4. Substantial Contribution to Resolution of Issues

A party may make a substantial contribution to a decision in one of several ways.³ It may offer a factual or legal contention upon which the Commission relied in making a decision,⁴ or it may advance a specific policy or procedural recommendation that the ALJ or Commission adopted.⁵ A substantial contribution includes evidence or argument that supports part of the decision even if the Commission does not adopt a party's position in total.

The parties requesting intervenor compensation state that they made a substantial contribution to the following issues.

AECA

AECA states that it has made a substantial contribution by (1) investigating PG&E's corporate policy issues underlying its filing, and (2) bringing an additional perspective (customers' willingness to pay more for more reliable service) to one of PG&E's themes (that customers demand reliability). Additionally, AECA states that after careful evaluation, it supported Commissioner Wood's alternate decision, which was ultimately adopted by the Commission.

Redwood

Redwood states that it has made a substantial contribution to two nuclear plant decommissioning issues, (1) authorization of early decommissioning expenditures at Humboldt Bay, and (2) rejection of ORA and the Federal Executive Agency's recommendations that no additional funds be collected for Diablo Canyon's eventual decommissioning. Redwood's compensation request is limited to its participation on these two issues.

TURN

TURN states that it has made a substantial contribution regarding service quality; electric distribution expenses; electric distribution capital; gas distribution expenses; gas distribution capital; common and miscellaneous administrative and general expenses; common and miscellaneous capital depreciation; and Section 376 costs (i.e., certain costs relating to implementation of electric restructuring.)

With respect to Section 376 costs, TURN explains that it has sought and been awarded compensation for some of TURN's work in a separate proceeding. However, the hours devoted to the Section 376 issue in this general rate case concerned the treatment here of the restructuring implementation costs, and TURN has not been compensated for these costs in the Section 376 proceeding.

Weil

Weil states that he has made a substantial contribution regarding electric bypass forecasts; electric production expenses; electric distribution expenses; recorded cost ratemaking; injuries and damages; postage; uncollectibles, meter reading; customer service expenses, attrition; the Major Additions Adjustment Clause; and the filing of PG&E's next general rate case.⁶

Weil has reduced his time to reflect the percentage of his contribution and to account for duplication. For example, he requests compensation for 100% of his time on several issues, and a reduced percentage on other issues where there was greater duplication or where another party's position may have ultimately prevailed. (Weil requests the listed reductions for his time spent on the following issues: 5% for electric production expenses; 70% for electric distribution issues; 10% for customer service expenses; 10% for administrative and general expenses; 5% for attrition; and 25% for other issues.) We find Weil's proposed reductions reasonable.

We agree that AECA, Redwood, TURN, and Weil made substantial contributions to D.00-02-046 in the areas they identify. We adopted AECA, Redwood, TURN, and Weil's identified proposals in whole or in part and benefited from these participants' policy discussion on all of those issues which they addressed.