+ 2019
9/06/2019: PGP Comments on Commerce Discussion Draft on Social Cost of Carbon
10/11/2019: PGP Comments to Commerce on October 21 Workshop Agenda
11/07/2019: PGP Comments on Carbon and Electricity Markets Workgroup Nominating Participants
+ 2020
5/19/2020: PGP Comments to Commerce on Draft Rules for the Treatment of Renewable Energy Credits
6/08/2020: PGP Comments to Commerce on Draft Rule Issues for the Incremental Cost of Compliance Mechanism
6/15/2020: PGP Comments to Commerce on Draft Rules for Planning and Compliance
6/29/2020: PGP Comments to UTC on the “Use” of Renewable Resources and Nonemitting Electric Generation
7/13/2020: PGP comments to Commerce on draft rules
7/31/2020: Joint utility comments and legal memo on “use” to UTC and Commerce
9/14/2020: PGP comments to Commerce on 2nd set of draft rules
9/25/2020: Joint utility letter and proposed rule language on “use” to UTC and Commerce
12/02/2020: PGP comments to Commerce on proposed rules
12/03/2020: PGP comments to UTC on “use” of Renewable Resources and Nonemitting Electric Generation
+ 2021
6/02/2021: PGP and Joint Utilities Comments on Energy Storage Rulemaking Issues
6/14/2021: PGP and Joint Utilities Comments on Doublecounting Rulemaking Issues
8/12/2021: 2-page Overview of Joint Utility Proposal “multiyear compliance with annual surplus accounting”
8/12/2021: Joint Utility presentation on proposal “multiyear compliance with annual surplus accounting”
11/12/2021: PGP Comments to Commerce on UTC Proposed Rules
11/12/2021: PGP Comments to UTC on Proposed Use Rules
12/06/2021: Joint Utility Comments to UTC and Commerce on Double-Counting
12/06/2021: Joint Utility Comments to UTC and Commerce on Double-Counting - Attachment A
+ 2022
2/09/2022: PGP Comments to Commerce on Jan. 19th Draft CETA Rules
4/22/2022: PGP Comments to UTC on Docket UE-210183 Relating to electricity markets and compliance with CETA
4/27/2022: PGP Comments to Commerce on Proposed Rulemaking for Ch. 194-40 WAC – Clean Energy Transformation Act
+ 2023
9/15/2023: PGP Comments to Commerce on CETA Interim Assessment
9/15/2023: Joint Utility Comments to Commerce on CETA Interim Assessment