“A final decision closing proceeding R.10-05-006 has not been issued. Therefore, the request is timely pursuant to Public Utilities Code § 1804(c).” The Commission should apply the same standard to the instant request by finding that Reid’s request is timely under PU Code § 1804(c). PART II: SUBSTANTIAL CONTRIBUTION Did the Intervenor substantially contribute to the final decision (see § 1802(i), § 1803(a), and D.98-04-059). Intervenor’s Claimed Contribution(s) Specific References to Intervenor’s Claimed Contribution(s) CPUC Discussion 1. Additional Security Reid recommended that “The Commission should not require any additional security from projects that have received a Phase 1 study but have left the interconnection queue while bidding into BioMAT.” (Comments of L. Jan Reid on the Bioenergy Feed-In Tariff, August 24, 2016 (Reid FIT Comments), p. 1) Although the Commission did not adopt Reid’s recommendation, Reid made a substantial contribution to the Commission’s resolution of the Additional Security issue. Verified 2. Developer Refunds Reid recommended that “The Commission should order that the BioMAT deposits shall be refunded to the project developer only if the developer has executed a BioMAT contract with an IOU.” (Reid FIT Comments, p, 1) The Commission agreed with Reid when it ordered that “the deposit [is] to be refunded upon the developer’s execution of a BioMAT standard contract with the IOU.” (D.16-10-025, slip op. at 3) Verified
Comments at 4.) This position incorrectly relies on language in Section 399.15(b)(2)(B) that addresses years after 2030. Reid applies the word “subsequent” to the years 2016-2020, rather than the clear application of “subsequent” to mean the years following 2030.” D.16-12-040 at footnote 6. 6. Additional Compliance Periods Reid argued that “It is not reasonable for the Commission to attempt to plan compliance filings more than fourteen years into the future. It is important that the Commission maintain its flexibility to adjust to changing conditions in the RPS program. Therefore, the Commission should not establish additional compliance periods beyond 2030 because the legislature may change the RPS requirements after 2030 and/or may significantly change other elements of the RPS program. Either of these changes would affect the compliance periods.” (Reid SB350 Comments, p. 5) Although the Commission did not adopt Reid’s recommendation, Reid made a substantial contribution to the Commission’s resolution of the Additional Compliance Periods issue. Not Verified. “Reid’s argument that Commission cannot set PQRs for these compliance periods because it lacks authority appears to be based on the SB 2 (1x) language of prior Section 399.15(b)(2)(B), not on SB 350’s language for that section.” D.16-12-040 at footnote 14. 7. Procurement Quantity Requirements Reid recommended that “The Commission should not treat the procurement quantity requirements (PQRs) for the three compliance periods through 2030 differently from the PQRs established for the compliance periods through 2020.” Verified
this proceeding are available in Attachment A to this pleading. The cost listings demonstrate that the hours claimed are reasonable given the scope and timeframe of this part of the instant rulemaking. No compensation for administrative time is requested, in accordance with Commission practice. (D.99-06-002, discussion, slip op. at 8-10). I understand that the Commission may audit my books and records to the extent necessary to verify the basis for any award, pursuant to PU Code §1804(d). c. Allocation of hours by issue: Verified Specific Claim:* Claimed CPUC Award ATTORNEY, EXPERT, AND ADVOCATE FEES Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate $ Total $ L. Jan Reid, Expert and Advocate 2016 70.6 225 D.16-11-020, Appendix A, Advocate Information, Hourly Fee Adopted. 15,885.00 $225.00 $15,435.00 Subtotal: $15,885.00 Subtotal: $15,435.00 INTERVENOR COMPENSATION CLAIM PREPARATION ** Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate Total $ L. Jan Reid 2017 4.9 112.50 D.16-11-020, Appendix A, Advocate Information, Hourly Fee Adopted. 551.25 4.9 $112.50 $551.25 Subtotal: $551.25 Subtotal: $551.25