CEC: Comments on 2011 IEPR Final Report

Reason for Submission:  Last opportunity to comment on 2011 IEPR before adoption by the Commission.

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This filing represents the Clean Coalition's comments that acknowledge the tremendous work done by CEC in developing IEPR, but notes that several core assumptions in analyses must be revisited in the 2012 IEPR update.  Urgent outstanding issues include: regional target methodology for 12 GW DG goal, bias towards central station renewables, and the need to integrate energy policy silos.