As we welcome in 2025, we wanted to share with you some updates on our current policy priorities—our efforts to advance renewable energy and promote a sustainable future. At Center for Resource Solutions (CRS), we are committed to ensuring beneficial renewable energy policies and markets continue to thrive in 2025 and beyond. Your support and collaboration are key to achieving these goals. We encourage you to stay engaged with these initiatives and take advantage of opportunities to provide input on these critical issues. If you have any questions, comments, or suggestions, please feel free to reach out to us. Together, we can continue building a cleaner, more sustainable future.
California
SB 253 Climate Corporate Data Accountability Act
In 2024, SB 253 established new requirements for U.S.-based companies with over $1 billion in annual revenue operating in California to report direct (Scope 1), indirect energy-related (Scope 2), and supply chain-related (Scope 3) greenhouse gas (GHG) emissions. CRS is focused on ensuring that SB 253 reporting requirements prioritize market-based emissions accounting across Scopes 1, 2, and 3 to align with California’s climate goals and global standards. Key recommendations include requiring the use of Energy Attribute Certificates (EACs) to substantiate renewable energy use and prevent double counting of renewable energy.
To streamline compliance and reduce costs, CRS advocates for leveraging third-party programs such as Green-e® for verification and assurance of renewable energy use. Additional priorities include harmonizing reporting requirements with established frameworks like the Greenhouse Gas Protocol to reduce duplication and ensure consistency. CRS also supports enhancements to California’s Power Source Disclosure program and the Western Renewable Energy Generation Information System (WREGIS) to make it easier for organizations to comply with SB 253.
For more information see the Information Solicitation for SB 253
Renewable Portfolio Standard (RPS) 10th Edition Guidebook Update
The California Energy Commission (CEC) is updating the RPS Guidebook, which includes facility certification and generation reporting requirements for the state’s RPS program. CRS supports clarifications on WREGIS account retirements that would enable the use of retail sales portfolio-specific retirements and enable retail customers to receive data on their pro-rata share of the RPS. The current lack of clarity on RPS reporting and WREGIS retirement requirements is preventing California Community Choice Aggregators (CCAs) from receiving Green Power Partnership (GPP) recognition. Improving this data availability will also support organizations doing business in California that will be using the Greenhouse Gas Protocol to report emissions under California SB 253.
For more information see the CEC’s Notice and Request for Comment on Proposed Scope for the RPS GB 10th Edition
Amendments to Cap-and-Trade Regulation
In Q1 2025 the California Air Resource Board (CARB) is expected to release proposed amendments to the Cap-and-Trade Program, with a 45-day public comment period followed by a Board vote and a 15-day comment period for additional changes before final administrative review. A key focus for CRS is ensuring continued allocation of allowances to the Voluntary Renewable Energy Program (VREP). These allowances are critical to ensuring that voluntary purchases of renewable energy drive emissions reductions beyond what would otherwise occur under regulation. The proposed addition of 5.5 million allowances to the VREP reserve account by mid-2025 provides crucial support for voluntary renewable energy markets, addressing the 2023 allowance deficit and ensuring sufficient allowances for 2024 generation requests.
For more information see the rulemaking website
Related CRS Comments: Comments in Response to the California Public Workshop: Potential Amendments to the Cap-and-Trade Regulation
Amendments to Cap-and-Trade Regulation
In Q1 2025 the California Air Resource Board (CARB) is expected to release proposed amendments to the Cap-and-Trade Program, with a 45-day public comment period followed by a Board vote and a 15-day comment period for additional changes before final administrative review. A key focus for CRS is ensuring continued allocation of allowances to the Voluntary Renewable Energy Program (VREP). These allowances are critical to ensuring that voluntary purchases of renewable energy drive emissions reductions beyond what would otherwise occur under regulation. The proposed addition of 5.5 million allowances to the VREP reserve account by mid-2025 provides crucial support for voluntary renewable energy markets, addressing the 2023 allowance deficit and ensuring sufficient allowances for 2024 generation requests.
For more information see the rulemaking website
Related CRS Comments: Comments in Response to the California Public Workshop: Potential Amendments to the Cap-and-Trade Regulation
Minnesota
100% Carbon-Free Electricity (CFE) Standard
In 2023, Minnesota adopted a 100% carbon-free electricity standard that obligates the state’s utilities to supply customers entirely with power generated without emitting CO2 by 2040 (with targets of 80% by 2030 and 90% by 2035). However, the Minnesota Public Utility Commission’s (PUC’s) proposed implementation rules allow utilities to claim the percentage of CFE in the regional grid average to comply with the standard without the associated renewable energy certificates (RECs). CRS filed comments arguing that the provision double-counts renewable generation attributes. CRS proposed instead that the PUC require utilities to use a residual resource mix to determine the percentage of unclaimed CFE in Midcontinent Independent System Operator (MISO) imports to ensure credible CFE claims in Minnesota and other states. CRS filed comments and is continuing to engage in this proceeding.
For more information see the PUC Notice
Related CRS Comments: Comments on Implementation of Changes to Minnesota’s Renewable Energy Standard and Carbon Free Standard
Oregon
HB 2021 Implementation and Voluntary Renewable Electricity Products in the West
In response to the Oregon Public Utilities Commission (PUC)’s decision last year not to require RECs for renewable energy used to meet the state’s clean energy targets law (HB 2021), CRS announced standard changes in the Green-e® Energy program restricting the eligibility of RECs associated with generation reported for compliance. This was necessary to prevent double counting and maintain impact (i.e., “regulatory surplus”) for the voluntary market. More information is available here.
Later, in July and October respectively, the Oregon Commission approved requests from PGE and PacifiCorp to remove requirements and references to Green-e® certification in their voluntary products. CRS is continuing conversations with Oregon PUC and Department of Environmental Quality (DEQ) staff and the utilities about the diminished quality of voluntary products in Oregon and disclosure to customers. CRS is also communicating with neighboring states and the federal government about concerns with using these RECs for effective and impactful state and federal programs. While there is no open proceeding, we encourage stakeholders to continue to engage with CRS, the Oregon PUC, and Oregon DEQ.
Washington
Cap-and-Invest Program Linkage Rulemaking Meeting on Electricity Topics
Washington’s Department of Ecology is considering amendments to Chapter 173-441 WAC, Reporting of Emissions of Greenhouse Gases, and Chapter 173-446 WAC, the Climate Commitment Act Program Rule that would allow Washington’s carbon market to link with the California-Québec carbon market. CRS has submitted detailed comments to Ecology, Commerce, and the Utilities and Transportation Commission about the Cap-and-Invest Program (and the Clean Energy Transformation Act) regarding potential double counting of renewable energy from centralized wholesale electricity markets if RECs are not required to verify the renewables. This double-counting would mean that Washington citizens get less renewable energy than they should, as those renewables are claimed by other state’s programs and voluntary buyers. CRS will continue to engage though the linkage rulemaking to advocate that the Cap-and-Invest and other state programs properly account for renewables from wholesale markets.
For more information see the Department of Ecology’s webpage: Chapters 173-441 and 173-446 WAC – Electricity Markets
Related CRS Comments here
Western Region
Western Wholesale Market Updates
CRS has been actively involved in the development of protocols for tracking and reporting greenhouse gas (GHG) emissions within new Western regional wholesale power markets. Both the California Independent System Operator (CAISO) and the Southwest Power Pool (SPP) are developing approaches to track and report GHG emissions within their real-time and day-ahead Western market offerings for entities in states with different carbon reduction policies.
In addition to mechanisms that “deem” or attribute GHG emissions to states with GHG pricing programs, these regional market operators also wish to provide participating load-serving entities (LSEs) with market GHG data for reporting emissions to states with GHG reduction or reporting requirements. Competing allocation methods in the West could jeopardize renewable energy market and program integrity and risks double-counting renewable attributes and emissions that are claimed under state and voluntary programs. We encourage all parties to engage directly with CAISO and SPP working groups as well as with WREGIS to support coordination and accurate accounting.
CAISO’s GHG Coordination Working Group is beginning to develop an accounting and reporting approach for the Western Energy Imbalance Market (WEIM) and the Extended Day Ahead Market (EDAM). CRS has recommended improving data transparency and coordination with the Western Renewable Energy Generation Information System (WREGIS) and will continue to provide feedback on issues including accounting for null power and calculation of market residual mix.
SPP has completed a draft GHG Tracking and Reporting protocol for its Markets+ day-ahead market, through its Markets+ GHG Task Force. The protocol currently acknowledges RECs and null power with disclaimer language and in optional reporting. CRS is advocating for the inclusion of a null power-adjusted residual mix, REC requirements for allocated renewable generation, and coordination and data sharing with WREGIS. Additional stakeholder input is expected prior to the protocol’s finalization.
For more information and detailed CRS recommendations, see CRS’s Background Report: GHG Allocation and RECs in Western Markets
