CPUC: High levels of DER and avoided transmission investments in Integrated Resource Planning – reply comments

Reason for submission: Reply comments proposing a Reference System Plan for the CPUC Integrated Resource Planning process

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This filing represents the Clean Coalition’s reply comments on the California Public Utilities Commission’s (CPUC) Staff Proposal on Implementing the Integrated Resource Planning (IRP) process. The Clean Coalition recommended that the development of a Reference System Plan as the model plan for all load-serving entities (LSE) consider a scenario with high levels of distributed energy resources (DER) and avoided transmission investments. In addition, the Clean Coalition pushed for full consideration of transmission costs as well as the energy services and avoided transmission costs of DER.

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