Comments submitted on the Federal Trade Commission (FTC)’s proposed update to its Guides for the Use of Environmental Marketing Claims (“Green Guides”). Overall, we are very supportive of the proposed…

…and our remaining concerns about the Western Climate Initiative recommendation that renewable energy certificates (RECs) have no role in mandatory GHG reporting and compliance protocols. We reiterated why we think…

A joint letter from CRS, clean energy businesses, organizations, and environmental groups write to you in support of including a provision in the Cap and Trade Regulation to establish a…

The price of gasoline is a telling economic weathervane. When gas is cheap, it is not given much attention. When gas prices hit record highs, however, as in 2008, the…

CRS submitted a comment letter to New Mexico’s Environmental Improvement Board urging the adoption of a set aside to ensure that voluntary renewable energy purchases continue to reduce carbon dioxide…

This report contains the activities and financial reporting documents for 2009.

…CARB’s recognition of these property rights inherent in RECs would not increase CARB’s risk of a regulatory taking under the Fifth Amendment, and that declaring that RECs do not constitute…

This letter expresses CRS’s view on off-the top as well as other allocation issues. We express our view that CARB’s proposed approach to allowance distribution would be an unfortunate overreaction…

CRS authored a letter to the California Air Resources Board on the issue of off-the-top treatment of voluntary renewable energy purchases and marshaled another coalition of nonprofit organizations and clean…

Comments and recommendations submitted on the WCI’s Market Design Committee’s whitepaper by the WeCAN Markets and Cap Setting and Allowance Distribution Committees, pertaining to the disposition of unsold allowances and…