of Clean Energy’s DE-NOI-0202301 (Clean Hydrogen Hubs)
CRS’s comments pertain to DOE’s potential demand-side support mechanisms for clean hydrogen hubs (H2Hubs). Key recommendations include ensuring support for both compliance and voluntary market demand and designing an eligibility-based selection process that considers the amount of renewable resources used to produce hydrogen the carbon intensity of particular products as well as social impact and …
Comments to the EPA on Clean Air Act (CAA) Section 111 Proposed Rule
CRS proposes that Section 111 of the Environmental Protection Agency’s Clean Air Act require retirement of energy attribute certificates (EACs) to demonstrate use of low-GHG electrolytic hydrogen and that renewable fuel certificates be obtained and retired for low-GHG hydrogen produced by steam methane reforming with biomethane or renewable natural gas to avoid double counting. Low-GHG …
Scope 3 GHG Accounting for Upstream Clean Electricity Use
In recent years, companies have begun working to reduce electricity-related greenhouse gas (GHG) emissions in their upstream supply chains and support supply chain practices that advance clean energy worldwide. However, companies implementing these actions struggle to reflect the carbon free attributes of supplier clean electricity use in their scope 3 footprints. This Clean Energy Accounting Project …
Guidance for Supplier Clean Electricity Procurement
Companies working to increase clean electricity use in their upstream supply chains have lacked guidance on how to design clean electricity procurement programs with comparable criteria and metrics that meet their unique needs while supporting global supplier action. This Clean Energy Accounting Project (CEAP) Guidance for Supplier Clean Electricity Procurement (the guidance) was designed through …
CRS NewSolutions (Summer 2023)
In This Issue: Policy and Advocacy • Voluntary Market Impact • CEAP Updates • Green-e Program Updates • Renewable Energy Markets Conferences • On the Road • Recently Published • New Staff
Readiness for Hourly: U.S. Renewable Energy Tracking Systems
This report provides an overview of the current readiness of established U.S. renewable energy certificate (REC) tracking systems to track on an hourly basis, based on interviews with the system operators. Topics include current capabilities, goals, challenges for implementation, and estimated timeframes. This report is intended to be a resource for stakeholders interested in learning …
Responses to Greenhouse Gas Protocol’s Corporate Standards and Guidance Update Surveys
CRS responded to three surveys and submitted two proposals addressing potential changes to the Greenhouse Gas (GHG) Protocol’s Corporate GHG emissions and accounting standards guidance. 1. Corporate Accounting and Reporting Survey Addresses identifying the primary goal of the standard, favoring the most precise data, and defining the emissions reductions claims enabled by the standard. Download …
Comments to the U.S. Federal Trade Commission (FTC) on Regulatory Review and Request for Public Comment on the Green Guides
CRS comments are focused on the Renewable Energy Claims (§ 260.15), Carbon Offsets (§ 260.5), and Certifications and Seals of Approval (§ 260.6) sections of the Guides, as well as claims not currently covered by the Guides.