Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a Yes Yes party to the proceeding? b. Were there other parties to the proceeding with Yes Yes positions similar to yours? c. If so, provide name of other parties: Verified Sierra Club, City of Oxnard. d. claim of non-duplication: Verified Intervenor’s participation in Phase II was extremely collaborative. CEJA relied on CEJA’s other and is only claiming time spent on ex parte meetings. parties’ briefing, CEJA coordinated with Sierra Club and the City of Oxnard, and conducted a joint ex parte meeting with the City. Additional Comments on Part II: # Comment CPUC Discussion Intervenor’s 1. Regarding rejection of the Verified Ellwood contract, CEJA advocated that the Commission not approve it at this time. CEJA is concerned about the environmental justice implications of approving a power plant in a low-income community of color and rejecting one in a non-environmental justice community. The outcome, which requires SCE to seek to meet local need without Ellwood, goes some distance toward addressing concern. CEJA’s 3. Regarding preparing for Verified additional procurement in the event the CEC fails to certify Puente, advocacy ensured CEJA’s that the Commissioners were informed of the evolving situation before the CEC. While the final decision did not implement
Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Yes b. Were there other parties to the proceeding with positions similar to yours? Yes Yes c. If so, provide name of other parties: Sierra Club, City of Oxnard. Verified d. Intervenor’s claim of non-duplication: CEJA’s participation in Phase II was extremely collaborative. CEJA relied on other parties’ briefing, and is only claiming time spent on ex parte meetings. CEJA coordinated with Sierra Club and the City of Oxnard, and conducted a joint ex parte meeting with the City. Verified Additional Comments on Part II: # Intervenor’s Comment CPUC Discussion 1. Regarding rejection of the Ellwood contract, CEJA advocated that the Commission not approve it at this time. CEJA is concerned about the environmental justice implications of approving a power plant in a low-income community of color and rejecting one in a non-environmental justice community. The outcome, which requires SCE to seek to meet local need without Ellwood, goes some distance toward addressing CEJA’s concern. Verified 3. Regarding preparing for additional procurement in the event the CEC fails to certify Puente, CEJA’s advocacy ensured that the Commissioners were informed of the evolving situation before the CEC. While the final decision did not implement Verified