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ALJ/WAC/avs PROPOSED DECISION Agenda ID #15567Ratesetting

Decision ___________________

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Application of Southern California Edison Company (U338E) for Approval of its Energy Savings Assistance and California Alternate Rates for Energy Programs and Budgets for Program Years 2015-2017.

Application 14-11-007(Filed November 18, 2014)

And Related Matters.Application 14-11-009Application 14-11-010Application 14-11-011

DECISION GRANTING COMPENSATION TO CALIFORNIA HOUSING PARTNERSHIP CORPORATION FOR CONTRIBUTION

TO DECISION 16-11-022

Intervenor: California Housing Partnership Corporation

For contribution to Decision (D.) 16-11-022

Claimed: $162,481.25 Awarded: $156,054.00

Assigned Commissioner: Michael Picker Assigned ALJ: W. Anthony Colbert

PART I: PROCEDURAL ISSUES

A. Brief description of Decision: This decision approves the applications of the four major California Investor-Owned Utilities and sets forth theparameters for the administration and participation in the California Alternate Rates for Energy (CARE) Program and the Energy Savings Assistance (ESA) Program.

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A.14-11-007 et al. ALJ/WAC/avs PROPOSED DECISION

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

Intervenor CPUC VerifiedTimely filing of notice of intent to claim compensation (NOI) (§ 1804(a)):

1. Date of Prehearing Conference (PHC): February 20, 2015 Verified

2. Other specified date for NOI: N/A

3. Date NOI filed: March 23, 2015 Verified

4. Was the NOI timely filed? YesShowing of customer or customer-related status (§ 1802(b)):

5. Based on ALJ ruling issued in proceeding number:

A.14-11-007 et al. Verified

6. Date of ALJ ruling: February 18, 2016 Verified

7. Based on another CPUC determination (specify):

8. Has the Intervenor demonstrated customer or customer-related status? YesShowing of “significant financial hardship” (§ 1802(g)):

9. Based on ALJ ruling issued in proceeding number: Awaiting ruling in A.14-11-007 on March 18, 2006 motion for reconsideration (unopposed)1

Verified

10. Date of ALJ ruling: N/A Verified

11. Based on another CPUC determination (specify):A

12. 12. Has the Intervenor demonstrated significant financial hardship? YesTimely request for compensation (§ 1804(c)):

13. Identify Final Decision: D.16-11-022 Verified

14. Date of issuance of Final Order or Decision: 11/21/2016 Verified

15. File date of compensation request: 01/09/2017 Verified

16. Was the request for compensation timely? Yes

1 D.14-08-054 (Aug. 28, 2014) found that Intervenor CHPC had made a showing of customer-related status and significant financial hardship and granted intervenor compensation to CHPC in A.12-07-001.

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C. Additional Comments on Part I:

# Intervenor’s Comment(s) CPUC Discussion

Filed Motion for Reconsideration of ruling on amended notice of intent on March 18, 2016. The motion was unopposed.

PART II: SUBSTANTIAL CONTRIBUTION

A. Did the Intervenor substantially contribute to the final decision (see § 1802(i), § 1803(a), and D.98-04-059).

Intervenor’s Claimed Contribution(s)

Specific References to Intervenor’s Claimed Contribution(s)

CPUC Discussion

1. UNSPENT FUNDS: CHPC identified the IOUs’ accumulated unspent funds, authorized for ESA dating back to 2009, as a potential resource for new program initiatives to serve ESA’s unmet purposes. CHPC quantified for each utility the unspent funds and failure to meet multifamily homes treated goals based on the IOUs Annual Reports. CHPC recommended that 32% of the unspent fund balance be spent on Multifamily housing to meet the unmet goals for this sector, which has been underserved by ESA.

Protest filed by NRDC/NCLC/CHPC on January 12, 2015 against IOU Applications for ESAP/CARE Program and Budget for 2015-2017 filed 11-18-14 (“Jan.12 Protest”), on page 12: “In retrospect, budgets for the prior 2012-2014 cycle proved more than adequate to expand the measures available for multifamily buildings, and, going forward, the IOUs should readily be able to respond to the multifamily directives of D.14-08-030 while still responsibly managing their budgets. In its recent advice letter filing, SCE reports significant unspent ESAP funds for every program year since 2009. Clearly, SCE could significantly expand the measures it provides in the multifamily sector without exceeding previously-authorized spending levels, as it has cumulatively underspent prior authorized spending by over $70 million. PG&E, SDG&E, and SCG reported similar challenges meeting their multifamily goals and both have accumulated substantial amounts of unspent funds: PG&E estimates over $50 million in unspent funds between 2012-2014, SDG&E estimates $20 million in unspent funds

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UNSPENT FUNDS (p. 2 of 3)

by 2014 year-end, and SCG reports $75 million in unspent funds from 2012 and 2013 alone.”

D. 16-11-022 p. 173: The treatment of low-income occupied multifamily properties by the ESAProgram has been a central issue as this proceeding has unfolded. We recognize that program changes are necessary to better serve the energy needs and reduce the hardships on ESA-eligible households living in this building type, while also considering cost-effectiveness. (See also FPF 46)

D. 16-11-022 p. 196: In light of the large unspent funds balance from previous program cycles, IOUs are directed to use that unspent fund balance to address the needs of this sector…we establish a budget of $80 million of unspent funds (which is approximately 20% of the total unspent fund balance) for the upgrades to common area measures as described in today’s Decision.

D. 16-11-022 p. 207-208: We find that the multifamily segment that houses predominantly low-income Californians has been underserved by ESA and by the Commission’s energy efficiency and other programs, meriting additional funding and programmatic focus through ESA. Deploying the substantial unspent funds of ESA to meet these needs is well-suited to reducing energy hardships for low-income Californians, and to meeting our energy conservation and GHG reduction targets. (see also FOF 49)

FOF 80: The IOUs have a combined unspent funds carryover of approximately $400,520,379 for

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UNSPENT FUNDS (p. 3 of 3)

2009-2015.

FOF 82: It is reasonable to use unspent funds to promote achievement of unmet energy savings goals.

COL 85: California Public Utilities Code Section 382(e) directs the Commission to ensure that all eligible low-income electricity and gas customers are given the opportunity to participate in low-income energy efficiency programs, including customers occupying apartments or similar multiunit residential structures.

COL 185: Unspent funds should be used to promote achievement of unmet energy savings goals, as directed within this decision.

OP 136: [IOUs] shall include in their annual reports a summary of unspent funds, identifying both funds that are carried over and funds that are not carried over …

2. INCOME VERIFICATION. CHPC provided a thorough explanation of the tenant income documentation procedures used by owners of rent-restricted properties, which justify an owner affidavit approach, in the testimony of Multifamily property owner Samara Larson of LINC Housing. CHPC supported SCG/SDGE applications’ proposal for landowner affidavits as a means of self-certification. Since the utilities provided no details, procedures or verification process for such

Jan. 12 Protest p. 15: “We strongly recommend that a comprehensive expedited enrollment process, including a timeline for implementation, be developed in order to take advantage of existing government certified income verification methods and to create a uniform process for use by all of the utilities…[utilities should] take advantage of the income documentation performed for properties assisted by the federal Low Income Housing Tax Credit (LIHTC) available through the State Treasurer’s Office Tax Credit Allocation Committee (TCAC). LIHTC helps finance many affordable housing properties that do not have funding from HUD, yet similarly require strict income verification of tenants as a

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“self-certification”, CHPC made a series of specific recommendations. In addition, Ms. Larson described owners’ existing obligations to funders to re-verify tenant income data every 12 months. Ms. Larson was the only witness to advocate for a streamlined income verification process and property owner waiver (POW) as adopted in the Decision.

INCOME VERIFICATION (page 2 of 3)

condition of residence. This information is also available to property owners and managers who could attest to the income qualification of their tenants.”Testimony of Samara Larson, LINC Housing filed by NRDC/NCLC/CHPC on April 27, 2015 on Topic: Income Verification Using Government-Verified Tenant Income Data (April 27 Larson-02 Income) p. 3-4: “A6. Tenants must complete a comprehensive application when they seek to rent in government assisted affordable housing. The application requires documentation of all sources of income and assets for every adult in the household. The owner verifies all of this information prior to occupancy, including calling the employers to verify employment and income. A typical completed tenant application file will consist of 50-100 pages, with length varying based on the number of adults in the household . This is a list of the [ten] types of documents collected for every member of the household.”

April 27 Larson-02 Income p.5: “A8. We survey resident income regularly, and depending on the funding source requirements, the level and frequency of certification at a property varies. Because we submit information to various government agencies at different times throughout the year, regardless of the dates tenants assume occupancy, we request additional information from tenants on a rolling basis so it always current within 12 months or less.”

April 27 Larson-02-Income p. 7: “A10. It would be so much more efficient and expedient than the current door-to-door process for verifying tenant income for ESAP, as

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INCOME VERIFICATION (page 3 of 3)

well as providing a rigorous verification system.” p.10: “A14. We would get the results much more quickly, in a day or two, rather than waiting six weeks. In addition, more apartments would have qualified because we have income records for every household.”

D.16-11-022 p. 192: “For this [rent-restricted] multifamily housing type verification of eligibility is routine as the building is dedicated to use by low-income Californians”

D. 16-11-022 p. 200-201: We similarly direct all of the IOUs, as part of its conforming Advice Letter, to develop and implement an owner or authorized representative affidavit process for… the building is registered as low-income affordable housing …with qualified income documentation less than 12 months old on file. These buildings will be eligible for whole building enrollment without the need for door-to-door tenant income documentation. The process should allow for large portfolio owners/operators to simultaneously submit affidavits for many properties in multiple service territories at one time. This self-certification affidavit should also act as a [property owner waiver] POW form for ESA Program and other EE program installations. (See similar language in COL 76, COL 77 and OP 46)

3. PROGRAM DELIVERY. CHPC provided numerous recommendations to improve the efficiency and effectiveness of ESAP program delivery for multifamily property owners by: (i) working directly with multifamily property owners, (ii) expanding the duties of the

Jan 12 Protest re: TCAC Coordination p.17:“ By connecting with TCAC to identify properties interested in pursuing major rehabs, the IOUs could better capture opportunities to work with building owners as they are planning deep building retrofits.”

Jan 12 Protest RE: Work with Owners

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utilities’ Single Point of Contact (SPOC) including expanded technical assistance and reporting requirements for SPOCs, (iii) reaching owners through other government agencies, (iv) streamlining paperwork and (v) creating a Multifamily Working Group.

PROGRAM DELIVERY (p. 2 of 4)

p. 16: “…instances where tenants and owners were both marketed program offerings that only the building owner had authority to authorize. This is an instance where visits could easily have been minimized by first working directly with the building owner.”

Jan 12 Protest Re: SPOC p. 19: “Although all of the utilities endorse the idea of a single point of contact, and have begun to implement it in various ways, the applications fail to fully address the direction in the [prior ESAP] Decision to include “the level of funding, staff time, or other resources the ESA Program will dedicate to the single point of contact effort” …the current proceeding should establish guidelines for the SPOC in order to provide consistency across the utilities and guarantee an appropriate level of funding and staff time.

Jan 12 Protest RE: Working Group p. 19: “We recommend the Commission hold workshops specific to the multifamily sector in this proceeding and establish a multifamily stakeholder group to address these issues on a continuing basis.”

Testimony of Samara Larson, LINC Housing filed by NRDC/NCLC/CHPC on April 27, 2015 on Topic: Multifamily Property Owner’s Perspective On ESAP: Coordination With Other IOU Energy Efficiency Programs, Single Point Of Contact, And IOUs Working Directly With Property Owners (April 27 Larson-03-Owners) RE: SPOC p. 3: “A6. The utilities’ current brochures and websites are quite good and provide clear information about what each individual program offers. However, it is difficult to obtain comprehensive information

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about the interactions between programs and the different qualifications for the programs.”

April 27 Larson-03-Owners p. 4 “A7. For ESAP, because the application is tenant oriented, I need to complete 100 applications to serve 100 apartments… It seems particularly odd to the tenants because most of the ESAP measures do not affect things they own in the apartment.” AND “For the other energy efficiency programs, each one requires a separate application to the same utility. It is not cumbersome, but senselessly repetitive. An efficient application process should be designed that will fill in all of the data about my company once I have entered the company name.”

April 27 Larson-03-Owners p. 5: “A8. This problem results from the contractor showing up at the property and wanting to talk to someone right away. The property manager is likely to be the most readily available staff person on-site, however, the manager is not the appropriate person to provide such permission. The manager is not responsible for assessing equipment costs, operating expenses or replacement. These are the responsibilities of the property owner. This is another example in which working directly with property owners would greatly improve the efficiency and effectiveness of ESAP.”

April 27 Larson-03-Owners p. 7-8: “A11. As a building owner, I need more than a contact simply pointing me to the available programs. The “Single Point of Contact (SPOC)” should be the person who coordinates successful integration, delivery and management of the utilities’ programs, working with

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me all the way through. Ideally, the SPOC role would start with facilitating a single application for all programs, and run the interference inside the utility necessary to get the information and approvals needed from all available programs. Next, based on the SPOC understanding of all programs, he or she would help me understand what I lose or gain by taking various options…An effective SPOC will maximize the energy efficiency gains, and minimize the service delivery visits experienced by multifamily owners and tenants. The “account executive” model some utilities have tried for the SPOC does not fulfill the functions I require.”

Testimony of Amy Dryden, Build It Green, filed by NRDC/NCLC/CHPC on April 27, 2015 on Topic: Current Energy Efficiency Programs and Common Area Measures (April 27 Dryden-05: “Ideally, property owners are funneled through an IOU’s “single point of contact” to evaluate the extent of the scope of work and identify which program is appropriate for the property. ..although, it is also my understanding that IOUs are handling the layering of programs differently.”

Sept 6 Comments p.13: “…much more coordination from a SPOC will be required beyond OBF technical support…we recommend that the SPOC budget for all of the new initiatives authorized in this Decision be described in the ESA/CARE Annual Reports. This should include SPOC technical assistance for the new multifamily program authorized by this decision to provide common area measures and audits provided throughout the State, as well as the Decision-directed SPOC activities in the

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Aliso Canyon affected area.”4. WHOLE BUILDING / COMMON AREAS. CHPC provided guidance and recommendations on how the ESAP program can be expanded to provide a whole building energy efficiency retrofit program for multifamily housing (MF), which provides common area and central system measures. Recommendations included the use of audits to guide the whole house approach. CHPC provided evidence that this approach can remedy the chronic problem of ESAP underserving multifamily housing and provide the benefits of ESAP to MF residents in buildings where a substantial majority of the tenants are ESAP eligible.

WHOLE BUILDING/ COMMON AREAS (page 2 of 5)

Apr.27 Larson-03-Owners p. 9: “Successful integration of the utilities’ energy efficiency programs requires a holistic approach to assessments and audits to maximize energy savings results, while minimizing administrative expense.”

Apr.27 Dryden-05 p. 6: “The EUC programs already require a whole building ASHRAE level II audit or similar. The purpose of this audit is to identify the opportunities for whole building savings.”

Apr.27 Dryden-05 p. 11: “The intention of having a common set of core measures is to create consistency in standards and terminology where possible. The common core measures should be based on the most commonly used measures in the programs.”

Apr.27 Dryden-05 p. 12-13: “D. PROPOSAL FOR NEW COMMON AREA MEASURES FOR MULTIFAMILY PROPERTIES:“…allowing common area measures to be part of the direct install program will allow deeper savings for affordable multifamily properties, in addition to increased savings for programs and consistency in the work.” For a project to be eligible for installation of common area measures, we recommend adhering to the threshold that 80% of the units be qualified for ESAP.”

Ex parte notice with “Open letter” sent to all Commissioners and service list, filed by CHPC on May 16, 2015, [May 16 ExParte] p.3: “As already recognized by the CPUC, there is no explicit prohibition against ratepayer

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funds being used to provide assistance to property owners for investments in energy efficiency improvements to reduce kWhs or therms associated with usage by low-income tenants solely because the property owner is paying the bill.”

Comments filed by NCLC and CHPC on September 6, 2016 on Proposed Decision and Alternate Proposed Decision on IOU Applications for ESAP/CARE Program and Budget for 2015-2017 (Sept 6 Comments) p. 4: “[CPUC] formally ordered that “the Multifamily Segment Study” be “adopted” (D. 14-08-030, Ordering ¶ 34, p. 118) and separately ordered the companies to “propose new, cost-effective measures for the multifamily sector, including common area measures and central heating, cooling, and hot water systems.” Id., Ordering ¶ 41, p. 121 (emphasis added). Thus, it is now abundantly clear from prior decisions that the Commission not only has the legal authority to require the ESA-administering utilities to serve common areas/systems in which low-income households reside, but that as a separate policy matter ESA should serve those common areas if tenants in multifamily housing are to be given the fair and reasonable access afforded other ESA-eligible households. (See APD, p. 171, summarizing NCLC and CHPC position).”

D. 16-11-022 p. 188: To address the needs of low-income Californians living in multifamily housing we authorize measures to address the physical structure, including common area measures, as well as treatment of the tenant’s dwelling unit.

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D. 16-11-022 p. 189-190: The law does not limit energy efficient treatment of the physical structure to that inside the dwelling unit. In construing a statute, we must first recognize the plain meaning of the statute and show fidelity to the words the legislature has chosen…. Treating common areas of the physical structure outside of the dwelling unit is consistent with the code’s objective to reduce energy consumption and hardship as reflected in rent costs for building energy use.

D. 16-11-022 p. 191: Therefore, in consideration of our statutory mandates and the directives adopted in D.14-08-030, we adopt a new strategy for the multifamily sector going forward. We agree that the SPOC is an important first step, but alone is not sufficient. Coordinating and leveraging ESA with other programs is important and a priority we authorize in this Decision, but it must be coupled with authorization of measures to address the building structure to achieve reduce energy burdens.

D. 16-11-022 p. 195: For rent restricted low-income multifamily housing, meeting our criteria as discussed below, we approve full funding and deployment of common area measures, including HE central air conditioning, water heaters, and lighting, and also approve water/energy nexus measures consistent with those approved for dwelling units by this Decision, and consistent with the whole building audit recommendations. (See also COL 86)

D. 16-11-022 p. 197: We seek to target both retrofits and replacements in the

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common areas of multifamily buildings.

D. 16-11-022 p. 208-209: As part of the SPOC approach, we agree with NRDC et al.’s suggestions to allow for projects participating in other IOU programs and the ESA Program to use ASHRAE Level II audit findings to inform installations for multifamily buildings seeking common area measures and upgrades.

FOF 34: It is reasonable to authorize a common core set of ESA Program measures. The IOUs already offer a similar set of core measures with slight variations across their IOU service territories based on climate zones, housing stock, and contractor and CBO relationships.

FOF 48: Treating common areas of multifamily buildings is important to improving the energy consumption of the physical structure in which low income tenants live. Failure to treat the common areas of a multi-unit building may undermine the effectiveness of measures implemented inside of a dwelling unit.

COL 84: The IOUs should draw from their unspent ESA balances to fund the common area ESA multifamily building efforts authorized by this decision, including program coordination and leveraging efforts, development of appropriate MOUs, and administration of this program segment.

OP 43. [The IOUs] shall fund in the Energy Savings Assistance Program common area measures for the following multi-family buildings dedicated to providing affordable

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housing to low-income Californians in deed restricted, government and non-profit owned multi-family buildings, as described in this Decision, subject to a cap of $80 million of unspent funds pro-rated by each utility…(similar language in Decision p. 196)

5. PROGRAM ALIGNMENT. CHPC provided evidence of the lack of coordination among various energy efficiency programs administered by the utilities and the California Department of Community Services & Development (CSD). CHPC demonstrated how the failure to coordinate undermines achievement of energy savings and discourages participation in ESAP. CHPC provided guidance for methods to improve program coordination, and integrating multiple programs to achieve better results.

PROGRAM ALIGNMENT (page 2 of 5)

Jan 12 Protest p. 12: We urge the Commission to require IOUs to provide sufficient detail on their proposals to coordinate ESAP with MFEER, EUC, programs offered by the Department of Community Services & Development (CSD), and others, in order to comply with the mandates of D.14-08-030 to coordinate among multifamily programs, including providing proposals to pool funds.

Prehearing Conference Statement filed by NRDC/NCLC/CHPC on March 2, 2015 (“March 2 PHC”) p. 4: “We agree that the Commission should examine the IOU coordination efforts, but ask the Commission to explicitly state that coordination efforts also include coordination with the general Energy Efficiency programs, such as Energy Upgrade and the Multifamily Energy Efficiency Rebate program.”

April 27 Stamas-01 p.25-26: “Layering programs that still have varying timelines, unique eligibility and enrollment rules, unique administrators, and incentives that cut against participation in multiple programs, does not provide for true coordination… Furthermore, program budgets and timelines are incongruent with providing integrated offerings, see Table 5: Utility Program Budgets Based on Historic 2013 ESA Expenditures and Average of 2013 and 2014 Non-ESA Budgets” p. 33: “As Table 5 illustrates, utilities’ budgets in other multifamily

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programs are generally inadequate to serve affordable multifamily properties eligible for ESA.”

April 27 Larson-03-Owners p. 5-7: “A9. The Energy Upgrade program is only in the pilot stage and the program cycle is too short for multifamily property owners to truly leverage building assessment recommendations, or consider a whole portfolio approach. However, some coordination challenges are apparent, resulting from a fundamental disconnect between the requirements and purposes of the programs. For example, Energy Upgrade is the only program with full energy audit requirement, whereas ESA, MIDI and MFEER require a checklist-type assessment. Another issue is timing and financing the energy efficiency work… just some of the reasons why we need ongoing and coordinated technical support from the utilities in order to facilitate participation in their multiple programs and maximize incentives that will achieve deeper energy savings. This means comprehensive assistance describing the scope of work and help identifying maximum energy savings by allocating which measures are undertaken by which program.”

April 27 Dryden-05 p. 6: “…the property owner has to attempt to coordinate upgrades and access to different programs sequentially. This increases the burden on staff and on the tenants, who may have to put up with multiple visits from energy auditors and contractors/installers. This also increases the overall non-energy cost/benefit ratios as administrative costs will increase... In general,

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property owners have said that they find this layered or two-step program approach daunting. To avoid it, they often make a choice as to which program to participate in and do not attempt to access multiple programs due to the complexity of differing applications and the difficulty of achieving additional energy savings to access any second program that may be available.”

Apr. 27 Dryden-05 p. 8: “This level of coordination among programs will require a shift in the paradigm of how utilities are serving the property owner, but this integrated approach that targets the owner is highly consistent with findings and recommendations made in the Cadmus multifamily study and the Commission’s guidance document. This model allows for property owners with qualifying properties to leverage greater funding to achieve greater energy retrofits while meeting the goals of the ESAP and Whole Building Programs. The property owners can access the available utility assistance without filling out multiple applications and complying with each program’s rules…”

Apr. 27 Dryden-05 p. 9: “Appendix 1 to my testimony includes a summary of the measures offered under ESA and the MFEER Program. What is clear from that Appendix is that there are significant disparities among the companies as to whether particular measures are offered at all, and, if they are offered, whether they are offered through just ESAP, just MFEER, or through both programs. For owners of multifamily properties in different utility service territories, this creates significant confusion and acts as

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a barrier to accessing those programs.”

May 16 ExParte p.3: “Further, that the ESA program include a multifamily specific offering that can leverage budgets from other IOU programs, such as Energy Upgrade and the MFEER, to permit whole building energy investments in this sector in recognition of the unique challenges of these building types and the split incentives involved in their financing.”

D. 16-11-022 p. 189: The Commission will explore other partnerships such as with the US Department of Housing and Urban Development (HUD), state, local, federally recognized tribal, and non-profit housing agencies and administrators, and other multifamily housing agencies, to coordinate, leverage, and deploy the ESA Program with other local, federally recognized tribal, state, and federal programs to achieve the statutory objectives of ESAP and the goals established in this Decision.

D. 16-11-022 p. 203: We emphasize our support for SDG&E’s innovative efforts to use its RFP process to procure a one-stop shop EE contractor that will deliver both ESA and other EE programs. This is the type of thoughtful, serious and truly integrative approach that the low-income multifamily market requires. As documented by NRDC et al.’s extensive research in support of their procedural findings, Commission funded evaluations, and demonstrated by CSD’s approach to the multifamily market, a single program implementer program design may overcome many of the administrative barriers experienced by this housing sector. Updates on the

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roll-out and delivery of this SPOC contracting innovation process should be routinely provided to the Commission’s Energy Division.

D. 16-11-022 p. 209-210: In summary, we direct the ESA Program to provide funding and coordinate with the Program Administrators well-positioned multifamily programs to deliver deep energy retrofits specific to low income multifamily housing.

COL 29 The IOUs should coordinate their ESA Program efforts with their activities in the Energy Efficiency proceeding, R.13-11-005, and present plans for full adoption in their next ESA Program cycle applications

6. ELIGIBLE MULTIFAMILY. CHPC provided explicit guidance to explain and justify the new ESAP Multifamily approach for government-assisted, rent-restricted housing. As a state-created nonprofit organization established to expand and preserve the supply of homes affordable to low-income households in California, CHPC is uniquely qualified to advise on this issue. CHPC provided evidence that rent-restricted housing is predominantly occupied by ESAP eligible tenants, and that the very nature of restricted rents precludes a cash flow that could enable energy efficiency upgrades. CHPC provided a specific definition for qualified rent-restricted housing that, based on our experience in this field, will avoid misunderstandings and

April 27 Larson-02-Income Verfication Testimony p. 5: “A7. Yes. Affordable housing owners are required to verify tenant income in order to determine if the tenant qualifies for subsidized housing. Affordable housing owners are required to verify tenant income as a condition of receiving most sources of funding used to construct and maintain affordable housing by housing and community development agencies...In addition, as non-profit housing owners we must provide tenant income data to local tax assessors twice per year in order to verify our tax exempt status….The penalties for non-compliance are severe. For example, HUD can recapture the subsidies, and TCAC can take away the tax credits. These are two of the largest sources of funding for affordable housing. No affordable housing owner would risk jeopardizing these funds.”

Ex parte notice with “Open letter” sent to all Commissioners and service list, filed by CHPC on May 16, 2015, (May

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unintended consequences for implementation of the program.

ELIGIBLE MULTIFAMILY (page 2 of 7)

16 ExParte) p. 1: “Because the differences between the types of housing assistance programs is important to the underlying discussion about whether more aggressive actions are appropriate for common area/central system measures under ESAP, CHPC respectfully submits a clarification on the differences between government-assisted housing and Section 8, and responds to the question how these properties would be served…. The common denominator that speaks to the promise of continued public benefit for this category of affordable housing is the existence of a regulatory agreement or deed restriction governing rent levels and the income requirements of the occupants.”

May 16 ExParte p. 2: “As demonstrated by the database and analysis developed by the U.S. Departments of Energy and Housing and Urban Development as part of their 2009-2011 joint initiative to weatherize a larger portion of the low-income affordable rental property stock, these government-assisted properties are predominately occupied by households meeting the ESA program’s income requirements and have rent affordability and other regulatory restrictions that limit property cash flow and ability to undertake whole building energy efficiency retrofits outside of project refinancing. There is a finite number of eligible government-regulated multifamily affordable rental properties located within the IOU’s service areas: approximately 4,200 government-assisted multifamily rental properties with over 300,000 low-income rental units. CHPC can provide lists of the eligible properties as requested.”

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May 16 ExParte p. 3: “…government-assisted housing under the definition provided above would be predominately occupied by qualified low-income households ….As such there is a specific economic rationale for “more aggressive” action, as called for by Commissioner Florio, since most of these properties would not participate in the general energy efficiency program unless other resources can be leveraged to cover the costs of energy improvements.”

May 16 ExParte p. 3: “In order to address the gap described by Commissioner Sandoval [at Oral Argument], between the common area/central system measures that the general energy efficiency program can provide to owners who can afford to participate, and the unmet needs in properties without sufficient cash flow, ESA program guidelines and policies must be aligned with the circumstances affecting energy efficiency investments for this market segment. What CHPC and other parties have requested is that common area/central system measures be funded under ESA for government-assisted affordable rental properties that (1) can document that they are serving a majority of ESA-eligible customers, and (2) that have income and rent restrictions imposed by a federal and/or state agency.”

Sept 6 Comments p. 9-10: “Based on our experience with other government programs serving this housing sector, we recommend the following clarifications of the definition of housing which ESA can serve at no cost (shown in bold underline):“Some multifamily properties [buildings] are dedicated to providing

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affordable rents low-income populations through deed restriction, ownership, or contract. Examples include properties [buildings]owned by the U.S. Department of Housing and Urban Development (HUD), Tribal Housing for low-income tribal members, housing [own and run] legally controlled by local housing authorities, non-profit organization s or other owners where the building is deed or contract restricted to house low-income tenants under an agreement with HUD, the California Department of Housing and Community Development and/or the State Treasurer’s Office (hereinafter “rent- restricted low-income multifamily housing”) restricting rents to affordable levels based on tenant income levels, that are regularly verified by HUD or the specified state agency.

The first proposed revision clarifies that the property is “controlled” rather than “owned” is necessary to avoid confusion that may occur due to the unique nature of how rent-restricted low-income multifamily housing is financed… The second proposed revision adds precision about the conditions required for categorical eligibility including monitoring and enforcement by a federal or state agency.”

D. 16-11-022 p. 191-192: In considering the positions of the parties, we consider their arguments about the ownership model of the multifamily sector and its effect on energy efficiency incentives and potential for ESA program participation. Some multifamily properties are dedicated to low-income population through deed restriction, ownership, or contract. Examples include properties owned by HUD, owned or controlled housing for

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low-income federally-recognized tribal members, housing legally controlled by local housing authorities, non-profit organizations or other owners where the building is deed or contract restricted to house low-income tenants under an agreement with HUD, the California Department of Housing and Community Development and/or the State Treasurer’s Office restricting rents to affordable levels based on tenant income levels, that are regularly verified by HUD or the specified state agency (hereinafter ―rent restricted low-income multifamily housing). For this subset of buildings dedicated to providing affordable housing to low-income Californians, the legislative directives that authorize ESA authorize to conserve energy permit treatment to the physical structure housing the ESA-eligible Californians, not just measures inside the tenant’s dwelling unit. We concur with NRDC et al. that such treatment should include the unit and the common areas of the building for rent restricted low-income multifamily housing.

D. 16-11-022 p. 193: We note that many non-profit controlled multifamily buildings use government grants as a source of funding for construction and/or operation of the facility. Deed-or-rent restrictions often come with taxpayer or local zoning support and government buildings are often a product of public/private partnerships. Whether the rent is restricted by the owner (government or a non-profit) or by the deed itself, there is often cross support from multiple different groups to support the rent restriction.

D. 16-11-022 p. 193-194: We are

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informed by California Public Utilities Code Section 2852(a) which states ―The rental housing units targeted for lower income households are subject to a deed restriction or affordability covenant with a public entity or nonprofit housing provider organized under Section 501(c)(3) of the Internal Revenue Code that has as its stated purpose in its articles of incorporation on file with the office of the Secretary of State to provide affordable housing to lower income households that ensures that the units will be available at an affordable rent for a period of at least 30 years. (see also COL 69)

D. 16-11-022 p. 194: For the purposes of the common area measure support envisioned today, we adopt the 65% ESA-eligible tenant multi-family common area measure rule for participating deed restricted multifamily buildings to facilitate building participation and target ESA program dollars to multifamily buildings that house predominantly ESA-eligible tenants. (see also COL 68)

FOF 47: A significant subset of California’s low-income population lives in rent-restricted affordable housing in multifamily properties. The owners of these properties are legally controlled by local housing authorities, non-profit organizations, or other owners that restrict occupancy by deed or contract to the low-income populations under an agreement with HUD, the California Department of Housing and Community Development, and/or the State’s Treasurer’s Office restricting rents to affordable levels based on tenant income levels, that are regularly verified by HUD or the specified state agency (hereinafter rent

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restricted low-income multifamily housing).

FOF 50: It is reasonable to use ESA Program funds for the subset of multifamily buildings dedicated to providing affordable housing to low-income Californians, including deed restricted, government and non-profit owned multifamily buildings, including common areas. We do not differentiate between properties that are restricted by deed, by public entity (including federally-recognized tribal or government ownership) or non-profit ownership.

1. 7. ON BILL FINANCING.2. CHPC is unique in California

for combining extensive experience in housing finance transactions with a deep commitment to affordable housing policy and technical assistance. CHPC provided an analysis of the problems faced by owners of rent-restricted properties in accessing investment capital for energy efficiency retrofits. This analysis reflected CHPC’s experience implementing the pre-pilot for the CPUC-approved Master Meter Multifamily Financing Pilot, which provides an On-Bill Repayment option for energy efficiency improvements in rent-restricted multifamily housing, and included recommendations to expand and improve this financing program to better serve this housing sector by providing more funds over a longer repayment period.

[Sept 6 Comments] p. 11: “CHPC supported the design and implementation of the Master-Meter Multifamily On-Bill Repayment (OBR) Pilot, approved by the Commission in D. 13-09-044. CHPC developed and field-tested a pre-pilot OBR program and worked closely with nonprofit deed restricted housing owners who attempt to use this program... The main reason these owners have not used the OBF program is that the five-year term and $100,000 financing limits render this program virtually useless for the types of improvements with longer estimated useful lives that these programs require. CHPC’s prepilot test of OBR has shown that OBR will be virtually impossible to develop as a successful financing tool due to the lack of capital sources willing to forgo traditional loan structures for financing of this type.”

[Sept 6 Comments] p. 12: “The simple solution to this problem is to revise the rules for the On Bill Financing (OBF) program to enable low-income rent-restricted multifamily housing properties to have access to the OBF

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ON BILL FINANCING (page 2 of 3)

terms provided for government properties, specifically an OBF per property limit of $250,000 with ten-year term. Low-income rent-restricted multifamily housing of this type is so regulated and controlled by government agencies as to be virtually indistinguishable from properties owned directly by federal, state and local governments. Accordingly, it is fair and reasonable that these properties be provided OBF terms comparable to government properties.”

D.16-11-022 p. 203: To make the ESA multifamily program initiative a success, we must address financing barriers and technical assistance. Findings from a variety of evaluation studies on the multifamily segment and the developed record for this proceeding indicate that lack of access to investment capital and lack of technical assistance to property owners are persistent barriers to the successful delivery of energy efficiency into this market segment and in particular to the low income occupied multifamily housing sector. Understanding these challenges, and looking at the lay of the land of existing financing and multifamily programs currently available to the market, we direct the IOUs to leverage their current On-Bill Financing (OBF)/On-Bill Repayment (OBR) programs in order to create an additional leverage points for multifamily properties serving low-income residents to access OBF.

D.16-11-022 p. 204: It appears that the underutilization of the OBF program among multifamily properties is the result of a lack of awareness and an unwillingness to tap into loans of up to $100,000 with five-year payback

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ON BILL FINANCING (page 3 of 3)

terms, which sheds further light on the dramatic costs associated with retrofitting the multifamily market sector.

D.16-11-022 p. 205: Specifically, these OBF implementation plans should revise the program to: (1) better integrate OBF with the ESA Program SPOC model that has been further established and empowered in this Decision; and (2) propose modified loan terms that are more accessible to the multifamily market by increasing the financing limits to $250,000 with the terms expanded to ten-years for multifamily properties that meet our criteria specified in this Section. These plans should identify strategies, update program design, and include detailed marketing plans to reach the multifamily sector, including the low-income occupied multifamily housing sector.

COL 81: The OBF/OBR plans should aim to: (1) better integrate OBF with the ESA Program SPOC model that has been further established and empowered in this Decision; and (2) consider and, if warranted, propose modified loan terms that are more accessible to the multifamily market, and the plans should identify strategies, update program design, and include detailed marketing plans to reach the multifamily sector, including the low-income occupied multifamily housing sector. (similar language in OP 51.)

3. LEVERAGING LIWP. CHPC recommended programmatic and funding integration of ESAP with the California Department of Community Services and Development (CSD) Cap-and-Trade-funded Low Income

Jan 12 Protest p. 12: We urge the Commission to require IOUs to provide sufficient detail on their proposals to coordinate ESAP with MFEER, EUC, programs offered by the Department of Community Services & Development (CSD- Low Income Weatherization Program), and others,

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Weatherization Program (LIWP) for Large Multifamily properties. CHPC has extensive experience with LIWP and is uniquely positioned to recommend a fully integrated whole building approach for multifamily properties using ESAP and LIWP resources.

LEVERAGING LIWP (page 2 of 3)

in order to comply with the mandates of D.14-08-030 to coordinate among multifamily programs, including providing proposals to pool funds.

Apr 27. Dryden-05 p. 7: “ The structure of this [ESA} adder would be an additional incentive per unit provided to a multifamily owner accessing EUC or other whole building program—such as the Community and Services Department’s Low Income Weatherization Program, perhaps based on the average ESAP costs per unit, or other metric.”

Sept 6 Comments p.12: “NCLC and CHPC support the APD recommendation to create an ESA balancing account that will establish funding for leveraging LIWP-MF Cap-and-Trade funding…”

D.16-11-022 p. 201-202: Utilizing a single expert implementer, the CSD LIWP for large multifamily property presents an excellent opportunity for treating this population while our ratepayer funded programs continue to work towards more cost-effective approaches. To leverage these dollars and energy efficiency upgrades, we direct the creation of an ESA Program sub-account that will establish funding for leveraging with the LIWP multifamily effort. …

COL 78/OP 47: There should be an ESA Program balancing account that will establish funding for leveraging with the LIWP multifamily effort, which should mirror our direction to leverage with the CSD/CEC and CSD/DWR Drought Mitigation Efforts. (See also Decision pp. 201-202)

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COL 79/OP 48: “The IOUs should create a new balancing account to fund only measures currently offered by the ESA Program and approved for multifamily households”

B. 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:CHPC’s participation was closely coordinated with NCLC and NRDC, and they were our main contact throughout the proceeding, but we also worked with and found common goals with: ORA, TURN, Center for Accessible Technology, Brightline Defense Project, Marin Clean Energy (MCE) and Greenlining Institute.

d. Intervenor’s claim of non-duplication:

Coordinating with partners NCLC, NRDC: CHPC worked closely with NCLC and NRDC on most filings, however we carefully divided issues so that no duplicative work was performed. Our organizations explicitly share goals for increasing energy efficiency in multifamily housing serving low-income residents, but we each have different areas of expertise. CHPC deferred to NCLC on legal issues and other state’s programs, and deferred to NRDC on energy savings goals, cost effectiveness, other states’ examples, and specific energy efficiency measures such as heat pumps and power strips.

CHPC is a leading expert on the barriers to energy efficiency participation by affordable rental housing owners and managers in California. CHPC established the Green Rental home Energy Efficiency Network (GREEN) in 2010 to work collaboratively with affordable housing organizations in California to increase access to energy efficiency and renewable energy resources. Accordingly, CHPC took the lead on issues requiring expertise on affordable multifamily housing owner participation barriers, such as the process for verifying tenant income, defining “rent-restricted” housing, and the need for ESAP to cover common area measures.

CHPC, NRDC and NCLC organizations would divide review of documents e.g. comments and share summaries. In preparation of common filings we would engage in sequential drafting of documents: first, we worked together to develop a common outline, second, one group would write an initial draft

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structuring the document and adding their area of expertise, finally, the other two groups would add their unique expertise and edits. Through this method we simplified the review of our recommendations for the CPUC and other parties. CHPC’s timesheets heavily discount the time we spent coordinating with NCLC and NRDC to avoid duplicative counting of hours spent on coordination efforts. In addition, by filing comments jointly, we significantly reduced the amount of time that would have been incurred by each group in drafting its own testimony and pleadings.

Coordinating with ORA and Other Parties: CHPC consulted with ORA staff including email exchanges with Camille Watts-Zahga and Alexander Cole on issues throughout the proceeding and an in person meeting with Dan Buch in the development of responses to the PD and APD. In addition, we coordinated with ORA and the five groups mentioned above on developing recommendations for PHC statements filed on 3-2-15. CHPC consulted with these six groups in preparation for Oral Argument in May of 2016, and coordinated before the All Party meeting in August 2016 on issues where we have interests in common, identifying which groups took the lead based on their priorities and expertise, and avoiding duplication their efforts.

PART III: REASONABLENESS OF REQUESTED COMPENSATION

A. General Claim of Reasonableness (§ 1801 and § 1806):

a. Intervenor’s claim of cost reasonableness:CHPC advocates for the interests of low-income multifamily tenants and affordable housing building owners/managers. CHPC has significant experience in affordable housing finance, and works with multifamily housing owners and tenants on energy efficiency retrofits. CHPC made specific program recommendations in order to improve the ESAP program and to meet owners and tenants needs under feasible requirements. CHPC made a substantial contribution to the decision as described above.

CPUC Discussion

b. Reasonableness of hours claimed:CHPC coordinated with other parties to avoid duplication of efforts (Part II(B)(d) above). CHPC’s total hours claim is conservative for the following reasons:1. CHPC worked diligently to divide labor internally to those best suited for the particular tasks. Megan Kirkeby, CHPC’s Sustainable Housing Policy Manager, had primary responsibility for performing substantive research, and for the drafting and review of filings and other proceeding-related documents. Ann Gressani, consultant to CHPC, was the primary assistant to Megan Kirkeby in all proceeding-related activities including drafting and review of filings and coordinating with other parties.

2. As noted above, section II.B., regarding duplication of efforts,

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CHPC also made sure that other parties with similar interests were aware of our planned efforts.

3. All of CHPC’s comments were informed by many hours of consultation with multifamily property owners to deepen the value of comments regarding program improvements, but CHPC does not claim any of this research time toward the proceeding in the interest of keeping this claim reasonable and conservative.

c. Allocation of hours by issue:

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B. Specific Claim:*

CLAIMED CPUC AWARD

ATTORNEY, EXPERT, AND ADVOCATE FEES

Item Year Hours Rate $ Basis for Rate* Total $ HoursRate

$ Total $

Ann Gressani (Expert and Advocate)

2014 29.25 $300 See Attachment (Basis for Rates)

$8,775.00 28.75 $300 $8,625.00



$50,475.00 161.25

$300 $48,375.00



$59,250.00 191.50

$300 $57,450.00

Megan Kirkeby (Expert and Advocate)


$16,282.50 83.50 $195 $16,283.00

Caroline McCormack (Expert and Advocate)


$4,995.00 27.75 $180 $4,995.00

Matt Schwartz (Expert)


$6,307.50 21.75 $290 $6,308.00

Wayne Waite (Expert and Advocate)


$4,050.00 13.5 $300 $4,050.00

Stephanie Wang (Attorney)


$1,925.00 5.5 $350 $1,925.00

Subtotal: $ 152,060.00 Subtotal: $148,010.00

OTHER FEESDescribe here what OTHER HOURLY FEES you are Claiming (paralegal, travel **, etc.):

Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate Total $

Ann Gressani 2016 5.0 $150 See Attachment (Basis for Rates)

$750.00 0 $0 0

Caroline McCormack


$90.00 0 $0 0

Subtotal: $840.00 Subtotal: $0

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INTERVENOR COMPENSATION CLAIM PREPARATION**Item Year Hours Rate $ Basis for Rate* Total $ Hours Rate Total $


$750.00 5 $150 $750.00


$4,500.00 30 $150 $4,500

Wayne Waite 2016 11.25 $150 See Attachment (Basis for Rates)

$1,687.50 11.25 $150 $1,688.00

Stephanie Wang


$1,618.75 2.75 $175 $481.00

Caroline McCormack


$225.00 0 $90 $0

Stephanie Wang


$350.00 1 $175 $175.00

Caroline McCormack


$450.00 5 $90 $450.00

Subtotal: $9,581.25 Subtotal: $8,044.00

TOTAL REQUEST: $162,481.25 TOTAL AWARD: $156,054.00

*We remind all intervenors that Commission staff may audit their records related to the award and that intervenors must make and retain adequate accounting and other documentation to support all claims for intervenor compensation. Intervenor’s records should identify specific issues for which it seeks compensation, the actual time spent by each employee or consultant, the applicable hourly rates, fees paid to consultants and any other costs for which compensation was claimed. The records pertaining to an award of compensation shall be retained for at least three years from the date of the final decision making the award.**Travel and Reasonable Claim preparation time typically compensated at ½ of preparer’s normal hourly rate

ATTORNEY INFORMATIONAttorney Date Admitted to CA

BAR2Member Number Actions Affecting

Eligibility (Yes/No?)If “Yes”, attach

explanation

Stephanie Wang September 29, 2008 257437 No

D. CPUC Disallowances and Adjustments:

Item Reason

A California Housing Partnership Corporation (CHPC) requests a rate of $195 per hour for work completed by Kirkeby in 2015. Kirkeby has a Master’s in Public Policy and eight years of experience in affordable housing policy. The Commission finds reasonable a rate of $195 per hour for Kirkeby’s work in 2015.

California Housing Partnership Corporation (CHPC) requests a rate of $300 per hour 2 This information may be obtained through the State Bar of California’s website at http://members.calbar.ca.gov/fal/MemberSearch/QuickSearch .

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http://members.calbar.ca.gov/fal/MemberSearch/QuickSearch


for work completed by Gressani in 2015. Gressani has more than 25 years of experience working with the legislature and CPUC on energy and regulatory issues. The Commission finds reasonable a rate of $300 per hour for Gressani in 2014.

California Housing Partnership Corporation (CHPC) requests a rate of $180 per hour for work completed by McCormack in 2016. McCormack has 6 years of experience working on affordable housing and energy policy issues. The Commission finds reasonable a rate of $180 per hour for McCormack in 2016.

California Housing Partnership Corporation (CHPC) requests a rate of $290 per hour for work completed by Schwartz in 2016. Schwartz has more than 25 years of experience working on affordable housing and sustainability policy issues, and has a Master’s degree in Public Policy. The Commission finds reasonable a rate of $290 per hour for Schwartz in 2016.

California Housing Partnership Corporation (CHPC) requests a rate of $300 per hour for work completed by Waite in 2016. Waite has more than 35 years of experience working on affordable housing and energy policy issues. The Commission finds reasonable a rate of $300 per hour for Waite in 2016.

California Housing Partnership Corporation (CHPC) requests a rate of $350 per hour for work completed by Wang in 2016. Wang has more than 8 years of legal experience working on affordable housing and energy policy issues. The Commission finds reasonable a rate of $350 per hour for Wang in 2016.

B Reduction of to Gressani’s hours of 0.5 in 2014, 7 in 2015 and 6 in 2016 for coordination with Joint Parties. Such hours spent merely avoiding duplication are not compensable. National Consumer Law Center did not request compensation for hours spent conferring with other joint parties; we do not see fit to compensate California Housing Partnership for such hours.

Reduction to Travel Hours for Gressani and McCormack. Travel and travel time within a radius of 120 miles or less is non-compensable (see, D.10-11-032)

C Reduction to Wang’s hours of 6.5 for 2016 and 1 for 2017 for excessive and unexplained intervenor compensation claim preparation hours. Reduction to McCormack’s hours of 2.5 for 2016 for intervenor compensation claim preparation hours. Seventy-One (71) total hours is an excessive and unreasonable total for intervenor compensation claim preparation.

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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 Rule 14.6(c)(6))?

Yes

FINDINGS OF FACT

1. California Housing Partnership Corporation has made a substantial contribution to D.16-11-022.

2. The requested hourly rates for California Housing Partnership Corporation’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 $156,054.00.

CONCLUSION OF LAW

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

ORDER

1. California Housing Partnership Corporation shall be awarded $156,054.00.

2. Within 30 days of the effective date of this decision, Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas & Electric Company, and Southern California Gas Company shall pay California Housing Partnership Corporation their respective shares of the award, based on their California-jurisdictional electric and gas revenues for the 2015 calendar year, to reflect the year in which the proceeding was primarily litigated. 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 March 25, 2017, the 75th day after the filing of California Housing Partnership Corporation’s request, and continuing until full payment is made.

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

This decision is effective today.

Dated _____________, at San Francisco, California.

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A.14-11-007 et al. ALJ/WAC/avs

APPENDIX

Compensation Decision Summary InformationCompensation Decision: Modifies Decision?Contribution Decision(s): D1611022Proceeding(s): A1411007, A1411009, A1411010, A1411011Author: ALJ ColbertPayer(s): Pacific Gas and Electric Company, Southern California Edison Company,

San Diego Gas & Electric Company, Southern California Gas Company

Intervenor Information

Intervenor Claim Date

Amount Requested

Amount Awarded

Multiplier? Reason Change/Disallowance

California Housing Partnership Corporation

01/09/2017 $162,481.25 $156,054.00 N/A Deductions for Travel, Excessive Hours, and

Duplication

Advocate Information

First Name Last Name Type Intervenor Hourly Fee Requested

Year Hourly Fee Requested

Hourly Fee Adopted

Ann Gressani Expert CHPC $300 2014 $300Ann Gressani Expert CHPC $300 2015 $300Ann Gressani Expert CHPC $300 2016 $300

Megan Kirkeby Expert CHPC $195 2015 $195Caroline McCorma

ckExpert CHPC $180 2016 $180

Caroline McCormack

Expert CHPC $180 2017 $180

Matt Schwartz Expert CHPC $290 2016 $290Wayne Waite Expert CHPC $300 2016 $300

Stephanie Wang Attorney CHPC $350 2015 $350Stephanie Wang Attorney CHPC $350 2016 $350Stephanie Wang Attorney CHPC $350 2017 $350

(END OF APPENDIX)

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