Comments on the White House Council on Environmental Quality Implementing Instructions for Executive Order 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability

The Clean Air Task Force, The NorthBridge Group, and Green Strategies, Inc. argue that current greenhouse gas accounting rules are outdated and fail to incentivize the diverse portfolio of carbon-free energy (CFE) resources needed for full grid decarbonization by 2035. They recommend adopting a 'bottom-up' book and claim approach for energy attribute certificates (EACs) to prevent double counting and suggest a 'Carbon Facts' label to track both attributional emissions (associated with electricity use) and consequential avoided emissions (actual carbon reductions). The authors specifically urge CEQ to define the 50% hourly match goal by 2030 as either a minimum of 50% CFE in every hour or a high annual average of at least 80% hourly time-matching to ensure the development of firm CFE and storage resources.

• The authors recommend that CEQ update its instructions to use attributional accounting to produce a more accurate measurement of emissions tied to the timing and location of electricity use, and to track incremental resource development, specifically identifying new firm CFE and investments in storage, load management, and transmission.
• The authors propose two alternative definitions for the 50% hourly match goal by 2030 to avoid lenient standards that would not promote firm CFE and storage: requiring a minimum of 50% CFE in every hour, or requiring a high average hourly time match of at least 80%.
• The document criticizes the current 'top down' residual mix methodology based on eGRID data, arguing it is flawed because it does not account for state-level clean energy mandates or non-bypassable CFE purchases, which can lead to inaccurate credits for Agencies.
• The authors suggest a 'bottom up' book and claim approach for tracking CFE, where all qualifying EACs (including those from mandatory or non-bypassable purchases) are retired to substantiate claims, thereby preventing double counting and harmonizing voluntary and compliance markets.

APA

Clean Air Task Force (2023). Comments on the White House Council on Environmental Quality Implementing Instructions for Executive Order 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability. https://cdn.catf.us/wp-content/uploads/2023/04/26155628/white-house-ceq-clean-energy-industries-jobs-comments.pdf

Chicago

Clean Air Task Force. Comments on the White House Council on Environmental Quality Implementing Instructions for Executive Order 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability. 2023. https://cdn.catf.us/wp-content/uploads/2023/04/26155628/white-house-ceq-clean-energy-industries-jobs-comments.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Comments on the White House Council on Environmental Quality Implementing Instructions for Executive Order 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability |date=7 March 2023 |url=https://cdn.catf.us/wp-content/uploads/2023/04/26155628/white-house-ceq-clean-energy-industries-jobs-comments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2023comments, author = {{Clean Air Task Force}}, title = {{Comments on the White House Council on Environmental Quality Implementing Instructions for Executive Order 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability}}, publisher = {Clean Air Task Force}, year = {2023}, month = mar, url = {https://cdn.catf.us/wp-content/uploads/2023/04/26155628/white-house-ceq-clean-energy-industries-jobs-comments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }