In other words, Joint Intervenors object to the presentation only of an stage” mitigated to cost ratio” or related optimization. Instead, they “early “risk suggest the following: Risk reduction calculations and risk mitigated to cost rankings need not be or stage” calculations. Using [the] “pilot” “early Joint Intervenors Approach or requirements based on that approach, the RAMP filing should provide risk reduction calculations that are comparable across the enterprise and use risk reduction per dollar spent to prioritize projects. Optimization should be implemented to the extent possible. Joint Intervenors also point out that the Joint Intervenors’ Approach would assist with the RAMP steps to the probabilistic calculation in the “implement shortterm” and in the identification of data collection requirements.” “assist Aside from the Components” matrix, Joint Intervenors strongly “Ten oppose the concept of an SED Order” that would enable SED to “Adoption formally adopt each utility’s RAMP filing and application prior to the GRC. Joint Intervenors objected to this proposal for two reasons. First, Intervenors “Joint oppose any process that purports to allow SED, or any unit of CPUC staff to issue an order that has binding effect or otherwise has the status of a Commission determination.” This would constitute an delegation of “improper the Commission’s authority” since major GRC issues generally require the higher level judgement of Commissioners. Second, Joint Intervenors also point out that the proposed Order” is contrary to the direction of D.1412025 which “Adoption directs the issuance of a single, final SED report before parties have an opportunity to ask questions or provide comments on it. a report that “Issuing has binding effect without even an opportunity for parties to be heard would be
In other words, Joint Intervenors object to the presentation only of an “early stage” “risk mitigated to cost ratio” or related optimization. Instead, they suggest the following: Risk reduction calculations and risk mitigated to cost rankings need not be “pilot” or “early stage” calculations. Using [the] Joint Intervenors Approach or requirements based on that approach, the RAMP filing should provide risk reduction calculations that are comparable across the enterprise and use risk reduction per dollar spent to prioritize projects. Optimization should be implemented to the extent possible. Joint Intervenors also point out that the Joint Intervenors’ Approach would assist with the RAMP steps to “implement the probabilistic calculation in the shortterm” and “assist in the identification of data collection requirements.” Aside from the “Ten Components” matrix, Joint Intervenors strongly oppose the concept of an SED “Adoption Order” that would enable SED to formally adopt each utility’s RAMP filing and application prior to the GRC. Joint Intervenors objected to this proposal for two reasons. First, “Joint Intervenors oppose any process that purports to allow SED, or any unit of CPUC staff to issue an order that has binding effect or otherwise has the status of a Commission determination.” This would constitute an “improper delegation of the Commission’s authority” since major GRC issues generally require the higher level judgement of Commissioners. Second, Joint Intervenors also point out that the proposed “Adoption Order” is contrary to the direction of D.1412025 which directs the issuance of a single, final SED report before parties have an opportunity to ask questions or provide comments on it. “Issuing a report that has binding effect without even an opportunity for parties to be heard would be
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