Renewable Energy Markets Association Response to EPA's Final Clean Power Plan

The Renewable Energy Markets Association (REMA) applauds the Environmental Protection Agency (EPA) for releasing a strong, achievable final Clean Power Plan. We look forward to working with the states to ensure that purchases of renewable energy and their environmental credits are used to comply with the plan, state goals and to reach beyond them by encouraging voluntary purchases.
 
REMA represents the collective interests of businesses that sell or promote the sale of renewable energy products, including renewable technology, renewable electricity, and Renewable Energy Certificates (RECs) to individuals, companies, and institutions throughout North America. We are the leading national organization focused on maintaining the integrity and continued growth of the compliance and voluntary renewable energy markets, and we actively engage in proceedings at the federal and state level when policies impact the renewable energy markets. In October 2014, REMA was pleased to submit comments pursuant to the proposed rule.
 
Under any state or federal implementation plan, REMA urges regulators to take steps to maintain the integrity of renewable energy purchases, including preventing double counting. Seconding the EPA's comment that market-based systems can be the most efficient method by which states can achieve their specific goals, REMA encourages states to adopt the use of the renewable energy marketplace.
 
REMA also encourages states to reach beyond the stated goals of the CPP and their own state requirements, by utilizing the Voluntary Renewable Energy (VRE) market. The VRE is substantial market for purchases of renewable electricity above and beyond state Renewable Portfolio Standard (RPS) mandates and federal agency purchasing requirements. These VRE purchases support the development of renewable energy generation nationwide beyond the requirements some states have and in place of those that do not have a renewable energy requirement, like an RPS. VRE purchases have continued to climb with a year-on-year positive growth rate. The VRE market affords renters, homeowners, businesses, and institutions flexibility in purchasing renewable energy. Integrity and accountability are essential to the continued function of the VRE market and its support of renewable energy. REMA looks forward to better understanding the relationship between RECs and Emission Rate Credits (ERCs), and to ensuring that environmental and contractual integrity are preserved through single end-user or claimant ownership.
 
Should states or the EPA have questions or concerns about the role the compliance or voluntary markets play or could play in achieving state and/or federal implementation plans, REMA would welcome the opportunity to engage in such a discussion.
 
 
The Renewable Energy Markets Association (REMA)