Petition for a declaratory order regarding the extra credits for apprentice labor provision of RCW 19.285.0404(2)(h), Docket U-111663; Washington Utilities and Transportation Commission.

CRS submitted comments to the Washington Utilities and Transportation Commmission with regard to Puget Sound Energy’s (PSE) petition to bifurcate the apprentice labor multiplier from the Renewable Energy Credit (REC). CRS believes this bifurcation would directly result in the double counting of renewable energy attributes if the REC were sold into the voluntary market, or to meet another state’s RPS, and the multiplier was claimed by a utility in Washington using it for RPS compliance.