no party criticizing the backstop has offered a workable method for calculating the net rate impacts. The Decision agrees that SB 43 requires utilities to use the RPS backstop method for any overprocurement on behalf of GTSR subscribers. The Decision further agrees with TURN that the determination of net impacts on non-participants is difficult and that no party has identified a “reasonable, practicable, definitive method for determining a price difference.” brief of TURN on the Application of SCE for approval of a Green Tariff Shared Renewables Program, May 9, 2014, pages 3-4 D.15-01-051, pages 47-50. 6. PROCUREMENT / SCE PROPOSAL TO SATISFY ADDITIONALITY TURN urged the Commission to reject SCE’s procurement and portfolio proposal as unreasonable and inconsistent with SB 43. TURN argued that the proposal fails the additionality test and would not produce any incremental renewable power to serve subscribers. TURN urged the Commission to require dedicated procurement comparable to the approaches proposed by PG&E and SDG&E. The Decision agrees with TURN and finds that SCE’s proposal “fails to meet the additionality requirements of SB 43”. The Decision requires SCE to restructure its GTSR program to promote additional resources consistent with the approaches approved for SDG&E and PG&E. Direct Testimony of Matthew Freedman on the Green Rate Application of SCE, April 11, 2014, pages 2-6, 8-11 Opening brief of TURN on the Application of SCE for approval of a Green Tariff Shared Renewables Program, May 2, 2014, pages 3-16 D.15-01-051, pages 25-26 Verified. 7. ENHANCED COMMUNITY RENEWABLES / CITY OF DAVIS TURN argued that SB 43 does not authorize the City of Davis to administer its own GTSR program and does not allow for the bill Opening brief of TURN on the Enhanced Community Renewables Proposal of PG&E, May 5, 2014, pages 7-8 Verified.
crediting arrangement proposed by the City. The Decision agrees that SB 43 did not intend to create a separate program managed by the City of Davis and rejects the proposal to apply a different rate structure to apply to projects eligible for the City of Davis reservation. Reply brief of TURN on the Enhanced Community Renewables Proposal of PG&E, May 9, 2014, pages 2-4 D.15-01-051, pages 74-78. 8. ENHANCED COMMUNITY RENEWABLES / PG&E PROPOSAL TURN express concerns about PG&E’s proposed Enhanced Community Renewables program, noting that there is a weak linkage between customer interest and subscription and particular local projects. TURN urged the Commission to provide more time for PG&E to develop the specifics for viable program. TURN also urged the Commission to allow the structure to evolve over time and to consider modifications through an advice letter or petition to modify the final decision. The Decision agrees with TURN that PG&E’s proposal does not provide for a direct link and fails to provide an adequate role for local communities. The Decision also agrees with TURN that more specifics are necessary in order to approve a program for PG&E customers. The Decision directs PG&E to submit additional details in a subsequent advice letter filing. Opening brief of TURN on the Applications of PG&E and SDG&E for approval of a green tariff shared renewables program, March 21, 2014, pages 26-28. Opening brief of TURN on the Enhanced Community Renewables Proposal of PG&E, May 5, 2014, pages 1-5 Reply brief of TURN on the Enhanced Community Renewables Proposal of PG&E, May 9, 2014, page 1 D.15-01-051, pages 60-61 Verified.
APPENDIX Compensation Decision Summary Information Compensation Decision: D1609054 Modifies Decision? Contribution Decision(s): D1501051, D1605006 Proceeding(s): A1201008 Author: ALJ Cooke Payer(s): Pacific Gas and Electric Company, San Diego Gas & Electric, and Southern California Edison Company Intervenor Information Intervenor Claim Date Amount Requested Amount Awarded Multiplier? Reason Change/Disallowance The Utility Reform Network (TURN) 7/18/2016 $213,614.54 $213,614.54 N/A N/A Advocate Information First Name Last Name Type Intervenor Hourly Fee Requested Year Hourly Fee Requested Hourly Fee Adopted Matthew Freedman Attorney TURN 375.00 2012 375.00 Matthew Freedman Attorney TURN 400.00 2013 400.00 Matthew Freedman Attorney TURN 410.00 2014 410.00 Matthew Freedman Attorney TURN 410.00 2015 410.00 Matthew Freedman Attorney TURN 415.00 2016 415.00 Hayley Goodson Attorney TURN 355.00 2014 355.00 Eric Borden Expert TURN 180.00 2015 180.00 Nina Suetake Attorney TURN 315.00 2012 315.00 Marcel Hawiger Attorney TURN 410.00 2014 410.00 John Sugar Expert TURN 205.00 2012 205.00 John Expert TURN 210.00 2013 210.00 (END OF APPENDIX)