75-76 clarifies that the acceptance of fee awards from a court (or administrative agency such as this Commission) is not necessarily inconsistent with the basis of the IRC charitable exemption of public interest law firms.”].) PART II: SUBSTANTIAL CONTRIBUTION Did the Intervenor substantially contribute to the final decision (see § 1802(j), § 1803(a), 1803.1(a) and D.98-04-059). Intervenor’s Claimed Specific References to Intervenor’s CPUC Contribution(s) Claimed Contribution(s) Discussion A. Inclusion of consideration Proposed Order pages 9, 41, 47 Verified of additional communities B. Inclusion for consideration Proposed Order, page 12 Verified financial considerations as well as those of public health, safety, and the environment. Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s CPUC Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a Yes Verified party to the proceeding? b. Were there other parties to the proceeding with No. Not during Verified positions similar to yours? the time period covered by this filing c. If so, provide name of other parties: Agreed, d. Intervenor’s claim of non-duplication: intervenor did The communities and interests we represent on this proceeding are not engage in complimentary but distinct from those that ORA represents. We are excessive specifically focused on representing those communities and households that duplication in do not have natural gas service. Additionally, we represent a variety of issues this proceeding and concerns related to, but distinct from gas service, including environmental and community health.
75-76 clarifies that the acceptance of fee awards from a court (or administrative agency such as this Commission) is not necessarily inconsistent with the basis of the IRC charitable exemption of public interest law firms.”].) PART II: SUBSTANTIAL CONTRIBUTION Did the Intervenor substantially contribute to the final decision (see § 1802(j), § 1803(a), 1803.1(a) and D.98-04-059). Intervenor’s Claimed Contribution(s) Specific References to Intervenor’s Claimed Contribution(s) CPUC Discussion A. Inclusion of consideration of additional communities Proposed Order pages 9, 41, 47 Verified B. Inclusion for consideration financial considerations as well as those of public health, safety, and the environment. Proposed Order, page 12 Verified 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 Verified b. Were there other parties to the proceeding with positions similar to yours? No. Not during the time period covered by this filing Verified c. If so, provide name of other parties: d. Intervenor’s claim of non-duplication: The communities and interests we represent on this proceeding are complimentary but distinct from those that ORA represents. We are specifically focused on representing those communities and households that do not have natural gas service. Additionally, we represent a variety of issues and concerns related to, but distinct from gas service, including environmental and community health. Agreed, intervenor did not engage in excessive duplication in this proceeding
200507721.docx