CPUC: Joint comments with NRDC, EDF, and 350 supporting societal cost test

Reason for submission: Joint comments supporting the Societal Cost Test in the Integrated Distributed Energy Resources (IDER) proceeding

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This filing represents joint comments submitted by the Clean Coalition, National Resources Defense Council (NRDC), Environmental Defense Fund (EDF), and 350 Bay Area on the Amended Proposal on Societal Cost Test in the California Public Utility Commission’s (CPUC) Integrated Distributed Energy Resources (IDER) proceeding. The comments argued in favor of immediate adoption of the SCT as the primary cost test, supported the greenhouse gas valuation methodology and improvements in related standard cost tests, but argued for the use of a lower discount rate and the inclusion of additional impact factor values.

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