10. Other Process and Procedural Issues

10.1. Parties' Comments

Several parties' comments indicate that they would have preferred a longer process to evaluate Phase 2 options in this proceeding. CFC suggests that the time allowed for review and stakeholder feedback on the staff proposal was too short and more time is needed to develop specific approaches and to evaluate and review the program proposals.

PG&E and SDG&E suggest holding at least one workshop, with SDG&E suggesting that workshops discuss "what do we want EPIC to accomplish and how can those goals best benefit customers who pay for it?"⁴¹

DRA requests a prehearing conference and a series of potential workshops related to: areas of investment; governance issues, specifically the method of actual project selection and funding; administrative costs; schedule of investment plan and coordination with IOU R&D efforts; intellectual property issues and ratepayer "payback;" and IOU R&D activities.

Finally SCE agrees that workshops would be useful and further argues that § 729 requires the Commission to hold a hearing to allow parties to vet the program proposal. However, SCE did not specifically request hearings in any documents or assert that there are any disputed issues of fact, stating in their reply comments that "the Commission should also set a schedule that allows parties to request hearings if disputed issues of fact remain after the workshops."⁴²

10.2. Discussion

We appreciate that the timetable for decision making in this entire proceeding has been short. However, the staff proposal itself was extensive and 27 individual or joint parties submitted a lengthy set of comments and reply comments in response. Thus, we have a robust record in Phase 2.

The purpose of Phase 2 in general, and this decision in particular, is to set a framework for how the EPIC program will be overseen and designed. As described herein, there will be a separate process every three years, starting this year, to evaluate individual investment plans developed and submitted by the administrators for deployment of EPIC funds. Those investment plans will have much more detailed information about planned investments, as well as criteria for selecting and evaluating proposals. Thus, many of the types of workshops and processes requested above by parties will be conducted during the process of evaluating the investment plans, and need not be done in phase 2 of this proceeding.

In addition, in response to SCE's argument that we are required to conduct a hearing in Phase 2, we have met this requirement by allowing parties to file comments on the staff proposal. As stated above, SCE did not specifically assert in its comments in either Phase 1 or Phase 2 of this proceeding that there are disputed issues of fact that require hearings; rather they only commented that there may be. SCE also did not request hearings. Further comment opportunities and workshops are likely as we consider the investment plans required to be filed November 1, 2012.

⁴¹ SDG&E comments, March 7, 2012, at 4.

⁴² SCE reply comments, March 16, 2012, footnote 9 at 4.