PART II: SUBSTANTIAL CONTRIBUTION Did the Intervenor substantially contribute to the final decision (see § 1802(i), § 1803(a), and D.98-04-059). Claimed Contribution(s) Specific References to CPUC Intervenor’s Claimed Discussion Intervenor’s Contribution(s) 1. Allocation of Penalty: TURN advocated that Accepted. the $850 million penalty be allocated 81 percent to TURN Supplemental Brief, 7/26/16, pp. capital investments and 19 percent to current 1-4. expenses. The Commission adopted TURN’s recommendation. D.16-12-010, pp. 18-19. 2. Results of Operation (RO) Modeling: TURN Accepted. TURN 9/26/16 Workshop proposal, advocated that, in reflecting the penalty in the RO summarized in D.16-12-010, p. 26. Model results, the Commission should reject and remove the entire $688.5 PG&E’s proposals million amount of the capital portion of the penalty D.16-12-010, p. 27. from rate base. The Commission adopted TURN’s recommendation. Accepted. 3. Rejection of tax arguments: In reply PG&E’s TURN Reply Comments on PD, comments on the Proposed Decision (PD), TURN 11/28/16, pp. 1-3. advocated that the Commission reject PG&E’s arguments that the with PD’s method conflicts precedent regarding tax benefits and that the method D.16-12-010, pp. 30-31. constitutes a violation of normalization under the Internal Revenue Code and federal tax policy. The Commission agreed analysis and with TURN’s rejected arguments. PG&E’s 4. Clarification of RO Output Tables: TURN Accepted. TURN Opening Comments on PD, pp. recommended that, in order to avoid future 8-10 confusion, the RO output tables appended to the PD in Appendix C should include additional footnotes D.16-06-056, Appendix C, Tables 1 and to explain how certain figures were developed. The 2, and Appendix E, Table 1. Commission adopted recommendation and TURN’s added clarifying footnotes.
PART II: SUBSTANTIAL CONTRIBUTION Did the Intervenor substantially contribute to the final decision (see § 1802(i), § 1803(a), and D.98-04-059). Intervenor’s Claimed Contribution(s) Specific References to Intervenor’s Claimed Contribution(s) CPUC Discussion 1. Allocation of Penalty: TURN advocated that the $850 million penalty be allocated 81 percent to capital investments and 19 percent to current expenses. The Commission adopted TURN’s recommendation. TURN Supplemental Brief, 7/26/16, pp. 1-4. D.16-12-010, pp. 18-19. Accepted. 2. Results of Operation (RO) Modeling: TURN advocated that, in reflecting the penalty in the RO Model results, the Commission should reject PG&E’s proposals and remove the entire $688.5 million amount of the capital portion of the penalty from rate base. The Commission adopted TURN’s recommendation. TURN 9/26/16 Workshop proposal, summarized in D.16-12-010, p. 26. D.16-12-010, p. 27. Accepted. 3. Rejection of PG&E’s tax arguments: In reply comments on the Proposed Decision (PD), TURN advocated that the Commission reject PG&E’s arguments that the PD’s method conflicts with precedent regarding tax benefits and that the method constitutes a violation of normalization under the Internal Revenue Code and federal tax policy. The Commission agreed with TURN’s analysis and rejected PG&E’s arguments. TURN Reply Comments on PD, 11/28/16, pp. 1-3. D.16-12-010, pp. 30-31. Accepted. 4. Clarification of RO Output Tables: TURN recommended that, in order to avoid future confusion, the RO output tables appended to the PD in Appendix C should include additional footnotes to explain how certain figures were developed. The Commission adopted TURN’s recommendation and added clarifying footnotes. TURN Opening Comments on PD, pp. 8-10 D.16-06-056, Appendix C, Tables 1 and 2, and Appendix E, Table 1. Accepted.
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