4. Was the NOI timely filed? Yes Showing of eligible customer status (§ 1802(b) or eligible local government entity status (§§ 1802(d), 1802.4): 5. Based on ALJ ruling issued in proceeding number: A.16-09-001 Verified 6. Date of ALJ ruling: October 27, 2017 Verified 7. Based on another CPUC determination (specify): 8. Has the Intervenor demonstrated customer status or eligible government entity status? Yes Showing of “significant financial hardship” (§1802(h) or §1803.1(b)) 9. Based on ALJ ruling issued in proceeding number: A.16-09-001 Verified 10. Date of ALJ ruling: October 27, 2017 Verified 11. Based on another CPUC determination (specify): 12. 12. Has the Intervenor demonstrated significant financial hardship? Yes Timely request for compensation (§ 1804(c)): 13. Identify Final Decision: D.18-01-024 Verified 14. Date of issuance of Final Order or Decision: January 17, 2018 Verified 15. File date of compensation request: March 19, 2018 Verified 16. Was the request for compensation timely? Yes PART II: SUBSTANTIAL CONTRIBUTION Did the Intervenor substantially contribute to the final decision (see § 1802(j), § 1803(a), 1803.1(a) and D.98-04-059). Intervenor’s Claimed Contribution(s) Specific References to Intervenor’s Claimed Contribution(s) CPUC Discussion Small Business Utility Advocates (SBUA) actively participated in the Priority Review Projects (PRPs) portion of the proceeding, including in discovery, by submitting an Opening brief, by joining workshops and D.18-01-024 (“Final Decision”). Opening Brief of SBUA on the Priority Review Transportation Electrification Proposal from SDG&E, SCE, and PG&E, served on June 16, 2017 (“SBUA Opening Brief”). Verified
discussions with other parties, including the May 17, 2017 Priority Review Workshop, by submitting Opening and Reply comments on the Proposed Decision by ALJs Goldberg and Cooke, and by engaging in meetings with the Energy Division and ex parte meetings with Commission staff. SBUA supported the PRPs in general and specifically recommended modifications to improve their effectiveness. SBUA continually advocated for the PRPs to include more robust data reporting to develop lessons learned, to increase marketing and outreach (M&O), and to allow for greater participation by small businesses in the TE process. SBUA also argued for diverse representation on the Program Advisory Councils (PAC), enhanced contracting opportunities for small businesses, and special rates for small commercial customers to promote electric vehicle (EV) adoption in one of the SDG&E PRPs. In D.18-01-024, the Commission addresses in some capacity all of the major issues that SBUA advocated for, while a few issues are left for further consideration with PACs, the Standard Review Projects (SRP), or other Commission proceedings (e.g., whether to adopt a special EV rate for small commercial customers). SBUA submits that small SBUA Opening Comments on the Proposed Decision of ALJs Sasha Goldberg and Michelle Cooke, served on Dec. 12, 2017, (“SBUA Comments on PD”). SBUA Reply Comments on PD, served on Dec. 18, 2017 (“SBUA Reply Comments on PD”). SBUA’s Motions for Party Status for A.17-01-20, A.17-01-21, and A.17-01-22, respectively, served on March 14, 2017 (“SBUA’s Motions for Party Status”) (highlighting importance of small business representation in TE proceedings, including with regard to PRPs). See also Attachment 1, Hourly Records of attorney Lillian Rafii, including participation in PRP meetings, ex parte meetings with Commission staff regarding PRPs, and meetings with Energy Division; see also, e.g., SCE Reply Brief on PRPs, served on July 10, 2017, p. 2 (SCE cites for support SBUA’s position in favor of proposed portfolio of priority review projects).
customers. SBUA therefore recommended that the utilities analyze and collect additional reporting data to optimize the lessons learned from the PRPs and maximize the SB 350 goal of accelerating widespread TE across customer classes. SBUA’s advocacy also included engaging with the Commission’s Energy Division to provide input on creating and formatting the qualitative and quantitative data templates on the current TE market to inform the utilities on the small commercial customer participation. In the Final Decision, the Commission directed Energy Division staff (see pp. 95-96) to develop final reporting templates “in consultation with the utilities and the PACs.” D.18-01-024 includes language that emphasizes the importance of gathering data to evaluate current gaps in information and to measure widespread EV adoption, including with final report templates that include metrics on small businesses. of producing “data concerning the current and future TE market”). Final Decision, p. 95 (referencing PRP reporting templates at www.cpuc.ca.gov/sb350te, which templates now include metrics for “small business participation”); Order, Paragraph 35, p. 116 (utilities “must utilize the current data gathering template available on the Commissions’ website (http://www.cpuc.ca.gov/sb350te/) under the “reporting requirements” section of this page.”). References to Claimant’s Presentations: SBUA Opening Brief, pp. 5-6, 11, 13 (advocating for additional studies, information, and reporting on for all customers, including small business and their adoption levels of EVs), 14. SBUA Comments on PD, pp. 7-9, (final reporting templates should include metrics on small business participation and satisfaction). SBUA Reply Comments on PD, pp. 1-4 (advocating for enhanced metrics on the final reporting templates to avoid inadvertently excluding small business participation, and supporting similar recommendations from ChargePoint, East Yard Communities for Environmental Justice, Center for Community Action and Environmental Justice, Sierra Club, and Union of Concerned Scientists). Attachment 1, Hourly Records of
Presentations: SBUA Opening Brief, pp. 3, 5 (“collectively the PRPs for each utility should be designed to ensure a significant degree of participation by and consideration of small commercial customers”), 8, 12. SBUA Comments on PD, pp. (“To ensure small business stakeholders have a voice, each PAC should include as part of its diversity mandate small business representatives”). See also Attachment 1, Hourly Records of attorney Lillian Rafii, including participation in SDG&E’s first PAC meeting (see, e.g., entry on Mar. 9, 2018). 3. Marketing and Outreach / Customer Engagement SBUA advocated to increase the participation of customers with enhanced marketing, education, and outreach measures, including with PG&E’s Open RFP. SBUA’s recommendations were intended to address barriers within the small business community and to improve the widespread adoption of TE. SBUA proposed measures that would increase customer awareness of TE and also increase infrastructure siting decisions to attract and promote small business exposure to EVs. In SBUA’s briefing and ex parte References to Final Decision: Final Decision, pp. 14 (ACR mandate to explain any marketing and outreach components of the PRPs), 84-85 (PG&E Open RFP not adopted but PG&E should “develop criteria and procedures for its RFP in conjunction with its PAC”). Order, Paragraph 23, p. 108 (rejecting PG&E Open RFP on which SBUA advocated for changes to increase marketing and outreach to small businesses); compare with PG&E Reply Brief, served on July 10, 2017, p. 10 (arguing against SBUA’s recommendation changes to PRPs Verified
SCE site at least two out of five of its Urban DCFC Cluster pilot sites that directly promote access to small businesses). 4. Other Issues (Competition / Contracting / Small Commercial Rate) Competition / Contracting. SBUA raised concerns regarding competition on the utility ownership model for nonutility enterprises and advocated for increased customer choice. SBUA further supported other parties’ and ORA’s positions in this regard. See ORA’s Opening Brief on PRPs, served on June 16, 2017, p. 9 (“SDG&E’s portfolio does not encourage private investment and unfairly competes with nonutility enterprises”). SBUA consistently advocated for increased direct contracting opportunities and supplier diversity for small business vendors over the course of the planned PRP program implementation. This position was echoed by other parties, including the National Diversity Coalition and Greenlining Institute, both of which recommended attracting drivers to minority-owned businesses that also have overlapping constituents in the small business community. The Final Decision included a directive for SDG&E to partner the remainder of their Fleet Delivery Services Program with diverse and local enterprises, References to Final Decision: Final Decision, pp. 15 (the utility ownership model should be piloted during these initial TE programs to “compare a variety of models to identify and address the different barriers associated with certain market segments.”), 28 (SDG&E to identify and partner with minority-owned business enterprises/women-owned business enterprises and/or locally-owned fleets), 43 (the Commission decided to consider whether to approve SDG&E’s Commercial Grid-Integration Rate, through the Standard Review Project track and “[f]or the approved Fleet Delivery Services Program, SDG&E is directed to work with participating customers to determine the most appropriate available rate at the time of implementation.”). References to Claimant’s Presentations: SBUA Opening Brief, pp. 5 (recommending “careful consideration of new small commercial customer rates to promote EV adoption”), 7 (utility ownership of charging stations eliminates “the potential for a small commercial customer to do so”), 10 (recommending SDG&E spend at least 50% of the Green Taxi/Shuttle/Rideshare program funds on small businesses given their significant representation in the service region), 13 Verified