Word Document PDF Document

ALJ/TJS/gd2 Date of Issuance 5/29/2012

Decision 12-05-034 May 24, 2012

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking to Consider Smart Grid Technologies Pursuant to Federal Legislation and on the Commission's own Motion to Actively Guide Policy in California's Development of a Smart Grid System.

Rulemaking 08-12-009

(Filed December 18, 2008)

DECISION GRANTING REQUEST OF THE UTILITY REFORM NETWORK FOR INTERVENOR COMPENSATION FOR SUBSTANTIAL CONTRIBUTIONS TO DECISION (D.) 09-09-029, D.09-12-046, D.10-06-047, AND D.11-07-056

Claimant: The Utility Reform Network (TURN)

For contributions to: D.09-09-029, D.09-12-046, D.10-06-047, and D.11-07-056

Claimed: $119,996.34

Awarded: $117,964.34

Assigned Commissioner: Michael Peevey

Assigned ALJ: Timothy Sullivan

Claim Filed:

September 27, 2011

PART I: PROCEDURAL ISSUES

A. Brief Description of Decision:

D.09-09-029 adopted policies for utility cost recovery of projects which would be submitted to the Department of Energy (DOE) for grants under the American Recovery and Reinvestment Act of 2009 (ARRA).

D.09-12-046 addresses various requirements instituted by the Energy Information and Security Act (EISA) of 2008 and concludes that California does not need to adopt specific policies concerning smart grid due to prior state action and/or inconsistency with state policies.

D.10-06-047 adopted specific guidance for the content of utility smart grid deployment plans required pursuant to SB 17, adopted a process for reviewing the plans and any smart grid capital investments, and ordered further review of privacy and policy issues.

D.11-07-056 adopted privacy and security rules concerning utility use and release of customer usage data to utility contractors and/or third parties, and provided guidance on the provision of customer usage and price data to customers.

B. Claimant must satisfy intervenor compensation requirements set forth in Public Utilities Code §§ 1801-1812:

 

Claimant

CPUC Verified

Timely filing of notice of intent (NOI) to claim compensation (§ 1804(a)):

1. Date of Prehearing Conference:

March 27, 2009

Correct

2. Other Specified Date for NOI:

   

3. Date NOI Filed:

April 24, 2009

Correct

4. Was the notice of intent timely filed?

 

Showing of customer or customer-related status (§ 1802(b)):

5. Based on ALJ ruling issued in proceeding number:

R.08-12-009

Correct

6. Date of ALJ ruling:

May 13, 2009

Correct

7. Based on another CPUC determination (specify):

n/a

 

8. Has the claimant demonstrated customer or customer-related status?

Yes

Showing of "significant financial hardship" (§ 1802(g)):

9. Based on ALJ ruling issued in proceeding number:

R.08-12-009

Correct

10. Date of ALJ ruling:

May 13, 2009

Correct

11. Based on another CPUC determination:

N/a

 

12. Has the claimant demonstrated significant financial hardship?

Yes

Timely request for compensation (§ 1804(c)):

13. Identify Final Decision

D.11-07-056

Correct

14. Date of Issuance of Final Decision:

July 29, 2011

Correct

15. File date of compensation request:

September 27, 2011

Correct

16. Was the request for compensation timely?

Yes

PART II: SUBSTANTIAL CONTRIBUTION

A. Claimant's description of its contribution to the final decision (see § 1802(i), § 1803(a) & D.98-04-059)

Contributions to D.09-09-029

Citation to Decision or Record (Provided by Claimant)

Showing Accepted by CPUC

Cost Recovery - Rebuttable Presumption: TURN provided legal analysis arguing that the "rebuttable presumption" that an analysis submitted to the DOE (for an approved project) is accurate violates statutory requirements.

TURN Comments on Proposed Decision (PD), August 10, 2009, at 2-10.

The Commission changed the `rebuttable presumption' language in the proposed decision to limit it to a presumption of the reasonableness of the DOE "analysis."

D.09-09-029, at 21 (describing TURN's position)

The Commission rejected TURN's arguments concerning the reasonableness of relying on DOE data and analysis, but did not adopt a "rebuttable presumption" of reasonableness. Required Advice Letter filing with review by ED.

D.09-09-029, at 24-27, 34-36.

Yes

Cost Recovery: TURN opposed the authorization of a memo account to book incremental costs for any projects submitted to the DOE but not approved, and opposed using an Advice Letter process for reasonableness review.

TURN also opposed utility balancing account proposals.

TURN Comments on ACR, June 17, 2009, at 7-9; and Reply Comments, June 29, 2009, at 5-6.

D.09-09-029, at 28-29 (describing TURN's position)

The Commission authorized memo accounts, and stated that information submitted to the DOE is "likely" to prove adequate, but rejected an AL process and required an application to allow CPUC review ("the complex information contained in the DOE application is best reviewed by this Commission through an application process - not through an advice letter.")

D.09-09-029, at 31-32.

Yes

Contributions to D.09-12-046

   

Baseline: TURN urged the Commission to develop a baseline for assessing Smart Grid (SG) investments and an inventory of present assets.

February 9, 2009, at 2.

This issue was addressed subsequently in D.10-06-047, at 21-22.

Yes

Definition of SG: TURN at first recommended defining SG, but subsequently recommended focusing on the functionalities of a SG and holding workshops.

TURN Reply Comments, March 9, 2009, at 5-7.

The Commission ordered a series of workshops to address the various functional aspects of a smart grid.

Yes

Proposed EISA Policies on Cost Recovery: TURN recommended against adopting any of the standards, including:

TURN recommended against specific requirements that IOU must consider smart grid investments due to lack of basic definitions, but recommended an evaluation of alternatives to ensure against stranded costs.

TURN recommended against any changes in ratemaking regarding cost recovery of SG investments.

Cost recovery of abandoned plant should be addressed on a case-by-case basis.

TURN Comments, February 9, 2009, at 6-9.

TURN Comments, October 26, 2009, at 2-7.

The CPUC declined to adopt any of these standards.

Joint Ruling, September 28, 2009.

D.09-12-046, Sec. 4, at 19-39 (also summarizing TURN's positions).

Yes

Price and Usage Information: TURN recommended against adopting the federal standard.

TURN Comments, October 26, 2009 at 8-10.

CPUC agrees, though reaffirms California goal to provide near real-time and wholesale price information.

D.09-12-046, at 50-51.

Yes

TURN recommended that the CPUC initiate a separate phase to address privacy and security issues relevant to data access by customers and third parties.

TURN Comments, February 9, 2009, at 9-11.

TURN Comments, October 26, 2009, at 10-14.

CPUC orders next phase to address cost and privacy issues. Specific issues addressed later.

D.09-12-046, at 54, 65, 69.

Yes

Contributions to D.10-06-047

   

Privacy: TURN recommended that the Commission open a separate phase to explicitly address privacy concerns and adopt appropriate rules to protect data privacy.

The CPUC agreed that additional information is needed and ordered a subsequent phase to address privacy issues

D.10-06-047, at 10, 118; Ordering Paragraph 16, at 145.

Yes

Review of Smart Grid Deployment Plan (SGDP): TURN supported review of deployment plans in a single proceeding, facilitating participation by many parties and allowing comparison of utilities' different strategies.

TURN Opening Comments, March 9, 2009, at 3.

CPUC agreed with position of TURN (and many other parties) to review in a single proceeding.

D.10-06-047, at 88.

Yes

Review of SG investments (Sec. 4.3): TURN recommended that any actual request for cost recovery of capital investments must be reviewed in a separate application or the general rate case. TURN expressed a preference for the GRC.

The Commission agreed that no investments would be authorized in the SGDP and that authorization could be sought in a separate application or the rate case. Sec. 4.3.2, at 95.

Agreed with TURN's position in principle. ("Finally, we agree that Smart Grid investments may be best considered in rate cases and prefer that IOUs propose Smart Grid investments as part of their GRCs. However, for the reasons cited above, it is impractical to adopt this as a procedural requirement because of the timing of GRCs and because of the likely need to make investments to facilitate the timely disclosure of information on usage and prices to customers.")

D.10-06-047, at 114.

Yes

Demarcation Point for Utility Investments: TURN supported a clear demarcation point so as to prohibit utility investments in equipment on the customer side of the meter, and so as to more easily evaluate the costs and benefits of SG.

While the CPUC declined to adopt a demarcation point based on insufficient record, it agreed to review this issue when SGDP are submitted, and it directed the utilities to "fully explain and justify" any proposed investments on the customer side of the meter.

D.10-06-047, at 109.

Yes

Contributions to D.11-07-056

   

TURN supported adopting the Fair Information Practices as a policy blueprint.

D.11-07-056, at 16 (summary of TURN position)

Yes

Scope: TURN recommended the proposed rules apply to gas utilites and aggregators.

CPUC rejected recommendation based on original scoping, but implemented new phase to address gas utilites, ESPs and other entities.

D.11-07-056, at 45-46.

Yes

Data Transfer by Utility to Agents/Contractors: TURN supported the rules proposed by Center for Democracy & Technology and the Electronic Frontier Foundation (CDT/EFF) for data transfer to third parties. TURN supported with some clarifications concerning `secondary purpose.'

The Commission adopted the proposed rules with some modifications, including TURN's proposed clarification.

D.11-07-056, Sec. 5.6 generally, and, esp. at 82.

Yes

Transfer of backhaul data to third parties: TURN recommended registration as the preferred option. TURN supported explicit customer authorization with automatic expiration. TURN supported education concerning data implications prior to any

CPUC ordered utilities to file applications with cost recovery and registration proposals for third party access to backhaul data.

CPUC rejected automatic expiration but required annual reminder as reasonable alternative.

D.11-07-056, at 81, 114-115.

Yes

TURN recommended the CPUC adopt more detailed privacy tariff language.

The Commission concluded that any details can be addressed via subsequent Tier 2 advice letter filings.

D.11-07-056, at 95 (summarizing TURN position) and at 96-97 (Sec. 5.9.2).

Yes

Provision of actionable price and usage data to customers: TURN supported provision of bill-to-date, bill forecast and tier crossing information, as well as a rate calculator for residential customers.

D.11-07-056, at 101-102 (summary of TURN position)

CPUC agrees that IOUs should provide certain actionable price and usage data. Rejects rate calculator.

D.11-07-056, at 103.

Yes

Other price data:

TURN opposed provision of wholesale price data to residential customers.

TURN opposed provision of real-time data to residential customers.

Orders collaboration with Independent System Operator to evaluate feasibility of providing wholesale prices.

Orders pilot study to explore providing real-time prices.

Yes

Third party access to data through 500 Home Area Network (HAN): TURN opposed HAN activation as premature, and opposed the HAN pilot based on utility costs.

CPUC ordered a HAN pilot but noted that funding for the roll out of an activated HAN has already been approved.

D.11-07-056, at 117.

Yes

B. Duplication of Effort (§§ 1801.3(f) & 1802.5):

 

Claimant

CPUC Verified

a. Was the Division of Ratepayer Advocates (DRA) a party to the proceeding?

Yes

Correct

b. Were there other parties to the proceeding?

Yes

Correct

c. Name of other parties:

    The service list for this proceeding provides a long list of intervenors, representing vendors, vendor associations and representatives, consumer groups, environmental groups, and privacy rights advocates.

Yes1

d. Claimant's description of how it coordinated with the DRA and other parties to avoid duplication or how Claimant's participation supplemented, complemented, or contributed to that of another party:

    TURN worked closely with other parties and held several telephonic and in-person meetings in order to coordinate positions and share work, especially on issues concerning privacy. In this proceeding, TURN coordinated with both DRA and other intervenors, including Utility Consumers' Action Network (UCAN), Consumer Federation of California (CFC), CDT, and EFF. A review of the attorney hourly time entries shows multiple telephonic meetings to discuss issues and work coordination. TURN also hosted an in-person meeting to discuss privacy issues, coordinate positions and coordinate workload.

    Coordination among parties both improved substantive policy positions and also reduced the hours of TURN's participation. For example, TURN filed joint pleadings with CFC (October 26, 2009) and with CDT/EFF/UCAN on privacy issues, where we had a shared position and analysis. TURN also did not devote significant time to the policy framework for privacy, as CDT/EFF took the lead role on explaining the application of Fair Information Practices to CPUC rules. TURN was able thus to focus on more details concerning proposed language, as well as issues related to the provision of price and usage data to customers. TURN coordinated especially with CDT, EFF, DRA and UCAN on these issues.

Yes

C. Claimant's Additional Comments on Part II:

#

Comment

1

While TURN has segregated different recommendations by Decision, we note that due to multiple intervening events (ARRA, SB 17, etc.) the scope of this proceeding was modified several times. Thus, the discussion of certain issues and topics (e.g. privacy, cost recovery, cost effectiveness) was not neatly segregated for each decision. More specifically, TURN addressed issues such as privacy, cost effectiveness and cost recovery in several pleadings that spanned the different phases of the proceeding and ultimately impacted more than one decision. Thus, TURN's reference to the record supporting each recommendation and Commission action may not fully cover TURN's analyses and showings on each issue.

2

While TURN did not prevail on all issues, we believe that the extent of our success in providing recommendations and analyses that were adopted by the Commission or assisted the CPUC in its deliberations supports compensation for all of our time and expenses in this proceeding. The primary issue on which TURN's recommendations were not adopted concerned the provision of wholesale and real-time price data to residential customers. However, the Commission did adopt our basic policy recommendation of focusing on the provision of "actionable" information to electricity consumers.

PART III: REASONABLENESS OF REQUESTED COMPENSATION

A. General Claim of Reasonableness (§§ 1801 & 1806):

Explanation by Claimant of to how the cost of Caimant's participation bore a reasonable relationship with benefits realized through participation

CPUC Verified

The issues addressed in the various decisions concerned policies related to privacy of customer usage data, cost recovery for smart grid investments and utility provision of various usage and price data to customers.

It is not possible to quantify the benefits of TURN's participation in this proceeding. Some of the issues involved strictly policy matters (e.g., privacy). TURN advocated for several policy/ratemaking mechanisms concerning cost recovery and reasonableness review of smart grid utility investments and smart grid pilot projects that should eventually result in financial benefits to utility customers.

Yes

B. Specific Claim:*

Claimed

CPUC Award

ATTORNEY AND ADVOCATE FEES

Item

Year

Hours

Rate

Basis for Rate

Total $

Year

Hours

Rate

Total $

Michel Florio

2009

1.75

$535.00

D.09-11-029

$936.25

2009

1.75

$535.00

$936.25

Marcel Hawiger

2009

88.00

$325.00

D.08-08-027

$28,600.00

2009

88.00

$325.00

$28,600.00

Marcel Hawiger

2010

162.75

$350.00

D.11-09-037

$56,962.50

2010

162.75

$350.00

$56,962.50

Marcel Hawiger

2011

27.25

$350.00

Res. ALJ-267

$9,537.50

2011

27.25

$350.00

$9,537.50

Robert Finkelstein

2009

5.25

$470.00

D.09-10-051

$2,467.50

2009

5.25

$470.00

$2,467.50

Robert Finkelstein

2010

0.75

$470.00

D.10-09-042

$352.50

2010

0.75

$470.00

$352.50

Hayley Goodson

2009

1.50

$280.00

D.09-10-051

$420.00

2009

0.00

$280.00

0.00

William Nusbaum

2010

7.00

$435.00

 

$3,045.00

2010

7.00

$435.00

$3,045.00

Nina Suetake

2009

10.75

$280.00

D.10-11-032

$3,010.00

2009

5.25

$280.00

$1,470.00

Subtotal: $105,331.25

Subtotal: $103,371.25

EXPERT FEES

Item

Year

Hours

Rate

Basis for Rate

Total $

Year

Hours

Rate

Total $

Barbara Alexander

2009

57.75

$120.00

D.10-11-032

$6,930.00

2009

57.75

$120.00

$6,930.00

Barbara Alexander

2010

18.75

$120.00

 

$2,250.00

2010

18.75

$120.00

$2,250.00

Barbara Alexander

2011

4.00

$120.00

 

$480.00

2011

4.00

$120.00

$480.00

Gayatri Schilberg

2009

5.86

$200.00

D.10-11-032

$1,172.00

2009

5.86

$200.00

$1,172.00

Gayatri Schilberg

2011

2.26

$200.00

 

$452.00

2011

2.26

$200.00

$452.00

Subtotal: $11,284.00

Subtotal: $11,284.00

INTERVENOR COMPENSATION CLAIM PREPARATION**

Item

Year

Hours

Rate

Basis for Rate

Total $

Year

Hours

Rate

Total $

Marcel Hawiger

2010

0.50

$175.00

 

$87.50

2010

0.50

$175.00

$87.50

Marcel Hawiger

2011

10.50

$175.00

Res. ALJ-267

$1,837.50

2011

10.50

$175.00

$1,837.50

Nina Suetake

2009

1.00

$140.00

 

$140.00

2009

1.00

$140.00

$140.00

Subtotal: $2,065.00

Subtotal: $2,065.00

COSTS

#

Item

Detail

Amount

 

Amount

1

Consultant Travel

Transportation and Lodging

$1,180.57

 

$1,148.57

2

Copies

 

$38.60

 

$38.60

3

Lexis

 

$26.82

 

$26.82

4

Phone

 

$30.10

 

$30.10

5

Working Meals

 

$40.00

 

$0.00

Subtotal: $1,316.09

Subtotal: $1,244.09

TOTAL REQUEST: $119,996.34

TOTAL AWARD: $117,964.34

* We remind all intervenors that Commission staff may audit their records related to the award and that intervenors must make and retain adequate accounting and other documentation to support all claims for intervenor compensation. Claimant's records should identify specific issues for which it requested compensation, the actual time spent by each employee or consultant, the applicable hourly rates, fees paid to consultants, and any other costs for which compensation was claimed. The records pertaining to an award of compensation shall be retained for at least three years from the date of the final decision making the award. 

** Reasonable claim preparation time and travel time typically compensated at ½ of preparer's normal hourly rate.

C. Additional Comments on Part III:

#

TURN

CPUC

Comment

1

X

 

Allocation of Time. TURN used the following time codes:

ARRA - work related to the cost recovery and ratemaking issues concerning utility recovery of costs for projects submitted to DOE for ARRA grant funding

EISA - general work related to EISA policies, reading other pleadings, etc.

Policy - EISA work related specifically to the enumerated policies

Reg - EISA work related specifically to regulatory treatment of smart grid investments

Privacy - work related to privacy. Spanned multiple phases of the proceeding.

SB 17 - work related to SB 17 smart grid plans, excluding privacy

TURN sometimes uses categories that relate more to the nature of the task rather than a particular issue, including:

GP - general work unrelated to an issue and necessary for participation (e.g., reading ALJ Rulings)

# - work spanning multiple issues not easily separable

Res - legal research

Based on the time sheet entries, TURN's time in this proceeding was allocated approximately as follows among the major issue categories:

Privacy - 40%

EISA - 15%

EISA Reg (EISA cost recovery) - 10%

EISA Policy - 5%

SB 17 - 20%

ARRA - 10%

2

X

 

Reasonableness of Attorney Time: TURN's attorneys devoted approximately 300 hours to this proceeding. TURN suggests that this amount is reasonable, given that the proceeding had four separate phases addressing the impacts of the ARRA, the impacts of SB 32, the impacts of the federal EISA, a separate phase addressing state privacy issues, and various aspects of policy related to customer usage and price data.

3

X

 

Reasonableness of Expert Witness Time: TURN's witnesses devoted approximately 88 hours to this proceeding. The majority of the work was performed by Alexander, a national expert on utility ratemaking and cost issues and smart meter deployments, especially as they relate to the rate impacts on disadvantaged customers. Alexander was essential in crafting TURN's policies concerning privacy regulations and proper responses to utility cost recovery and smart grid plan proposals. Alexander was invited as a panelist on the "consumer issues" workshop panel. She has represented various consumer groups and state agencies across the country on issues related to smart meter deployment and smart grid investments. Schilberg provided limited assistance to address California-specific ratemaking and AMI issues.

1

 

X

According to TURN, Alexander voluntarily waived compensation for 12.00 hours of travel between her home in Winthrop, Maine, and San Francisco, to the July 31, 2009 Smart Grid workshop.2

D. CPUC's Comments, Disallowances & Adjustments:

#

Reason

Goodson's professional hours

Goodson's work, as described in her time records, was limited to her participation in the January 21, 2009 internal strategy meeting (also reflected in Finkelstein's and Florio's time records), and reading of TURN's comments (presumably, TURN's February 9, 2009 opening comments on the rulemaking). We find that Goodson's participation was duplicative of other participants' efforts. We disallow hours spent on these tasks.

Suetake's professional hours

On April 21, 2009, Suetake attended Smart Grid symposium via webcast, but did not perform any substantive work relevant to the subject decisions. Hawiger attended the same event, and continued to actively participate. We find that Suetake's attendance was duplicative of Hawiger's efforts and unproductive. We reduce Suetake's professional hours by 4.50.

We disallow compensation for the estimated 1.00 hour spent on the non-compensable3 clerical task of formatting comments (February 9, 2009). We note that this task is combined with others in one time record, in violation of Rule 17.4(b)(2).

Direct Costs

TURN requests $32.00 for airport transportation but fails to provide a copy of the receipt. We disallow $12.00 for this expense as not covered by the allowable $20.00 limit for an undocumented charge.4 We also disallow $40.00 for meals, as non-compensable.5

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(2)(6))?

Yes

FINDINGS OF FACT

1. TURN has made a substantial contribution to D.09-09-029, D.09-12-046, D.10-06-047, and D.11-07-056.

2. The claimed fees and costs, as adjusted herein, are comparable to market rates paid to experts and advocates having comparable training and experience and offering similar services.

3. The total of reasonable contribution is $117,964.34.

CONCLUSION OF LAW

1. TURN's claim, with any adjustment set forth above, satisfies all requirements of Public Utilities Code §§ 1801-1812.

ORDER

1. The Utility Reform Network is awarded $117,964.34.

2. Within 30 days of the effective date of this decision, Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company shall pay The Utility Reform Network the total award. Payment of the award shall include interest at the rate earned on prime, three-month commercial paper as reported in Federal Reserve Statistical Release H.15, beginning December 11, 2011, the 75th day after the filing of claimant's request, and continuing until full payment is made. We direct Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company to allocate payment responsibility among themselves, based on their California-jurisdictional electric revenues for the 2010 calendar year, to reflect the year in which the proceeding was primarily litigated.

3. The comment period for today's decision is waived.

4. This decision is effective today.

Dated May 24, 2012, at San Francisco, California.

I abstain.

/s/ MICHEL PETER FLORIO

APPENDIX

Compensation Decision Summary Information

Compensation Decision:

D1205034

Modifies Decision? No

Contribution Decisions:

D0909029, D0912046, D1006047, and D1107056

Proceeding:

R0812009

Author:

ALJ Timothy Sullivan

Payer:

Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company

Intervenor Information

Intervenor

Claim Date

Amount Requested

Amount Awarded

Multiplier?

Reason Change/Disallowance

The Utility Reform Network

9/27/2011

$119,996.34

$117,964.34

No

Inefficient effort (internal duplication); clerical work, undocumented direct costs, non-compensable direct cost (meals)

Advocate Information

First Name

Last Name

Type

Intervenor

Hourly Fee Requested

Year Hourly Fee Requested

Hourly Fee Adopted

Michel

Florio

Attorney

The Utility Reform Network

$535.00

2009

$535.00

Marcel

Hawiger

Attorney

The Utility Reform Network

$325.00

2009

$325.00

Marcel

Hawiger

Attorney

The Utility Reform Network

$325.00

2010

$325.00

Marcel

Hawiger

Attorney

The Utility Reform Network

$325.00

2011

$325.00

Robert

Finkelstein

Attorney

The Utility Reform Network

$470.00

2009

$470.00

Robert

Finkelstein

Attorney

The Utility Reform Network

$470.00

2010

$470.00

Hayley

Goodson

Attorney

The Utility Reform Network

$280.00

2009

$280.00

William

Nusbaum

Attorney

The Utility Reform Network

$435.00

2010

$435.00

Nina

Suetake

Attorney

The Utility Reform Network

$280.00

2009

$280.00

Barbara

Alexander

Expert, Consumer Affairs Consultant

The Utility Reform Network

$120.00

2009

$120.00

Barbara

Alexander

Expert, Consumer Affairs Consultant

The Utility Reform Network

$120.00

2010

$120.00

Barbara

Alexander

Expert, Consumer Affairs Consultant

The Utility Reform Network

$120.00

2011

$120.00

Gayatri

Schilberg

Expert

The Utility Reform Network

$200.00

2009

$200.00

Gayatri

Schilberg

Expert

The Utility Reform Network

$200.00

2010

$200.00

(END OF APPENDIX)

1 Among other participants there were The Greenlining Institute, Utility Consumers' Action Network, Environmental Defense Fund, Green Power Institute, CAlifornians for Renewable Energy, Black Economic Council, Latino Business Chamber of Greater Los Angeles, Consumer Federation of California, Interstate Renewable Energy Council, Local Government Sustainable Energy Coalition, Center for Energy Efficiency and Renewable Technologies, California Independent System Operator Corporation, etc.

2 A copy of TURN's e-mail of April 19, 2012, informing about this voluntary reduction can be found in the "Correspondence" file for this proceeding.

3 See, e.g., D.98-11-049, 1998 Cal. PUC LEXIS 805, *5.1.3 ("Professional fees assume overheads and are set accordingly. We therefore deny additional recovery for clerical work.")

4 In accordance with our practice, a single charge in excess of $20.00 should be supported with a copy of the invoice or receipt.

5 See, D.10-03-020 at 7; D.09-10-055 at 15, D.07-08-021 at 9, etc.

Top Of PageGo To First Page