Policy Documents
July 23, 2009
CRS submitted letters to the Senate Environment and Public Works Committee and Energy and Natural Resources Committee, advocating for the set-aside and retirement of allowances to account for voluntary renewable energy activity, and emphasizing the importance of making clear the demarcation between voluntary and compliance markets for renewable energy claims, respectively.
Letter to the Senate Environment and Public Works Committee
Letter to the Senate Energy and Natural Resources Committee
February 27, 2009
CRS submitted letters to the House and Senate arguing for off-the-top treatment of voluntary renewable energy purchases under a federal cap-and-trade program to reduce the pollution responsible for climate change.
Letter to the House Energy and Commerce Committee
Letter to the Senate Environment and Public Works Committee
Regional Policy
CRS's participation in the Global Warming Action Coalition (GWAC), which participates in the implementation of California's Global Warming Solutions Act, and the Western Climate Advocates Network (WeCAN), which participates in the implementation of the Western Climate Initiative, has resulted in a number of group letters responsive to comment opportunities offered as part of those policymaking processes.
May 27, 2010
CRS wrote a letter to the WCI Electricity and Markets Committees recommending WCI recind a recently released recommendation that RECs have no role in mandatory GHG reporting and compliance protocols, and that null power be assigned the emissions profile of system power, following best practices.
Letter to WCI Electricity and Markets Committees
May 7, 2010
CRS drafted these comments on the WCI Auction Design White Paper (April 14, 2010) for the Western Climate Advocates Network.
CRS/WeCAN comments to the WCI Market Design Committee
February 17, 2010
CRS commented on the Voluntary Carbon Standard's proposed Methodology for Weatherization of Single and Multi-Family Buildings, for the Maine State Housing Authority.
CRS comments to VCS Maine State Housing Authority
January 14, 2010
CRS was the lead author of the Western Climate Advocates Network comment letter submitted to the Western Climate Initiative’s Electricity Committee on its paper "Voluntary Renewable Energy Market: Issues and Draft Recommendations," (January 14, 2010). CRS also submitted our own letter commenting on the draft recommendations.
January 13, 2010
Chris Busch led the development of this technical comment letter to the WCI Partners with input on their proposed methods for cap setting, from the Western Climate Advocates Network (WeCAN) Cap Setting and Allowance Distribution Committee.
WeCAN comments on the WCI's "Draft Guidance for Developing WCI Partner Jurisdiction Allowance Budgets"
2009
August 28, 2009
CRS led the drafting of the Western Climate Advocates Network comments on the "Draft Statement of Principles on Competitiveness" and "Review of Proposed Options for Addressing Industrial Competitiveness Impacts" released by the Western Climate Initiative's Cap Setting and Allowance Distribution Committee.
WeCAN comments on the WCI's "Draft Statement of Principles on Competitiveness"
June 19, 2009
CRS was the lead author on the Western Climate Advocates Network response to WCI stakeholder discussion questions pertaining to addressing competitiveness concerns.
WeCAN Response to WCI's Stakeholder Discussion Questions on Competitiveness
CRS also contributed to the comments of the Western Climate Advocates Network on the WCI's white paper on rewarding early action.
WeCAN Response to WCI's White Paper on Early Reduction Allowances (ERAs)
April 15, 2009
Lead author on the letter from the WeCAN Cap Setting and Allocation Distribution Committee to the WCI Committee of the same name with comments on the 2009-2010 workplan.
Letter to the WCI Cap Setting and Allocation Distribution Committee
March 9, 2009
CRS was a contributing author on the WeCAN letter to the WCI's Complementary Policy Committee.
Letter to the WCI's Complementary Policy Committee
California Climate Policy
June 7, 2010
CRS authored a letter to the California Air Resources Board on the issue of off-the-top treatment of voluntary renewable energy purchases and marshaled another coalition of nonprofit organizations and clean energy industry stakeholders to support the concept. Read the letter and see the full list of signatories.
CRS also submitted our own letter on off-the-top as well as other allocation issues. We express our view that CARB's proposed approach to allowance distribution would be an unfortunate overreaction to emission leakage concerns, and resulting overcompensation of carbon emitters would represent a lost opportunity to bolster the emerging clean energy economy that can contribute badly needed new jobs. Read the letter.
December 14, 2009
CRS was a member of the California Air Resources Board's Economic and Technology Advancement Advisory Committee (ETAAC), and contributed to the renewable energy and energy efficiency sections of the final report.
Report: Advanced Technology to Meet California's Climate Goals: Opportunities, Barriers & Policy Solutions
September 25, 2009
CRS brought together a coalition of nonprofits to support a letter to the Economic and Allocation Advisory Committee on the topic of economic modeling issues. The letter urges the Committee to explain that CARB’s results are consistent with other studies. The CARB findings on the economic impacts of the Scoping Plan corroborate many other studies done in the California context and elsewhere. The results of these economic studies show relatively small net macroeconomic effects from greenhouse gas reduction efforts of similar magnitude to AB 32, even before other environmental benefits and avoided climate damages are considered.
Letter to AB 32 Economic and Allocation Advisory Committee on on Economic Modeling
June 12, 2009
CRS submitted comments arguing for an off-the-top approach to voluntary renewable energy
purchases in response to the invitation to comment on the use of set-asides in a California cap-and-trade program.
Along with the Center for Energy Efficiency and Renewable Technologies and SunPower Corporation, CRS brought together an impressive coalition of public interest nonprofit groups, renewable energy industry stakeholders (including major wind and solar associations), and others (faith groups, venture capitalists) in support of an off-the-top approach to voluntary renewable energy purchases in response to the invitation to comment on the use of set-asides in a California cap-and-trade program.
April 13, 2009 and May 29, 2009
CRS was the lead author on two GWAC group letters, one on the issue of how to manage concerns about emissions leakage and competitiveness under cap-and-trade and the other on the question of how to go about setting the level of the cap.
Letter to CARB on Emission Leakage and Competitiveness
Letter to CARB on Cap Setting
March 31, 2009
CRS contributed to the development of a letter on how to reward early action achieved before the cap-and-trade program is put in place.
Letter to CARB on Rewarding Early Action