TURN outlines several issues important to making the utility indifferent to procurement of distributed energy resources (DERs) over traditional utility “wires” solutions. TURN outlines concerns about the ability to achieve actual avoided cost benefits in the area of utility distribution capacity capital spending. The primary problem is that utility distribution capacity spending is justified based on complex load growth forecasts and analyses of potential impacts of overloading on assets such as line transformers, conductors and substation transformers. Not only is the utility information advantage huge, but also utility forecasts of specific project timelines are often wrong. Ensuring that DERs actually replace or defer real projects, resulting in ratepayer savings, will be extremely difficult.