Before the Public Utilities Commission of the State of California s75

ALJ/EDF/jt2 Date of Issuance 5/8/2017

Decision 17-04-032 April 27, 2017

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

In the Matter of the Application of Pacific Gas and Electric Company for Approval of its Electric Vehicle Application 15-02-009 Infrastructure and Education Program (U39E). (Filed February 9, 2015)

DECISION GRANTING COMPENSATION TO THE UTILITY REFORM NETWORK FOR CONTRIBUTION TO DECISION 16-12-065

Intervenor: The Utility Reform Network For contribution to Decision (D.) 16-12-065 Claimed: $210,499.18 Awarded: $210,734.18 Assigned Commissioner: Carla J. Peterman Assigned ALJ: Darwin Farrar & Michelle Cooke

PART I: PROCEDURAL ISSUES

A. Brief description of Decision: The Commission modified PG&E’s original and enhanced proposed Electric Vehicle charging infrastructure program and the proposed settlement and reduced the size and cost of the proposed deployment, so as to authorize the installation of 7,500 level 2 charging ports over the course of three years, at a cost of $130 million, subject to a one-way balancing account. The Decision also adopts an education and outreach proposal for the program. The Decision rejected PG&E and the settling parties’ proposal to also include 100 direct current fast chargers (DCFCs) in the program and limited PG&E’s ownership of EV charging stations.

B. Intervenor must satisfy intervenor compensation requirements set forth in Pub. Util. Code §§ 1801-1812:

Intervenor CPUC Verified Timely filing of notice of intent to claim compensation (NOI) (§ 1804(a)): 1. Date of Prehearing Conference (PHC): June 12, 2015 Verified 2. Other specified date for NOI: N/A Verified 3. Date NOI filed: July 13, 2015 Verified 4. Was the NOI timely filed? Yes Showing of customer or customer-related status (§ 1802(b)):

185070055 - 1 - 5. Based on ALJ ruling issued in proceeding See Comment #1 R.14-05-001 number: 6. Date of ALJ ruling: See Comment #1 September 5, 2014 7. Based on another CPUC determination (specify): See Comment #1 8. Has the Intervenor demonstrated customer or customer-related status? Yes Showing of “significant financial hardship” (§ 1802(g)): 9. Based on ALJ ruling issued in proceeding number: R.14-05-001 Verified 10. Date of ALJ ruling: September 5, 2014 Verified 11. Based on another CPUC determination (specify): N/A 12. 12. Has the Intervenor demonstrated significant financial hardship? Yes Timely request for compensation (§ 1804(c)): 13. Identify Final Decision: D. 16-12-065 Verified December 21, 2016 14. Date of issuance of Final Order or Decision: Verified February 21, 2017 15. File date of compensation request: Verified 16. Was the request for compensation timely? Yes

C. Additional Comments on Part I:

# Intervenor’s Comment(s) CPUC Discussion

TURN did not receive an affirmative 1. ruling on its Notice of Intent in this proceeding. As explained in the Commission’s Intervenor Compensation guide, “normally, an ALJ Ruling need not be issued unless: (a) the NOI has requested a finding of “significant financial hardship” under § 1802(g); (b) the NOI is deficient; or (c) the ALJ desires to provide guidance on specific issues of the NOI.” (page 12) Since none of these factors apply to the NOI submitted in this proceeding, there was no need for an ALJ ruling in response to TURN’s NOI.

PART II: SUBSTANTIAL CONTRIBUTION

A. Did the Intervenor substantially contribute to the final decision (see § 1802(i), § 1803(a), and D.98-04-059). A.15-02-009 ALJ/EDF/jt2

Intervenor’s Claimed Contribution(s) Specific References to CPUC Discussion to D.16-01-045 Intervenor’s Claimed Contribution(s) 1. Reasonableness of Proposed Verified Settlement

TURN argued that the proposed settlement - TURN Opening Brief, June 17, was unreasonable and not in the public 2016, pp. 1-2, 13 & 24-26. interest because it maintained the general program size and risks to ratepayers of the -TURN Comments on the enhanced proposal and had potential anti- Settlement Agreement, April 12, competitive impacts. The Commission 2016, pp. 5-10. declined to adopt the settlement agreement and instead adopted an EV program that incorporates portions of various parties’ proposals, including, but not limited to, - D.16-12-065, p. 13. TURNs recommendations to remove DCFCs from the program and limit utility ownership to sites located in multi-unit dwellings (MUDs) and disadvantaged communities (DACs). The Commission - D.16-12-065, p. 30. also agreed with TURN that the Settlement Agreement had potential anti-competitive impacts. 2. Size of Program Verified PG&E originally proposed a very large program of up to 25,000 charging stations. - D.16-12-065, pp. 7-8. As will be discussed in the phasing section below TURN was successful in convincing - D.16-12-065, p. 10. the Commission to significantly scale back - Borden Direct Testimony, this proposal. PG&E then proposed its November 30, 2015, p. 25 enhanced proposal of 7,430 level 2 (L2) (recommending dual-port charging stations and 100 DCFC. PG&E technology) then reached a settlement with some parties for a program consisting of 7,500 L2 charging stations and 100 DCFC. TURN - TURN Opening Brief, June 17, recommended that the Commission adopt a 2016, p. 13 & 28-29. modified version of PG&E’s compliant proposal, with up to 5000 L2 charging ports - TURN Opening Brief, June 17, and 10 DCFCs. TURN also advocated for 2016, p. 19. the use of multi-port L2 chargers. The Commission agreed that the programs - D.16-12-065, p. 46, FN. 109. proposed in the Settlement Agreement and in PG&E’s enhanced proposal were too - D.16-12-065, p. 60 & p. 79 FOF risky and adopted a modified version that #30. utilizes dual port technology for up to 7,500 L2 ports and declined to include any DCFCs.

3 3. Need for a Phased Approach Verified PG&E originally proposed a very large - D.16-12-065, pp. 7-8. program of up to 25,000 L2 charging stations and 100 DCFCs with a cost of over $650 million. On June 16, 2015, the ALJ issued a ruling requesting comments from parties regarding recommendations for a phased approach for the program. TURN worked with the Joint Minority Parties (JMP) to develop a detailed phasing proposal and also filed reply comments. - Comments of TURN & JMP on TURN’s phasing proposal recommended a ALJ June 16, 2015 Ruling limited scale pilot phase and a larger scale Requesting Comments, July 2, second phase (if necessary) informed by the 2015, pp. 4-5 & 7-10. results and learnings of the pilot phase. In making this recommendation, TURN noted that a phased approach reduces ratepayer risks and increases ratepayer benefits by - Comments of TURN & JMP on collecting best practices and lessons learned ALJ June 16, 2015 Ruling from the pilot phase. The Assigned Requesting Comments, July 2, Commissioner and ALJ agreed with TURN 2015, pp. 6-7. and rejected PG&E’s original proposal and required PG&E to instead submit supplemental testimony for a pilot phase - Joint Assigned Commissioner & program limited to 10% of original ALJ Scoping Memo & Ruling, proposal. The Assigned Commissioner and September 4, 2015, p. 7 and 15, ALJ based this determination in part of Ruling Paragraph #1. TURN’s recommendations and analysis and agreed that a phased approach is necessary to give the Commission the opportunity to - Joint Assigned Commissioner & collect and evaluate data regarding ALJ Scoping Memo & Ruling, ratepayer costs and benefits and potential September 4, 2015, p. 7. anticompetitive impacts. 4. Costs of the Program & Cost Recovery Verified TURN did significant analysis of the costs of PG&E’s enhanced proposal and the settlement agreement and identified many costs that were excessive or unnecessary. - Borden Direct Testimony, Specifically, TURN questioned the more November 30, 2015, p. 26 than $1.1 million in capital contingency costs and almost $2 million in O&M contingency costs requested for the EV - TURN Opening Brief, June 17, Cost of Ownership Tool and the Site Host 2016, p. 43. Online Application Portal. The Commission agreed that these contingency costs were excessive and reduced them by - D.16-12-065, p. 61. 90 percent and 50 percent (respectively) for a cost reduction of almost $2 million. The Commission also agreed with TURN’s A.15-02-009 ALJ/EDF/jt2

analysis that the proposed program costs - D.16-12-065, p. 62 & p. 86 FOF were too high and adopted TURN’s #15. proposal to require the use of a one-way balancing account for the program costs. 5. Direct Current Fast Chargers Verified (DCFC) TURN recommended that PG&E significantly scale back its DCFC deployment proposal from 100 to 10 - Borden Direct Testimony, DCFCs. TURN raised concerns with the November 30, 2015, pp. 15-16. extra cost and ratepayer risks associated - TURN Opening Brief, June 17, with DCFCs. Decision 16-12-065 cited 2016, p. 28 & p. 43. TURN’s analysis regarding the extra costs and risks of DCFCs when determining that PG&E had not sufficiently justified their - D.16-12-065, pp. 43-45. DCFC proposal. The settling parties attempted to challenge this finding in their comments on the proposed decision and TURN encouraged the Commission to not - TURN Reply Comments on PD, modify this aspect of the proposed decision December 12, 2016, pp. 1-2. (PD) because the proposal to pilot 100 DCFC was not supported by the evidentiary record. The Commission agreed and found that including DCFC in - D.16-12-065, p. 79, FOF #30. the pilot phase was inappropriate. 6. Utility Ownership Verified TURN argued that rather than installing and - Borden Direct Testimony, owning charging stations, PG&E should November 30, 2015, pp. 12-13 install make-ready stubs (all of the necessary electrical infrastructure up to, but not including, the charging station.) In making this recommendation, TURN noted - TURN Opening Brief, p. 43. that PG&E’s proposed ownership of all of the equipment is a significant cost since the utility proposed to ratebase all capital - D.16-12-065, p. 60. expenditures and earn its authorized rate of return (currently 8.06 percent) over the life of the equipment. TURN also recommended a make-ready stub approach in order to - TURN Opening Brief, p. 35 & mitigate the potential anti-competitive 40. impacts of the program and reduce the risks to ratepayers. The Commission found merit in TURN’s arguments and limited PG&E’s - D.16-12-065, p. 37. ownership to the make-ready infrastructure only for non-MUD and non-DAC locations. The Decision further limited PG&E’s - TURN Reply Comments on PD, ownership of charging stations in the MUD p. 3. and DAC locations to 35 percent of total

5 - D.16-12-065, p. 83 OP #1. ports projected to be installed through the pilot program. 7. Disadvantaged Communities Programs Verified (DACs) The Settlement proposed an expanded definition of DACs which included areas with a high concentration of customers eligible for PG&E’s CARE program in addition to the top quartile of Disadvantaged Communities identified by CalEnviroScreen 2.0 tool on a PG&E service territory basis. TURN researched the impacts of this proposal and found that it resulted in many areas with a high concentration of wealthy workplaces (including Google, LinkedIn, Twitter, - TURN Opening Brief, pp. 56-57. Bank of America) being classified as DACs and thus eligible for 100% ratepayer subsidized EV charging infrastructure under PG&E’s proposal. TURN recommended that CalEnviroScreen 2.0 be - TURN Comments on PD, p. 2. used exclusively to identify DACs. The - D.16-12-065, p. 49 & 79 FOF Commission adopted this proposal. TURN #23. also recommended that the participation payment waiver for DACs only be applied - TURN Opening Brief, p. 57. to MUD sites. The Commission agreed and - D.16-12-065, p. 49. adopted this recommendation. 8. Participation Payment Verified PG&E originally proposed to install EV charging stations and all supporting infrastructure on private properties at no cost to the property owners. Throughout the proceeding TURN strongly advocated for the need for site hosts to make a participation payment in order to receive the charging infrastructure on their - Borden Direct Testimony, property. In making this recommendation November 30, 2015, p. 11. TURN noted that requiring site hosts to make a financial contribution to participate optimized site selection and limited potential free ridership. TURN also noted that the participation payment structure - TURN Opening Brief, p. 45. proposed in the settlement was unnecessarily low. The Commission agreed and adopted a program structure that required a meaningful participation payment and cited TURN’s analysis of the settlement’s participation payment - D.16-12-065, pp. 50-51 & 85. A.15-02-009 ALJ/EDF/jt2

proposal in determining it was too low. TURN also challenged the broad categories (all DAC locations, non-profits, government agencies and sites owned by school districts) for participation payment - TURN Opening Brief, pp. 47-48. waivers proposed in the settlement. D.16- 12-065 references TURN’s analysis in determining the waiver categories - D.16-12-065, pp. 47-49. proposed in the settlement were too broad. The Decision limited the waiver to only MUDs in DAC locations. 9. Rebates Verified In testimony TURN proposed that PG&E be limited to installing make-ready stubs for charging stations and require site hosts to purchase charging stations and then - Borden Direct Testimony, receive a partial rebate for the cost of the November 30, 2015, p. 10-14. charger. The Commission found some merit in TURN’s arguments and adopted a program that offers 25% rebates for charging stations at participating workplaces and 50% rebates for MUD locations where the site hosts chooses the - D.16-12-065, p. 86 OP #13. non-utility ownership option. In comments on the PD the Settling Parties argued that the rebate costs would be recovered from ratepayers independent of the established program cost cap. TURN disagreed with this interpretation of the PD - TURN Reply Comments on PD, and requested that the Commission clarify pp. 2-3. that the rebate costs were included in the $130 million program budget. The Commission agreed with TURN’s - D.16-12-065, p. 84 OP #4. interpretation and clarified the final decision to expressly indicate, “the authorized funding of $130 million includes the cost of rebates.” 10. Bridge Funding Verified TURN challenged PG&E’s bridge (between phase 1 and phase 2) funding proposal included in its supplemental testimony as well as the settlement. TURN analyzed - Borden Direct Testimony, both proposals and raised concerns that the November 30, 2015, pp. 23-25. bridge funding proposal could significantly - TURN Opening Brief, pp. 63-64. increase the size and budget of the phase 1 program without sufficient CPUC review. Instead, TURN recommended that any cost - TURN Opening Brief, p. 11.

7 savings during phase 1 of the program be used during the bridge period. The - D.16-12-065, pp. 73-74. Commission agreed with TURN that additional bridge funding was not necessary and denied PG&E’s bridge - D.16-12-065, p. 88 OP #21. funding request and instead authorized PG&E to use any left over funds at the end of phase 1 for the bridge period (if necessary). 11. Education and Outreach Costs Verified The PD authorized PG&E to spend $5 million on education and outreach for the program. In comments on the PD, PG&E argued that the $5 million was in addition to the program budget of $130 million adopted - TURN Reply Comments on PD, in the PD. TURN noted PG&E’s p. 5. interpretation was inconsistent with the PD and therefore should be rejected. In response to TURN’s comments the Commission revised the PD so that D.16- - D.16-12-065, p. 84 OP #4. 12-065 limits the budget for the program to $130 million and expressly includes education and outreach costs in the $130 million budget.

B. Duplication of Effort (§ 1801.3(f) and § 1802.5):

Intervenor’s CPUC Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to Yes Verified 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 The primary active parties aligned with TURN were ORA and the Joint Minority Parties (represented by the National Asian American Coalition). ChargePoint, TechNet and EVCA were aligned with TURN on issues of competitive impact and utility ownership. TURN was part of a coalition of seven non-settling parties who jointly opposed the settlement. d. Intervenor’s claim of non-duplication: Verified TURN's compensation in this proceeding should not be reduced for duplication of the showings of other parties. In a proceeding involving multiple participants, it is virtually impossible for TURN to completely avoid some duplication of the work of other parties. TURN was aligned with the Office of Ratepayer Advocates and the Joint Minority Parties (JMP) regarding certain core issues, including the size and scope of the A.15-02-009 ALJ/EDF/jt2 program. However, TURN provided a specific proposal regarding an alternative program size and cost. TURN also provided significant additional analysis concerning the risks to ratepayers of PG&E’s enhanced proposal and the settlement that contributed to the Commission’s final determination concerning a proper program size. There were a significant number of parties that were very supportive of PG&E’s enhanced proposal from the beginning of the proceeding, and twelve parties settled with PG&E. As is apparent from the multiple entries coded as “Coord” in the time sheets, TURN engaged in multiple meetings and discussions with other parties in order to minimize duplication, allocate issues, and coordinate strategies. TURN took reasonable steps to keep any duplication to a minimum, and to ensure that when it did happen, our work served to complement and assist the showings of the other parties. TURN was part of a coalition of seven non-settling parties who jointly opposed the settlement. TURN played an active role in organizing the coalition and took a lead role drafting the non- settling parties’ joint response to the motion for adoption of the settlement agreement. TURN was also very active in creating the “Joint Guiding Principles and Recommendations” the coalition of non-settling parties presented in their opening briefs.

TURN also filed a joint pleading with the Joint Minority Parties, “Comments on the ALJ’s June 16, 2015 Ruling Requesting Comments on Phasing”. TURN worked with the JMP to develop a proposal for a multi-phased approach for the application and drafted a majority of the comments and reply comments. The Commission should find that TURN's participation was efficiently coordinated with the participation of ORA and Joint Minority Parties wherever possible, so as to avoid undue duplication and to ensure that whenever duplication occurred, it served to supplement, complement, or contribute to the showing of the other intervenor. And consistent with such a finding, the Commission should determine that all of TURN’s work is compensable consistent with the conditions set forth in Section 1802.5.

PART III: REASONABLENESS OF REQUESTED COMPENSATION

A. General Claim of Reasonableness (§ 1801 and § 1806): a. Intervenor’s claim of cost reasonableness: CPUC Discussion TURN’s participation in A.15-02-009 contributed to a substantial reduction in the Verified authorized program costs from $160 million proposed in the contested settlement agreement to $130 million, thus not only reducing the immediate impact on rates but also reducing the risk of stranded costs that would be paid by ratepayers and improving the ability of the Commission to measure the impact of utility infrastructure investments on future electric vehicle adoption. Further, D.16-12- 065 adopted TURN’s recommendation and denied PG&E’s additional bridge funding request for the period between phase 1 and phase 2 which could have increased costs by up to an additional $54 million. The Commission also adopted TURN’s recommendations regarding requiring site hosts to make a meaningful participation payment, including adopting a rebate structure for workplace

9 locations and limiting the types of locations eligible for participation payment waivers. This program structure will reduce ratepayer costs for the program, including reducing future operation and maintenance expenditures.

The budget of PG&E’s original EV infrastructure proposal was $650 million and TURN was one of the key players advocating for a phased approach and a significantly scaled back program, which the Commission adopted.

All of the other benefits of TURN’s participation cannot be quantified as they involved policy issues. However, TURN’s participation contributed to the development of an EV infrastructure program that is better designed, less risky for ratepayers, and targeted to primarily fill gaps in the private market and lead to increased EV adoption. TURN urges the Commission to recognize that these outcomes were some of the most important in this proceeding, and are likely to provide substantial benefits, albeit benefits that may be hard to quantify in dollars. b. Reasonableness of hours claimed: Verified In this request TURN seeks compensation for approximately 300 hours of expert witness time and approximately 570 hours of attorney time. This amount of resources was warranted and reasonable in light of a number of factors: 1) the scale and costs of PG&E’s original proposal, the enhanced proposal, and the proposed settlement all presented significant risks to ratepayers; 2) the policy significance of creating a well designed and sustainable EV infrastructure program necessary to support the Governor’s ambitious EV adoption goals; 3) PG&E ultimately submitted three distinct proposals, each with voluminous testimony that had to be individually analyzed and reviewed; 4) the robustness of the evidentiary record in this proceeding (including 4 days of evidentiary hearings in which TURN play an active role) and the large number of parties involved; and 5) TURN’s devotion of time and resources in making a good faith effort to settle with the settling parties, including engaging in multiple settlement negotiations and developing a comprehensive counter proposal. TURN devoted the resources of two attorneys and TURN’s in-house energy analyst, who served as an expert witness to this proceeding in order to address key issues related to the deployment of electric vehicles including, the electric vehicle market, rate design, EV technology, and cost forecasting and ratemaking. In the following subsections, TURN describes the responsibilities of the different staff members and explains the reasonableness of the hours and effort devoted to this proceeding.

Attorney Time Elise Torres Ms. Torres was TURN’s lead attorney in this proceeding and represented TURN in evidentiary hearings, at settlement meetings and took the lead on drafting all of TURN’s legal pleadings. Ms. Torres assisted Mr. Borden with discovery and A.15-02-009 ALJ/EDF/jt2 reviewed and edited his testimony and rebuttal testimony. Her hours for work in the proceeding represents the equivalent of 11 full-time weeks.

Marcel Hawiger Mr. Hawiger participated throughout the proceeding, and took the lead on issues concerning time of use pricing, the potential grid benefits of EVs, and PG&E’s cost and cost recovery proposals. Mr. Hawiger also conducted legal research regarding new SB 350 provisions applicable to the proposed program. Mr. Hawiger also provided assistance and guidance to Ms. Torres in this proceeding. Due to the large number of complex issues in this proceeding, the involvement of two attorneys was reasonable.

Bob Finkelstein Mr. Finkelstein provided 2.25 hours of assistance in this proceeding specifically related to the issue of bonus depreciation raised in settlement negotiations and the review of TURN’s legal arguments regarding the relevant SB 350 statutes.

Expert Witness Time Eric Borden Mr. Borden is TURN’s in-house energy analyst and joined TURN in February 2015. Prior to TURN, Mr. Borden worked as a consultant in energy and finance for approximately seven years. His academic research addressed electric vehicles and public charging infrastructure. In this proceeding, Mr. Borden was TURN’s lead expert on all issues relating to the program and conducted extensive research and analysis to develop TURN’s recommendations. William Marcus William Marcus of JBS Energy provided 0.84 hours of assistance to TURN regarding the limited issue of understanding PG&E’s discount rate proposal raised during settlement agreements.

Coordination among staff and presence of multiple TURN attorneys or experts at meetings:

A relatively small percentage of hours reflect internal and external meetings involving two or more of TURN’s staff members. The Commission should recognize such meetings do not reflect internal duplication, but rather are essential to effective and efficient coverage of a large litigation case that involves multiple issues.

There are a limited number of hours devoted to internal planning meetings. Such meetings are essential to the effective development and implementation of TURN’s strategy in these cases. Strategy planning meetings with multiple staff are essential, as each staff member contributes particular knowledge and expertise to develop complex case strategy that require a certain amount of “group-think.” Furthermore, in a large proceeding with multiple issues such as this proceeding,

11 TURN sometimes assigns more than one attorney to cover different issues, both to maximize the use of attorneys with particular expertise and for basic workload management. Some internal coordination is then necessary to ensure proper coverage and allocate responsibilities. Such a process is overall more efficient and effective than having a single attorney cover the entire proceeding on issues that are less familiar to the attorney.

Similarly, there are a limited number of hours for external meetings, including settlement meetings, involving TURN’s primary attorney (Ms. Torres) and expert witness (Mr. Borden). The Commission should understand that this is often essential when TURN’s attorney needs to rely on the expertise of the expert witness in evaluating proposals in real time. TURN’s requested hours do not include any for a TURN attorney or expert witness where his or her presence at a meeting was not necessary in order to achieve the meeting’s purpose. TURN submits that such meetings can be part of an intervenor’s effective advocacy before the Commission, and that intervenor compensation can and should be awarded for the time of all participants in such meetings where, as here, each participant needed to be in the meeting to advance the intervenor’s advocacy efforts. c. Allocation of hours by issue: Verified This proceeding addressed several policy issues related to the proper structure and implementation of PG&E’s EV infrastructure program. Attorney and expert consultant time was allocated both by issue as well as activities. Certain work activities, such as participation in settlement negotiations (including settlement meetings, reviewing settlement documents, drafting settlement documents) cannot be allocated by issue due to confidentiality restrictions, and are thus coded as “sett. or settlement.”

TURN uses a combination of activity and issue codes when itemizing the hourly work performed by attorneys and experts. The main activity codes used for time accounting in this proceeding include the following:

GP – 158 hours – 17% of total General Participation work essential to participation that typically spans multiple issues and/or would not vary with the number of issues that TURN addresses. This includes reviewing PG&E’s original application and testimony, PG&E’s supplemental testimony, the Scoping Memo, AC & ALJ Rulings, party motions, party ex parte notices, etc. Also includes time spent reviewing parties’ testimonies, rebuttal testimonies, opening briefs, and reply briefs. TURN also includes in this category time devoted to attending and preparing for the PHC and time reviewing the proposed decision (PD), parties’ comments on the PD, and the final decision.

Coord. – 66 hours – 7% of total Includes the amount of time TURN spent discussing the proceeding with ORA and the Joint Minority Parties, and determining which issues each would focus on to minimize duplication. Also includes limited hours meeting with other intervenors to discuss concerns regarding PG&E’s application and the proposed settlement. In order to maximize efficiency and minimize the impact on the A.15-02-009 ALJ/EDF/jt2

Commission’s limited resources, TURN coordinated with other parties opposed to the settlement to develop a joint strategy, reduce duplication, and filed a joint response to the motion to adopt the settlement.

# – 94.5 hours – 11% of total Work covering multiple issues that cannot be easily segregated. Including some work preparing the protest, TURN’s PHC statement, testimony and reviewing/editing testimony, briefs, and comments on the PD.

General Hearings (GH) – 64 hours - 7% of total Time preparing for and participating in four days of evidentiary hearings, including the development of cross-examination exhibits Also includes time spent preparing for and attending the pre-hearing conference (PHC).

Costs – 19.5 hours – 2% of total Work related to researching and analyzing the reasonableness of the costs and the cost workpapers for PG&E’s proposed programs and the program proposed in the settlement agreement. Also includes work researching and analyzing the appropriateness of PG&E’s cost recovery proposal for charging station rebates.

Ratepayer Benefits – 40 hours – 5% of total Includes time spent researching and analyzing PG&E’s claims that the proposed program would benefit ratepayers, including analyzing the complex “grid benefits” PG&E asserted would result from the program. Includes time spent reviewing PG&E’s comments regarding the BMW EV demand response pilot. Also includes time researching the relevant sections of the Public Utilities Code regarding EV infrastructure programs and requiring that such programs be “in the interests of ratepayers” and drafting legal arguments regarding the interpretation of these statutes.

Participation Payment & Rebates – 14 hours – 2% of total Includes some work researching and analyzing the appropriate rebate levels for the program and developing TURN’s rebate proposal. Includes time spent developing a rebate and participation payment proposal, which TURN presented at settlement negotiations. Also includes time spent reviewing and analyzing the participation payment proposal included in the settlement agreement.

Disadvantaged Communities (DAC) – 20 – 2% Time spent reviewing and analyzing PG&E’s original DAC proposal and the DAC proposal presented in the settlement. Includes time spent reviewing DAC maps, researching the specifics of these locations and developing related exhibits for evidentiary hearings and cross examination questions. Also includes time spent researching and developing TURN’s low-carbon fuel standard funds proposal for DACs.

Phasing – 48 hours – 5.5% of total Time spent developing TURN’s phased approach proposal in response to ALJ Farrar’s June 16, 2015 Ruling Requesting Comments on Phasing. Also includes

13 time spent reviewing other parties’ phasing comments and drafting reply comments.

Direct Current Fast Chargers (DCFC) – 25 hours – 3% of total Time spent reviewing and analyzing PG&E’s original DCFC proposal and the DCFC proposal presented in the settlement. Includes time spent researching DCFC technologies and CEC funding and private investments into DCFCs in California. Also includes time spent developing related exhibits for evidentiary hearings and cross examination questions

Size & Scope – 93 hours – 11% of total Time spent researching and developing an alternative size and scope proposal for PG&E’s program. Includes time spent reviewing PG&E’s three different size and scope proposals and the size and scope proposal in the proposed settlement. Also includes time spent researching and analyzing PG&E’s attach rate analysis and developing related exhibits for evidentiary hearings and cross examination questions.

IOU Ownership – 29 hours - 3% of total Time spent researching and developing recommendations regarding PG&E’s ownership of charging stations. Also includes time spent researching the competitive impact of PG&E’s proposal and developing alternative recommendations.

Research – 34 hours – 4% of total Includes time spent reviewing past commission decisions and other reports relevant to the proceeding. Also includes legal research conducted regarding the applicable statutes and precedent for this proceeding.

Discovery – 80 hours – 9% of total Includes TURN’s expert witness and attorney time preparing data requests and TURN attorney time reviewing and editing data requests (TURN filed over 10 extensive data requests in this proceeding). Also includes time spent reviewing data request responses and responses to other party data requests.

Sett. or Settlement – 88 hours - 10% of total Time spent attending and participating in settlement negotiations. Also includes work preparing for settlement meetings, including the review of proposals, associated research and analysis, and the preparation of a comprehensive counter offer. Also includes some time spent preparing response to settlement motion and drafting comments on settlement.

COMP – 11 hours Work preparing TURN’s notice of intent to claim compensation (1.5 hours) and final request for compensation and supporting documents (9.5 hours).

As TURN described in the opening section of this compensation request, our substantial contributions to the Commission’s decision were of such magnitude A.15-02-009 ALJ/EDF/jt2 and so wide ranging that it warrants an award of full compensation. TURN submits that under the circumstances this information should suffice to address the allocation requirement under the Commission’s rules. Should the Commission wish to see additional or different information on this point, TURN requests that the Commission so inform TURN and provide a reasonable opportunity for TURN to supplement this showing accordingly.

B. Specific Claim:*

CLAIMED CPUC AWARD ATTORNEY, EXPERT, AND ADVOCATE FEES Basis for Item Year Hours Rate $ Rate* Total $ Hours Rate $ Total $ Elise 2015 135 $215 D1604037 $28,702.50 133.51 $215 $28,702.50 Torres Elise 2016 318 $230 D1608015 $73,197.50 318.25 $230 $73,197.50 Torres Elise 2017 3 $230 $690 3 $230 $690.00 Torres Marcel 2015 12.75 $410 D1506021 $5,227.50 12.75 $410 $5,227.50 Hawiger p. 28; D1508023 p. 24

Marcel 2016 108.25 $415 D1606024 $44,923.75 108.25 $415 $44,923.75 Hawiger Bob 2016 2.25 $510 D1611004 $1,147.50 2.25 $510 $1,147.50 Finkelstein p. 18 & Res. ALJ329 (1.28% increase rounded to nearest $5)

Eric 2015 162.75 $180 D1605015 $33,525 162.75 $180 $29,295.00 Borden Eric 2016 136 $190 $21,375 136 $190 $25,840.00 Borden WIlliam 2016 .84 $280 D1606024 $235.20 .84 $280 $235.20 Marcus Subtotal: $209,023.95 Subtotal: $209,258.95 INTERVENOR COMPENSATION CLAIM PREPARATION **

1 Deduction for 1.5 hours spent on NOI, re-categorized as intervenor compensation claim preparation.

15 Item Year Hours Rate $ Basis for Total $ Hours Rate Total $ Rate* Elise 2015 1.5 $107.5 @ 50% of $161.25 1.5 $107.50 $161.25 Torres $215 Elise 2017 9.5 $115 @ 50% of $1,092.5 9.5 $115 $1,092.50 Torres $230 Subtotal: $1,253.75 Subtotal: $1,253.75 COSTS # Item Detail Amount Amount 1 Copies Copying of pleadings for ALJ $169.20 $169.20 and Commissioner Offices 2 Postage Postage for pleadings to CPUC $24.25 $24.25 3 Phone Phone bill for calls or conference $22.42 $22.42 calls necessary for proceeding 4 Legal LexisNexis research conducted $5.61 $5.61 Research for the opening brief filed in this Fees proceeding Subtotal: $221.48 Subtotal: $221.48 TOTAL REQUEST: $210,499.18 TOTAL AWARD: $210,734.18

ATTORNEY INFORMATION Attorney Date Admitted to CA Member Number Actions Affecting BAR2 Eligibility (Yes/No?) If “Yes”, attach explanation Marcel Hawiger January 1998 194244 No Elise Torres December 2011 280443 No Bob Finkelstein January 1990 146391 No

PART IV: OPPOSITIONS AND COMMENTS

A. Opposition: Did any party oppose the Claim? No

B. Comment Period: Was the 30-day comment period waived (see Yes Rule 14.6(c)(6))?

FINDINGS OF FACT

2 This information may be obtained through the State Bar of California’s website at http://members.calbar.ca.gov/fal/MemberSearch/QuickSearch. A.15-02-009 ALJ/EDF/jt2

1. The Utility Reform Network has made a substantial contribution to D.16-12-065.

2. The requested hourly rates for The Utility Reform Network’s representatives, as adjusted herein, are comparable to market rates paid to experts and advocates having comparable training and experience and offering similar services.

3. The claimed costs and expenses, as adjusted herein, are reasonable and commensurate with the work performed.

4. The total of reasonable compensation is $210,734.18.

CONCLUSION OF LAW

1. The Claim, with any adjustment set forth above, satisfies all requirements of Pub. Util. Code §§ 1801-1812.

1. The Utility Reform Network shall be awarded $210,734.18.

2. Within 30 days of the effective date of this decision, Pacific Gas and Electric Company shall pay The Utility Reform Network the total award. Payment of the award shall include compound interest at the rate earned on prime, three-month non-financial commercial paper as reported in Federal Reserve Statistical Release H.15, beginning May 7, 2017, the 75th day after the filing of The Utility Reform Network’s request, and continuing until full payment is made.

3. The comment period for today’s decision is waived.

4. This decision is effective today.

Dated April 27, 2017, at San Francisco, California.

MICHAEL PICKER President CARLA J. PETERMAN LIANE M. RANDOLPH MARTHA GUZMAN ACEVES CLIFFORD RECHTSCHAFFEN Commissioners

APPENDIX Compensation Decision Summary Information Compensation D1704032 Modifies Decision? No Decision: Contribution D1612065 Decision(s): Proceeding(s): A1502009 Author: ALJ Farrar Payer(s): Pacific Gas and Electric Company

Intervenor Information

Intervenor Claim Amount Amount Multiplier? Reason Date Requested Awarded Change/Disallowance The Utility February $210,499.18 $210,734.18 N/A Miscalculations Reform Network 21, 2017

Advocate Information

First Name Last Name Type Intervenor Hourly Fee Year Hourly Fee Hourly Fee Requested Requested Adopted Marcel Hawiger Attorney TURN $410.00 2015 $410.00 Marcel Hawiger Attorney TURN $415.00 2016 $415.00 Elise Torres Attorney TURN $215.00 2015 $215.00 Elise Torres Attorney TURN $230.00 2016 $230.00 Elise Torres Attorney TURN $230.00 2017 $230.00 Eric Borden Expert TURN $180.00 2015 $180.00 Eric Borden Expert TURN $190.00 2016 $190.00 William Marcus Expert TURN $280.00 2016 $280.00 Bob Finkelstein Attorney TURN $510.00 2016 $510.00

(END OF APPENDIX)