1. Clean Co. opposed PG&E’s motion to hold the RAM solicitations in abeyance, arguing in our Response (29 July 2016) that it will: Lead to higher costs for ratepayers and losses for developers; The RPS is a floor not a ceiling; A recent UCS report suggested that meeting the state’s GHG reduction goals may require a 50% RPS by 2024; PG&E’s argument that further cost reductions may result from further delays in RAM procurement is flawed b/c under this rationale there is always reason to wait for further cost reductions. The Commission issued a ruling on Nov 8, 2016 agreeing with the Clean Coalition and denying PG&E’s motion to hold the auctions in abeyance, stating (Ruling, p. 3): “The procurement of RPS-eligible solar resources that PG&E now seeks to postpone has therefore been authorized, in one programmatic form or another, for more than six years.” The ruling required PG&E to proceed with its two remaining auctions. To be more precise, Clean Coalition’s opposition to PG&E’s motion was on two main grounds: If granted, it will lead to substantial losses for developers and therefore higher costs for ratepayers; and because the Commission has already ordered PG&E to conduct the 2016 and 2017 Renewable Auction Mechanism (RAM) solicitations. 2. Clean Co. opposed PG&E’s Petition for Modification (PFM). The Commission, in ruling on the PFM, agreed with our objections, along with other arguments, and rejected PG&E’s PFM. The Decision agreed with the Clean Co. and denied PG&E’s motion to cancel its RAM auctions (Decision, p. 1): “We deny Pacific Gas and Electric Company’s (PG&E) Petition to Modify Decision (D.) 14-11-042 on the grounds that PG&E has failed to meet its burden set forth in Rule 16.4 (b) of the Commission’s Rules of Practice and Procedure to justify the request relief.” Verified
5. Clean Co. also highlighted the representations that PG&E had made with respect to canceling its PV program and moving that capacity to the RAM program instead, weighing heavily in favor of preserving the remaining capacity in RAM that had been transferred from the PV program (Clean Co. response to PFM, p. 3) The Decision agreed, citing responses by parties (Decision, p. 13): “As the responses have correctly pointed out, the PG&E’s request to close the Solar Photovoltaic Program was tied to PG&E transferring the remaining procurement obligations to RAM. PG&E made assurances that such an outcome would result in procurement that better matches PG&E’s demonstrated RPS need, which is later in the decade and beyond. We hold PG&E to these representations and, as a result, see no reason to defer the procurement of RPS-eligible solar resources through RAM.” 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 Yes b. Were there other parties to the proceeding with positions similar to yours? Yes Yes c. If so, provide name of other parties: Sierra Club, SEIA and ORA. Verified to the extent to which these statements refer to Sierra Club’s and SEIA’s positions. As D.17-08-025 noted, the ORA supported PG&E’s PFM.
Specific Claim:* CLAIMED CPUC AWARD ATTORNEY, EXPERT, AND ADVOCATE FEES Item Year Hour s Rate $ Basis for Rate* Total $ Hours Rate $ Total $ Hunt 2016 6.75 375 D.16-06-049 2,531.25 6.75 $375.00 $2,531.25 Hunt 2017 4.5 385 Res. ALJ-345 1,732.50 4.50 $385.00 $1,732.50 White 2016 8.5 300 D.16-08-014 2,550.00 8.5 $300.00 $2,550.00 White 2017 9.75 315 Res. ALJ-345 3,071.25 9.75 $315.00 $3,071.25 Subtotal: $ 9,885.00 Subtotal: $ 9,885.00 OTHER FEES Describe here what OTHER HOURLY FEES you are Claiming (paralegal, travel **, etc.): Item Year Hour s Rate $ Basis for Rate* Total $ Hours Rate Total $ Ramsey 2016 1 205 D.16-11-017 205 1.00 $205.00 $205.00 Ramsey 2017 1.5 205 D.16-11-017 307.50 1.50 $205.00 $307.50 Subtotal: $512.50 Subtotal: $512.50 INTERVENOR COMPENSATION CLAIM PREPARATION ** Item Yea r Hour s Rate $ Basis for Rate* Total $ Hours Rate Total $ Hunt 2017 5 193 Res. ALJ-345 963 5.00 $192.50 [A] $962.50 White 2017 1 157.5 Res. ALJ-345 157.5 1.00 $157.50 $157.50 Subtotal: $1120.50 Subtotal: $1,120.00 COSTS # Item Detail Amount Amount TOTAL REQUEST: $11,518.00 TOTAL AWARD: $11,517.50