Policy Program Update: Arizona, California, and Voluntary Market Developments

As we wrap up the first quarter of 2026, Center for Resource Solutions (CRS) continues to advance policies that strengthen the credibility and impact of renewable energy markets. Through ongoing work in regional and voluntary market design, CRS is helping ensure that clean energy claims remain transparent, verifiable, and aligned with evolving national and international standards. This update highlights recent regulatory developments, program progress, and key initiatives that are shaping credible, market-based climate action in the year ahead.

ARIZONA

Arizona Corporation Commission Repeals Renewable Energy Standard

The Arizona Corporation Commission has finalized its decision to repeal the state’s Renewable Energy Standard and Tariff (REST) under Title 14, Chapter 2 of the Arizona Administrative Code. The repeal eliminates Arizona’s longstanding clean energy requirements, including provisions governing renewable energy certificate (REC) retirement and compliance obligations.

CRS previously submitted formal comments opposing the repeal, emphasizing the importance of REC retirement, transparent tracking, and credible verification to ensure accurate and verifiable renewable energy claims. CRS cautioned that repealing REST could undermine market confidence and reduce voluntary investment in the state.

Read the final decision: Arizona Corporation Commission REST Repeal Decision
Read CRS’s full comment letter: CRS Comments on ACC REST Repeal

CALIFORNIA

SB 253 Implementation — CRS Highlights Key Accounting and Reporting Considerations

The California Air Resources Board (CARB) has initiated rulemaking to implement the Climate Corporate Data Accountability Act (SB 253), including establishing an initial timeline for Scope 1 and Scope 2 emissions reporting. CRS submitted comments emphasizing the importance of clear, consistent, and credible accounting approaches as CARB develops the reporting framework. CRS recommended that market-based accounting be applied across all emissions scopes (1, 2, and 3) to ensure accurate attribution of renewable energy and avoid double counting.

CRS also urged alignment with the Greenhouse Gas Protocol’s 2015 Scope 2 Guidance and cautioned against requiring full hourly matching at this stage, noting that current tracking systems and data availability are not yet sufficiently developed to support reliable hourly reporting. These recommendations are intended to support a reporting framework that is transparent, verifiable, and aligned with established standards.

Read the proposed rulemaking notice: California Corporate GHG Reporting and Climate Risk Disclosure Regulation
Read CRS’s full comment letter: CRS Comments on SB 253 Implementation

 

CALIFORNIA

CARB’s Cap-and-Invest Program Update

CRS has submitted comments to CARB on the proposed updates to the state’s Cap-and-Invest Program, focusing on the need to sustain and strengthen the Voluntary Renewable Energy Program (VREP). The VREP reserve, which enables voluntary renewable energy purchases to deliver emissions reductions beyond compliance obligations, is now fully depleted, affecting the future of California’s voluntary renewable market.

CRS recommends that CARB establish a long-term, data-driven mechanism to allocate allowances more smoothly and consistently across all voluntary renewable generation. Such a framework would ensure ongoing alignment between verified renewable generation and allowance retirements, preserving the integrity and additionality of California’s voluntary renewable energy market.

Read more:
CARB Cap-and-Invest Program Notices & Comment Docket
CRS Comment Letter
Voluntary Renewable Energy Sign-on Letter

 

VOLUNTARY POLICY

Public Consultations and Working Groups

The Greenhouse Gas Protocol (GHGP) closed its public consultation period for both Scope 2 and consequential metrics / avoided emissions on January 31. Across the two consultations, approximately 1,400 responses were submitted, reflecting significant stakeholder engagement. The GHGP Secretariat is expected to publish summary findings in the coming months and will also release organization-attributed responses, except in cases where respondents requested anonymity.

In parallel, the Science Based Targets initiative (SBTi) is progressing its updates alongside GHGP. Its public consultation period concluded on December 12 of last year, following a review of stakeholder feedback.

CRS has also been invited to participate in Pilot 2 of the Taskforce for Climate Action Transparency (TCAT), contributing specifically to the electricity track. The pilot will run from the end of April through the end of July 2026. Key areas of focus will include advancing impact accounting methodologies for electricity projects, clarifying how these impacts are reflected in reporting statements, and exploring approaches to integrate electricity project activities and outcomes within target-setting frameworks.


Case Study: CRS advisory services helps organizations navigate their clean energy transitions and achieve impactful decarbonization goals.

In a recent project for a large American multinational information technology company, CRS developed a consistent methodology to estimate electricity emissions from products sold across international markets, where electricity generation mixes, tracking systems, and residual mix data vary by country.

CRS also provided technical consulting to support the development of an electricity strategy document and downstream emissions accounting framework. We advised on a market-based methodology for estimating low-carbon electricity and created fallback methodologies for markets where country-specific data is limited.

The result was a globally applicable framework of residual mix factors by country and a hierarchy of data, enabling the company to estimate the carbon intensity of electricity used by its products and support consistent accounting across its international markets.

If you have questions about residual mix, customer product use phase guidance, or standard supply service, our mission-driven Advisory Services team is here to help. We also bring deep expertise in renewable energy procurement, credible claims and standards development, emissions accounting, clean energy verification, and impactful procurement strategies. With decades of hands-on experience, we support clients in developing and implementing renewable energy strategies that are practical, scalable, and impactful—driving real emissions reductions and accelerating market transformation.

Whether you’re just starting or advancing your climate commitments, CRS’s Advisory Services can help you take meaningful, measurable action. To learn more, visit resource-solutions.org/services or contact us at services@resource-solutions.org.



The Clean Energy Accounting Project (CEAP) announced the Clean Fuels Series (CFS), an 18-month effort to fill remaining gaps in emissions accounting for clean fuels, including developing the additional components needed to expand CEAP’s Market-Based Accounting for Clean Fuels guidance into a comprehensive Scope 1 reporting framework. The CFS’s final work stream will be determined by its Founding Partners in consultation with CEAP staff and the CFS Council, which operates both as a fuels-focused advisory committee and a traditional CEAP working group. For more information or to join the Clean Fuels Series, contact CEAP Senior Program Manager Renee O’Donnell at renee.odonnell@resource-solutions.org.

Newest Initiative: CEAP also recently launched its newest initiative, Accounting for Utility-Scale Clean Energy Storage. An expert technical working group is focused on questions addressing double counting of attributes associated with stored and discharged energy, properly characterizing and attributing energy leaked during storage, and accounting for utility-scale clean power storage in the context of state renewable portfolio standards (RPSs) and renewable energy standards (RESs). If you’re interested in learning more about the working group or the scope of the project, reach out to CEAP Senior Program Manager Renee O’Donnell at renee.odonnell@resource-solutions.org.

Other active CEAP initiatives include:
Accounting for Utility-Scale Clean Energy Storage
Accounting for Transacted Time-Stamped Information
Best Practices for Power Source and Emissions Disclosure
Hourly Utility Product Design Options

 



On March 25, CRS held a kickoff meeting for all participants in its newest program, the Clean Energy Tracking Collaborative (CETC). Current participants represent a range of tracking-system stakeholders, and organizations interested in engaging in current or future working groups are encouraged to contact CRS. The CETC Advisory Committee includes representatives from Carbon Solutions Group, Google, and national laboratories. Tracking system participants include CleanCounts (M-RETS), NAR, NYGATS, PJM-GATS, and WREGIS.

Following the All-Participants Meeting, CETC will launch its first Technical Working Group focused on hourly data and certificates. The group will examine tracking system hourly functionality, data availability, and implementation considerations associated with enabling hourly certificate tracking.

CETC is a forum for advancing the evolution and expansion of tracking system infrastructure. By bringing together tracking system operators, regulators, policymakers, market participants, and technical experts, CETC participants collaborate to identify high-priority needs for tracking system functionality and data, and to develop practical guidance and recommendations. The Collaborative is focused on helping tracking systems evolve to meet emerging market and accounting needs while strengthening transparency and credibility across clean energy markets.

For more information, please reach out to: cetc@resource-solutions.org or visit: resource-solutions.org/cetc


Conferences & Publications

  • March: Peggy Kellen spoke at the 2026 Carbon Disclosure & Decarbonization Forum on Greenhouse Gas Protocol updates, highlighting key changes to Scope 2 and Scope 3 accounting and implications for corporate reporting.
  • April: Lucas Grimes attended North American Carbon World, engaging with stakeholders on carbon markets and policy developments.
  • April: Lucas Grimes moderated a panel at the California Clean Energy Summit on state policy alignment and progress toward California’s 2045 clean energy goals.
  • April: Christopher Cooper will speak at the Future of RNG North America Conference on renewable natural gas market trends and policy developments.
  • May: Peggy Kellen will attend the CEBA Connect Spring Summit, engaging with corporate buyers and stakeholders on clean energy procurement and market development.
  • June: Devon Johnson and Mark Teklinski will attend the RECS Market Meeting in Prague.
  • July: Mark Teklinski will attend the NARUC Summer Policy Summit engaging with Public Utility Commissioners regarding the Clean Energy Tracking Collaborative.

Upcoming Events

FEATURED

Renewable Energy Markets™ Asia 2026
Singapore | 21–22 April, 2026

The annual Renewable Energy Markets™ (REM™) Asia conference is a unique event that brings together leading industry players throughout Asian renewable energy markets to meet, network, learn, and plan for the future of the region. The renewable energy landscape in Asia is moving faster than ever, and no other conference offers a greater advantage for those who build, buy, and market clean energy than the REM™ Asia conference. Decisionmakers from around the world meet for two days of in-depth conversations, panel discussions, and targeted small group meetings focused on providing the latest information and strategies for those leading the region’s clean-energy transition.

Learn More

 

FEATURED

Renewable Energy Markets™ 2026
Washington, DC | September 1–3, 2026

Renewable Energy Markets™ (REM™) is the leading conference for the clean energy marketplace, attended by leaders from federal and state governments, large corporate purchasers, the nation’s leading utilities and electricity generators, and marketers from around the world. Join us for one day of pre-conference workshops and two days of sessions focused on the states, businesses, organizations, and households that choose clean, renewable electricity every day.

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2026 RECS Market Meeting
Prague, Czechia | June 2–3, 2026

The 2026 RECS Market Meeting (RMM) will address these questions and many others. The time for renewables markets is now or never, and the RMM is rising to this challenge with a new venue, a new conference format, and a fresh approach to engaging delegates. Moving the conference to Prague will make it more accessible to more delegates, and we eagerly anticipate welcoming you to a fantastic venue with excellent networking spaces that overlook the historic city.

Learn More