California Stakeholder Advisory:
Assembly Bill 1110 (Ting)


August 28, 2015

Center for Resource Solutions (CRS) and Green-e® Energy would like to let you know about California Assembly Bill (AB) 1110, Greenhouse gases emissions intensity reporting: retail electricity suppliers, introduced by Assembly Member Ting, which represents a potentially impactful development in California.

AB 1110 would require a retail supplier, including an electrical corporation, local publicly owned electric utility, electric service provider, and community choice aggregator to disclose the emissions of greenhouse gas (GHG) emissions intensity associated with its electricity sources. CRS supports GHG disclosure to retail customers as the major thrust of this bill. We also support standardizing a GHG accounting methodology in California. However, the bill also includes language stipulating how the accounting should be done. The bill prohibits the use of Renewable Energy Credits (RECs) for GHG disclosure, and instead assigns the GHG emissions attributes to the null electricity. Doing so would effectively disaggregate or double count the REC in California by not requiring demonstration of REC ownership for delivered renewable electricity to be counted as zero emissions. This would potentially affect RECs from any facility supplying electricity or null power to a retail supplier in California.

CRS has submitted a letter expressing our concerns with the bill and providing recommendations to Assembly Member Ting's office and the organizations in support and opposition to the bill. AB 1110 passed out of the California Senate Appropriations Committee on August 27, 2015 and is headed to the California Senate floor without changes that would address our concerns. The bill will need to return to the State Assembly for a concurrence vote before the end of the legislative session on September 11, 2015.

Due to its potential impact on supply and renewable energy claims, CRS urges interested parties, particularly participants sourcing from California, to review AB 1110 and CRS's letter to Assembly Member Ting. Participants may also want to inform customers for whom GHG Scope 2 claims are important.

CRS's letter is available here.

More information about the bill can also be found here.

Please contact Todd Jones at 415-561-2118 or for a copy of CRS's comments on the bill and if you have any questions about this issue.