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…

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’…

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…

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…

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…

…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’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…

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

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…

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…