agree upon alternative provisions that address the specific concerns raised in the APD. Discussion We do not find that the fact that Settling Parties filed a Notice to Accept as directed by D.17-05-013 supports Rafferty’s assertion that his position in comments on the PD “had a catalytic effect” that led to that action. Rafferty offers no proof to support his assertion. In the absence of a substantial contribution here, Rafferty’s claim for intervenor compensation on this item must be denied. Undergrounding In D.17-05-013 the Commission determined that PG&E should establish a Rule 20A balancing account that tracks the annual capital and expense costs for Rule 20A undergrounding projects, on a forecast and recorded basis, so that overcollected balances in the account remain available for future Rule 20A projects. Contribution Intervenor’s Claimed Rafferty devotes several pages of his claim to describing his claimed contributions on this issue. Rafferty asserts that CAUSE’s comments on the APD provided extensive input into the safety benefits that the audit could realize with appropriate siting decisions. Rafferty seeks recognition that his “extensive analysis of Rule 20A enables the impending audit to consider safety impacts, which should be acknowledged as a substantial contribution.” Rafferty states that his analysis including the following: CAUSE filed almost 15 pages of comments analyzing the precedents of this Commission and the municipal ordinances and actions that they require. These are matters of law, not required to be entered into the evidentiary record.
agree upon alternative provisions that address the specific concerns raised in the APD. Discussion We do not find that the fact that Settling Parties filed a Notice to Accept as directed by D.17-05-013 supports Rafferty’s assertion that his position in comments on the PD “had a catalytic effect” that led to that action. Rafferty offers no proof to support his assertion. In the absence of a substantial contribution here, Rafferty’s claim for intervenor compensation on this item must be denied. Undergrounding In D.17-05-013 the Commission determined that PG&E should establish a Rule 20A balancing account that tracks the annual capital and expense costs for Rule 20A undergrounding projects, on a forecast and recorded basis, so that overcollected balances in the account remain available for future Rule 20A projects. Intervenor’s Claimed Contribution Rafferty devotes several pages of his claim to describing his claimed contributions on this issue. Rafferty asserts that CAUSE’s comments on the APD provided extensive input into the safety benefits that the audit could realize with appropriate siting decisions. Rafferty seeks recognition that his “extensive analysis of Rule 20A enables the impending audit to consider safety impacts, which should be acknowledged as a substantial contribution.” Rafferty states that his analysis including the following: CAUSE filed almost 15 pages of comments analyzing the precedents of this Commission and the municipal ordinances and actions that they require. These are matters of law, not required to be entered into the evidentiary record.
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