VI. Substantial Contribution

UCAN serves with six other non-financially interested entities on SDG&E's PRG (including the Commission's Office of Ratepayer Advocates (ORA), Energy Division and the California Energy Commission), and approximately 20 other organizations on SDG&E's PAG. The attachments to UCAN's request for compensation document that UCAN has been an active participant in SDG&E's advisory group process since the selection of advisory group members in February 2005. In particular, UCAN attended general PAG meetings throughout the development of SDG&E's June 1 filings on portfolio plans and budgets, participated in sub-committee meetings on specific topics, and reviewed PAG materials for those meetings. In addition, UCAN provided in-person consultation with SDG&E program managers and with the full PAG group utilizing the expertise of its technical consultants.

As a PRG member, UCAN also participated in the development of the written PRG assessment of SDG&E's proposed portfolio plans, as required by D.05-01-055. Finally, consistent with the Commission's direction in D.05-09-043, UCAN reviewed SDG&E's materials for the PRG review of third-party responses to SDG&E's competitive solicitations, and participated in the PRG meetings on third-party programs.

The attachments to UCAN's request provide an hourly breakdown of time spent by UCAN's attorney and UCAN's technical consultants, with a brief description of activities associated with those hours. We agree with UCAN that an issue breakdown is not feasible given the breadth of issues explored by the advisory groups during the 2006-2008 planning process, particularly since this was the first planning cycle following the establishment of new policy rules, energy efficiency goals and a new administrative structure for post-2005 energy efficiency activities. The PAG and PRG members analyzed and discussed numerous issues, including residential and large customer program design and funding issues, cost-effectiveness methodology, data availability issues, and legal and procedural matters.

As discussed in D.05-01-055, the advisory group and PRG members "all burned the midnight oil for many weeks to develop and analyze portfolio plans that were responsive to the new energy efficiency rules adopted in April, 2005." We also noted that "the advisory group process established by D.05-01-055 was constructive and collaborative." Based on the submittals in A.05-06-016 et al., we concluded that this process "has served this Commission well" in reaching our determinations in D.05-09-043.⁶ UCAN's participation in SDG&E's PAG and PRG was an integral part of the constructive and collaborative process described in that decision, and clearly contributed to the substantive resolution of issues in D.05-09-043. Although not all of the specific recommendations contained in the SDG&E PRG assessment were adopted by that order, they helped frame the threshold issues for debate in this proceeding. Moreover, the vast majority of PRG/PAG portfolio design recommendations were carefully considered and incorporated into SDG&E's portfolio plans prior to its filing, as documented in that submittal.

In sum, we conclude that UCAN made a substantial contribution to SDG&E's PAG and PRG, and in turn made a substantial contribution to D.05-09-043 and the compliance activities that followed from that decision.

⁶ D.05-09-043, mimeo., p. 93.