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Skip Navigation LinksPUC > Energy > Procurement and Resource Adequacy > LTPP > 2008 > GHG Lifecycle Analysis

2008 LTPP Rulemaking: GHG Lifecycle Analysis

In comments to the OIR, Community Environmental Council (CE Council) requested that the Commission consider lifecycle emissions analysis for all utility activities (generation, energy efficiency, demand response) in this proceeding. The CE Council has raised this issue in R.06-04-009 (the climate change proceeding) and the Assigned Commissioner stated, on Feb. 2, 2007: 

  • This would require well-established, peer-reviewed analyses and/or submission by the parties of alternative analyses for review in this proceeding. Because the methodology for lifecycle analysis of GHG emissions is still being developed, and widely accepted studies have not been completed, I do not include lifecycle analysis of GHG emissions in the scope of Phase 2....[I]t is possible that the CPUC may want to consider analysis of lifecycle emissions during a later proceeding.

Pursuant to the August 28, 2008 ACR/Scoping Memo, the Assigned Commissioner did not formally include this issue in scope of the 2008 LTPP proceeding.  Instead, Energy Division agreed to initiate an information gathering process as a first step to assessing whether the issue merits formal consideration in a future proceeding yet to be determined.  The process is for any party wishing to share information on this subject to submit that information to the assigned Energy Division analyst, Simon Eilif Baker (  This page hosts a body of literature and data sources provided to Energy Division, so that it can be reviewed and debated by interested parties.  Any party wishing to participate in a discussion group on these studies should contact the assigned analyst to be included in a distribution list for that dialogue.  Based on this dialogue and Energy Division's own assessment of whether the issue can be analyzed robustly, with defensible data and quantification methods, and whether the results are sufficiently impactful to influence energy resource decisions, GHG liefcycle emissions could conceivably be brought before the Commission in a later proceeding. 


Last Modified: 3/4/2009

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