CRS provided general feedback on the Request for Information regarding the Retail Supply of Carbon Pollution-Free Electricity (CFE) to inform the United States Government’s (USG’s) procurement of CFE to meet the objectives of Executive Order 14057 focused on the availability of Energy Attribute Certificates and best practices for claiming standard delivery CFE.

CRS’s comments pertain to a utility-specific carbon intensity (CI) value of electricity and book-and-claim accounting for biomethane and hydrogen.

The UNECE Portal on Standards for the SDGs features a CRS case study of Bank of America’s purchase of renewable energy certificates (RECs) that were certified by Green-e® Energy. In 2019, Bank of America purchased enough Green-e® certified RECs to match 100% of its North American operations, including retail locations, ATMs, data centres, and corporate …

CRS’s comments pertain to the overall viability and desirability of different certificates within the Proposal and their impacts on existing markets and program, with specific concerns regarding the disaggregation of energy attributes and the creation of multiple new certificates.

CRS submitted information on the topics of REC Accounting and REC Retirement as addressed in the Application, and in response to comments made by the Commissioners in their discussion about RECs under HB 2021 following public comment at the November 1, 2022 Public Meeting.

CRS submitted comments as part of the informal rulemaking process for the Climate Commitment Act Program, Chapters 173-446 WAC, focused on implementation of the voluntary renewable reserve account and compliance obligations for certain renewable energy imports.

CRS submitted comments on proposed regulatory changes to the RFS program focusing on new regulations governing the generation of Renewable Identification Numbers for electricity made from renewable biomass that is used for transportation fuel (eRINs).

CRS’s comments pertain to the use of a market-based Scope 2 total for GHG accounting, the use of market-based instruments in Scopes 1 and 3, the proposed exclusive use of the Greenhouse Gas Protocol (GHGP) standard, and verification of GHG inventories.

CRS’s comments on the ISSB’s March 2022 Exposure Draft IFRS S2 Climate-related Disclosures pertain to the transition plans and carbon offsets and cross-industry metric categories and greenhouse gas emissions. CRS’ comments emphasize the importance of not conflating carbon offsets and renewable energy certificates (RECs), disclosure specifically related to voluntary renewable energy procurement, information about voluntary …

CRS’s comments include general support for the CEC’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen production and use claims that meet the requirements of AB 209.