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  • Comments to the CA Air Resources Board on Renewable Electricity in the Low Carbon Fuel Standard (LCFS)
  • Author: Maya Kelty
  • Published: January 6th, 2017| Comment | 4 Pages
  • Comments to the California Air Resources Board (ARB) regarding potential changes to how electricity used as a transportation fuel is treated in the ARB's Low Carbon Fuel Standard (LCFS) Program (pursuant to California Assembly Bill AB 32 and the Governor's Executive Order S-01-07). These comments pertain to the use of renewable electricity as a transportation fuel and the associated verification measures required to ensure exclusive use of renewable electricity. Specifically, these comments address topics and questions posed on slides 5 and 21 from the December 2, 2016 Workshop on Grid and Renewable Electricity and pages 4 and 13 of the November 23, 2016 Staff Discussion Paper.

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  • Comments in response to the October 21, 2016 California Cap-and-Trade Regulation Amendments Workshop
  • Author: Todd Jones
  • Published: November 4th, 2016| Comment | 2 Pages
  • CRS comments regarding potential 2016 amendments to the California Cap-and-Trade Regulation discussed at the workshop held on October 21, 2016. Comments focus on post-2020 allowance allocation to Electrical Distribution Utilities (EDUs) and, in particular, on Staff's most recent proposal regarding the RPS Adjustment, included in the Post-2020 Electrical Distribution Utility Allocation Informal Proposal. Comments also provide a recommendation for how to administer the RPS Adjustment and avoid double counting with directly delivered renewable energy.

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