2. Background

The Utility Reform Network (TURN) seeks compensation in the amount of $246,368.73 for substantial contributions to D.05-04-024, D.05-12-022, D.06-02-032, D.06-06-063, D.06-07-032, D.07-09-040, D.08-01-006, D.08-07-048, D.08-09-024 and the Mohave Alternatives/Complements Study. The amount of compensation at issue and the number of decisions that TURN claims to have made a substantial contribution to, suggest that a more thorough recitation of the interrelated history of these proceedings is in order.

On April 1, 2004, the Commission issued its Order Instituting Rulemaking (OIR) to Promote Policy and Program Coordination and Integration in Electric Utility Resource Planning. The objective of this rulemaking was to establish an overall procurement incentive framework that would be consistent with the goals of the Energy Action Plan. In furtherance of this objective the staff paper entitled "An Incentive Framework for Utility Procurement of Energy Resources Modeled After Cap-and-Trade Principles of the Sky Trust" was circulated with the OIR and, on November 23, 2004, a ruling scheduling workshops to discuss the staff proposal issued. After the workshop, a report on the workshop, and comments and reply comments on the report, on January 13, 2006, a draft decision was issued. Following another round of comments and reply comments, on 5

February 16, 2006, the Commission issued D.06-02-032, its final Opinion on Procurement Incentives Framework.1 Thus, R.04-04-003 provided the forum for the Commission's first substantive look into the creation of a framework that would align resource planning and procurement with the goals of the Energy Action Plan, while simultaneously reducing greenhouse gas (GHG) emissions.

This Commission issued R.04-04-025 on April 28, 2004. This proceeding was intended to serve as the forum for developing the common methods, input assumptions, and updating procedures for avoided cost calculations in Commission proceedings, including but not limited to Energy Efficiency, Demand Response, Distributed Generation, and the ongoing Annual Earnings Assessment Proceedings. Subsequently, in D.03-12-062 the Commission directed that this rulemaking also serve as the forum for updating Qualifying Facility (QF) avoided cost pricing. A prehearing conference was held on November 9, 2004. Pursuant to the January 4, 2005, Assigned Commissioner's Ruling and Scoping Memo the proceeding was divided into three phases.2

Phase 1, which resulted in D.05-04-024,3 considered the applicability of the E3 Research Report for use in evaluating energy efficiency investments for the 2006-2008 program cycle.4 On December 7, 2005, the Commission took up the issue of avoided costs valuation for energy efficiency programs in the 2006 Update Phase. This phase followed from D.05-09-043 wherein the Commission identified a number of issues related to energy efficiency avoided costs and the E3 calculator. Workshops held in the fall of 2005 on avoided costs, and in
March of 2006 on the E3 Draft Report on 2006 Update to Avoided Costs and E3 Calculator, would inform the scope of the 2006 Update in R.04-04-025.

1 D.06-02-032 is one of the decisions for which TURN seeks compensation.

2 A fourth Phase entitled the "2006 Update" phase was subsequently added.

3 D.05-04-024 is one of the decisions for which TURN seeks compensation.

4 During the summer of 2004, Energy Division conducted a two-day workshop on the Draft E3 Report, entitled A Forecast of Cost Effectiveness Avoided Costs and Externalities Adders. Comments and Reply Comments on the Draft E3 Report comprised the record in Phase 1.

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