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 Energy Savings Target Brightline argued the energy savings goal needed to consider factors other than Brightline supported the 10% energy savings reduction requirement in the Aliso Canyon area during the gas leak emergency. Brightline Opening Brief, 7/6/15, p. 2. D.16-11-022, p. 48-51. Brightline comments on PD/APD adopting measures in response to the Aliso Canyon gas leak, 4/15/16, p. 2. D.16-04-040, p. 25. Verified Go-Back Rule Brightline initially recommended the Commission modify the Go-Back Rule and return to the 8 year standard rather than the 10 year standard. Though the Commission eliminated the Go-Back rule, the 8 year modification was discussed extensively by PG&E and other parties, Brightline supported the elimination of the Rule. Brightline Opening Brief, 7/6/15, p. 2. D.16-11-022, p. 55-56 & 61-62 Brightline comments on the PD/APD, 9/16/16, p. 2-3. D.16-11-022, p. 66. Verified
unspent funds could be used if additional measures were adopted. D.16-11-022, p. 356-357. G. General Brightline pointed out the need for more measures that address the nexus such as toilet and washing machine replacement. Brightline urged the Commission to adopt Commissioner Sandoval’s Alternate Proposed Decision rather than the Proposed Decision writing by Law Judge Colbert. Brightline Opening Brief, 7/6/15, p. 1-2. D.16-11-022, p. 145-147. Brightline comments on the PD/APD, 9/16/16, p. 1-2. Verified Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? Yes Verified c. If so, provide name of other parties: Center for Sustainable Energy, Natural Resources Defense Council, California Housing Partnership Corporation, Greenlining Institute, Energy Efficiency Council, The East Los Angeles Community Union, the Maravilla Foundation, and PG&E. Verified d. Intervenor’s claim of non-duplication: Brightline coordinated with other parties representing low-income and disadvantaged communities to avoid duplication, including the Energy Efficiency Council and the Greenlining Institute. Verified
PART III: REASONABLENESS OF REQUESTED COMPENSATION General Claim of Reasonableness (§ 1801 and § 1806): a. Intervenor’s claim of cost reasonableness: Brightline’s cost of participation is much lower than originally anticipated in its NOI. When compared to the public’s benefits, the cost of participation is reasonable. The Commission authorized ESA budgets close to $400 million per year so the total amount approved will surpass $2 billion (see D.16-11-022, p.38). ESA provides energy services to low-income customers throughout California to both help them lower their utility bills and to improve the health and comfort of these customers, so the value of these programs is difficult to quantify. CPUC Discussion Verified b. Reasonableness of hours claimed: Brightline’s hours are reasonable because of its efforts to coordinate with other parties to avoid duplication. In addition, staff worked diligently to minimize costs by minimizing the time attorneys with higher billable rates spent on the proceeding. No time is claimed for internal coordination, time required to get new staff up to speed, or for travel. Furthermore, the rates requested are conservative. Verified c. Allocation of hours by issue: A. Energy Savings Target = 6.32% B. Go-Back Rule = 14.23% C. Three Measure Minimum Rule = 11.07% D. Introducing/Evaluating Measures = 10.28% E. Program Cycle Length = 4.35% F. Fund Shifting = 3.16% G. Aliso Canyon = 32.41% H. General = 18.18% Verified
Eddie Ahn Attorney Brightline Defense Project $305 2016 $305 Eddie Ahn Attorney Brightline Defense Project $305 2017 $305 Ivan Jimenez Advocate Brightline Defense Project $125 2016 $125 Ivan Jimenez Advocate Brightline Defense Project $125 2017 $125 (END OF APPENDIX)