Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a party Yes Verified to the proceeding? b. Were there other parties to the proceeding with positions Yes Verified similar to yours? c. If so, provide name of other parties: Verified California Energy Storage Alliance (“CESA”), Environmental Defense Power and Clean Coalition. Fund (“EDF”), Green Institute (“GPI”), d. claim of non-duplication: Noted Intervenor’s Sierra Club offered a unique perspective throughout the proceeding, continuing its active participation on the energy storage issue from prior proceedings. Sierra Club has been a consistent and active environmental group advocating on issues specifically related to greenhouse gas emission reductions and the importance of integrating renewable energy resources to meet customer and grid reliability demands. While these positions often complement those of other environmental non-profit groups, ratepayer advocates, industry associations, and energy storage companies who participated in the proceeding, Sierra Club represented the interests of its members throughout California, including ratepayers who care deeply about protecting the environment and mitigating the impacts of climate change. Sierra Club members strongly support a rapid transition to an electric grid fueled by renewable energy. Sierra position on Club’s V1G differed with other environmental groups, the Natural Resources Defense Council and the Environmental Defense Fund, in the proceeding. Sierra differed significantly from those offered by Club’s comments the Office of Ratepayer Advocates. Sierra Club coordinated with CESA, EDF, GPI, and Clean Coalition, but submitted its own comments in all instances because it had unique perspectives to offer. This coordination made for a better and more robust record. PART III: REASONABLENESS OF REQUESTED COMPENSATION: General Claim of Reasonableness (§ 1801 and § 1806):
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? Yes Verified c. If so, provide name of other parties: California Energy Storage Alliance (“CESA”), Environmental Defense Fund (“EDF”), Green Power Institute (“GPI”), and Clean Coalition. Verified d. Intervenor’s claim of non-duplication: Sierra Club offered a unique perspective throughout the proceeding, continuing its active participation on the energy storage issue from prior proceedings. Sierra Club has been a consistent and active environmental group advocating on issues specifically related to greenhouse gas emission reductions and the importance of integrating renewable energy resources to meet customer and grid reliability demands. While these positions often complement those of other environmental non-profit groups, ratepayer advocates, industry associations, and energy storage companies who participated in the proceeding, Sierra Club represented the interests of its members throughout California, including ratepayers who care deeply about protecting the environment and mitigating the impacts of climate change. Sierra Club members strongly support a rapid transition to an electric grid fueled by renewable energy. Sierra Club’s position on V1G differed with other environmental groups, the Natural Resources Defense Council and the Environmental Defense Fund, in the proceeding. Sierra Club’s comments differed significantly from those offered by the Office of Ratepayer Advocates. Sierra Club coordinated with CESA, EDF, GPI, and Clean Coalition, but submitted its own comments in all instances because it had unique perspectives to offer. This coordination made for a better and more robust record. Noted PART III: REASONABLENESS OF REQUESTED COMPENSATION: General Claim of Reasonableness (§ 1801 and § 1806):
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