Throughout its involvement in the proceeding, SBUA took all reasonable steps to coordinate its efforts with other parties and keep unnecessary duplication to a minimum. SBUA representatives engaged in multi-party discussions, including with ORA and other intervenors, and workshops covering the solicitation process in order to identify areas of overlap and minimize repetitive comments. Where SBUA agreed with other than going parties’ positions, rather through lengthy independent analyses, SBUA made short statements of support. Examples include our coordination with and support of parties advocating for an independent work paper review process and our support of Commission review requirements proposed by other parties. SBUA Solicitation Process Reply Comments p.4 (supporting See e.g. MCE/BayREN comments on coordination) p.6 (supporting ORA and Verified workpaper proposals). Additionally, advocacy differed from that of other ratepayer SBUA’s advocates in that it focused on the interests of small business exclusively community. For and example, while ORA’s, TURN’s, NRDC’s advocacy primarily related to general solicitation design and overall cost effectiveness, SBUA was the only party to raise equity issues specifically relating to small commercial customers. Therefore, while other parties may have had positions that were similar to SBUA in some instances, our perspectives and goals were necessarily different, and were supplemented, not duplicated, by efforts on common issues. Additional Comments on Part II: # Comment CPUC Discussion Intervenor’s Sections SBUA has reviewed its work thus Noted A & B far in the EE Business Plan Proceeding in order to identify the tasks necessary to advance positions and with a SBUA’s direct bearing on the Solicitation Process Decision. Only those activities reasonably relating to the Solicitation Process have been included in this request. SBUA’s other activities relating to the EE Business Plans will be covered in a separate request for intervenor
Throughout its involvement in the proceeding, SBUA took all reasonable steps to coordinate its efforts with other parties and keep unnecessary duplication to a minimum. SBUA representatives engaged in multi-party discussions, including with ORA and other intervenors, and workshops covering the solicitation process in order to identify areas of overlap and minimize repetitive comments. Where SBUA agreed with other parties’ positions, rather than going through lengthy independent analyses, SBUA made short statements of support. Examples include our coordination with and support of parties advocating for an independent work paper review process and our support of Commission review requirements proposed by other parties. See e.g. SBUA Solicitation Process Reply Comments p.4 (supporting MCE/BayREN comments on coordination) p.6 (supporting ORA and Verified workpaper proposals). Additionally, SBUA’s advocacy differed from that of other ratepayer advocates in that it focused exclusively on the interests of small business community. For example, while ORA’s, TURN’s, and NRDC’s advocacy primarily related to general solicitation design and overall cost effectiveness, SBUA was the only party to raise equity issues specifically relating to small commercial customers. Therefore, while other parties may have had positions that were similar to SBUA in some instances, our perspectives and goals were necessarily different, and were supplemented, not duplicated, by efforts on common issues. Additional Comments on Part II: # Intervenor’s Comment CPUC Discussion Sections A & B SBUA has reviewed its work thus far in the EE Business Plan Proceeding in order to identify the tasks necessary to advance SBUA’s positions and with a direct bearing on the Solicitation Process Decision. Only those activities reasonably relating to the Solicitation Process have been included in this request. SBUA’s other activities relating to the EE Business Plans will be covered in a separate request for intervenor Noted
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