XV. TURN's Offset-Only Proposal

1. Parties' Comments

TURN proposes an alternative program that would not require PG&E to acquire customers. PG&E would instead use funding - presumably the same A&M funding PG&E seeks here - to directly contract for emissions reductions. TURN notes that PG&E would gain experience in the market for offsets without the added expense of marketing to customers. PG&E could return to the Commission to expand its program to include customers once it gained such expertise.

DRA notes that there is no record regarding TURN's proposal since TURN first raised it in post-hearing briefs. PG&E continues to support the proposal in its application.

2. Discussion

TURN's proposal requires further input and record development, and we are not prepared to adopt it here.