combining the utility’s evidence, plus that from external sources to provide the Commission with a more complete perspective on how PG&E’s proposed expenditures fit into the broader, long-term context of replacing the utility’s aging distribution system assets. CFC anticipated using the supplementary information assembled to demonstrate that PG&E’s planned expenditures were both inconsistent with the long-term expense trajectory required to sustain the system in good condition, yet also presenting a expenditure spike inconsistent with the avoiding unnecessary rate-shock. Further, CFC examined the reported incident causes affecting PG&E gas distribution, and noted the non-trivial proportion of causes linked to company conduct. CFC argued for some of the steep increased expenditures being rightly recovered from shareholders, because company conduct contributed to the incidences. CFC proposed reducing the Gas Distribution expenses budget by $18.7M, on the basis that, some repairs are directly the result of incorrect operation. Section 191 reports required by, and filed with, the Pipeline and Hazardous Materials Safety Administration (PHMSA) identify leaks caused by CFC- Leak Management Corrective Maintenance Expenses, pp. 3-6 CFC- Leak Management Corrective Maintenance Expenses, pp. 5,6,11,14 CFC- Leak Management Corrective Maintenance Expenses, pp. 2,12 CFC- Leak Management Corrective Maintenance Expenses, pp. 5,6 CFC- Leak Management Corrective contribution to the proceeding. CFC’s alleged contributions on this issue did not assist the Commission’s decisionmaking process. Because of the lack of substantial contribution on this issue, the Commission disallows 75% of CFC’s hours claimed regarding “Gas Distribution Maintenance Expenditures (GDST).”
perspective on essential infrastructure replacement. During discovery, CFC established that PG&E had not determined a long-term funding rate that would suffice in perpetuity. CFC anticipated that covering this matter during an oral presentation may have persuaded the Commission to formally require PG&E to include an “in perpetuity” approach, for the following GRC application. CFC anticipated furthering our argument during oral hearing. CFC recommended reducing the MWC ‘FI’ budget from $90.3M to $71.5M, based on the proportion of repairs reported to PHMSA in categories related to company conduct. The proceeding went to a settlement phase rather than oral hearing. Due to the settlement administration, CFC was not able to fully advance our arguments. Also, PG&E may have been able to produce arguments for why our proposed 50/50 resolution should have been a different apportionment. Instead, CFC participated in negotiating the settlement on Gas Distribution expenditures through TURN. The eventual settlement for Gas Distribution leak management expenses featured a $2.5M reduction. CFC accepted that solution, as it represented the only CFC- Leak Management Corrective Maintenance Expenses, pp. 2,12. D.17-05-013, p.54. The Settlement Agreement adopted PG&E’s position. See D.17-05-013 at 120.
service quality performance to provide consumers and the Commission a published metric, capturing PG&E’s progress toward ensuring all its ratepayers are receiving comparable service quality. Had there been an oral phase, CFC would have argued for institutionalizing the formula adopted as a permanent dimension of reliability reporting for PG&E aimed at ensuring consistent service for all PG&E ratepayers. CFC submitted the detailed formula to PG&E, as part of the Settlement communications. The formula was adopted as part of the Settlement, exactly as defined in CFC’s submission. 3. Liability Insurance (INSL) CFC opposed PG&E’s Excess & Other Liability insurance budget proposal of $55.4M. PG&E’s Liability Insurance expenses have grown at an annualized rate exceeding 20%. Insurance expense is a function of both consequence and frequency, and PG&E’s loss experience has contributed to the premiums the company pays. CFC provided testimony showing that while Northern California property value increases have contributed to the company’s liability exposure, PG&E’s relatively poor loss experience (claims frequency and severity) has primarily caused the steep premium increases the budget proposes covering. CFC testimony also showed how PG&E had offered CFC- Excess and Other Liability Insurance Testimony, pp2, 3. CFC- Excess and Other Liability Insurance Testimony, p.5 CFC- Excess and Other Liability Insurance Testimony, p.5 Verified. The Settlement Agreement adopts half of CFC’s proposed reduction. See D.17-05-013 at 105.
Specific Claim:* Claimed CPUC Award ATTORNEY, EXPERT, AND ADVOCATE FEES Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate $ Total $ Nicole Johnson 2015 68.9 300 D1506062 D1507029 $20,670 51.33 $300 $15,399.00 Nicole Johnson 2016 232.2 305 Resolution ALJ-329 $70,821 191.56 $305 $58,425.80 Nicole Johnson 2017 51.9 310 Resolution ALJ-345 $16,089 45.18 $310 $14,005.80 William Nusbaum 2015 6.5 465 Res. $3,023 6.5 $465 $3,022.50 William Nusbaum 2016 64.8 470 Res. $30,456 47.79 $470 $22,461.30 Tony Roberts 2015 129.3 275 See Note 5 Below $35,558 116.92 $230 $26,891.60 Tony Roberts 2016 457.8 275 See Note 5 Below $125,895 206.32 $235 $48,485.20 Tony Roberts 2017 0.5 275 See Note 5 Below $138 0.5 $240 $120.00 Subtotal: $302,649.5 Subtotal: $188,811.20 INTERVENOR COMPENSATION CLAIM PREPARATION ** Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate Total $ Nicole Johnson 2015 2 $150 $300.00 Nicole Johnson 2017 8.8 155 ½ rate from Res. ALJ-345 $1,364.00 8.8 $155 $1,364.00 Tony Roberts 2017 58.3 137.5 See Note 5 Below $8,016.25 15 $120 $1,800.00 Subtotal: $9,380.25 Subtotal: $3,464.00 TOTAL REQUEST: $312,030.25 TOTAL AWARD: $192,275.20
May 12, 2016 claims total of 15.17 hours for a DR response and writing testimony May 13, 2016 claims total of 20 hours for analysis and writing testimony We disallow all claimed time accrued after the initial 12 hours as excessive, for a total disallowance of 12.5 hours. [10] CFC requests a total of 67.1 hours of compensation for preparation of its Intervenor Compensation Claim. After re-categorizing 2 hours as intervenor compensation claim preparation, CFC spent a total of 69.1 hours preparing this claim. CFC has used the expedited forms available to intervenors to simplify these tasks and is also experienced in the completion of compensation claims. We disallow 43.3 hours of Roberts’ 2017 hours in this category as excessive. PART IV: OPPOSITIONS AND COMMENTS A. Opposition: Did any party oppose the Claim? No B. Comment Period: Was the 30-day comment period waived (see Rule 14.6(c)(6))? No If not: Party Comment CPUC Discussion No comments received. FINDINGS OF FACT Consumer Federation of California has made a substantial contribution to D.17-05-013. The requested hourly rates for Consumer Federation of California’s representatives, as adjusted herein, are comparable to market rates paid to experts and advocates having comparable training and experience and offering similar services. The claimed costs and expenses, as adjusted herein, are reasonable and commensurate with the work performed. The total of reasonable compensation is $192,275.20.