business interests in the PA’s solicitation processes. In addition, SBUA supported ORA, Verified, and Green Fan’s proposals for a more independent workpaper process in order to encourage the development of new technologies that could be transformative for small commercial customers. Although the Commission recognized this as an important issue, it decided to consider the potential for an independent workpaper process in a future proceeding but required PAs to accept and review all third party workpapers in the meantime. discretion.”). Decision, Sec. 3.10.4 Workpaper Issues, p. 49 (“We acknowledge there could be benefits to full consideration of [workpaper] issues, but intend to undertake such further consideration in the energy efficiency rulemaking (R.13-11-005 or its successor) in the future. In the meantime, the program administrators are required to accept and review all third party workpapers before submission to the Commission.” Finding of Facts, Paragraph 11, p. 54 (“Participation in PRGs is an eligible activity for intervenor compensation, subject to the limitations in that program.”). Conclusions of Law, Paragraph 11, p. 57 (“Each utility should have at least one PRG, with members who are not financially in solicitation results and represent diverse stakeholder interests, to provide feedback during the third party solicitation process. The PRGs should be involved at all stages of the solicitation process. PRG participation should be eligible for intervenor compensation.”). Conclusions of Law, Paragraph 13, p. 58 (“The Energy Division Director should approve of the composition of the PRGs for each utility.”). References to Claimant’s Presentations:
SBUA Comments on PD; see, e.g., p. 9 ("[T]he final solicitation process decision should make it clear that Energy Division is responsible not only for reviewing the individual qualifications of PRG members proposed by the PAs but also for ensuring that PRG members represent diverse market segments and interests.”). SBUA Solicitation Process Opening Comments see, e.g., pp. (comments supporting use of new PRGs and IEs with a diverse range of experience including individuals with small business expertise). SBUA Reply Comments on Comprehensive Solicitation Process Proposals; see, e.g., pp. 3-4 (comments on PRC Composition, including “[PRGs] should be comprised of interested stakeholders and [...] should include consumer advocates. Commission should therefore direct that a new PRG be formed that the PRG include consumer advocates for various groups, with at least 1 member representing the interests of the small business community.”), p. 6 (comments on the necessity of an independent workpaper process to encourage transformative technologies for the small business sector). 3. Expanding contracting opportunities for small businesses. References to Final Solicitation Process Decision: Verified
Throughout its involvement in the proceeding, SBUA took all reasonable steps to coordinate its efforts with other parties and keep unnecessary duplication to a minimum. SBUA representatives engaged in multi-party discussions, including with ORA and other intervenors, and workshops covering the solicitation process in order to identify areas of overlap and minimize repetitive comments. Where SBUA agreed with other parties’ positions, rather than going through lengthy independent analyses, SBUA made short statements of support. Examples include our coordination with and support of parties advocating for an independent work paper review process and our support of Commission review requirements proposed by other parties. See e.g. SBUA Solicitation Process Reply Comments p.4 (supporting MCE/BayREN comments on coordination) p.6 (supporting ORA and Verified workpaper proposals). Additionally, SBUA’s advocacy differed from that of other ratepayer advocates in that it focused exclusively on the interests of small business community. For example, while ORA’s, TURN’s, and NRDC’s advocacy primarily related to general solicitation design and overall cost effectiveness, SBUA was the only party to raise equity issues specifically relating to small commercial customers. Therefore, while other parties may have had positions that were similar to SBUA in some instances, our perspectives and goals were necessarily different, and were supplemented, not duplicated, by efforts on common issues. Additional Comments on Part II: # Intervenor’s Comment CPUC Discussion Sections A & B SBUA has reviewed its work thus far in the EE Business Plan Proceeding in order to identify the tasks necessary to advance SBUA’s positions and with a direct bearing on the Solicitation Process Decision. Only those activities reasonably relating to the Solicitation Process have been included in this request. SBUA’s other activities relating to the EE Business Plans will be covered in a separate request for intervenor Noted
Specific Claim:* Claimed CPUC Award ATTORNEY, EXPERT, AND ADVOCATE FEES Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate $ Total $ Kathryn 2017 46.7 $230 ALJ-345 $10,741 46.70 $230.00 $10,741.00 James 2017 26.3 $450 2015 rate from ALJ-329 (1.28% COLA), ALJ-345 (2.14% COLA), plus first 5% step increase in the 13+ year experience tier (rounded to nearest $5) $11,835 26.30 $450.00 $11,835.00 James 2018 1.5 $450 As above. $675 1.50 $460.00 [B] $690.00 Subtotal: $23,251.00 Subtotal: $23,266.00 INTERVENOR COMPENSATION CLAIM PREPARATION ** Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate Total $ Kathryn 2018 10.5 $115 50% of 2018 rate $1,207.50 10.50 $117.50 [A] $1,233.75 James 2017 1.8 $225 50% of 2017 rate $405 1.80 $225.00 $405.00 James 2018 7.7 $225 50% of 2018 rate $1,732.50 7.70 $230.00 [B] $1,771.00 Subtotal: $3,345.00 Subtotal: $3,409.75 TOTAL REQUEST: $ 26,596.00 TOTAL AWARD: $26,675.75