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In December 2025, the California Energy Commission (“CEC”) updated its RPS Eligibility Guidebook containing the rules that determine which projects qualify for the state's Renewables Portfolio Standard (“RPS”). The changes incorporated into CEC's RPS Eligibility Guidebook, 10th Edition (“Guidebook”) are intended to align RPS policy with how developers are actually building projects today, especially hybrid projects that pair renewables with storage. The updated Guidebook clarifies the rules related to projects with co-located energy storage systems, establishes clearer expectations for measurement and reporting, and reduces surprises during RPS certification and verification of reported renewable energy credits (“RECs”). If you're developing renewable energy resources intended to serve Californians, the new rules will impact how you approach RPS certification at the CEC.
For projects in California state waters (off-shore wind), outside California, and outside the United States, the Guidebook includes clearer locational requirements for renewable facilities to qualify for RPS eligibility. The Guidebook maintains the program's focus on interconnection while explicitly clarifying that a facility's physical siting can be outside the Western Interconnection.
The Guidebook resolves past confusion around how pairing storage with a renewable energy resource affects the creation of RECs particularly in relation to when storage losses must be netted against RPS output. The revised edition describes the netting requirements in a more simplified and straightforward way, and better aligns verification standards with commercial practice. The Guidebook also clearly states that only storage counted as an “addition or enhancement” behind the same reporting meter as the renewable facility generation would trigger loss netting. Standalone energy storage that is designated and metered separately from the meter at which the renewable facility reports the RPS-eligible generation to WREGIS is not reduced to account for losses from the energy storage system.
Another important shift: metering. The Guidebook explicitly recognizes both AC and DC metering and updates accuracy expectations, while keeping existing installations from being forced into costly retrofits. For developers, this allows for more freedom to pick the metering approach that best fits the desired design and strategic model, without second-guessing whether the approach will pass muster. The Guidebook provides for better alignment with tracking systems and industry practice, which should reduce conflict during both the RPS certification process and the REC verification process.
Beyond storage and metering, the new Guidebook implements recent legislation and clarifies resource eligibility, including updates that recognize certain fuel cells and linear generators and refine rules around biomethane delivery and hydroelectric categories. It also takes steps to align verification practices—particularly for more complex delivery arrangements. In short, the document is meant to harmonize RPS eligibility requirements with current practices by renewable energy developers.
The Guidebook is poised to make RPS registration more transparent, metering clearer, and verification smoother—while opening the door for newer technologies to play a bigger role. For a more detailed summary of the recent changes to the Guidebook, click here. In our summary, we further unpack what changed, why it matters, and how to prepare upcoming projects for smooth registration and compliance.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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