Comments on CPUC Energy Division Staff White Paper on Implementing GHG Planning Targets in the Integrated Resource Planning Process (Proceeding R.16-02-007)

Comments on the California Public Utilities Commission (CPUC) Energy Division Staff’s White Paper on Implementing GHG Planning Targets in the IRP Process. Comments are focused on Question for Parties no. 6, the methodologies for developing and reporting against GHG planning targets and the relevance of other methodologies/protocols developed for other state programs, and the treatment of voluntary renewable energy generation in GHG target reporting.