Duplication of Effort (§ 1801.3(f) and § 1802.5): Assertion CPUC Discussion Intervenor’s a. Was the Office of Ratepayer Advocates (ORA) a Yes party to the proceeding? b. Were there other parties to the proceeding with Yes positions similar to yours? c. If so, provide name of other parties: BAC The Clean positions sometimes d. claim of non-duplication: Intervenor’s Coalition’s overlapped with those of BAC, but our proposals and the justification for our positions were not identical. Further, the Clean reasoning brought a Coalition’s unique perspective from our experience developing interconnection organization’s requirements and designing procurement mechanisms, including the ReMAT program upon which BioMAT is based. Finally, the Clean Coalition presented independent positions intended to further the public interest goal of reducing barriers to the deployment of renewable resources, whereas BAC is an industry association representing commercial interests. Additional Comments on Part II: # Comment CPUC Discussion Intervenor’s PART III: REASONABLENESS OF REQUESTED COMPENSATION (Completed by Intervenor except where indicated) General Claim of Reasonableness (§ 1801 and § 1806): a. claim of cost reasonableness: Intervenor’s CPUC The Clean Coalition independently developed its policy positions based on the Discussion expertise developing interconnection requirements and designing organization’s procurement mechanisms. We have developed Feed-in-Tariffs with similar requirements to BioMAT for several municipal utilities. We have also been active in implementing and advocating for refinements to ReMAT, and many of our interconnection proposals stem from this experience. Finally, we have significant expertise regarding interconnection requirements, as evidenced by our participation in the Rule 21 proceeding at the state level and in front of the Federal Energy Regulatory Commission at the federal level. The Clean Coalition devoted significant resources to develop the expertise relied upon in comments, but we seek compensation only for the hours directly associated with our advocacy in this proceeding. b. Reasonableness of hours claimed: Clean Coalition staff worked to develop new interconnection requirements for Category 3 projects seeking a contract under the BioMAT tariff. We allocated staff time based on previously developed expertise to ensure efficient participation. Although we have spent
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 b. Were there other parties to the proceeding with positions similar to yours? Yes c. If so, provide name of other parties: BAC d. Intervenor’s claim of non-duplication: The Clean Coalition’s positions sometimes overlapped with those of BAC, but our proposals and the justification for our positions were not identical. Further, the Clean Coalition’s reasoning brought a unique perspective from our organization’s experience developing interconnection requirements and designing procurement mechanisms, including the ReMAT program upon which BioMAT is based. Finally, the Clean Coalition presented independent positions intended to further the public interest goal of reducing barriers to the deployment of renewable resources, whereas BAC is an industry association representing commercial interests. Additional Comments on Part II: # Intervenor’s Comment CPUC Discussion PART III: REASONABLENESS OF REQUESTED COMPENSATION (Completed by Intervenor except where indicated) General Claim of Reasonableness (§ 1801 and § 1806): a. Intervenor’s claim of cost reasonableness: The Clean Coalition independently developed its policy positions based on the organization’s expertise developing interconnection requirements and designing procurement mechanisms. We have developed Feed-in-Tariffs with similar requirements to BioMAT for several municipal utilities. We have also been active in implementing and advocating for refinements to ReMAT, and many of our interconnection proposals stem from this experience. Finally, we have significant expertise regarding interconnection requirements, as evidenced by our participation in the Rule 21 proceeding at the state level and in front of the Federal Energy Regulatory Commission at the federal level. The Clean Coalition devoted significant resources to develop the expertise relied upon in comments, but we seek compensation only for the hours directly associated with our advocacy in this proceeding. CPUC Discussion b. Reasonableness of hours claimed: Clean Coalition staff worked to develop new interconnection requirements for Category 3 projects seeking a contract under the BioMAT tariff. We allocated staff time based on previously developed expertise to ensure efficient participation. Although we have spent
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