PART III: REASONABLENESS OF REQUESTED COMPENSATION General Claim of Reasonableness (§ 1801 and § 1806): a. claim of cost reasonableness: Intervenor’s CPUC Discussion of participation is much lower than originally anticipated in Brightline’s cost Verified its NOI. When compared to the the cost of participation is public’s benefits, reasonable. The Commission authorized ESA budgets close to $400 million per year so the total amount approved will surpass $2 billion (see D.16-11-022, p.38). ESA provides energy services to low-income customers throughout California to both help them lower their utility bills and to improve the health and comfort of these customers, so the value of these programs is difficult to quantify. b. Reasonableness of hours claimed: Verified hours are reasonable because of its efforts to coordinate with Brightline’s other parties to avoid duplication. In addition, staff worked diligently to minimize costs by minimizing the time attorneys with higher billable rates spent on the proceeding. No time is claimed for internal coordination, time required to get new staff up to speed, or for travel. Furthermore, the rates requested are conservative. c. Allocation of hours by issue: Verified A. Energy Savings Target = 6.32% B. Go-Back Rule = 14.23% C. Three Measure Minimum Rule = 11.07% D. Introducing/Evaluating Measures = 10.28% E. Program Cycle Length = 4.35% F. Fund Shifting = 3.16% G. Aliso Canyon = 32.41% H. General = 18.18%
PART III: REASONABLENESS OF REQUESTED COMPENSATION General Claim of Reasonableness (§ 1801 and § 1806): a. Intervenor’s claim of cost reasonableness: Brightline’s cost of participation is much lower than originally anticipated in its NOI. When compared to the public’s benefits, the cost of participation is reasonable. The Commission authorized ESA budgets close to $400 million per year so the total amount approved will surpass $2 billion (see D.16-11-022, p.38). ESA provides energy services to low-income customers throughout California to both help them lower their utility bills and to improve the health and comfort of these customers, so the value of these programs is difficult to quantify. CPUC Discussion Verified b. Reasonableness of hours claimed: Brightline’s hours are reasonable because of its efforts to coordinate with other parties to avoid duplication. In addition, staff worked diligently to minimize costs by minimizing the time attorneys with higher billable rates spent on the proceeding. No time is claimed for internal coordination, time required to get new staff up to speed, or for travel. Furthermore, the rates requested are conservative. Verified c. Allocation of hours by issue: A. Energy Savings Target = 6.32% B. Go-Back Rule = 14.23% C. Three Measure Minimum Rule = 11.07% D. Introducing/Evaluating Measures = 10.28% E. Program Cycle Length = 4.35% F. Fund Shifting = 3.16% G. Aliso Canyon = 32.41% H. General = 18.18% Verified
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