4. Substantial Contribution

Aglet has been an active and productive participant as a member of the PRG for each of the three electric utilities. In Decision (D.) 02-10-062, the Commission stated that "participation in the procurement review process ... by non-market participants who are eligible to request intervenor compensation should be fully compensated because their active participation makes a significant contribution to this proceeding" (pp. 3-4). Aglet's consultant Jan Reid participated in the three PRGs on behalf of Aglet. Reid is an expert and has participated in the PRG of PG&E since July 2005, the PRG of SCE since August 2005, and the PRG of SDG&E since January 2006.

Decision 07-11-024 laid out requirements that entities eligible to claim intervenor compensation must meet to request funding for PRG activities. Aglet's requests that we consider today pre-date the adoption of D.07-11-024. Although Aglet failed to provide the Commission with additional information to address the areas in which their participation made a substantial contribution, historically Aglet's contributions in PRG proceedings have involved: analyzing and preparing comments on various issues for discussion at the PRG meetings; the development of models to evaluate capacity contracts; gas options; hedging targets; and renewable contracts. In the past, Aglet's participation in the PRGs has allowed issues to be identified in advance of a utility application, so these issues can be resolved in a more expeditious and efficient manner than through litigation.

Because the request here was made before we clarified these requirements, in the interest of fairness, the Commission is approving Aglet's award in this proceeding. Aglet has submitted a spreadsheet outlining its participation as a member of the PRG and has contributed substantially to the development of the process and the resource portfolio planning. Aglet's future requests for intervenor compensation however, need to include an assessment of all areas as outlined in D.07-11-024. In this proceeding, we find Aglet's claim for substantial contribution to be reasonable.